ML20235W760

Forwards AEOD Assessment of LERs for Period Apr 1986 - Aug 1987,as Part Pf SALP Program.Results of Evaluation Revealed Facility Overall LER Quaility Above Current Industry Average Score of 8.5 Points

ML20235W760
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	10/13/1987
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8710190014
Download: ML20235W760 (44)

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UNITED STATES g ito I

6. f uq(% NUCLEAR ' REGULATORY COMMISslON z Ei)' r( S REGIONIH f 799 ROOSEVELT PO AD UWif'h-h" CLEN ELLYN. ILLINOIS 60137 k , [ ,

OCT 131987 Docket No. 50-155 Consumers Power Company ATTN: Dr. F. W. Buckman N ce President Nuclear' Operations i 212 West Michigan Avenue i Jackson, MI 49201 Gentlemen:

As part of the Nuclear Regulatory Commission's (NRC) Systematic Assessment of Licensee Performance (SALP) Program, the NRC's Office of Analysis and Evaluation of Operational Data (AE00) performed an assessment of Licensee Event Reports (LERs) issued by Big Rock Point during the period of April 1, 1986 through August 31, 1987.

The results of AE0D's assessment indicated an improvement in the quality of LERs issued. This review provides an overview of the quality of the LER's by comparing the contents of the LER's to the reporting requirements of i 10 CFR 50.72(b) and 'he guidelines contained in NUREG-1022. AE0D gave Big Rock Paint an overall avi age score of 9.2 out of a possible 10 points, compared to a current industry average of 8.5 for those units / stations that have been evaluated to date. The identification of failed components is considered to be deficient, but no significant weaknesses were found, and the quality of most .

text discussions improved from the previous evaluation.

Enclosed for your review is a copy of AE0D's evaluation of your LER quality.

Please contact us if you have any questions.

Sincerely, j f5ftarie8 ]loL Charles E. Norelius, Director l Division of Reactor Projects {

Enclosure:

AE0D Assessment See Attached Distribution \

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i48 Consumers Power Company--  : 2. OCT 13.1987 4

r . Distribution cc w/ enclosure:~

.Mr.'.Kenneth W.' Berry, Director Nuclear Licensing 1 Thomas.W.'Elward, Plant- .

Manager-

• JOS/98B3(RIDS)~.

Licensing fee Management Branch Resident. Inspector, RIII l

Ronald Cailen, Michigan-

.Public Service Commission-Michigan Department of-Public Health 1 1

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' LICENSEE EVENT REPORT. (IR)

( QUATEfY EVAIDATICH FOR-BIG ROCK ICINT -

DURING 'IHE PERIOD FRCH APRIL 1, 1986 TO AUGUST 31, 1987 5

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Big Rock Point during the i period frem April 1, 1986 to August 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 No. 1 and 2.

This is the second time the Big Rock Point LERs have been evaluated using this methodology. The results of this evaluation indicate that the overall quality of the Big Rock Point LERs for the three areas that are evahated (i.e., the text, abstract, and coded fields) has improved considerably since the previous evaluation. The first evaluation's overall average LER score was ?.1, which was below the industry average (7.7) at that time. For the current evaluation, Big Rock Point's overall average LER score is 8.9, which is now above the current industry average LER score (8.5). The quality of most text discussions improved from the previous evaluation with the exception of the identification of failed components, which is now considered to br deficient.

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'LER QUALITY EVALUATION'FOR L . BIG ROCK POINT p.

l INTRODUCTION In or' der to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Big Rock Point during the period from April 1,~1986 to August 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 No. 1 2 and 2.3 The sample consists of a total of nine LERs, which represents the total number that were available at the time the sample was taken for the unit. See.

Appendix A for a list of the LER numbers in the sample.

.This is the second time that the Big Rock Point LERs have been evaluated using the same methodology. As before, it was necessary to start the evaluation before the end of the e.ssessment period because the input was due such a short time after t'ne 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 f, viewed in that. light. However, the minimum requirements of the regulation -

.must be met. I

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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 l determining a score (0-10 points) for the text, abstract, and coded fields of each LER.

f The LER specific comments serve two purposes: (1) they point out what l 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 j that was evaluated. Likewise, the scores serve two purposes: (1) they )

serve to illustrate in numerical terms how the analysts perceived the  !

content of the information that was presented, and (2) they provide a basis i for determining an overall score for each LER. The overall score for each LER is the result of combining the scores for the text, abstract, and coded fields (i .e. , 0.6 x text score + 0.3 x abstract' score + 0.1 x coded fields score = overall LER score).

