05000293/FIN-2015001-01
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Finding | |
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Title | Failure to Perform Testing of Safety Related Undervoltage Alarm Relays |
Description | The inspectors identified an NCV of very low safety significance (Green) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control, because Entergy did not establish requirements in accordance with their test program for safety-related 4160 volt (V) degraded voltage relays in accordance with Updated Final Safety Analysis Report (UFSAR) Section 8.4.7. Specifically, 4160V switchgear relays 127-509/1 & 2 undervoltage setpoints were not tested for the first time until March 2015, which identified the relays were out of calibration by 22 percent. This impacted operators ability to perform alarm response procedure ARP-C3L, which directs operators to trip the X107A emergency diesel generator (EDG) when the alarm for relay 127-509/1 & 2 is received. Entergy entered condition report (CR)-PNP-2015-1614 and CRPNP- 2015-1623 into the corrective action program (CAP) to address the degraded condition. Corrective actions included an immediate operability determination and recalibration of the relays to their required set points prior to restoration of the X107A EDG. This finding is more than minor because it impacted the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, the finding is similar to example 1.a in Appendix E of IMC 0612, because no record of testing had ever been recorded or performed; and that testing in 2015 determined that relays 127-509/1 & 2 were degraded and would have impacted the operators ability to take alarm response procedure actions. In accordance with IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent a loss of a safety system, did not represent a loss of a safety function of a system or a single train greater than its allowed outage time, and did not screen as potentially risk significant due to external events. Specifically, although testing was not being performed to ensure proper relay response, inspectors confirmed relay protection was available to ensure that at a minimum emergency core cooling system (ECCS) injection valves would not have been impacted if the X107A EDG voltage regulator failed during a loss of offsite power (LOOP)/loss of coolant accident (LOCA). This finding had a cross-cutting aspect in the area of problem identification and resolution related to identification because Entergy did not implement the CAP with a low threshold for identifying issues. Specifically, Entergy had multiple opportunities to identify that relays 127-509/1 & 2 undervoltage dropout settings were not being tested during establishment of the test setup or through periodic trending against similar relays in other systems [P.1]. |
Site: | Pilgrim |
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Report | IR 05000293/2015001 Section 1R15 |
Date counted | Mar 31, 2015 (2015Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | B Dionne B Scrabeck E Burket E Carfang E Love E Miller J Schoppy N Floyd O Masnyk-Bailey R Mckinley S Barr |
Violation of: | 10 CFR 50 Appendix B Criterion XI |
CCA | P.1, Identification |
INPO aspect | PI.1 |
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Finding - Pilgrim - IR 05000293/2015001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2015Q1
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