The inspectors identified an
NCV of
10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(4) for Entergys failure to conduct an adequate risk assessment prior to securing the C
feedwater pump. Specifically, the inspectors identified that Entergy personnel had not analyzed the impact to plant risk of securing the C
feedwater pump. Entergys corrective actions included briefing operators that securing a
feedwater pump was a HRE-TRAN, i.e. an activity considered to raise the likelihood of an initiating event that is likely to result in a plant trip, and initiating
CR-VTY-2012-02160 and
CR-VTY-2012-02894. The inspectors determined that the issue was more than minor because it is similar to
IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, example 7.e in that the overall elevated plant risk put the plant into a higher risk category established by Entergy. The inspectors determined the significance of the finding using
IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management
Significance Determination Process. The finding was determined to be of very low safety significance (Green) because the
Incremental Core Damage Probability Deficit for the timeframe that the C
feedwater pump was being secured was less than
1E-6 (approximately
4E-9). The inspectors determined that the finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because the procedure describing HRE-TRAN was not sufficiently clear and complete in its description to ensure nuclear safety.