The results of the LER quality evaluation are divided into two .

categories: . (1) detailed information and (2) summary information. The 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), 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, a: 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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I RESULTS i

A discussion of the analysts' conclusions concerning LER quality is l presented below. Thes'e conclusions are based solely on the results of the evaluation of the contents.of the LERs selected for review and as such represent the analysts' assessment of the unit's performance (on a scale of 0 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.

I 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 units / stations that have not been previously evaluated or those that have 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, Big Rock Point's average score for the text of the LERs that were evaluated is 9.2 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 summary section of Table 2 provide ,

an indication of how well each text requirement was addressed by the unit I for the nine 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.

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 i 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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SUMMARY

OF SCOFE3 F0F. LIG ROCK POINT Average High Low Text 9.2 10.0 8.7 Abstract 8.4 10.0 6.0 1

Coded Fields 8.7 9.3 8.0 Overall 8.9 9.3 8.1

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

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(".p p . .. TABLE'2. 'LEh REQUIREMENT FERCENTAGE SCORES FOR BIG' ROCK POINT.

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

1(21.f;)(A) i - Plant condition prior to event 89 ( 9)

- ( 2 ; < 11)(B)' - --Inoperable equipment'that contribu ed b

- (2;4;i)(C)- - - Date(s)-and approximate time (s) 97 ( 9)

. (2)(ii)(D) - - Root cause and intermediate cause(s) 98 ( 9)

(2)(ii)(E) -

- Mode, mechanism, and effect 100 ( 5)

(2)(ii)(F). - - EIIS codes 72 ( 9)

(2)(11)(G) -

- Secondary function affected b (2;;11)(H) - - Estimate of unavailability . ( 0)

( 2i(ii)(1) - - Method of discovery. 94 ( 9) y

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

(2)(ii)(J)(2) - Personnel error (procedural deficiency) 88 ( 4)

.(2)(ii)(K) '- - Safety system responses 100 ( 3)

(2)(ii)(L) - - Manufacturer and model no, information 75 ( 5)

(3) - - - - - - Assessment of safety consequences 98 ( 9)

(4)'- - - - - - Corrective actions 97 ( 9)

(52 - - - - - - Previous similar event information 33 ( 9)

(2?ti - - - - Text presentation 91 ( 9)

. ABE~EACT

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

Major occurrences (immediate cause/effect) 96 ( 9)

Plant / system / component / personnel responses 92 ( 3)

- Root cause information 89 ( 9)

Corrective action information 69 ( 9)

' Abstract presentation 84 ( 9) 6 1

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L. CODED > FIELDS i

[ Percentage Item Number (s) - Descriptions Scores ( )

l l',:1', and 3 -- Plant name(unit #), docket #, page #s '100 ( .9) p 4~- .-:- - -

Title:

72 ( 9) 5, 6, and 7 - Event date, LER no., report date 89 ( 9) 8-.---- Other facilities involved 100 ( 9)

9. 'and110 ' - -  : Operating mode and power level 78 ( 9) 11_ -'- - - Reporting requirements 94 ( 9) 12' -----

Licensee contact information 96 ( 9) 100 ( 9)

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Coded component failure information 14 end 15~- - Supplemental report information 99 ( 9)

a. Percentage scores are the result of dividing the total points for e req 0irement'by.the number of points pessible for that requirement.

(Ne e: Some requirements are not applicable to all LERs; therefore, the nu.ber of points possible was adjusted accordingly.) The number in parer. thesis is the number of LERs for which the requirement was considered ap;.icable, i

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 giver 100!e if it is provided and is.always considered "not applicable" when it . r ot .

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. (1) excluded certain less significant' information from a number of the discussions concerning that requirement or (2) totally failed to address the requirement in one or two of the selected LERs. The unit should review I

the LER specific comments presented in Appendix 0 to determine why it received less than a perfect score for a requirement.

