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05000247/FIN-2010002-02Refueling Cavity Leakage into Containment2010Q1The inspectors identified an unresolved item in that the Entergy technical staff has not evaluated the impact of reactor refueling cavity water leakage on the dissimilar metal welds between the stainless steel liner and the carbon steel studs that attach the liner to the concrete wall. During reactor refueling activities that occur for approximately two weeks every other year, when the refueling cavity is flooded, water (containing approximately 2700 ppm boric acid) has leaked at a rate of between 2 and10 gpm. The water dripped on equipment in the 46 foot level of containment. The effects of the leakage have not been evaluated with regard to liner attachment welds and carbon steel hardware. The reactor refueling cavity leakage has been documented in Entergy\'s corrective action program back to 1993. Entergy personnel had previously attempted to repair this leakage by applying various chemically bonded coatings to the stainless steel liner in various prospective leak locations. The coatings have not proven effective in stopping the leakage. As documented in CR-IP2-2008-01629 Entergy plans to research available technologies to identify a new permanent coating material and to apply this new material to specified areas of the leaking liner during the next three refueling outages. Completion of these activities is planned for 2014. Until a new permanent coating is identified and applied, a temporary coating material would be used as an interim measure to minimize leakage. If this remediation plan does not stop the leakage by 2014, Entergy will perform additional monitoring to assess the condition of potentially affected structures. During the refueling outage in April 2010 (2RF019) the inspectors determined that Entergy personnel had not identified a new permanent coating material and had applied a temporary coating to prospective leak locations. The inspectors determined the reactor refueling cavity liner is a safety-related structure. The UFSAR section 9.5.1.4, Protection Against Radioactivity Release from Spent Fuel and Waste Storage states: The reactor cavity, refueling canal and spent fuel storage pit are reinforced concrete structures with a seam-welded stainless steel plate liner. These structures are designed to withstand the anticipated earthquake loadings as seismic Class I structures so that the liner prevents leakage even in the event the reinforced concrete develops cracks. The reactor refueling cavity liner is classified as a QA category A structure in design drawing UE&C #9321-F-1283. The stainless steel liner is attached to the concrete cavity walls by a system of carbon steel Nelson Studs which are listed as being seismically qualified in drawing detail K. In CR-IP2-2000-09120 (documented in calendar year 2000), Entergy staff stated that the dissimilar metal weld between the stainless steel liner and the Nelson Studs may be subject to attack by galvanic corrosion or by intergranular stress corrosion cracking if sufficient concentrations of chloride ionic impurities are present due to leaking from the concrete cavity walls. This condition report was administratively closed without taking documented corrective action. Although there is no known degradation to this point, the inspectors concluded additional information is required by Entergy related to their assessment of this condition in accordance with Entergy procedures. The inspectors acknowledge that the leakage only occurs for approximately two weeks every other year, when the refueling cavity is flooded with water. For the remaining period of each operating cycle, this area is dry and area conditions should not be conducive to corrosion. (URI 05000247/2010002-02, Refueling Cavity Leakage into Containment)
05000247/FIN-2010002-03Improper Generrex Isolation Caused Reactor Trip2010Q1A self-revealing finding of very low safety significance was identified because Entergy personnel did not establish procedures that were appropriate to the task, and personnel did not adequately implement the procedures that existed for isolating the generator exciter system on the main generator. Specifically, on January 11, 2010, Entergy personnel did not properly isolate one rectifier exciter bank on the exciter system of the main generator while repairing a leak in the associated cooling water line. Entergy staff did not ensure that the procedural direction was adequate to ensure that the workers could recognize when the exciter rectifier disconnect switches were in the fully open position. In addition, Entergy supervisors did not stop the maintenance in the face of uncertainty when presented with several indications that the 24 exciter rectifier bank had not been isolated, including detecting unexpected voltage in the 24 exciter rectifier cabinet and a high temperature alarm associated with the exciter rectifier. As a result, the rectifier bank was not properly isolated electrically while the cooling water to the rectifier was isolated. This resulted in overheating the exciter bank control circuits which caused a main turbine trip and a reactor trip. This finding is more than minor because the performance deficiencies caused a reactor trip. The finding is associated with both the procedure quality and human performance attributes of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors performed a Phase 1screening in accordance with Inspection Manual Chapter (IMC) 0609 \"Significance Determination Process (SOP)\" and determined that the finding is of very low safety significance (Green) because it did not contribute to the likelihood that mitigation equipment or functions would not be available. The finding has a cross-cutting aspect in the area of human performance related to decision making. Entergy personnel did not make safety-significant or risk significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained (H.1.a).
05000247/FIN-2010003-01Inoperable Control Room Ventilation System due to Damper Mispositioning2010Q2The inspectors identified a Green NCV of Technical Specification (TS) 3.7.10 because Entergy personnel did not ensure proper configuration control of a damper in the control room ventilation system (CRVS), which resulted in both trains of CRVS being inoperable for greater than the TS allowed outage time. Although the closed damper was identified by the licensee during planned testing to fulfill Surveillance Requirement (SR) 3.7.10.4, this finding is being considered an NRC-identified finding due to significant questions from the inspectors that resulted in the implementation of additional corrective actions. Entergy personnel entered this issue into their Corrective Action Program (CAP) as CR-IP2-201 0-03076 and CR-IP2-201 0-03564 for resolution. Planned corrective actions included reinforcement of human performance tools, utilization of operating experience during future pre-job and pre-outage briefings, revised system check-off list, and implementation of a more robust method for locking the damper in position. This finding was greater than minor because it was associated with the Barrier Performance attribute of the Barrier Integrity cornerstone, and it impacted the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. This finding is of very low safety significance because it impacted the radiological barrier function of the control room but did not impact other barrier functions of the control room. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Work Practices component, because Entergy personnel did not ensure that human error prevention techniques were applied to ensure work activities on the \\\'A\\\' CRVS damper did not impact the nearby CCRB1 damper.
05000247/FIN-2010003-02Licensee-Identified Violation2010Q2TS 3.7.1, main steam safety valves (MSSVs), requires that MSSVs shall be operable, which, in part, is specifically met if as-found lift setpoints are within applicable acceptance criteria during in-service testing. Contrary to this requirement, on March 9, 2010, during performance of MSSV testing, Entergy personnel identified that MS- 45C and MS-48C exceeded as-found lift set pOints. Entergy technicians subsequently performed satisfactory adjustments and as-left testing to ensure operability was restored. Entergy documented this issue in the corrective action program for resolution under condition report CR-IP2-2009-01181. In addition, Entergy personnel analyzed the past operability and associated impact on the safety analysis with two MSSVs potentially lifting at greater than allowable setpoints and concluded that the condition would not have prevented the accident mitigation capability of the MSSVs overpressure function. Although two MSSVs were determined to be inoperable for an unknown duration, and potentially longer than the allowed outage time listed in the Unit 2 technical specifications, the inspectors determined that this finding is of very low safety significance because it did not increase the probability or consequences of any anticipated operational occurrence or accidents covered by the safety analysis.
