05000293/FIN-2016011-06

Finding

Title

Design Change Not Appropriately Reviewed by Entergy

Description

The NRC team identified a preliminary greater than Green finding and apparent violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with Entergys failure to ensure that design changes were subject to design control measures commensurate with those applied to the original design and were approved by the designated responsible organization. Specifically, Entergy received a new style right angle drive for the A emergency diesel generator radiator blower fan from a vendor but failed to adequately review the differences in the design of the drives to identify potential new failure mechanisms for the part or the need for related preventive measures. Entergy entered this issue into the corrective action program as CR-PNP-2016-07443. The performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. 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 team screened the finding for safety significance and determined that a detailed risk evaluation was required based on the A emergency diesel generator being inoperable for greater than the technical specification allowed outage time. Region I senior reactor analysts performed a detailed risk evaluation. The finding was preliminarily determined to be of greater than very low safety significance (greater than Green). The risk important sequences were dominated by external fire risk. Specifically, a postulated fire in the B 4 kilovolt (KV) switchgear room with a consequential loss of the unit auxiliary generator power supply, non-recoverable loss of off-site power (LOOP) to both safety buses A5 and A6, loss of the B emergency diesel generator with the conditional failure of the A emergency diesel generator, along with the loss of bus A8 feed (from the shutdown transformer or station blackout (SBO) diesel generator) to safety buses A5 and A6. The internal event risk was dominated by weather related LOOPs, failure of the A emergency diesel generator, with failure of the B emergency diesel generator and SBO diesel generator to run, along with failure to recover offsite power or the emergency diesel generators. See Attachment 1, A Emergency Diesel Generator Cooling Water System Degradation Detailed Risk Evaluation, for a detailed review of the quantitative criteria considered in the preliminary risk determination. The NRC team did not assign a cross-cutting aspect to this finding because the performance deficiency occurred in May 2000. Entergys program has undergone changes since May 2000, and the NRC team did not identify any recent examples of this performance deficiency. Other aspects of Entergys performance related to this issue are further discussed in Sections 5.10.3 and 6.3.4.

06
Site:	Pilgrim
Report	IR 05000293/2016011 Section 4OA4
Date counted	Mar 31, 2017 (2017Q1)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 95003
Inspectors (proximate)	D Jackson C Bickett F Arner R Clagg J Bream D Dodson A Nguyen E Duncan G Pick R Ruiz A Sanchez D Silk J Josey J Brand G Eatmon K Miller S Elkhiamy J Schoppy M Keefe L Micewski C Norton D Sieracki N Staples R Lorsona Nguyen A Sanchez C Bickett C Norton D Dodson D Jackson D Silk E Duncan F Arner G Eatmon G Pick J Brand J Bream J Josey J Schoppy K Miller L Micewski M Keefe N Staples R Clagg R Lorson R Ruiz S Elkhiamy D Sierack
Violation of:	10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion III, Design Control Technical Specification
INPO aspect
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v • d • e

Finding - Pilgrim - IR 05000293/2016011

1(4)2(8)3(0)4(0)5(0)6(0)7(2)8(0)9(0)10(0)201(0)301(0)403(4)404(0)405(2)14(3)