Specific Deficiencies and Observations-The deficiencies and observations of most concern for the text, abstract, and coded field sections of the LERs are discussed separately below. See Appendix D for a list of all deficiencies and observations.

Text Deficiencies and Observations The requirement to provide adequate identification for failed components, Requirement 50.73(b)(2)(11)(L), was considered deficient in two  :

of the five 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 l 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 (although not required) to provide information that would enable others to specifically identify that component.

Six of the nine LERs did not provide information concerning previous similar events, Requirement 50.73(b)(5).

The Energy Industry Identification System (EIIS) component function identifier and/or system name codes were not provided in four of the 8

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'nine LERs.L T'hese codes should.be p'rotfided for all components and systems referred to in the text.

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.

3. Root / Intermediate The underlying cause of the event. What

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Cause caused the component'and/or system failure or the personnel error.

4. . Corrective' Actions What was done immediately to restore the i

plant to a safe and stable condition and what was done or planned to prevent i recurrence of the event. .

1 Number 4 was not adequately addressed in six of the LERs. Simply i j

mentioning or summarizing information that was discussed in the text ]

concerning corrective actions would have resulted in a higher abstract average score. Three abstracts also had minor problems in the area of j

presentation; see the abstract comments in Appendix D.

Coded Fields Deficiencies and Observations One deficiency in the area of coded fields involves the titles, Item (4). Four of the nine titles failed to include adequate cause j information,'four failed to include an adequate result of the event and I l

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three' failed to indicate the link between the cause and the result. While Ethe result is considered to be the most important part of the title, cause-4' and link information (as suggested in NUREG-1022, Supplement No. 2) must be included.to make a title complete. Example titles are presented in i Appendix D'for many of the LERs which were considered to have poor titles.

'The operatir.g, mode, Item (9), was not included in two LERs; the power level, Item (10), was not included in two LERs. If the operating mode number is not applicable for the unit, then "N" should be entered. The power level should be either "0", or the percent power if the unit is in Mode 1 (power operation).

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SUMMARY

Table 3 provides a summary of the areas that need improvement for the Big Rock Point 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 in NUREG-1022, and NUREG-1022 Supplements Nc. I and 2.

As was mentioned earlier, this is the second time that the Big Rock Point LERs have been evaluated using the same methodology. The previous evaluation was reported in April of 1986. Table 4 provides a comparison of the scores for both evaluations. Improvements in the information provided concerning root cause, corrective actions, safety consequences, personnel error, system responses, and dates / times resulted in a large improvement in the average text score. The average abstract score showed a large improvement although the corrective actions information and presentation are still below average. Big Rock Point's overall average LER score (8.9) is now above the current industry overall average of 8.5. (Note: The industry overall average is the result of averaging the latest overall average LER score for each unit / station that has been evaluated using this methodology.)

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TABLE '3. ' AREAS MOST NEEDING IMPROVEMENT FOR BIG ROCK POINT LERs

' Areas Comments' 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.

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.

EIIS codes EIIS codes should be provided in the text for each component or system referred to in the text.

Abstracts All. corrective action information from the text should be summarized in the abstract.

Coded Fields

a. Titles Titles should be writter. such that they better describe the event. In particular, cause and result information and the link between them should be included in each title,

b. Operating mode and power The operating mode and power level fields

• should be filled in on all LERs. The letter "N" should be used in Item 9 if operating mode numbers are not defined in the Technical Specification.

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9 TABLE 4. COMPARfSON OF LER SCORES FOR BlG ROCK P0lNT l

1.' Report Date April-86 September-87 Text average 7.1 9.2 l Abstract average 6.7 8.4 Coded fields average 8.4 8.7 Overall LER average 7.1 8.9 13

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!... i l REFERENCES 1

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 Evalunion of Operational Data, Licensee Event Report System,'NUREG-1022 Supplement No. 1, U.S. Nuclear Regulatory Commission, February 1984. )'

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

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1 APPD1 DIX A IER SAMPIE maa; INFURMATIOi FOR BIG ROCK POD 7T f

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' DELE A-1. IER SAMPIE SELECTION FCR BIG ROCK POINT Sanple Number -IER Number Ocnnents

-1' 86-003-00

-2 86-005-00 SCRAM 3 86-006-00 4 87-001-00 SCRAM i

-5 87-002-00:

6 87-003-01 7 87-004-01 8 87-005-00

.9 87-007-00. SCRAM i

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.- ?AI LE B- 1. EVALUATION SCORES OF INDIV3 DUAL LERE FOR E:G EOCK POI!1T

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LER Sample Number 1

I 1 2 3 4 5 6 7 8 i Text 9.0 9.1 8.8 9.0 9.3 9.8 9.3 8,7

' Abstract 10'.0 6.0 9.2 7.5 9.1 8.1 9.0 9.-

i Coded Fields 8.5 8.4 9.0 9.1 9.3 8.0 8.7 8.c Overall 9.3 8.1 8.9 8.6 9.3 9.1 9.2 9.0 a

LER Sample Number 9 10 11 12 13 14 15 Avert.ge  ;,

Text 10.0 . . . . . . 9.2 Abstract 6.9 . . . . . . 8.4 Coded Fields 8.9 . . . . . . 8.7 Overall 9.0 . . . . . . 8.9 j

a. 9ee Appendix A f or a list of the correspondir.g LER nu:nbers.

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l APPENDIX C DEFICIENCY AND OBSERVATIQi CDU!7IS FOR BIG ROCK ICINT l

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TABLE-C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR' BIG CCK P0lNT l<

' Number of LERs with Deficiencies and Observations Sub paragraph Paragraph

[ Description of Deficiencies and Observations To'ta l s a

Totals ( )b

' 50.73(b)(2)(ii)( A)--Plant' operating 1 ( 9) conditions before the event were not included or were inadequate.

50.73(b)(2)(ii)(B)--Discussion of the status 0 ( 2) of the structures, components, or systems that were inoperable at the start of the event and.that contributed to the event was not included or was inadequate. 1 50.73(b)(2)(ii)(C)--Failure to include 1 ( 9) sufficient date and/or time information.

a. Date information was insufficient. O

b. Time'information was insufficient. 1 i

50.73(b)(2)(ii)(D)--The root and/or 1 ( 9)

, intermediate cause of the component or system failure' E s'not included or was ,

inadequate,

a. Cause of component failure was not 1 )

included or was inadequate. .

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b. Cause of system failure was not 0 included or was inadequate. 4 50.73(b)(2)(ii)(E)--The failure mode, 0 ( 5) )

mechanism (immediate cause), and/or effect I (consequence) for each f ailed component was  !

not included or was inadequate.

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a. Failure mode was not included or was .

inadequate.

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

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c. Effect (consequence) was not included j or was inadequate.

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KTABLE'C-1.

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Number of LERs with '

' Deficiencies and. .,

Observations i

Sub-paragraph Paragraph i Description of Deficiencies and Observations Totals a Totals (' )b 50.73(b)(2)(ii)(F)--The Energy Industry 4 ( 9) 1 Identification System component function identifie'r for each component or system was ,

l not included. j 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 4

inadequate.

50.73(b)(2)(ii)(H)--For a failure that -- ( 0) 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)(1)--The method of discovery 1 ( 9) of each component failure, system failure, ,

oersonnel error, or procedural error was not )

included or was inadequate. l

a. Method of discovery for each 0 component failure was not included or was inadequate.

b. Method of discovery for each system 0

. failure was not included or was inadequate. l

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

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

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TABLE C-1. (continued) 1 Number of LERs with' I

Deficiencies and 1 Observations

.Sdb paragraph Paragraph a

Description of Deficiencies and Observations- Totals Totals ( )b 50.73(b)(2)(ii)(J)(1)--Operator actions that 0 ('1) l affected the course of the event including l operator. errors and/or procedural

, deficiencies were not included or were l inadequate.

!- 50.73(b)(2)(ii)(J)(2)--The discussion of 2 ( 4) each personnel error was not included or was inadequate,

a. 0BSERVATION: A personnel error was 1 implied by the text, but was not explicitly stated,

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

c. 50.73(b)(2)(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)( P)( i i )(J )( 2 )( i i i )--Di sc u s s i o n 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 )( i i )(J )( 2 )( i v)--Di s cu s s i o n 0  ;

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

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i TABLE C-1. (continued)

L Number of LERs with Deficiencies and Observations )

Sub paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )b i

50.73(b)(2)(ii)(l!}--Automaticand/ormanual 0 ( 3) safety system responses were not included or were inadequate.

