05000247/FIN-2013003-01
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Finding | |
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| Title | Failure to Assess and Manage Risk Associated with Reactor Testing Below Normal Operating Conditions |
| Description | The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), requirements for monitoring the effectiveness of maintenance, when Entergy did not assess and manage the risk associated with reactor protection testing with Unit 3 below normal operating pressure. Specifically, on March 27, 2013, with Unit 3 just having entered Mode 3 and while raising reactor coolant system (RCS) temperature, required risk management actions were not taken regarding a reactor protection system test, and due to a problem with the test equipment, a low pressure safety injection (SI) actuated. Entergy operators took action to mitigate the SI, and the event was entered into the corrective action program (CAP) as CR-IP3-2013-2115. A root cause evaluation was initiated to determine the acceptability of conducting this test with the plant at low pressure in Mode 3 and address extent of condition. The finding was more than minor because it was associated with the configuration control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. In addition, in accordance with IMC 0612, Appendix E, Example 7.f, had the risk assessment for the testing been done using Entergys risk procedure, the assessment would have determined the impairment of the low pressure SI interlocks and would have placed the plant in an administrative higher risk condition (Orange). The finding was evaluated using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, and determined to be of very low safety significance (Green) when the risk assessment was performed correctly with the resulting actual incremental core damage frequency deficit determined to be very small, less than 1E-6. The inspectors determined this finding had a cross-cutting aspect in Human Performance, Work Control, when Entergy personnel did not take risk insights, job site conditions such as the plant pressure, technical specification requirements, and an inaccurate pressurizer level indication into consideration when preparing for testing along with the need for contingencies. |
| Site: | Indian Point  |
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| Report | IR 05000247/2013003 Section 1R13 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | P Cataldo J Richmond S Rutenkroger J Furia S Mccarver S Barr P Presby A Patel J Stewart K Dunham |
| Violation of: | 10 CFR 50.65(a)(4) Technical Specification - Procedures 10 CFR 50.65 Technical Specification |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Indian Point - IR 05000247/2013003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Indian Point) @ 2013Q2
Self-Identified List (Indian Point)
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