05000247/FIN-2010004-01Reactor Trip Breaker Preventative Maintenance Procedure was not Adequately Implemented2010Q3A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified because Entergy personnel did not adequately implement the preventive maintenance (PM) procedure for the B reactor trip breaker (RTB).Specifically, on March 10, 2009, Entergy staff did not adequately implement PM Procedure 0-BRK-401-ELC, Westinghouse, Reactor Trip and Bypass Circuit Breaker (DB-50), which resulted in the inoperability of the B RTB shunt trip device function on July 5, 2010. Entergy personnel took immediate corrective actions to replace the B RTB and its associated fuse block assembly. This issue was entered into Entergy\\\'s corrective action program as condition report (CR)-IP2-201 0-4451. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (Le. core damage). Specifically, inadequate preventive maintenance contributed to the failure of the shunt trip device function of the B RTB. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding did not result in a loss of system safety function because the undervoltage coil was operable; there was not an actual loss of safety function of a single train for greater than its technical specification allowed outage time; and the issue was not potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program attribute of complete and accurate identification of issues. Specifically, Entergy staff performing preventive maintenance did not identify and communicate RTB conditions completely and accurately such that the B RTB conditions were fully identified in the CAP.
05000247/FIN-2010004-02Plant Operation Outside Technical Specifications Due to a Leak in the Reactor Coolant Pressure Boundary2010Q3This issue is considered within the traditional enforcement process because there was no performance deficiency identified and NRC IMC 0612, Appendix B, Issue Screening directs disposition of this issue in accordance with the NRC Enforcement Policy. The inspectors used the Enforcement Policy, Section 6.1 - Reactor Operations, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor and best characterized as Severity Level IV (very low safety significance) because it is similar to Enforcement Policy Section 6.1, Example d.1. Additionally, the inspectors assessed the risk associated with the issue by using IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. The inspectors screened the issue and determined that RCS leakage is considered a Loss-of-Coolant Accident initiator, and evaluated using the Initiating Event criteria in Appendix A. Based on the weld defect size and characterization of the flaw, it is not expected this existing flaw would have impacted the structural integrity of the bypass line, the leakage would not result in exceeding the TS limit for identified RCS leakage (10 gpm) nor would the leakage have likely affected other mitigation systems resulting in a total loss of their safety function. As a result, this issue would screen as very low safety significance (Green). Because this issue is of very low safety significance (Green) and it has been determined that this issue was not within Entergy's ability to foresee and correct, that Entergy staff's actions did not contribute to the degraded condition, and that actions taken were reasonable to identify and address this matter, and as such no performance deficiency exists, the NRC has decided to exercise enforcement discretion in accordance with Section 3.5 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation of TSs (EA-1 0-212). Further, because licensee actions did not contribute to this violation, it will not be considered in the assessment process or the NRC's Action Matrix. This LER is closed. Specific documents reviewed during this inspection are listed in the attachment.
05000247/FIN-2010005-01Inadequate Compensatory Measures for Out of Service Plant Vent Process Radiation Monitor2010Q4The inspectors identified a Green NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), because Entergy staff did not implement adequate compensatory measures when the R-27 plant vent process radiation monitor, which is used for emergency action level (EAL) classification, was taken out of service. Specifically, between October 25, 2010 and November 24, 2010, the R-27 monitor was out of service for repair following preventive maintenance with inadequate compensatory measures regarding the impact on EAL classification capability. Entergy personnel implemented shortterm corrective actions by providing adequate compensatory instructions for the operating crews. The issue was entered into Entergy\'s CAP as CRlP-2010-06721 which includes longer-term corrective actions regarding emergency preparedness procedure changes. This finding is more than minor because it affected the Emergency Response Organization attribute of the Emergency Preparedness (EP) cornerstone to ensure that the Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Specifically, Entergy personnel did not provide adequate compensatory measures for when the R-27 plant vent monitors were taken out of service. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.9 and Sheet 1, Failure to Comply, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to event classification (10 CFR 50.47(b)(4)) was a risk-significant planning standard (RSPS) problem; but it was not a RSPS functional failure of the Indian Point Energy Center (IPEC) event classification process. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program attribute of taking appropriate corrective actions to address safety issues in a timely manner. Specifically, Entergy staff did not take appropriate emergency planning compensatory corrective actions when the R-27 plant vent radiation monitor was taken out of service.
05000247/FIN-2010005-02Inadequate Work Planning Control Relative to Regenerative Heat Exchanger Permanent Shielding Modification That Resulted in Additional Unplanned Collective Exposure2010Q4A Green self-revealing finding was identified because Entergy personnel did not adequately plan and control work activities related to a regenerative heat exchanger permanent shielding modification in accordance with radiation work permit (RWP) 20102537 , 2R19 Permanent Regen Hx Shielding. Specifically, Entergy personnel did not perform walkdowns to support modification package planning and provided limited field supervision which resulted in significant unplanned collective exposure (17.189 person-rem compared to a revised work activity estimate of 8.000 person-rem). This issue was entered into Entergy\'s CAP as CR-IP2-2010-02817. The finding is more than minor because it is associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective of ensuring the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine reactor operations. Additionally, this finding is similar to the more than minor example 6.j provided in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor lssues, because it involves an actual collective exposure greater than 5 person-rem and exceeded the planned, intended dose by more than 50%. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to have very low safety significance (Green) because the finding involved an as low as reasonably achievable (ALARA) planning issue and the 3-year rolling average collective dose history was less than 135 person-rem (52.261 person-rem average annual exposure for 2Q07-2Q09). The finding has a cross-cutting aspect in the area of human performance associated with the work control attribute because Entergy\'s planned work activities did not adequately ncorporate the job site interferences and their resolution in accordance with radiological safety
05000247/FIN-2010005-03Inadequate Work Coordination Relative to Reactor Cavity Liner Repair That Resulted in Additional Unplanned Collective Exposure2010Q4A Green self-revealing finding was identified because Entergy personneldid not adequately plan and control work activities related to reactor cavity liner repair in accordance with RWP 20102530, 2R19 Cavity Liner Repair. Specifically, outage schedule delay and inadequate work coordination resulted in the use of back-up workers to perform the reactor cavity sealant removalwork, and also resulted in reactor head shielding removal and cancellation of additional shielding that was specified in the ALARA plan, which resulted in significant unplanned collective exposure (7.058 person-rem compared to a revised work activity estimate of 3.635 person-rem). This issue was entered into Entergy\'s CAP as CR-lP2-2010-02817. This finding is more than minor because it is associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective of ensuring the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine reactor operations. lt is also similar to the more than minor example 6.j provided in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor lssues, because it involves an actual collective exposure greater than 5 person-rem and exceeded the planned, intended dose by more than 50%. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to have very low safety significance (Green) because the finding involved an as low as reasonably achievable (ALARA) planning issue and the 3-year rolling average collective dose history was less than 135 person-rem (52.261 person-rem average annua exposure for 2007 -2009). The finding has a cross-cutting aspect in the area of human performance associated with the work coordination attribute because Entergy personnel did not coordinate and implement work activities as planned, which resulted in significant dose overrun.
05000247/FIN-2010005-04Failure to Perform Required Quality Control lnspections2010Q4The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion X, lnspection, because Entergy personnel did not ensure that quality control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the quality assurance program (OAP). Entergy personnel performed extensive reviews and initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of quality control verification inspections. This issue was entered into Entergy\'s corrective action program (CAP) as CR-HQN-2009-01184 and CR-HQN-2010-0013. This finding is more than minor because it is a programmatic deficiency that if lef uncorrected, could lead to a more significant safety concern in that the failure to check quality attributes could involve an actual impact to plant equipment. This finding is associated with the design control attribute of the Mitigating Systems cornerstone because missed quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding is a qualification deficiency confirmed not to result in a loss of operability or functionality. Specifically, inspectors verified by sampling that work documents provided objectiv quality evidence that work activities that had missed quality control verifications were properly performed. The finding has a cross-cutting aspect in the area of human performance associated with the decision-making attribute because Entergy personnel did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether Quality Controlverification inspections were appropriate.
