The inspectors identified an
NCV of very low safety significance (Green) of
10 CFR Part 50, Appendix B, Criterion III, Design Control, because Entergy did not select and review safety-related cables suitable for application in the environment in which they were found. Specifically, Entergy allowed the continuous submergence of safety-related cables that were not qualified for continuous submergence and failed to demonstrate that the cables would remain
operable. Entergy initiated
CR-VTY-2009-04142 and
CR-VTY-2010-01422 to address the issues, commenced dewatering of the affected manholes, and initiated a preventive maintenance plan to ensure proper conditions. This finding is more than minor because if left uncorrected, the performance deficiency had the potential to
lead to a more significant safety concern. Specifically, the inspectors noted that the insulation of continuously submerged cables would degrade more than dry or periodically wetted cables which would
lead to failures. The inspectors determined the significance of the finding using
IMC 0609.04, Phase 1 -Initial Screening and Characterization of Findings. The finding was determined to be of very low safety significance (Green) because it was a design or qualification deficiency which was confirmed to have not resulted in a loss of operability or functionality. Specifically, the continuously submerged cables were not designed or qualified for that environment but were still fully capable of performing their design functions. The inspectors determined this finding had a cross-cutting aspect in the area of problem identification and resolution within the
CAP component because Entergy personnel did not thoroughly evaluate the problem when submerged cabling was identified. (P.1 (c))