ML20215D690

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Forwards Evaluation of LERs Submitted for Aug 1985 - Jul 1986.LERs of Above Average Quality
ML20215D690
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 10/03/1986
From: Kane W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Selman M
CONSOLIDATED EDISON CO. OF NEW YORK, INC.
References
NUDOCS 8610140247
Download: ML20215D690 (48)
v • d • e


Text

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08 0cT ses Docket No. 50-247 Consolidated Edison Company of New York, Inc.

ATTN: Mr. Murray Selman Vice President, Nuclear Power Indian Point Station Broadway and Bleakley Avenue Buchanan, New York 10511 Gentlemen:

Subject:

Assessment of the Quality of Licensee Event Reports (LERs) - Indian Point Station, Unit 2 As part of the SALP process, the NRC Office for Analysis and Evaluation of Operational Data (AE00) evaluated LERs submitted during the recent SALP assessment period for the Indian Point Nuclear Generating Station, Unit 2.

The assessments (portions enclosed) were performed using a methodology similar to that described in NUREG/CR-4178, "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73."

The NRC considers it important to achieve uniform, high quality LERs from all operating power reactors to enable licensees and AE00 to effectively identify

" precursor events" and emerging trends or patterns of potential safety significance. Generic studies triggered by events reported at specific units can lead to improvements in the level of reactor safety only if the available data-base is uniform and of high quality.

Based on a limited sample, AE00 concludes that the Indian Point 2 LERs sampled were of better than average quality as compared to other licensees that have been evaluated using this methodology. I invite you to review the enclosed analyses and to discuss the evaluation and any planned improvements to your event reporting system at the forthcoming NRC SALP management meeting.

Sincerely, I

signedBYa William F. Kane, Director i Division of Reactor Projects

Enclosure:

As stated 8610140247 861003 ~

PDR ADOCK 05000247 S PDR OFFICIAL RECORD COPY 1 SUMMERS 9/26/86 - 0001.0.0 g oi

Consolidated Edison Company 2 03 OCT 1986 of New York, Inc.

cc w/ encl:

Robert Spring,-Manager, Regulatory Affairs P. Kokolakis, Director, Nuclear Licensing Brent L. Brandenburg, Assistant General Counsel Walter Stein, Secretary - NFSC

- Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief Robert J. Bores, DRSS

P R P -

P Summers /rhl olm Callo e 9/3986 /

9M/86 940 /86 ' A/7/86 1

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I 0FFICIAL RECORD COPY 1 SUMMERS 9/26/86 - 0002.0.0 09/26/86

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SUMMARY

An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Indian Point 2 during the August 1, 1985 to July 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic nethodology presented in a report entitled "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT)",

NUREG/CR-4178, March 1985. The results of this evaluation indicate that Indian Point 2 has an overall average LER score of 8.3 out of a possible 10 points, compared to a current industry average score of 7.9 for those units / stations that have been evaluated to date using this methodology.

The principle weaknesses identified in the LERs, in terms of safety significance, involve the requirement to provide identification of failed components. The failure to adequately identify the manufacturer and model number of the components that fail prompts concern that others in the industry won't have insediate access to information involving possible generic problems.

Strong points for the Indian Point 2 LERs are the discussions of the mode, mechanism, and effect of failed components, the discussion of personnel errors, and the discussion of the safety consequences of the

, event.

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4 AE0D INPUT TO SALP REVIEW FOR INDIAN POINT 2 Introduction In order to evaluate the overall quality of the contents of the Licensee Event Reports (LERs) submitted by Indian Point 2 during the August 1, 1985 to July 31, 1986 Systematic Assessment of Licensee Performance (SALP) assessment period, a representative sample of the licensee's LERs was evaluated using a refinement of the basic methodology presented in NUREG/CR-4178. The sample consists of 11 LERs, which is half of the LERs that were on file at the time the evaluation was started.

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

It was necessary to start the evaluation before the end of the SALP assessment period because the input was due such a short time after the end of the SALP period. Therefore, not all of the LERs prepared during the SALP assessment period were available for review.

Methodology The evaluation consists of a detailed review of each selected LER to determine how well the content of its text, abstract, and coded fields meet 3

the requirements of 10 CFR 50.73(b), NUREG-1022 , and Supplements 1

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

The LER specific comments serve two purposes: (1) they point out what the analysts considered to be the specific deficiencies or observations ,

concerning the information pertaining to the event, and (2) they provide a

basis-for a count of general deficiencies for the overall sample of LERs.

Likewise, the scores serve two purposes: (1) they serve to illustrate in numerical terms how the analysts perceived the content of the information that was presented, and (2) they provide a basis for the overall score determined for each LER. The overall score for e&ch 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 these appendices, the reader is cautioned not to try to directly correlate the number of comments on a comment sheet with the LER scores, as the analyst has flexibility to consider the magnitude of a deficiency when assigning scores.