05000247/FIN-2010005-05Failure to lmplement the Experience and Qualification Requirements of the Quality Assurance Program2010Q4The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program (QAP), because Entergy personnel did not implement the qualification and
05000247/FIN-2010005-06Inadequate Main Boiler Feed Pump Speed Controller Setting2010Q4A Green self-revealing finding was identified because Entergy\'s procedure 2-IC-PC-N-P-408A, Main Boiler Feed Pump (MBFP) Discharge Pressure Spee Control, did not provide adequate guidance to ensure proper settings for the MBFP speed controller settings at low power operations. Specifically, between May 5, 2006 and September 3, 2010, procedure 2-lC-PC-N-P-408A did not provide adequate guidance to ensure proper settings for the MBFP speed controller settings at low power operations, resulting in a slow MBFP response, which contributed to a reactor trip from 41 % power. Entergy personnel took immediate corrective actions to change the MBFP speed controller settings. This issue was entered into Entergy\'s corrective action program (CAP) as condition report (CR)-lP2-2010-05484. This finding is more than minor because it is associated with the design control attribute of the Initiating Events cornerstone and affects the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety function during power operations. Specifically, inadequate design control of the MBFP speed controller settings contributed to a reactor trip. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding did not contribute to the likelihood that mitigation equipment or functions would not be available. The inspectors determined there was no cross-cutting issue associated with the finding because the performance deficiency did not reflect Entergy\'s current performance. Specifically, the performance deficiency occuned more than three years ago and was outside the current assessment period.
05000247/FIN-2010005-07Failure to Staff the Site TSC and OSC Within 60 Minutes of an Alert Emergency Declaration2010Q4A Green self-revealing NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), was identified because Entergy staff did not adequately implement the requirements of the IPEC Emergency Plan. On the evening of November 7, 2010, the Unit 2 operators declared an Alert emergency at 1849 hours. The technical support center (TSC) was staffed and declared operational at 2008 hours, and the operations support center (OSC) was staffed and declared operational at 2015 hours. Both of these activation times exceeded the 60-minute staffing requirement in the IPEC Emergency Plan. This issue was entered into Entergy\'s CAP as CR-IP2-2010-6813, CR-IP2-2010- 6831, and CR-IP2-2010-6871. This finding is more than minor because it affected the Emergency Response Organization (ERO) attribute of the EP cornerstone to ensure that Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Entergy personnel did not meet the requirements of the IPEC Emergency Plan in that the TSC and OSC were not staffed nor declared operational within 60 minutes of the Alert emergency declaration on November 7,2010. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.2 and Sheet 2, Actual Event lmplementation Problem, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to ERO augmentation (10 CFR 50.47 (b) (2) was a non-risk-significant planning standard problem which occurred during an Alert emergency and is therefore of very low safety significance (Green).This finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute of defining and effectively communicating expectations regard ing proced u ral com pliance and personnel following proced ures. Specifically, Entergy staff did not comply with ERO expectations and procedures regarding prompt reporting to an assigned emergency response facility during an actual event.
05000247/FIN-2010005-08Failure of Offsite Notification Procedure to Meet the Requirements of the Site Emergency Plan2010Q4The inspectors identified a Green NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), because the Entergy emergency plan implementing procedure (EPIP) for notification of offsite officials did not meet the requirements of the IPEC Emergency Plan. This EPIP had contained a deficiency in the backup process for offsite notification since July 2006. Entergy personnel responded by documenting the deficiency in CR-lP2-2010-07563 and by initiating a procedure change to align the backup process with the Emergency Plan commitments. This finding is more than minor because it affected the Emergency Response Organization attribute of the EP cornerstone to ensure that the Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Entergy procedures allowed for a back-up notification process that did not comply with the requirements of the site emergency plan: the Emergency Plan requires that the Shift Manager or his designee notify the offsite authorities of an emergency declaration, while Form EP-4 directed the delegation of this responsibility to an offsite authority itself. In accordance with Inspection Manual Chapter (lMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.5 and Sheet l, Failure to Comply, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to event notification (10 CFR 50.47(b)(5)) was a RSPS problem. lt was not a RSPS functional failure of the IPEC event notification process, because the deficiency in the IPEC EPIP was in the backup method for offsite notification, and despite the proceduralflaw offsite notifications were made in a timely and accurate manner on November 7,2010. The inspectors determined there was no cross-cutting aspect associated with this finding because the performance deficiency did not reflect Entergy\'s current performance. Specifically, the performance deficiency associated with a procedure change made in July 2006 occurred more than three years ago and was outside the current assessment period.
05000247/FIN-2010005-09Failure to Meet TS Oversight Requirement2010Q4A Green self-revealing NCV of Technical Specification (TS) 5.1, responsibility, was identified because on February 9, 2010, the control room supervisor (CRS) assigned as having the control room command function, left the control room without designating another senior reactor operator (SRO) qualified individual to assume the control room command function. The CRS promptly returned to the control room shortly after the issue was identified. This issue was entered into Entergy\'s CAP as CR-IP2-201 0-00708. he finding is more than minor because it could be reasonably viewed as a precursor to a significant event. Specifically, the absence of SRO oversight during licensed control room activities increases the likelihood of human performance errors contributing to an initiating event and reduces the effectiveness of event mitigation. The finding is associated with the human performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was not suitable for quantitative assessment using existing Significance Determination Process guidance. Using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, NRC management determined the finding to be of very low safety significance (Green) because of the short period the CRS was absent from the control room, and because no initiating events occurred during that time. The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because of the ineffective use of shift turnover practices, in that the CRS did not self check or communicate his decision to leave the control room to the rest of the control room staff.
05000247/FIN-2010005-10Licensee-Identified Violation2010Q4O CFR 50.47(b)(4), requires that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the licensee. 10 CFR 50.54(q), states in part, that licensees shall follow and maintain in effect emergency plans which meet the standards in 0.47(b). Contrary to the above, on October 2Q,2010, during an extent of condition review of industry operating experience, Entergy personnel identified that the R-54 radiation monitor\'s (monitor is for liquid effluent from the the value of 2.5e-1uCi/cc required to declare an Alert using emergency action level (EAL) Table 5.1. Entergy personnel documented this issue in the CAP as CR-IP2-20\'10-06417 and provided timely guidance to the control room operators to ensure proper classification of an event. In addition, Entergy personnel performed an apparent cause evaluation which included an extent of condition of the issue. The EAL chart and associated emergency plan procedures were revised to reflect the EAL changes. The inspectors determined that this finding is of very low safety significance because it did not result in a significant degradation of the risk significant planning standard function.
05000247/FIN-2010005-11Licensee-Identified Violation2010Q410 CFR 50, Appendix B, Criterion ll, Quality Assurance Program, requires, in part, that the licensee establish a quality assurance program which complies with Appendix B. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. Procedure EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level lll inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the Entergy\'s CAP as CR-HQN-2009-00111.