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

50.73(b)(3)--An assessment of the safety 1 ( 9) consequences and implications 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 1 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 1 ( 9) 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.

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TABLE C-1. (continued)

Number of LERs with Deficiencies and Observations Sub parag aph Paragraph Description of Deficiencies and Observations Totals' Totals ( )b

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a. A discussion of actions required to O correct the problem (e.g. , return the i component or system to an operational condition or correct the personnel ,

error) was not included or was 4 inadequate.

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

of the problem or similar event I (correct the root'cause) was not included or was inadequ' ate. '

c. OBSERVATION: A discussion of actions O 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 6 ( 9) similar events was not included or was inadequate.

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l-TABLE C-1. (continued) (

Number of LERs with j l

Deficiencies and {

Observations' 1

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1 Sub paragraph Paragraph

. Description of Deficiencies and Observations Totals a Totals ( )b, 50.73(b)(2)(1)--Text presentation 2 ( 9) inadequacies.

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a. OBSERVATION: A diagram would have 0  ;

aided in understanding the text discussion.

b. Text contained undefined acronyms 2 i and/or plant. specific designators,

c. The. text contains.other specific 0 deficiencies relating to the readability,

a. The "sub paragraph total" is a tabulation of specific deficancies 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. -

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C-6

TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR BIG ROCK POINT Number of LERs with l Deficiencies and )

Observations Sub paragraph Paragraph . l Description of Deficiencies and Observations Totals"- Totals ( )b A' summary' of occurrences (immediate cause 2 ( 9) . i and effect) was not included or was

-inadequate.

A summary of. plant, system, and/or personnel 1 ( 3)

> responses was not included or was inadequate.

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

b. Summary of system responses was not 1 included or was inadequate.

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

A summary of the. root cause of the event 3 ( 9) was not included or was inadequate.

A summary of the corrective actions taken or 6 ( 9) planned as a result of the event was not 4ncluded or was inadequate, i q

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C-7 I

4 TABLE C-2. (contir,ued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph a

Description of Deficiencies and Observations. Totals Totals ( )b l'

'f Abstract presentation inadequacies. 3 ( 9)

a. OBSERVATION: The abstract contains 0

-information not included in the text. 3 The, abstract is intended to be a summary of the text, therefore, the text should discuss all.information.

summarized in the abstract,

b. The abstract was greater than 0 1400 spaces. 3

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

d. The abstract contains other specific 3 deficiencies (i.e., poor summarization, contradictions,etc.).

1

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

.f t 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. 1 i

)

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C-8 C-____ ___ __

..h.

TABLE.C-3.-- CODED.FfELDS DEFICIENCIES AND OBSERVATIONS FOR BIG ROCK POINT

[

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph a

Description of Deficiencies and Observations Totals Totals ( )b Facility Name. 0 ( 9)

a. Unit number was not included or incorrect.

b. Name was not included or was incorrect.

c. Additional unit numbers were included but.not required.  !

Docket Number was not included or was 0 ( 9) incorrect.

Page Number was not included or was 0 ( 9) incorrect.

' Title was left blank or was inadequate. 8 ( 9)

a. Root cause.was not given or was 4 inadequate.

b. Result (effect) was not given or 4 was inadequate,

c. Link'was not given or was- 3 ,

inadequate, ,

I Event Date 2 ( 9) ,

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 ( 9)

Report Date 3 ( 9)

a. Date not included. I

b. OBSERVATION: Report date was not 2 within thirty days of event date (or discovery date if appropriate).

C-9 i

i

' TABLE:C-3. (continued)'

-4 Number of LERs with Deficiencies and Observations Sub paragraph Paragraph ,

- Description of Deficiencies and Observations Totals" Totals ( .)b ' j

'Other Facilities information in field is 0 ( 9) inconsistent with text and/or abstract. j l

Operating Mode was not included or was 2'( 9) inconsistent with text or abstract.