Discussion of Results A discussion of the analysts' conclusions concerning LER quality is e presented below. These conclusions are based solely on the results of the evaluation of the contents of the LERs selected for review and as such represent the analysts' assessment of each units performance (on a scale of j

0 to 10) in submitting LERs that meet the requirements of 10 CFR 50.73(b).

Table i presents the average scores for the sample of LERs evaluated

! for Indian Point 2. The reader is cautioned that the scores resulting from the methodology used for this evaluation are not directly comparable to the scores contained in NUREG/CR-4178 due to refinements in the methodology. -

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. 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, Indian Point's average score for the text.of the LERs that were ovaluated was 8.3 out of a possible 10 points. From Table 2 it can be seen that the text score actually resulted from the review and evaluation of 17 different requirements ranging from the discussion of plant operating conditions before the event [10 CFR 50.73(b)(2)(ii)(A)] to text presentation. The percentage scores in the text'sommary section of Table 2 provide an indication of how well each text requirement was addressed by the licensee for the 11 LERs that were evaluated.

Discussion of Specific Deficiencies A review of the percentage scores presented in Table 2 will quickly point out where the licensee is experiencing the most difficulty in preparing LERs. For example, requirement percentage scores of less than 75 indicate that the licensee probably needs additional guidance concerning these requirements. Scores of 75 or above, but less than 100, indicate that the licensee probably understands the basic requirement but has either: (1) excluded certain less significant information from a large number of the discussions concerning that requirement or (2) totally failed to address a requirement in one or two of the selected LERs. The licensee should review the LER specific comments presented in Appendix 0 in order to determine why he received less than a perfect score for certain requirements. The text requirements with a score of less than 75 or those with numerous deficiencies are discussed below in their order of importance. in addition, the primary deficiencies in the abstract and coded fields are discussed.

Many of the more important requirements (i.e., root cause, personnel error, safety assessment, and corrective actions) were discussed very tell. A review of the comments in Appendix D will aid in identifying any .

minor problems found in these requirements.

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a TABLE 1.

SUMMARY

OF SCORES FOR INDIAN POINT 2 Averaae  !!1gh, Low Text 8.3 9.2 6.1 Abstract 8.4 9.2 7.0 Coded Fields 8.4 9.2 7.4 Overall 8.3 8.9 7.0

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

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. TABLE 2. LER REQUIREMENT PERCENTAGE SCORES FOR INDIAN POINT 2 TEXT i

Percentage Reautrements ISO.73(b)1 - Descriotions Scores ( l'

(2)(11)(A) - - Plant condition prior to event 82 (11)

(2)(ii)(B) - - Inoperable equipment that contr.1buted b (2)(ii)(C) - - Date(s) and approximate times 82 (11)

(2)(11)(D) - - Root cause and intermediate cause(s) 88 (11) 4 (2)(11)(E) - - Mode, mechanism, and effect 97 (8)

(2)(ii)(F) - - EIIS Codes 9 (11)

(2)(11)(G) - - Secondary function affected b (2)(ii)(H) - - Estimate of unavailability 14 (7)

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

(2)(11)(J)(1) - Operator actions affecting course 88 (4)

(2)(11)(J)(2) - Personnel error (procedural deficiency) 97 (4)

(2)(11)(K) - - Safety system responses 83 (4)

(2)(11)(L) - - Manufacturer and model no. information 63 (8)

(3) ----- Assessment of safety consequences 94 (11)

(4) ----- Corrective actions 87 (11)

(5) ----- Previous similar event information 68 (11)

(2)(1) - - - - Text presentation 81 (11) i j ABSTRACT Percentage a <

Reauirements ISO.73(b)(111 - Descriotions Scores ( l

- Major occurrences (Immediate cause and effect 93 (11) information)

- Description of plant, system, component, and/or 75 (3) l personnel responses

- Root cause inf ormation 91 (11)

- Corrective Action information 74 (11)

- Abstract presentation 77 (11)

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TA8LE 2. (continued)

CODED FIELOS Percentage Item Number (s) - Description Scores ( )*

1, 2, and 3 - Facility name (unit no.), docket no. and 100 (11) page number (s) .

4 - - - - - - Title 72 (11) 5, 6, and 7 - Event date, LER No., and report date 100 (11) 8 - - - - - - Other facilities involved 100 (11) 9 and 10 - - Operating mode and power level 55 (11) 11 - - - - - Reporting requirements 100 (11) 12 - - - - - Licensee contact information 180 (11) 13 - - - - - Coded component failure information 93 (11) 14 and 15 - - Supplemental report information 91 (11)

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

(Note: Some requirements are not applicable to all LERs; therefore, the number of points possible was adjusted accordingly.) The number in parenthesis is the number of LERs for which the requirement was considered applicable.

b. A percentage score for this requirement is meaningless as it is not possible to determine from the information available to the analyst whether this requirement is applicable to a specific LER. It is always given 100%

if it is provided and is always considered "not applicable" when it is not.