05000247/FIN-2010006-01Fire Scenario Resulting in Loss of Charging Pump Suction2010Q1The team identified a Green, Non-Cited Violation (NCV) of 10 CFR 50,Appendix R, III,G.3, in that Entergy failed to provide one train of reactor coolant system makeup free of fire damage for the control room, cable spread room, and cable tunnel fire zones for postulated fire scenarios. Specifically, Entergy failed to assure that one charging pump would remain free of fire damage for alternate shutdown fire scenarios that could produce a spurious closure of the volume control tank motor operated outlet valve. Entergy initiated condition report CR-IP2-201 0-00720 for long term resolution and promptly initiated hourly fire watches in all affected fire areas except for the cable tunnel as an interim compensatory measure. The cable tunnel was evaluated as not requiring an hourly fire watch and being sufficiently protected with installed fire detection and automatic fire suppression in addition to administrative controls that limit personnel access. This finding is more than minor because it is associated with the External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the availability of the charging system was not ensured for postulated fires in alternative shutdown areas. The team used Phase 1,2, and 3 risk assessment tools of IMC 0609, Appendix F, Fire Protection Significance Determination Process, to determine that this finding was of very low safety significance (Green), with an estimated total core damage frequency in the low to mid E-7/year range. A cross-cutting aspect was not identified.
05000247/FIN-2010006-02Fire Scenario Resulting in Loss of Cooling Water to Charging Pumps2010Q1The team identified a Green, Non-Cited Violation of 10 CFR 50, Appendix R, III,G.3, in that Entergy failed to provide one train of reactor coolant system makeup free of fire damage for the control room, cable spread room, electrical switchgear room, and cable tunnel fire zones for postulated fire scenarios. Specifically, Entergy failed to assure that one charging pump would remain free of fire damage for alternate shutdown fire scenarios that could produce a spurious trip of a component cooling water (CCW) pump. Entergy initiated condition report CR-IP2-201 0-00751 for long term resolution and promptly initiated hourly fire watches in all affected fire areas except for the cable tunnel as an interim compensatory measure. The cable tunnel was evaluated as not requiring an hourly fire watch and being sufficiently protected with installed fire detection and automatic fire suppression in addition to administrative controls that limit personnel access. This finding is more than minor because it is associated with the External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (ie., core damage). Specifically, the availability of the charging system was not ensured for postulated fires in alternative shutdown areas. The team used Phase 1, 2 and 3 risk assessment tools of IMC 0609, Appendix F, Fire Protection SDP, to determine that this finding was of very low safety significance (Green), with an estimated total core damage frequency in the low to mid E-7/year. Across-cutting aspect was not identified
05000247/FIN-2010008-01UFSAR Section 5.1.3.12, Cathodic Protection, not updated consistent with current plant conditions2010Q2The inspectors identified a Severity Level IV (SLlV) NCV of 10 CFR 50.71 (e) because Entergy personnel did not revise the updated final safety analysis report (UFSAR) with information consistent with plant conditions. Specifically, Entergy personnel did not remove reference to or correct information to reflect current plant conditions related to systems described as having cathodic protection consistent with UFSAR Section 5.1.3.12, Cathodic Protection. Entergy personnel identified that the UFSAR was inconsistent with current plant conditions in 2005. However, the corrective action to resolve the discrepancy was not completed. Entergy issued CR-IP2-2010-03512 to address the UFSAR discrepancy. This issue is considered within the traditional enforcement process because it has the potential to impede or impact the NRC's ability to perform its regulatory functions. The inspectors used the Enforcement Policy, Supplement I - Reactor Operations, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor because the longstanding and incorrect information in the UFSAR had a potential impact on safety and licensed activities. Similar to Enforcement Policy Supplement I, example D.6, the inspectors determined the violation was of SLiV (very low safety significance) since the erroneous information not updated in the UFSAR was not used to make an unacceptable change to the facility nor impacted a licensing or safety decision by the NRC. The inspectors determined there was a cross-cutting aspect in the area of problem identification and resolution associated with the component area of corrective action effectiveness. Specifically, Entergy personnel did not implement adequate actions in a timely manner to update the UFSAR to be consistent with plant conditions.
05000247/FIN-2010402-01Licensee-Identified Violation2010Q4
05000247/FIN-2010403-01Security2010Q3
05000247/FIN-2010403-02Security2010Q3
05000247/FIN-2010403-03Licensee-Identified Violation2010Q3
05000247/FIN-2010403-04Licensee-Identified Violation2010Q3
05000247/FIN-2011002-01Main Steam System Configuration Control Procedure Not Adequate to Ensure Closure of MS-55D2011Q1The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy procedure 2-COL-18.1, Main Steam and Reheat System, was not adequate to ensure closure of main steam isolation valve (MSIV) bypass stop valve MS-55D. Specifically, between April 10, 2010 and September 12, 2010, procedure 2-COL-18.1 did not provide adequate instructions to operators to ensure MS-55D was closed, which resulted in MS-55D being left partially open, and unable to isolate the 24 steam generator (SG) during accident conditions. Entergy personnel took immediate corrective actions to close MS-55D. This issue was entered into Entergys CAP as condition reports (CRs) IP2-2010-05694 and IP2-2010-06745. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the inadequate procedure resulted in the manual 3-inch MSIV bypass stop valve MS-55D for the 24 SG being left partially open for approximately five months. Based on NRC senior reactor analyst review, it was determined that operators could have isolated the other three SGs with their MSIVs and steamed them to remove decay heat and depressurize the plant using their atmospheric dump valves, while isolating the 24 SG further down the main steam system at the turbine bypass and stop valves. Therefore, using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding did not result in a loss of the safety function given the operators ability to isolate the other SGs and the 24 SG with the turbine bypass and stop valves. Additionally, the finding was not potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined there was no cross-cutting issue associated with the finding because the performance deficiency did not reflect Entergy\'s current performance. Specifically, the procedure change occurred more than three years ago and was outside the current assessment period.
05000247/FIN-2011002-02Notification Process for State/Local Authorities During a Simulator Scenario2011Q1Following the emergency declaration of an Alert by operators during a simulator drill scenario on January 25, 2011, the operators entered emergency plan implementing procedure IP-EP-210, Central Control Room, Attachment 9.1, Shift Manager/Plant Operations Manager (Emergency Director) Checklist. The IPEC Emergency Plan, Section E, Notification Methods and Procedures, paragraph 1.b.5, requires in part that an immediate notification (within 15 minutes) of an Alert is made by the Shift Manager or his designee to the New York State and Westchester, Rockland, Putnam, and Orange Counties. The emergency plan implementing procedure checklist directs the Shift Manager to complete a New York State (NYS) Radiological Emergency Data Form and have a control room Offsite Communicator email and fax the data form to the offsite authorities. The Offsite Communicator must then confirm receipt of the information by offsite authorities. NRC regulations, specifically 10 CFR 50.47(b)(5), require in part that procedures have been established for notification, by the licensee, of State and local response organizations. The drill scenario simulated one county not being present during the initial notification call via the radiological emergency communication system (RECS). The Offsite Communicator provided the event notification to NYS and the counties that were present on the line. The NRC inspectors observed that during the drill the Offsite Communicator did not implement additional communication measures to ensure the county, not present during the initial notification, received the event notification via fax. The inspectors observed that not affirming receipt of the notification by the county would not be consistent with IPEC Emergency Plan Section E in ensuring the licensee notifies all state and local authorities. The inspectors also observed that Entergy evaluators did not address this issue during the simulator scenario critique. The inspectors questioned Entergy personnel regarding their views during the simulator scenario and the expected operator response. The inspectors concluded additional information is required from Entergy staff related to their assessment regarding the adequacy of the procedure IP-EP-210, Attachment 9.1 and operator training with regard to the implementation of that procedure. Prior to completion of this inspection, Entergy personnel revised the Control Room Initial Notification Checklist (Form EP-4) to provide direction to operators in the event initial notifications are not able to be completed for required state and local authorities.
