05000293/FIN-2014003-02
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Finding | |
|---|---|
| Title | Failure to Comply with TS Required Actions for Inoperable PCIV |
| Description | The inspectors identified a Green NCV of Technical Specification (TS) 3.7.A, Primary Containment, because Entergy failed to comply with the TS-required actions for inoperable PCIVs. Specifically, while maintenance was being performed on an inoperable automatic PCIV, Entergy failed to either isolate and deactivate at least one containment isolation valve in the same line, or to complete an orderly shutdown to the Cold Shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Entergy has captured this issue in CR-PNP-2014-2008, and has assigned corrective actions to update the Pilgrim TS bases document to provide additional guidance on acceptable methods of PCIV isolation. The performance deficiency is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone, and adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (i.e. containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Entergys failure to close and deactivate a valve in the same line as the inoperable PCIV as required by TS did not ensure the operability of the primary containment. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, effective July 1, 2012, the inspectors determined that this finding is of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components. This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because Entergy did not use decision-making practices that emphasize prudent choices over those that are simply allowable, or in this case, those that are perceived to be allowable. Specifically, Entergys reliance on the design characteristics of the PCIVs to meet the TS requirement, while refraining to take additional measures to ensure the valves remained closed in the case of personnel error or equipment malfunction, was not conservative. |
| Site: | Pilgrim |
|---|---|
| Report | IR 05000293/2014003 Section 1R15 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | B Dionne B Scrabeck E Carfang F Arner H Gray J Nicholson J Schoppy K Kolaczyk M Schneider R Latta R Mckinley S Chaudhary |
| Violation of: | Technical Specification Technical Specification - Procedures |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Pilgrim - IR 05000293/2014003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2014Q2
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