Power level was not included or was 2('9) )

inconsistent with text or-abstract. ]

Reporting Requirements 2 ( 9) ,

d

a. The reason for checking the "0THER" 0 i

. requirement was not specified in the  !

abstract and/or text.

b. OBSERVATION: It may have been more 0 appropriate to 'repot t the event under a different paragraph.  !

c. 0BSERVATION: It may'have been 2 appropriate to report this event under an additional unchecked paragraph.  !

- Licensee Contact 2 ( 9)

a. Field left blank. O

b. Position title was not included. 2

c. Name was not included. O l

d. Phone' number was not included. 0 J

l Coded Component Failure Information -1 ( 9) -]

a. One or more component failure 0 sub-fields were left blank,

b. Cause, system, and/or component code 0 is inconsistent with text.

c. Component failure field contains data 1 when no component failure occurred, j

d. Component failure occurred but entire 0 field left blank.

l- l l

C-10 1

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v '.

l4 OX TABLE C-3.. (continued)

Number of LERs with Deficiencies and Observations Sub paragraph Paragraph.

a Description of Deficiencies and Observations Totals Totals ( )b Supplemental Report 1 ( 9)

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

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

Expected submission date information.is 0 ( 9) inconsistent with the block checked in Item (14).

a. The "sub paragraph total" is a tabulation of specific deficiencies or

' observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub paragraph totals do not

necessarily add up to the paragraph total.

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

I C-11 l

% swww--_ _ _ _ _ _ _ _ . _ . . _ _ _ . . . _ _ _

)

L I 1

I O

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1 4

APPENDIX D IER CCH4ENT SHEETS NR BIG Ti)CK POINT

TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155) i i

Section Comments

1. LER Number: 86-003-00 Scores: Text = 9.0 Abstract = 10.0 Coded Fields = 8.5 Overall = 9.3 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)(11)(F)--The Energy Industry Identification System component codes for the monitor

[ MON] and the pump [P] were not included.

3. 50.73(b)(2)(ii)(I)--The type of review being done which led to the discovery of the deficiency was not included.

4. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comment.

Coded Fields 1. Item (4)--Title: Result is inadeouate. A more appropriate title might be "Inacie:uate Procedure Results in Missed Grab Sample Ana'ysis (Technical Specification Violation)".

2. Item (5)--Discovery date is given instead of event date, A more appropriate event date appears to be -

May 22,1986 (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter the first analysis was missed).

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D-1 1

1

~ABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

Section Comments *

2. LER Number: 86-005-00 Secres: Text = 0.1 Abstract = 6.0 Coded Fields = 8.4 Overall = 8.1 Text 1. 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.

2. 50.73(b)(5)--Informationconcerningprevioussimilar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. 50.73(b)(1)--Summary of responses is inadequate. The manual turbine generator trip is not included.

2. 50.73(b)(1)--Summary of the cable failure resulting from stress at bend near a connector and the turbine automatic trip solenoid linkage problem is not l

included.

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

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

Coded Fields 1. Item (4)--Title: Cause (cable breakage from stress) is vague, and link (while testing) is inadequate. A ,

better title might be: " Reactor Trip During Testing Due to Stress Breakage of Neutron Monitoring Cable". '

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

/

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D-2

e

+ a a

TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

Section Comments

3. LER Number: 86-006-00 Scores: Text = 8.8 Abstract ~= 9.2 Coded Fields = 9.0 Overall = 8.9 Text 1. 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.

2. 50;73(b)(2)(ii)(J)(2)--Discussion of the personnel error / procedural deficiency is inadequate. Why wasn't the event determined reportable on October 8, 1985?

3, 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. What actions were taken to ensure that deportability is determined in a timely manner?L

4. 50.73(b)(5)--Information concerning previous similar -

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

Abstract 1, 50.73(b)(1)--The deportability problem is not adequately addressed in the abstract (as it was not in the text).

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

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

3. Item (10)--Power level is not included.

4. Item (13)--The "N" in the "cause" field is not necessary. ,

r ,,

e 4  %

N

• s s

l D-3 i

TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

r.

Section Comments

4. LER Number: 87-001-00

-Scores: Text = 9.0 Abstract =.7.5 Coded Fields = 9.1 Overall = 8.6 Text , 1. 50.73(b)(2)(ii)(D)--Under Corrective Actions othe text indicates that the. Number 2 picoammeter will be repaired, which implies more than a sensitivity to noise.. If this is the case, the root cause for the problem should be discussed.