05000247/FIN-2011002-03Entergy Personnel Did Not Identify a Leak on the 25 Service Water Pump Piping2011Q1The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because Entergy personnel did not promptly identify and correct an adverse condition related to a service water (SW) pipe leak. Specifically, on October 29, 2010, NRC inspectors identified a leak on the base weld of the 25 SW pipe vacuum breaker which required subsequent evaluation and repair by Entergy personnel to restore operability of the 25 service water pump (SWP). This issue was entered into Entergys CAP as CR IP2-2010-6620. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the 25 SW pipe weld leak challenged the capability and the reliability of the SWP, and the pump was declared inoperable by Entergy personnel to conduct repairs. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding was not related to a design or qualification deficiency, did not represent a loss of system safety function, and the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the CAP attribute because Entergy personnel did not implement a CAP with a low threshold for identifying issues, specifically, identifying a leak on the 25 SWP piping.
05000247/FIN-2011003-01Entergy Did Not Identify and Correct a Performance Deficiency During an Emergency Preparedness Drill2011Q2The inspectors identified a Green NCV of 10 CFR 50.47, Emergency Plan, paragraph (b)( 14), because Entergy staff did not properly identify an emergency response deficiency which occurred during a drill. Specifically, during the operator training scenario conducted on January 25, 2011, the training staff did not identify that the Offsite Communicator had not contacted all offsite authorities, as required by the IPEC Emergency Plan (EP), thereby preventing the deficient performance from being placed in the corrective action program and remediated. This issue was entered into Entergy\'s CAP as CR-IP22011- 3498. This finding is more than minor because it affected the Emergency Response Organization attribute of the Emergency Preparedness cornerstone to ensure that Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.14 and Sheet 1, Failure to Comply, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to drill and exercise assessment (10 CFR 50.47(b)(14)) was a Planning Standard (PS) problem. Per Section 4.14.2.1 of Appendix B, states a critique that fails to identify any PS weakness during a limited facility interaction drill where there is a limited team of evaluators (e.g., facility table-top training drill, operator training simulator drill, individual facility training drill) is a green finding. The finding has a cross-cutting aspect in the area of human performance associated with the decision making attribute because Entergy Personnel did not communicate decisions and the basis for decisions to personnel who have a need to know the information in order to perform work safely, in a timely manner.
05000247/FIN-2011003-02Inadequate Monitoring of Maintenance Rule In-Scope Service Water Pump and Circulating Water Pump Bay Structures2011Q2The inspectors identified a Green NCV of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, because Entergy personnel did not monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined in paragraph (b) of 10 CFR 50.65, are capable of fulfilling their intended functions. Specifically, between August 25, 2004 and May 19, 2011, Entergy personnel did not monitor the condition of the service water pump (SWP) and circulating water pump (CWP) bays in a manner sufficient to provide reasonable assurance that the SWP and CWP bays remained capable of fulfilling their intended function. This issued was entered into Entergy\'s CAP as CR-IP22011- 2006. This finding is more than minor because if left uncorrected, the condition could have resulted in the loss of function due to degrading concrete material properties of structures and systems designed to mitigate design basis events. This finding is associated with the Mitigating Systems cornerstone. Entergy personnel evaluated the condition of the SWP and CWP bays and determined these structures continued to meet the licensing basis requirements, with reduced margin, and thus remained operable for design loads inclusive of site extreme environmental conditions. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, was not a loss of barrier function, and was not potentially risk significant for external events. The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because Entergy personnel did not define and effectively communicate expectations regarding procedural compliance and personnel follow procedures when Entergy staff documented a preventive maintenance (PM) task as complete when the work had not been performed.
05000247/FIN-2011003-03Inadequate Operability Evaluation for Degraded Pressurizer Modulating Heater Group Controller2011Q2The inspectors identified a Green NCV of 10 CFR 50, Appendix S, Criterion V Instructions, Procedures, and Drawings, because Entergy personnel did not adequately implement Procedure EN-OP-104 Operability Determination Process, to assess the operability of the pressurizer modulating heater group. Specifically, Entergy personnel did not adequately evaluate a degraded condition identified with the modulating heater group controller and the impact on the modulating heater group operability. This resulted in the modulating heater being inoperable between August 18, 2010 and January 19, 2011, and an unplanned entry into a Technical Specification (TS) limiting condition for operation (LCO) 3.4.9, Pressurizer. This issued was entered into Entergy\'s corrective action program (CAP) as CR-IP2-2011-3493. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure implementation resulted in the pressurizer modulating heater group being inoperable for approximately five months and an unplanned entry into a TS LCO. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the CAP attribute because Entergy personnel did not thoroughly evaluate the problems associated with the pressurizer modulating heater group controller such that the resolutions address causes and extent of conditions, as necessary. This includes properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality.
05000247/FIN-2011003-04Inaccurate 21 Static Inverter AC Output Voltmeter2011Q2The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, because Entergy personnel did not assure that adequate test instrumentation was available and used for 21 inverter surveillance tests. Specifically, between April 4, 2010, and July 13, 2011, the 21 inverter alternating current (AC) output voltage meter was used for TS surveillance tests without adequately addressing its degraded condition, which resulted in recording inaccurate and non-conservative TS surveillance test results. This issue was entered into Entergy\'s CAP as CR IP2-2011-03468. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affects the objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences (Le., core damage). Specifically, the degraded meter resulted in inaccurate and nonconservative TS surveillance results from April 4, 2010, to July 13, 2011. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding was not related to a design or qualification deficiency, did not represent a loss of system safety function because the control room instrument bus provided reasonable assurance that the requirements of the TS surveillance tests were met, and the finding did not screen as potentially risk significant due to external events. The finding has a cross-cutting aspect in the area of human performance associated with the decision making attribute because Entergy personnel did not use conservative assumptions in decision making. Specifically, Entergy personnel did not use appropriate assumptions regarding the inverter performance expectations during the 2010 to 2012 cycle considering actual performance during the 2008 to 2010 Cycle.
05000247/FIN-2011004-01Water Intrusion in the 480 Volt Room During Hurricane Irene2011Q3During Hurricane Irene's impact at Indian Point on August 28, 2011, operations personnel identified water intrusion in the 480 volt room. Water was entering the room through the seals around SW piping that penetrated the wall between the transformer yard and the 480 volt room. Operations personnel identified that the drain nearest to the water intrusion was plugged, and used a catch basin to direct the water to another drain. Operations personnel also placed sandbags around the 480 volt switchgear. The inspectors walked down the area during the hurricane and determined no water impacted the operation of the 480 volt switchgear. The inspectors are opening an URI to review the licensee's evaluation of the causes of the water intrusion into the 480 volt room and determine if there is a performance deficiency. Entergy personnel wrote CR-IP2-2011-4324 to address this issue.