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The manufacturar and/or model numbtr (or other uniqua identification) t;as not provided in the text of four of the eight LERs that involved a component failure, Requirement 50.73(b)(2)(ii)(L). Components that f ail should be identified in the text so that others in the industry can be made aware of potential problems. In addition, although not specifically_

required by the current regulation, it would be helpful to identify components whose design contributed to an event. An event at one station can often lead to the identification of a generic problem that can be corrected at'other plants or stations before they experience a similar problem.

An estimate of the elapsed time of the unavailability of a failed safety system was not provideo in six of seven LERs in which this requirementwasapplicable[50.73(b)(2)(ii)(H)]. Generally, if sufficient date and time information is provided for all major occurrences of the event, Requirement 50.73(b)(2)(ii)(C), it is sufficient to satisfy this requirement as the duration of the train failure can then be calculated.

Four of the eleven LERs reviewed f ailed to mention previous similar events or state that there were none, Requirement 50.73(b)(5). Previous similar events should be referenced appropriately (LER number if possible),

and if there are none, the text should so state.

Ten of the eleven LERs reviewed failed to include the Energy Industry IdentificationSystem(EIIS) codes. Requirement 50.73(b)(2)(ii)(F) requires inclusion of the appropriate EIIS code for each system ano component referred to in the text.

While.there are no specific requirements for an abstract, other than those given in 10 CFR 50.73(b)(1), an abstract should, as a minimum, summarize the following information from the text:

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

. Causes event. What 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.

Indian Point 2 had good discussions of item numbers 1 and 3 above.

Item numbers 2 and 4 could use some improvement however . Scores for these items should improve if the responses and corrective actions information contained in the text is summarized in the abstract.

The main deficiency in the area of coded fields involves the title, Item (4). Five of the titles f ailed to indicate the root cause and three failed to include the result (i.e., why the event was required to be reported). While result is considered the most important part of the title, cause information (and link, if necessary) must be included to make a title complete. An example of a title that only addresses the result cight be " Reactor Scram". This is inadequate in that the cause and link are not provided. A more appropriate title might be " Inadvertent Relay Actuation During Surveillance Test LOP-1 Causes Reactor Scram". From this title, the reader knows the cause was either personnel or procedural and surveillance testing was the link between the cause and the result.

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The operating mode (Item 9) was not provided in any of the 11 LERs, and two LERs f ailed to provide the power level. These items should be filled in on all LERs. For units with non-standard Technical Specifications (i.e., where the Technical Specifications do not define mode numbers for the various operating conditions) an "N" should be placed in Item 9.

The position title of the licensee contacts named in Item 12 was not provided in any of the sample LERs.

. Table 3 provides a sumary of the areas that need improvement for the Indian Point 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 these requirements can be found in NUREG-1022, Supplement No. I and 2.

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TABLE 3. AREAS MOST NEEDING IMPROVEMENT FOR INDIAN POINT 2 LERs Areas Comments Manufacturer and model number Component identification information information should be included in the text for each component failure or (although not specifically required by the current regulation) whenever a component is suspected of contributing to the event because of its design.

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

(unless this time period is explicitly provided).

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 all systems and components discussed in the text.

Abstract Major plant, system, and personnel responses and corrective actions discussed in the text should be

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summarized in the abstract.

Coded fields

a. Titles Titles should be written such that they better describe the event. In particular, the root cause of the event should be included in the title,
b. Operating mode and power The operating mode and power level 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 .-

Specifications.

,' TABLE 3. (continued)

Areas ,

Comments

c. Licensee contact position The position title of the licensee title contact named in Item 12 should be provided (see NUREG-1022, Item 12, page 24).

, REFERENCES

1. B. S. Anderson, C. F. Miller, B. M. Valentine, An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT), NUREG/CR-4178, March 1985.
2. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022, U.S. Nuclear Regulatory Commission, September 1983.
3. Office for Analysis and Evaluation of Operational Data, Licensee Event Report System, NUREG-1022 Supplement No. 1. U.S. Nuclear Regulatory Commission, February 1984.
4. Office for Analysis and Evaluation of Operational Data, Licensee Event ReDort System, NUREG-1022 Supplement No. 2, U.S. Nuclear Regulatory Commission, September 1985.

