05000247/FIN-2014002-02
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Finding | |
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Title | Incomplete Risk Assessment While Pressurizer Safety Valves Were Being Remov |
Description | The inspectors identified an NCV of 10 CFR Part 50.65(a)(4) when Entergy did not adequately re-assess and manage risk when planned maintenance was not completed as scheduled. Specifically, IPEC staff did not re-assess the risk when the scheduled activity to remove pressurizer safety valves was delayed and did not inform the control room operators in the change in plant configuration due to the delayed maintenance activity. As a result, for about one shift, the control room operators were not aware of reactor coolant system (RCS) status (intact vs. not intact) and could have been challenged in the completing recovery actions in the event of loss of residual heat removal (RHR) cooling. This issue was entered into the licensees corrective action program as CR-IP2-2014-1986. Not having re-assessed risk when safety valve removal was delayed and not keeping the control room operators aware of plant status due to the delayed maintenance activity resulted in the operators not knowing RCS status (intact vs. not intact) for about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, which was contrary to Entergys procedural requirements and was a condition reasonably within Entergys ability to foresee and correct and was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, operator response to a loss of decay heat removal could lead to an incorrect decision which could adversely affect or delay recovery actions. The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Initial Characterization of Findings, which directed the inspectors to screen the finding through IMC 0609, Appendix G, Shutdown Operations, using Attachment 1, Checklist 2, PWR [pressurized-water reactor] Cold Shutdown Operation: Loops Filled and Inventory in Pressurizer. No deficiencies were identified in Checklist 2 which required a phase 2 or phase 3 quantitative assessment as the licensee maintained adequate mitigation capability. The inspectors concluded this finding had a cross-cutting aspect in the area of Human Performance, Work Management, when the licensee work process did not identify changing risk during removal of the pressurizer safety valves and manage the need for coordination between the work group and operations. Specifically, no controls were in place during the delay in pressurizer safety removal to ensure control room operators remained informed of the status of the reactor coolant system. The lack of coordination could have impacted operators ability to respond to a loss of RHR event. |
Site: | Indian Point |
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Report | IR 05000247/2014002 Section 1R13 |
Date counted | Mar 31, 2014 (2014Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.13 |
Inspectors (proximate) | A Burritt A Patel E Burket E Gray G Newman J Furia J Stewart S Chaudhary S Pindale T. Lamb |
Violation of: | 10 CFR 50.65(a)(4) 10 CFR 50.65 |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Indian Point - IR 05000247/2014002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Indian Point) @ 2014Q1
Self-Identified List (Indian Point)
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