05000247/FIN-2011004-02Marginally Designed Fuse Results in Fuse Failure and lnoperability of the Refueling Water Storage Tank2011Q3The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion Ill, Design Control, because Entergy personnel did not establish measures to assure that the design basis for sizing of a fuse was adequate and correctly translated into specifications, drawings, procedures, and instructions. Specifically, between November 29, 2005 and September 13, 2010, the fuse for four control room annuciator panels SASC was marginally sized which resulted in fatigue-induced fuse failure, associated loss of lighting to the annunciator panels, the loss of the refueling water storage tank (RWST) low low level alarms, and the inoperability of the RWST. Entergy personnel immediately replaced the fuse. This issue was entered into Entergy's CAP as CR-IP2-201 0-5713 and CR-IP2-2011-2967. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the loss of the RWST low low level alarms impacts an alert function relied on by operations personnel to swap the suction of the safety injection pumps from the RWST to the containment sump during accident conditions. Using IMC 0609.04, Phase 1 -Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding was related to a design or qualification deficiency confirmed to result in a loss of operability of the RWST low low level alarms; however, the finding did not represent a loss of safety system function because RWST level indication was available via redundant level instruments on the control room instrument panel that operators also normally rely on and are trained to use. Also the finding did not screen as potentially risk significant due to external initiating events. The finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program attribute because Entergy personnel did not thoroughly evaluate problems associated with the fuse for control room annunciator panels SA-SC, such that the resolution address causes and extent of conditions, as necessary. This includes properly classifying, prioritizing, and evaluating for operability and reportability conditions adverse to quality.
05000247/FIN-2011005-01Untimely Conective Actions for Repeated Control Room Fan Failures2011Q4The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion XVl, Corrective Action, because Entergy personnel did not promptly correct an adverse condition related to the safety-related control room ventilation fan. Specifically, between September 1, 2O1O and September 27 ,2011, inspectors identified that Entergy personnel did not promptly implement corrective actions to revise maintenance procedures to include post maintenance belt tensioning after a break-in period which resulted in additional failures of the 21 central control room fan (CCRF) while in service. Entergy staff revised scheduled work orders to perform post-maintenance break-in checks. Entergy personnel entered this issue into the CAP as CR-
05000247/FIN-2011005-02Water Intrusion Due to Leaking Flood Penetration Seals in the 480 Volt Room During Hurricane lrene2011Q4The inspectors identified a finding because Entergy procedure ENN-DC-150, Condition Monitoring of Maintenance Rule Structures, did not have appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, since September 6, 2007, Entergy personnel did not have an adequate procedure with acceptance criteria to determine if wall penetrations were properly sealed, which resulted in water intrusion into the 480 volt room during Hurricane lrene due to degradation of two service water (SW) pipe penetrations. Entergy personnel immediately directed water to a floor drain, placed sandbags around the 480 volt switchgear, and initiated actions to develop a permanent repair to the penetration seals. Entergy personnel entered this issue into the CAP as CR-\\P2-2011-4324. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Also, in accordance with Inspection Manual Chapter (lMC) 0612, Power Reactor Inspection Reports, Appendix E, Minor Examples, this finding is similar to examples 3.i and 3.j. Specifically, water intrusion in the 480 volt room could impact all four trains of 480 volt switchgear. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, was not a loss of barrier function, and was not potentially risk significant for external events. The finding has a cross-cutting aspect in the area of human performance associated with the resources attribute because Entergy personnel did not have complete, accurate and up-to-date procedures and work packages, to ensure adequate inspection of flood penetration seals.
05000247/FIN-2011005-03Maintenance Procedure Not Followed for Inertia Latch Cleaning on 21 Service Water Pump2011Q4The inspectors documented a self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, lnstructions, Procedures, and Drawings, because Entergy personnel did not follow Entergy procedure 2-BRK-022-ELC, Westinghouse Model DB-50 Breaker Preventative Maintenance, to remove and clean the zinc dichromate plating on 480 volt DB- 50 breaker inertia latches. Specifically, between July 24,2008 and October 3,2011, Entergy personnel did not follow procedure 2-BRK-022-ELC, steps 4.6.16.11 - 4.6.16.15 to remove zinc dichromate plating on the 21 service water pump (SWP) breaker inertia latch, resulting in the inoperability of the 21 SWP. Additionally, Technical Specification (TS) 3.7.8.A, Service Water System, which requires that a SWP on the essential header be restored to operable within 72 hours, was not met. Specifically, between September 30, 2011 and October 3,2011, 21 SWP was inoperable for 76.2 hours without the pump being returned to operable status. Entergy\'s corrective actions included replacing the 21 SWP breaker, performing an extent of condition inspection of the other safety-related 480 volt DB- 50 breakers, human performance error reviews and re-enforcing expectations, and enhancing the procedure to provide additional guidance for breaker cleaning. Entergy personnel entered these issues into the CAP as CR-lP2-2011-4893. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 21 SWP was inoperable and accrued unavailability for a period of time which could impact the service water system function to provide a heat sink for the removal of process and operating heat from safety related components during a Design Basis Accident or transient. Using IMC 0609 Attachment 4 Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that a Phase 2 evaluation was required because the finding screened as potentially risk significant since the 21 SWP inoperability was an actual loss of safety function of a single train for greater than the allowed outage time. A Region I Senior Risk Analyst (SRA) conducted a Phase 3 analysis because the complexities with the service water line-up during the performance deficiency exposure period are not well represented in the NRC Phase 2 notebook. Based upon the conclusions of the Phase 3 analysis, the Region I SRA determined this finding was of very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because Entergy personnel did not define and effectively communicate expectations regarding procedural compliance and personnelfollowing procedures.
05000247/FIN-2011005-04Licensee-Identified Violation2011Q410 CFR 50, Appendix B, Criterion V, lnstructions, Procedures, and Drawings,\' requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on September 12, 2011, a non-intrusive inspection on the 22 EDG was not accomplished in accordance with the maintenance procedure. Specifically, maintenance personnel rotated the 22EDG governor linkage to set the fuel racks to the zero position instead of inspecting the fuel racks individually, This resulted in the 22EDG being declared inoperable for 18 hours and an unplanned yellow risk condition. Entergy personnel entered the issue in the CAP as CR-
05000247/FIN-2011007-01Failure to Correctly lmplement an Approved Setpoint Change to Reactor Protection System lnstruments2011Q4The team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion lll, Design Control, in that Entergy did not ensure that design changes, including field changes, were subject to design control measures commensurate with those applied to the original design. Entergy implemented an instrument setpoint change, but delayed re-calibration of the in-field setpoint values and did not evaluate the adequacy of the in-field actual setpoints, which were later found outside the value required by the design basis. Specifically, Entergy revised surveillance procedures for the Unit 2 reactor protection system (RPS) over-power delta(emperature (OPdT) instrument to use a setpoint value specified in the Core Operating Limits Report (COLR). However, the procedures were not required to be performed until the next regularly scheduled surveillance period. Technical Specification 3.3.1 requires the allowable values to be set as specified by the COLR. Two of the four instrument channels had in-field values outside of the required allowable value. Entergy entered this issue into their corrective action program and performed an immediate operability evaluation and determined that the OPdT instrument was capable of performing its intended functions with the current in-field values. The team determined that the failure to ensure in-service instrument setpoint values satisfied design and licensing basis requirements was a performance deficiency. This issue was more than minor because it was associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (e.9., fuel cladding) protect the public from radionuclide releases caused by accidents or events. The team performed a Phase 1 Significance Determination Process screening, in accordance with NRC IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined the finding was of very low safety significance (Green) because it affected only fuel barrier portion of the barrier integrity cornerstone. The team determined that this finding had a cross-cutting aspect in the area of Human Performance, Work Practices because Entergy did not ensure adequate supervisory or management oversight of a design change.