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f APPENDIX A LER SAMPLE SELECTION INFORMATION FOR INDIAN POINT 2

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. TABLE A-1. LER SAMPLE SELECTION FOR INDIAN POINT 2 Sample Number LER Number Comments 1 85-009-00 SCRAM 2 85-011-00 3 85-012-00 SCRAM 4 85-016-01 SCRAM S 86-001-00 SCRAM 6 86-002-00 7 86-003-00 8 86-006-00 9 86-008-00 10 86-011-00 11 86-012-00

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l APPENDIX B EVALUATION SCORES OF INDIVIDUAL LERs FOR INDIAN POINT 2

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TABLE 8-1. EVALUATION SCORES OF INDIVIDUAL LERs FOR INDIAN POINT 2 LER Sample Number a 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16.

Text 6.1 8.7 8.8 7.6 8.2 8.9 8.3 8.8 8.0 8.9 9.2 -- -- -- -- --

Abstract 8.1 9.2 7.0 8.2 7.8 9.0 8.8 8.8 8.6 8.1 8.4 -- -- -- -- --

Coded Fields 8.6 7.9 8.6 8.6 8.5 7.4 9.2 9.0 7.4 8.7 8.3 - -- -- -- -- --

Overall 7.0 8.8 8.2 7.9 8.1 8.8 8.5 8.8 8.1 8.7 8.9 -- -- -- -- --

LER Sample Number

  • 17 18 19 20 21 22 23 24 25 26 27 28 29 30 AVERAGE Text -- -- -- -- -- -- -- -- -- -- -- -- -- --

8.3 Abstract -- -- -- -- -- -- -- -- -- -- -- -- -- --

8.4 Coded Fields -- -- -- -- -- --

8.4 Overall -- -- -- -- -- -- -- -- -- -- -- -- -- --

8.3

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

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9 APPENDIX C DEFICIENCY AND OBSERVATION COUNTS FOR INDIAN POINT 2

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. TABLE C-1. TEXT DEFICIENCIES AND OBSERVATIONS FOR INDIAN POINT 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Descriotion of Deficiencies and Observations Totals # Totals ( )

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50.73(b)(2)(ti)(Al--Plant operating 2 (11) 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.

50.73(b)(2)(ii)(C)--Fa11ure to include .6 (11) sufficient date and/or time information.

a. Date information was insufficient. 3
b. Time information was insufficient. 4 50.73(b)(2)(ii)(D)--The root cause and/or 4 (11) intermediate failure, system failure, or personnel error 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

, c. Cause of personnel error was not 0 ,

included or was inadequate.

50.73(b)(2)(ii)(E)--The failure mode, 1 (8) 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 0 included or was inadequate
c. Effect (consequence) was not included 1 or was inadequate.

,' TABLE C-1. (continued)

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

50.73f b?(2)f ti)([1--The Energy Industry 10 (11)

Tdent1f Scatlon System component function identifier for each component or system was not included.

50.73(b)(2)(11)(G)--For a failure of a 0 (0) component with multiple functions, a list of systems or secondary functions which were also affected was not included or was inadequate.

50.73(b)(2)(11)(H)--For a failure that 6 (7) rendered a train of a safety system inoperable, the estimate of elapsed time from the discovery of the failure until the train was returned to service was not included.

50.73(b)(2)(11)(I)--The method of discovery 1 (11) of each component failure, system failure, personnel error, or procedural error was not included or was inadequate.

a. Method of discover. for each 1 component failure was not included or was inadequate

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

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

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TABLE C-1. (continued)

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

}0.73(b)(2)(ii)(J)(1)--Operator actions that 1 (4) affected the course of the event including operator errors and/or procedural deficiencies were not included or wera inadequate.

50.73(b)(2)(ii)(J)(2)--The discussion of 1 (4) 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)(11)(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)(11)--Discussion 0 as to whether the personnel error was contrary to an approved procedure, was a direct result of an error in an approved procedure, or was associated
.with an activity or task that was not covered by an approved procedure was not included or was inadequate.
d. 50.73(b)(2)(ii)(J)(2)(iii)--Discussion 0
e of any unusual characteristics of the work location (e.g.s her,t, noise) that directly contributed to the personnel error was not includet or was l inadequate.
  • I e. 50.73(b)(2)(11)(J)t{l[1v1--Discussion 0 l

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

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,' TABLE C-1. (continued)

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

50.73(b)(2)(11)(K)--Automatic and/or manual 1 (4) safety system responses were not included or ,

were inadequate.

50.73(b)(?)(11)(L)--The manufacturer and/or 4 (8) model number of each failed component was not included or was inadequate.

50.73(b)(3)--An assessment of the safety 3 (11) 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 3 of the event had it occurred under more severe conditions were not discussed. If the event occurred under what were considered the most severe conditions, the text should.so state.