IR 05000293/2016011: 1 2 3 4 5 6 7 8 9 10 11 12 13

Finding List (Pilgrim) @ 2017Q1

CCA Matrix: 2017Q1

	Q	CCA	Title
05000293/FIN-2016003-04	2016Q3	H.8	Failure to Adequately Evaluate the Effect of Degraded Normally Energized Agastat relays on PCIVs Operability
05000293/FIN-2016003-03	2016Q3		Failure to Properly Implement Agastat Control Relays Preventive Maintenance Procedure in Accordance with TS 5.4.1
05000293/FIN-2016003-02	2016Q3	P.5	Inadequate Operability Assessment on EDG B
05000293/FIN-2016003-01	2016Q3	P.2	Process Radiation Monitor Subsystems 10 CFR 50.65(a)(2) Not Met
05000293/FIN-2016403-02	2016Q4	H.1	Security
05000293/FIN-2016403-10	2016Q4		Security
05000293/FIN-2016004-05	2016Q4	H.5	Feedwater Regulating Valve Failure Results in Reactor Scram
05000293/FIN-2016004-04	2016Q4	H.14	Failure to Correct a Condition Adverse to Quality Associated with Main Steam Isolation Valve
05000293/FIN-2016004-02	2016Q4	H.6	Ineffective Corrective Actions to Correct High Pressure Coolant Injection System Vibrations
05000293/FIN-2016403-01	2016Q4	H.12	Security
05000293/FIN-2016403-03	2016Q4	H.11	Security
05000293/FIN-2016403-04	2016Q4	H.14	Security
05000293/FIN-2016403-06	2016Q4		Security
05000293/FIN-2016004-03	2016Q4	H.12	Failure to Properly Assess and Manage Risk Associated with Shutdown Transformer Protective Relay Testing
05000293/FIN-2016403-05	2016Q4	H.7	Security
05000293/FIN-2016004-01	2016Q4	H.14	Failure to Promptly Perform an Operability Evaluation for a Recirculation Flow Converter
05000293/FIN-2016011-10	2017Q1	H.14	Failure to Promptly Correct a Condition Adverse to Quality for the Residual Heat Removal System
05000293/FIN-2017001-01	2017Q1		Concern Regarding Ability to Declare EALs during Loss of Control Room Air Conditioning
05000293/FIN-2017406-01	2017Q1		Security
05000293/FIN-2017001-04	2017Q1		Failure to Submit a Required 50.72 Notification
05000293/FIN-2016011-07	2017Q1		Failure to Report Condition Prohibited by Technical Specifications and a Safety System Functional Failure
05000293/FIN-2017001-03	2017Q1	P.2	Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool
05000293/FIN-2017001-02	2017Q1	H.8	Failure to Follow Procedures for Controlled Shutdown
05000293/FIN-2016011-11	2017Q1	H.3	Failure to Adequately Develop and Implement Targeted Performance Improvement Plans
05000293/FIN-2016011-09	2017Q1	P.2	Ineffective Corrective Actions to Address Conditions Adverse to Quality Regarding Components in Contact with or Close Proximity to the Drywell Liner
05000293/FIN-2016011-08	2017Q1	P.2	Failure to Adequately Monitor the Performance of Maintenance Rule Scoped Components
05000293/FIN-2016011-05	2017Q1	H.1	Failure to Establish Corrective Actions to Address Scope of Procedure Quality Issues
05000293/FIN-2016011-04	2017Q1	H.4	Programmatic Issue with Implementation of the Operability Determination Process
05000293/FIN-2016011-03	2017Q1	H.8	Failure to Issue Appropriate Corrective Actions to Preclude Repetition for the Causes of the September 2016 Scram
05000293/FIN-2016011-02	2017Q1	H.8	Failure to Establish Corrective Actions to Preclude Repetition of a Significant Condition Adverse to Quality
05000293/FIN-2016011-01	2017Q1	H.12	Failure to Identify All Root Causes of a Significant Condition Adverse to Quality
05000293/FIN-2016011-06	2017Q1		Design Change Not Appropriately Reviewed by Entergy

Self-Identified List (Pilgrim)

	Q	Title
05000293/FIN-2016403-07	2016Q4	Licensee-Identified Violation
05000293/FIN-2016403-08	2016Q4	Licensee-Identified Violation
05000293/FIN-2016403-09	2016Q4	Licensee-Identified Violation
05000293/FIN-2016004-06	2016Q4	Licensee-Identified Violation
05000293/FIN-2016011-12	2017Q1	Licensee-Identified Violation
05000293/FIN-2016011-13	2017Q1	Licensee-Identified Violation

[Pilgrim Findings full list]

05000293/FIN-2016011-06

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