05000247/FIN-2012002-01Inadequate Corrective Actions for Clogged Drains in teh 480 Volt Switchgear Room2012Q1The inspectors identified a finding of very low safety significance for Entergy staff not following Entergy Procedure EN-LI-102, Corrective Action Program. Specifically, between initial plant startup and January 17, 2012, Entergy staff did not follow Procedure EN-LI-102, to classify equipment failures of the drains in the 480 volt switchgear room as repetitive such that an apparent cause would have been performed, and corrective actions developed to address the blocked drain. This resulted in instances of the drains in the 480 volt switchgear room being clogged. Entergy personnel performed an apparent cause evaluation (ACE), cleaned out the drains, and developed a preventative maintenance (PM) schedule to keep the drains cleared. Entergy personnel entered this issue into the CAP as CR-IP2-2011-4324. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and affects the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, water intrusion into the room with clogged drains could impact all four trains of 480 volt switchgear. Using IMC 0609.04, "Phase 1 Initial Screening and Characterization of Findings," the inspectors determine this finding was of very low safety significance (Green) using SDP Phases 1 and 3. Phase 1 screened this Initiating Event Cornerstone finding to Phase 3 because the finding increased the likelihood of a flood causing a loss of offsite power (LOOP) and station blackout (SBO), which would require use of the alternate safe shutdown system (ASSS). A Region I Senior Reactor Analyst (SRA) conducted the Phase 3 analysis and determined the finding was of very low safety significance. The finding has a crosscutting aspect in the area of problem identification and resolution associated with the CAP attribute because Entergy personnel did not periodically trend and assesses information from the CAP and other assessments in the aggregate to identify programmatic and common cause problems associated with the drains. (P.1(b) per IMC 0310)
05000247/FIN-2012002-02Abnormal Operating Procedure Not Followed for Annuciator Alarm Deficiency2012Q1The inspectors identified an NCV of Technical Specification 5.4.1.a, Procedures, because Entergy personnel did not follow Procedure 2-AOP-ANNUN-1, Failure of Flight or Supervisory Panel Annunciators, for an intermittent control roo annunciator problem. Specifically, between January 18, 2012 and January 30, 2012, operations personnel did not enter Procedure 2-AOP-ANNUN-1 when the entrance criteria were satisfied for an intermittent problem that involved control room annunciator horns sounding but alarms not flashing on control room panels SAF-SCF. The procedure directed troubleshooting the problem, notifying the shift manager (SM) / control room supervisory (CRS) to determine methods of compensatory monitoring, initiating a work request (WR) to repair the problem, determining emergency action level applicability and initiating a CR. After this issue was identified by NRC inspectors, Entergy personnels corrective actions included troubleshooting the issue, developing a standing order for an extra operator to verify annunciators during a transient, and initiating a WR to fix the annunciator issue during the refueling outage in March 2012. Entergy personnel entered this issue into the CAP as CR-IP2-2012-595. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure of the control room annunciators to alert operators to changing plant conditions during a transient could delay or impact operators ability to mitigate an accident. Using IMC 0609.04, "Phase 1 Initial Screening and Characterization of Findings," the inspectors determined this finding was of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not result in an actual loss of safety function, was not a loss of barrier function, and was not potentially risk significant for external events. The finding has a cross-cutting aspect in the area of human performance associated with decision making because Entergy personnel did not make safety-significant or risksignificant decisions using a systematic process including entering 2-AOP-ANNUN-1, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. This includes formally defining the authority and roles for decisions affecting nuclear safety, communicating these roles to applicable personnel, and implementing these roles and authorities as designed and obtaining interdisciplinary input and review on safety-significant or risk-significant decisions.
05000247/FIN-2012003-01Foreign Materials Control Procedure Not Followed Resulting in Degraded 21 Reactor Coolant Pump Seal Package2012Q2A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified because Entergy personnel did not follow procedure 0-PMP-401-RCS, Reactor Coolant Pump Seal Package Inspection, to prevent foreign material from entering the 21 reactor coolant pump (RCP) seal package. Specifically, during the March 2010 refueling outage, Entergy personnel did not follow procedure 0-PMP-401-RCS and implement the foreign material exclusion procedural controls which resulted in a degraded 21 RCP seal package. Entergy personnel subsequently replaced the 21 RCP seal package and entered this issue into the CAP as condition report (CR)-IP2-2011-5052. The performance deficiency associated with this finding was that Entergy staff did not follow procedure 0-PMP-401-RCS to prevent foreign material from entering the 21 RCP seal assembly. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the foreign material introduced into the 21 RCP seal package resulted in an increase in the likelihood of tripping the 21 RCP due to further potential for degradation of the 21 RCP seal package. Additionally, if left uncorrected, the foreign material had the potential to further damage the seal package and result in a more significant safety concern. Using IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined this finding was of very low safety significance (Green) because the finding would not result in exceeding the technical specification limit for RCS leakage and would not have affected other mitigation systems resulting in a total loss of their safety function. The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because Entergy personnel did not define and effectively communicate expectations regarding procedural compliance and personnel following procedures.
05000247/FIN-2012003-02An LER for an Inoperable Main Steam Safety Valve Was Not Submitted When Required2012Q2The inspectors identified a Severity Level lV, NCV of 10 CFR 50.73(a)(2)(i)(B), because Entergy personnel did not provide a written licensee event report (LER) to the NRC within 60 days of identifying during testing that MS-46D, main steam line safety valve, was inoperable and in a condition prohibited by the plants Technical Specification (TS). Entergy personnel adjusted the valves lift setpoint to within the TS operability limit, repaired and tested the valve before plant startup. Entergy staff entered this issue into the CAP as CR-IP2-2012-3320 and CR-IP2-2012-4153. The inspectors determined that the failure to provide a written LER within 60 days was a performance deficiency that was reasonably within Entergys ability to foresee and correct, and should have been prevented. This violation involved not making a required report to the NRC and is considered to impact the regulatory process. Such violations are dispositioned using the traditional enforcement process instead of the Significance Determination Process. Using the NRC Enforcement Policy Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report, example (d)(9), the NRC determined this violation is more than minor and is categorized as a Severity Level IV violation. Because this violation involves the traditional enforcement process with no underlying technical violation that would be considered more than minor in accordance with IMC 0612, a cross-cutting aspect is not assigned to this violation.
05000247/FIN-2012004-01Inadequate Operability Evaluation of Non-conforming Safety Related Batteries2012Q3The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy personnel did not adequately implement procedure EN-OP-104, Operability Determination Process, Section 5.1, to assess the operability of safety related station batteries on June 4, 2012. Specifically, Entergy personnel did not appropriately determine the impact on operability as a result of inadequate surveillance testing of the 21, 22 and 24 station batteries. Entergy staff re-performed the operability determination, identified the issues as nonconforming and implemented compensatory measures. Entergy entered this issue into the CAP as CR-IP2-2012-4009. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, after inspectors questioned the operability determination, the non-conforming condition was identified and resulted in the station batteries being declared operable with required compensatory measures, revising calculations and implementing a modification to reduce battery load. Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined this finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect in the area of human performance with the Decision Making attribute because Entergy personnel did not use conservative assumptions in decision making with regards to the non-conservative testing of safety related batteries and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action.
05000247/FIN-2012004-02Inadequate Test Control of Safety Related Batteries2012Q3The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, because Entergy did not assure that all testing required to demonstrate safety related batteries will perform satisfactorily was identified and performed in accordance with written test procedures. Specifically, temperature compensation for battery discharge testing was performed incorrectly which caused errors in the battery capacity calculations. Entergy staff immediately reviewed historical test results to confirm the batteries remained operable. Entergy entered this issue into the CAP as CR-IP2-2012-5338. This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In addition, it was similar to Example 2c of NRC IMC 0612, Appendix E, Examples of Minor Issues, in that the test control inadequacies affected multiple batteries and the issue was repetitive. Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined the finding screened as very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, 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, Resources Component, because Entergy did not ensure that complete, accurate, and up-to-date procedures were available and adequate to assure nuclear safety. Specifically, the battery discharge test procedures did not ensure that temperature compensation was correctly applied to provide accurate capacity calculations.