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50.73(b)(4)--A discussion of any corrective 5 (11) actions planned as a result of the event including those to reduce the probability

, of similar events occurring in the future l

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

  • Totals ( )
a. A discussion of actions required to 1 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 3 reduce the probability of recurrence of the problem or similar event (correct the root cause) was not included or was inadequate.
c. OBSERVATION: A discussion of actions 1 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 4 (11) similar events was not included or was inadequate.

TABLE C-1. (centinu2d)

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

Description of Deficiencies and Observations _ Totals Totals ( )

50.73(b)(2)(i)--Text presentation 7 (11) 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 4 deficiencies relating to the readability.
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, (e.g., an LER can be deficient in the area of both date and time information), the sub-paragraph totals do not necessarily add up to the paragraph total,
b. The " paragraph total" is the number of LERs that have one or more requirement deficiencies or observations. The number in parenthesis is the number of LERs for which the requirement was considered applicable.

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, TABLE C-2. ABSTRACT DEFICIENCIES AND OBSERVATIONS FOR INDIAN POINT 2 Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph Descriotion of Deficiencies and Observations _ Totals # Totals ( )

A summary of occurrences (immediate cause 2 (11) 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 1 included or was inadequate.
b. Summary of system responses was not 0 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 2 (11) was not included or was inadequate.

A summary of the corrective actions taken or 5 (11) planned as a result of the event was not included or was inadequate.

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, TABLE C-2. (continued)

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

  • Totals ( )

Abstract presentation inadequacies 4 (11)

a. OBSERVATION: The abstract contains 2 information not included in the text.

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

b. The abstract was greater than 0 1400 characters
c. The abstract contains undefined 0 acronyms and/or plant specific designators.
d. The abstract contains other specific 2 deficiencies (i.e., poor summarization, contradictions, etc.)
a. The "sub-paragraph total" is a tabulation of specific deficiencies or observations within certain requirements. Since an LER can have more than one deficiency for certain requirements, the sub-paragraph totals do not necessarily add up to the paragraph total.
b. The " paragraph total" is the number of LERs that have one or more deficiency or observation. The number in parenthesis is the number of LERs for which a certain requirement was considered applicable.

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. TABLE C-3. CODED FIELDS DEFICIENCIES AND OBSERVATIONS FOR INDIAN POINT 2 Number of LERs with Deficiencies and

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

Facility Name 0 (11)

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 (11) incorrect.

Page Number was not included or was 0 (11) incorrect.

Title was left blank or was inadequate 8 (11)

a. Root cause was not given in title 5
b. Result (effect) was not given in title 3
c. Link was not given in title 0 Event Date 0 (11)
a. Date not included or was incorrect.
b. Discovery date given instead of event date.

LER Number was not included or was incorrect 0 (11)

Report Date 0 (11)

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

l Other facilities information in field is 0 (11) inconsistent with text and/or abstract.

Operating Mode was not included or was 11 (11) inconsistent with text or abstract.

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Number of LERs with Deficiencies and Observations Sub-paragraph Paragraph 3

Description of Deficiencies and Observations Totals Totals ( )

Power level was not included or was 2 (11) inconsistent with text or abstract Reporting Requirements 1 (11)

a. The reason for checking the "0THER" 0 requirement was not specified in the abstract and/or text,
b. OBSERVATION: It may have been more 0 appropriate to report the event under a different paragraph.
c. OBSERVATION: It may have been 1 appropriate to report this event under an additional unchecked paragraph.

Licensee Contact 11 (11)

a. Field left blank 0
b. Position title was not included 11
c. Name was not included 0
d. Phene number was not included. O Coded Component Failure Infornation 3 (11)
a. One or more component failure 0 sub-fields were left blank.

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

c. Component failure field contains data 0 when no component failure occurred.
d. Component failure occurred but entire 2 field left blank.

,' TABLE C-3. (continued)

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

Supplemental Report 0 (11)

a. Neither "Yes"/"No" block of the supplemental report field was checked.
b. The block checked was inconsistent with the text.

Expected submission date information is 0 (11) 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.

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y ,,.. .,, ,. _ , , . , - . - . . . - _ _ _ ____._ _ ___ _ __

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  1. 4 9

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APPENDIX 0 4

LER COMMENT SHEETS FOR INDIAN POINT 2

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. TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247) l Section ' Comments

1. LER Number: 85-009-00 Scores: Text = 6.1 Abstract = 8.1 Coded Fields - 8.6 Overall - 7.0 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
2. 50.73(b)(2)(ii)(C)--Date and time information for major occurrences is inadequate. When were the repairs completed?
3. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the auxiliary feedwater valve controller and the stop valve is not included.

Each component failure involved in the event should be thoroughly discussed.

4. 50.73(b)(2)(ii)(E)--The effects of the stop valve failures and feedwater controller failure were not included.
5. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
6. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.

