10 CFR 50.65(a)(4) requires, in part, that before performing maintenance activities, the. licensee shall assess and manage the increase in risk that may result from proposed maintenance activities. Contrary to the above, on January 3, 2011, Entergy did not adequately assess and manage the increase in risk due to proposed emergent maintenance activities. This resulted in a non-conservative risk assessment and failure to take all of the appropriate risk management actions for the actual plant conditions. Entergy identified this after the emergent maintenance activities had been completed, and entered the issue into their corrective action program (
CR-VTY-2011-00028) to evaluate for appropriate corrective actions. The finding is more than minor because it is similar to
IMC 0612, Appendix E, Example 7.e; in that, the overall elevated plant risk put the plant in a higher licensee-established risk category. The finding was evaluated using
IMC 0609 Appendix K, \"Maintenance Risk Assessment and Risk Management
Significance Determination Process,\" and was determined to be of very low safety significance (Green) because the
Incremental Core Damage Probability Deficit between the actual plant conditions and the incorrect risk assessment for the duration of the activity was less than 1.0 E-6 (approximately 3.3 E-9)