05000293/FIN-2015002-02
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Finding | |
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Title | Inadequate Operability Determination for the B EDG Results in TS Violation |
Description | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when Entergy staff performed an inadequate operability determination that assessed the X-107B emergency diesel generator (EDG) following cylinder head leakage indications during pre-start checks for a planned monthly operability run. Specifically, after engine coolant had been observed spraying from one of the open cylinder test cocks during X-107B EDG pre-start checks, operators determined that the EDG remained operable because the volume of leakage that had been observed would not have precluded a successful start of the engine. Operators did not consider that potential sources of leakage, such as a crack in the cylinder or cylinder head, could reasonably worsen during operation, such that the engine would not be able to complete its 30-day mission time, and therefore should be declared inoperable. Entergys immediate corrective actions included replacement of the X-107B EDG 9L cylinder head and sending out the damaged cylinder head for analysis by a vendor. The completion of the analysis by the vendor is being tracked by CR-2015-2109. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Entergy staff inadequately determined that the X-107B EDG was operable, which resulted in the operability of the X-107A EDG not being verified, either through determination that it was not inoperable due to a common cause failure or performing TS SR 4.5.F.1 in its entirety. This finding was evaluated in accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the area of Human Performance, Conservative Bias, because Entergy staff did not use decision making practices that emphasized prudent choices over those that are simply allowed. Specifically, Entergy staffs operability determination for the X-107B EDG was based on the conclusion that the as found condition would not have caused the engine to be inoperable because it would not have created a hydraulic lock; they did not consider that the condition would likely worsen during EDG operation, nor did their operability determination consider EDG mission time |
Site: | Pilgrim |
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Report | IR 05000293/2015002 Section 1R15 |
Date counted | Jun 30, 2015 (2015Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | B Dionne B Scrabeck E Carfang E Knutson E Miller J Furia M Jimenez R Mckinley S Pindale T Burns |
Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Pilgrim - IR 05000293/2015002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2015Q2
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