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

picoammeter[II]androd[ ROD],althoughthesystem codes for these components were included.

3. 50.73(b)(2)(ii)(L)--If the picoammeter actually failed, as implied in the Corrective Actions section, then it should be identified.

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 (4)--Title: Link (shutdown) is not included and the cause is vague. A more appropriate title might be " Reactor Trip during Normal Shutdown due to Noise in the Power Range Picoammeter".

1 D-4 l

TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

Section Comments

5. LER Number: 87-002-00 Scores: Text = 9.3 Abstract = 9.1 Coded Fields = 9.3 Overall = 9.3 Text 1. 50.73(b)(2)(ii)(C)--When was the undervoltage relay recalibrates?

2. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

l Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The change of calibration procedure for the relay is not mentioned.

Coded Fields 1. Item (4)--Title: Result (Technical Specification Violation) 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)(1).

l D-5 L_________-________________. . _ _ . __

TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

Section Comments-

~

6. LER Number: 87-003-01 Scores: Text = 9.8 Abstract = 8.I' Coded Fields = 8.0 Overall = 9.1 Text 1.- 50.73(b)(2)(ii)(J)(2)--When the use of acetone was restricted, why wasn't an alternative (rather than

-demineralized water) sought at that time?

Abstract 1. 50.73(b)(3)--Summary of cause information is inadequate. The fact that acetone was no longer used and demineralized water had been chosen to replace its use was not mentioned.

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

.new cleaning agent (denatured alcohol) was not mentioned. In addition, the last sentence of the abstract implies there were no previous cleaning requirements for valves following lapping repairs.

3. Abstract does not adequately summarize the text.

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

Coced Fields 1. Item (4)--Title: Cause information (Inadequate Cleaning Agent and Procedure) is not included.

2. Item (7)--Report date is not included.

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

4. Item (Il)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1)(B).

D-6 L__________________________ J

TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

Section Comments

7. LER Number: 87-004-01 Scores: Text = 9.3 Abstract = 9.0 Coded Fields = 8.7 Overall = 9.2 Text 1. 50.73(b)(4)--Although there is no requirement to do so, a supplemental report may be appropriate to describe the corrective actions if these results significantly change the reader's perception of the event and/or require additional corrective actions be taken.

2. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

3. Use of the vertical lines to indicate revisions is good.

Abstract 1. 50.73(b)(1)--Summary of occurrences [immediate cause(s) and effects (s)] is inadequate. The affected safety system was not indicated.

2. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The possibility of further corrective actions, in particular, the possibility of lowering the test criteria, was not mentioned.

3. If space is needed to include the items discussed in Abstract comments 1 and 2, then the last sentence of the first paragraph and all of the second paragraph could be eliminated.

0-7

Q 4

j. TABLE D-1. SPECIFIC'LER COMMENTS FOR BIG ROCK POINT (155)

'Section Comments

8. LER Number: 87-005-00 Scores: Text = 8.7 Abstract = 9.7 Coded Fields = 8.0 Overall = 9.0 Text- 1. 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, i

2. 50.73(b)(3)--Discussion of the assessment of the iafety consequences 'and implications of the event is inadequate. What is the safety significance (if any) of placing the mode switch in the " Bypass Dump Tank" position during the control rod drive uncoupling?

3. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

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

Abstract 1. No comment.

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

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

3. Item (10)--Power level is not included.

i D-8

, * * ..t TABLE D-1. SPECIFIC LER COMMENTS FOR BIG ROCK POINT (155)

A Section Comments

9. LER Number: 87-007-00 Scores: Text = 10.0 Abstract = 6.9 Coded Fields = 8.9 Overall = 9.0 Text' 1. No comments.

Abstract 1. 50.73(b}{1)--Summary of occurrences [immediate causa(s; :nd effects (s)) is inadequate. The type of

.tr;p (Upscale /Downscale) was not mentioned.

2, 50.73(b)(1)--Summary of cause information is inadequate. The fact that the picoammeter spiked upscale was not mentioned.

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

4. Abstract does not adequately summarize the text.

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

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

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

D-9 {

1 i

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_ _ _ _ _ _ - _ - _ _ _ _ - - _ _ l