How long was the auxiliary feedwater system j . inoperable?

7. 50.73(b)(2)(ti)(L)--Identification (e.g. manufacturer l

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

8. 50.73(b)(3)--0BSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the text should so state.

TABLE 0-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

1. LER Number: 85-009-00 (continued)
9. 50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. Was the transformer repaired? When? The text should give specifics as to what was done to the controller and stop valves, and what was needed to prevent recurrence (e.g., were the controllers on the other auxiliary feedwater trains checked for the same problem?).
10. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.
11. Acronym (s) and/or plant specific designator (s) are undefined. SOR should be defined.

Abstract 1. OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the, abstract.

The power level is given in the abstract but not the text.

Coded Fields 1. Item (4)--Title: Root cause (water spray) is not included. A more appropriate title might be " Reactor Trip because of an Output Transformer Short due to an Improperly Directed Salt Water Discharge Spray".

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

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3. Item (12)--Position title is not included.
4. Item (13)--If repairs were required on the controller or stop valves, a line should be filled out for each component.

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TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247) l Section Comments l

2. LER Number: 85-011-00 Scores: Text - 8.7 Abstract - 9.2 Coded Fields a 7.9 Overall - 8.8 Text 1. 50.73(b)(2)(ii)(A)--Discussion of plant operating conditions before the event is not included.
2. 50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. More infornation should be provided so that the length of time that the plant remained shutdown because of the hurricane warning can be determined.
3. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.

Abstract 1. No comment.

Coded Fields 1. Item (4)--Title: Result is not included. A more appropriate title for this LER might be: " Plant Placed In Hot Shutdown Due to Proximity of a Hurricane as Required by Technical Specifications".

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. TABLE 0-1.

s SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

3. LER Number: 85-012-00 Scores: Text = 8.8 Abstract - 7.0 Coded Fields - 8.6 Overall - 8.2 Text 1. 50.73fb)(2)(11)(C)--The time that the plant was stabi lized in Hot Shutdown should be provided.
2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

3.

50.73(b)(2)(ii)(K)--Discussion of automatic and/or manual safety system responses is inadequate. The "other safety related equipment" that was observed to operate with no abnornalities should have been named.

4. 50.73(b)(5)--Information concerning previous similar events is not included. If no previous similar events are known, the text should so state.
5. Some ideas are not presented clearly (hard to follow)

(e.g., the first sentence of the " Analysis of Occurrence Section").

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

2. Abstract does not adequately summarize the text.

Additional space is available within the abstract field to provide the necessary information but it was

. not utilized.

Coded Fields 1. Item (4)--Title: Root cause is not included.

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

l 3. Item (12)--Position title is not included.

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  • TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

4. LER Number: 85-016-01

' Scores: Text - 7.6 Abstract - 8.2 Coded fields - 8.6 Overall - 7.9 Text 1. 50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. When was natural circulation established in the reactor?

2. 50.73(b)(2)(ii)(D)--The root and/or intermediate cause discussion concerning the failed components is inadequate. Why was the contact actuated on the pilot wire relay? What caused the open coil on the Auxiliary Feedwater Pump relay? What caused the failures of the' capacitor and transformer in the " low 4

flow" bistable? The results on the analysis'of the

, " low flow" relay should be discussed.

I

3. 50 73(b)(2)(11)(F)--The Energy Industry Identification System component function
identifier (s) and/or system name of each component or
system referred to in the LER is not included.
4. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.

How long were the Auxiliary Feedwater Pump and the

" low flow" channel inoperable? -

5. 50.73(b)(2)(11)(J)(2)--Discussion of the personnel error is inadequate. How hard did the operator tap the pilot wire relay? It seems that the adjacent relay maybe too sensitive.

4

6. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is inadequate. Could the capacitor and transformer in the " low flow" instrument be uniquely identified? If so, this should have been done.

Since the pilot wire relay contributed to the event, it should also be identified (even though not specifically required by the current regulation).

7. 50.73(b)(31--0BSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under
- what are considered the most severe conditions, the text should so state. . .

- p ,,.--+-..---,--e-n-w -- -- v-+-- -----,,------a w w.-m , - ~ . , + - - - - , - - - _- - - - - - - - - - - - - - - , - - -

L TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

4. LER Number: 85-016-01 (continued)
8. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. A discussion of actions required to reduce the probability of recurrence (i.e correction of the root cause) is not included or is inadequate. Without an adequate root cause  !

discussion (see text comment 2), it is not possible for the reader to determine if replacing the failed components is all the action necessary to prevent recurrence of the event.

9. Some ideas are not presented clearly (hard to follow). Information is sometimes presented in sections which are not relevent to the heading. For example, the last paragraph under Description of Occurrence contains corrective actions.

Abstract 1. 50.73(b)(1)--Summary of root cause is inadequate.

More details about the failures should be mentioned.

For example, after the phrase " failed bistable" in sentence one of paragraph two the phase "(, faulty capacitor, and transformer)" could be inserted.

3. OBSERVATION: The abstract contains information not included in the text. The abstract is intended to be a summary of the text; therefore, the text should discuss all information summarized in the abstract.

The time of the 6.9 KV trip is given in the abstract

, but not in the text.

Coded fields 1. Item (4)--Title: Root cause (transmitter failure) is not included.

2. Item (91--Operating mode is not included.
3. Item (12)--Position title is not included.
4. Item (13)--Information on the transforner and possibly the pilot wire relay appears to be needed.

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TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

5. LER Number': 86-001-00 Scores: Text - 8.2 Abstract - 7.8 Coded Fields - 8.5 Overall - 8.1 Text 1. 50.73(b)(2)(ii)(D)--The root cause discussion for the .

trip of 21 MBFP is very good. However, the cause of I the clogged orifices in the control oil system of 4

No. 22 MFBP is not given.

2. 50.73(b)(2)(11)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3. 50.73(b)(2)(ii)(J)(1)--Discussion of operator actions that affected the course of the event is unclear.

During the initial manual load decrease, why was the

" magnitude" of the load decrease sufficient to cause

a dropped rod runback? Does the procedure allow the
override of a NIS runback?
4. 50.73(b)(2)(ii)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text-is inadequate. The broken hose is identified very well, but because the speed control system of No. 22 MBFP did not respond and will be replaced, it should also be identified in the text.
5. 50.73(b)(41--Discussion of corrective actions taken or planned is inadequate. Since the cause of the clogged orifices in No. 22 M8FP is not given, a question remains concerning whether or not the new i Lovejoy speed control system will also be susceptible to clogging?

Abstract 1. 50.73(b)(11--Summary of plant responses is

, inadequate. The abstract should mention the runback and the failure of No. 2 6.9 KV bus to transfer.

2. 50.73(b)(1)--Summary of root cause of the clogged orifices in No. 22 MBFP is inadequate.
3. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. See text comment 5.

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TABLE 0-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

5. LER Number: 86-001-00 (continued)

Coded Fields 1. Rem (4)--Title: Root cause is not included.

2. I_t tem (9)--Operating mode is not included.
3. Item (12)--Position title is not included.

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r TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

6. LER Number: 86-002-00 Scores: Text = 8.9 Abstract = 9.0 Coded Fields = 7.4 Overall = 8.8 Text 1. 50.73(b)(2)(ii)(C)--Time information for major occurrences is inadequate. At what time were the setpoints found to be outside the required setpoint range? At what time were the valves adjusted to within the required setpoint range? '
2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not incluoed.
3. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the faileo system is not included.

See comment number 1.

4. Item (8)--Information in field is inconsistent with text and/or abstract. The first sentence of page 3 indicates that there have been previous similar events. The LER numbers for these events should be provided.
5. The text is inconsistent when describing the subject valves (e.g., safety vs. safety relief). Likewise, the title refers to the valves as relief valves.
6. It appears that the temperatures given in the second sentence of the second paragraph on page 3 for valves MS-45A and MS-45C are reversed.

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Abstract 1. 50.73(b)(1)--Summaryofoccurrences[immediate cause(s) and effects (s)] is inadequate. The abstract should mention that the setpoints found outside their limits represent valves in two or more independent trains in a single system designed to maintain safe shutdown or remove residual heat.

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  • TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

6. LER Number: 86-002-00 (continued)

Coded Fields 1. Item (4)--Title: Root cause is not included. A better title might be, "Setpoint Drift Causes Three Steam Generator Safety Valves To Have Non-Conservative Settings".

2. Item (91--Operating mode is not included.
3. Item (101--Power level is not included.
4. Item (121--Position title is not included.

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., TABLE 0-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

7. LER Number: 86-003-00 Scores: Text - 8.3 Abstract - 8.8 Coded Fields - 9.2 Overall - 8.5 Text 1. 50.73(b)(2)(11)(D)--Was the wear considered normal or were there unusual circumstances which may have j accelerated the wear?  !
2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
4. 50.73(b)(31--0BSERVATION: The consequences of the event had it occurred under more severe conditions should be discussed. If the event occurred under what are considered the most severe conditions, the text should so state.
5. 50.73(b)(4)--A discussion of actions required to reduce the probability of recurrence (i.e, correction of the root cause) is not included or is inadequate.

For example, will surveillance of the relays be increased?

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The installation of two new relays for comparison should be mentioned.

Coded Fields 1. Item (9)--Operating mode is not included.

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

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-5 TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

8. LER Number: 86-006-00 ,

Scores: Text - 8.8 Abstract - 8.8 Coded Fields - 9.0 Overall - 8.8 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

2. 50.73(b)(2)(11)(H)--A time estimate of the unavailability of the failed system is not included.
3. 50.73(b)(2)(11)(I)--Discussion of the method of discovery of the missing data is not included.
4. Acronym (s) and/or plant specific designator (s) are undefined. RTV and EQ should be defined.
5. The report would be more readable if the outline headings were underlined.

Abstract 1. 50.73(b)(11--Summary of occurrences (immediate cause(s) and effects (s)] is inadequate. The abstract should mention that the Hydrogen Recombiner System may not have functioned as designed.

Coded Fields 1. Acronyms such as EQ should be avoided in a title.

2. Item (9)--Operating mode is not included.
3. Item (12)--Contact Position is not included.
4. Item (13)--Component failure field contains data when no component failure occurred.

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  • TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

9. LER Numberi 86-008-00 Scores: Text = 8.0 Abstract - 8.6 Coded fields - 7.4 Overall = 8.1 Text 1. 50.73(b)(2)(ii)(C)--Date information for major occurrences is inadequate. On what date was it determined that the three relay setpoints were outside of their band? On what date was testing of the relays conducted using PP-R61, Rev. 2? What is the present " duration between checks" (3rd paragraph page 3)? Note: The dates given as " Event" and

" Discovery" should also be given in the text discussion. Given that the second sentence of the third paragraph on page 3 states that the exact determination of when the relays exceeded their setpoint band is not possible, the significance of the dates February 5 and 6, 1986, is not clear. It appears that these may be the true discovery dates.

2. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.
3. 50.73(b)(2)(11)(L)--Identification (e.g. manufacturer and model no.) of the failed component (s) discussed in the text is not included.
4. 50.73(b)(4)--Discussion of corrective actions taken or planned is inadequate. Was anything done to try to prevent recurrence of this event (e.g., more 9

frequent surveillance)?

5. A logical transition does not exist between all ideas.
6. Some ideas are not presented clearly (hard to follow).
7. What is Electrical Engineering Calculation EC&C-17 l Abstract 1. Abstract does not adequately summarize the text. For l

example, the time that the relays were determined to

- be outside their setpoint band vs. the report date is not mentioned in the abstract. See text comment number 1. Additional space is available within the abstract field to provide the necessary information but it was not utilized.

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TABLE 0-1.

, SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

9. LER Number: 86-008-00 (continued)

Coded Fields 1. Item (4)--Title: Result (setpoints outside of range set forth in Technical Specifications) is not included.

2. Item (9)--Operating mooe is not included.
3. Item (10)--Power level is not included.
4. Item (ll)--0BSERVATION: It appears it would have been appropriate to also report this event under paragraph (s) 50.73(a)(2)(1).
5. Item (12)--Position title is not included.

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f TABLE D-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments 4

10. LER Number: 86-011-00 Scores: Text = 8.9 Abstract - 8.1 Coded Fields - 8.7 Overall - 8.7 Text 1. 50.73(b)(2)(11)(C)--Date information for major occurrences is inadequate. The expected completion date for the review should be included.
2. 50.73(0)(2)(ii)(D)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
3. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function <

identifier (s) and/or system name of each component or

, system referred to in the LER is not included.

4. 50.73(b)(2)(ii)(H)--A time estimate of the unavailability of the failed system is not included.
5. 50.73(b)(31--Very good safety assessment.
6. 50.73(b)(4)--0BSERVATION: The score for this requirement is based on the assumption that the supplemental report will contain all the necessary information.
7. The report would be more readable if the outline headings were underlined.
  • 8. Acronym (s) and/or plant specific designator (s) are undefined. E0Ps and NPSH should be defined.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or f' planned as a result of the event is inadequate. The l fact that corrective actions will be based on the review should be mentioned.

Coded Fields 1. Item (4)--Title: Root cause (unknown) is not included.

s

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

,' 3. Item (12)--Position title is not included.

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TABLE 0-1. SPECIFIC LER COMMENTS FOR INDIAN POINT 2 (247)

Section Comments

11. LER Number: 86-012-00 Scores: Text - 9.2 Abstract - 8.4 Coded Fields - 8.3 Overall = 8.9 Text 1. 50.73(b)(2)(ii)(F)--The Energy Industry Identification System component function identifier (s) and/or system name of each component or system referred to in the LER is not included.

Abstract 1. 50.73(b)(1)--Summary of corrective actions taken or planned as a result of the event is inadequate. The abstract should state that the use of an "N/A" will no longer be permitted in a surveillance test.

Coded Fields 1. Item (91--Operating mode is not included.

2. Item (12)--Position title is not included.
3. Item (13)--Component failure field contains data when no component failure occurred.

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