05000247/FIN-2012004-03Inadequate Procedure Guidance to Maintain 22 ABFP Governor Oiler Level2012Q3On July 17, 2012, the inspectors identified that there was no visible oil level in the 22 ABFP governor oiler resevoir, which called into question the adequate lubrication of the governor bearing assembly and operability of the 22 ABFP. Entergy staff immediately added oil to the oiler reservoir and documented the condition in CRIP2- 2012-4631. Subsequently, Entergy determined the pump was operable based on an operability evaluation documented in CR-IP2-2011-5447, on November 2, 2011, for a similar condition. This evaluation determined that the pump remained capable of performing its intended function, since the oiler wick within the reservoir remained saturated. In addition, Entergy determined the pump was operable, because the wick was wet upon discovery, which indicated it had recently flowed oil to the governor bearing assembly. The governor oiler utilizes a wick feed oiler with an internal cotton wick which when saturated in oil, flows oil to the governor bearing assembly. The oiler design results in a flow of 2 to 5 drops per hour, which correlates to approximately 6 to 15 ounces per month. However, when the reservoir is empty, the wick becomes un-saturated and no oil flows. Once the oil passes through the governor bearing, it accumulates in the governor sump, where through periodic (every 6 months) preventive maintenance (PM), it is drained, measured and recorded to prevent excessive oil accumulation in the sump, which could adversely affect the governor or pump operation. On July 19, 2012, inspectors again identified that there was no visible oil level in the governor oiler, and that the oilers wick did not come in contact with the bottom of the reservoir as designed. Entergy immediately added oil to the oiler reservoir, adjusted the wick and documented the conditions in CR-IP2-2012-4756 & 4757. On July 25, 2012, the inspectors again identified no visible oil level in the reservoir. Entergy staff immediately added oil to the reservoir and documented the condition in CR-IP2-2012-4803. The NRCs recurrent identification of empty oiler reservoirs, resulted in Entergys initiation of a special log (2-12-079) to verify twice daily that (1) the reservoir oil level is visible, (2) the wick is saturated in oil, (3) entry of the action into operations logs, and (4) track all oil additions with the CAP. As a result of implementing the special log, the inspectors noted oil addition to the oiler increased from approximately twice a month, to daily. In addition, Entergy drained the governor sump using the PM procedure, on August 31, 2012, to prevent excess accumulation of oil in the sump and to compare the recorded volume of oil with the 10 ounces collected during the most recent PM performed on July 30, 2012. The oil collected was 8.5 ounces, which was determined by Entergy to be a volume within the range expected for a month. The inspectors noted that Entergys operability evaluations for the July 19 and July 25, 2012 conditions also referenced the November 2011 evaluation documented in CR-IP2- 2011-5547. The inspectors noted that the evaluation recommended that during oil replenishment, oil addition be maintained at about half way within the reservoir to preclude a siphon effect on the oiler. However, no corrective actions were assigned to implement this recommendation. Furthermore, the evaluation stated that the oilers oil consumption rate was within the expected range. However, the inspectors identified that this was contrasted by the governor sump draining results obtained on August 31, 2012. Specifically, based on 1999 correspondence between Entergy and the oilers vendor Dresser-Rand, Entergy should have expected adding oil to the oiler more frequently and collecting 36 90 ounces of oil during the periodic PM. During the oil additions that followed each event, the inspectors identified that procedure 2-SOP-AFW-001 was referenced for these oil additions, but only required the operator to verify governor oiler level is visible. Hence, the oil added was not quantified nor was an expected level in relation to the wick, specified in this procedure. The inspectors also identified that Entergy staff controlled the wick adjustment with engineering guidance, instead of an established procedure. Entergy initiated CR-IP2-2012-5711, to evaluate the overall condition of the 22 ABFP governor oiler. The evaluation determined that the monitoring of component and equipment operating parameters was less than adequate. Corrective actions included changing the design of the oiler to a gravity feed style oiler; revising the system monitoring criteria to include tracking governor oil consumption; changing the PM frequency from 6 months to 3 months; and evaluating the past operability of the pump as a result of not having the desired vendor-recommended flow rate to the governor bearing assembly (to be performed under CR-IP3-2012-2400). This issue will be tracked as a URI, because Entergys assessment of the impact of inadequate lubrication of the 22 ABFP governor bearing assembly on the past operability of the 22 ABFP with regard to being able to perform its intended safety function for its specified mission time of 29 hours is needed to determine whether the identified performance deficiency is more-than-minor. This information to be developed is tracked in Entergys CAP under CR-IP3-2012-2400.
05000247/FIN-2012004-04Inadequate Operability Evaluation of 22 Static Inverter with a Degraded Frequency Meter2012Q3The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy staff did not adequately implement procedure EN-OP-104 Operability Determination Process, section 5.1, to assess the operability of the 22 static inverter due to a degraded frequency meter on September 7, 2012. Specifically, Entergy personnel did not adequately evaluate the impact of the degraded meter on the operability of the static inverter. This condition caused the inverter to be inoperable. As a result of inspector questions, Entergy staff immediately declared the static inverter inoperable and replaced the frequency meter. Entergy staff entered this issue into the CAP as CR-IP2-2012-5620. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the degraded frequency meter resulted in the static inverter being declared inoperable on September 10, 2012 to replace the frequency meter. Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined this finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect in the area of human performance with the Decision Making attribute because Entergy personnel did not make safety-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. Specifically, Entergy did not obtain interdisciplinary input and reviews in resolving degraded 22 static inverter frequency meter.
05000247/FIN-2012005-01Inadequate Corrective Actions regarding operational controls of the steam generator blowdown valve radiation bypass switch2012Q4The inspectors identified a Green, NCV of Title 10 Code of Federal Regulations (CFR) Part 50, Criterion XVI, Corrective Actions, because Entergy personnel did not adequately identify and correct a condition adverse to quality associated with maintenance procedures and activities that adversely impact the steam generator (SG) safety function to remove decay heat. Specifically, Entergy personnel did not implement adequate corrective actions to address existing procedure deficiencies regarding operational controls on the steam generator blowdown (SGBD) valve radiation bypass switch. Entergys corrective actions included identifying and placing a hold on instructions directing use of the radiation bypass switch; implementing operator training; and identifying previous occurrences of the condition which resulted in the plant being placed in an unanalyzed condition. Entergy personnel entered this issue into the corrective action program (CAP) as CR-IP2-2013-0191. This finding is more than minor because if left uncorrected, the performance deficiency could lead to a more significant safety concern. Specifically, maintenance procedures inappropriately allowing operation of the SGBD valve radiation bypass switch could adversely impact the SG safety function to remove decay heat. The inspectors determined that this finding is of very low safety significance (Green) because the finding is a deficiency affecting the design of a mitigating system that maintained its functionality. Specifically, failure of the SGBD isolation valves to close would cause loss of SG water level because the remaining motor driven auxiliary boiler feedwater pump would exceed its design flow rate. However, given the time available, existing procedures, and operator training on isolating the SGBD flowpaths, either from the control room or locally, SG decay heat removal functionality was maintained. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program because Entergy staff did not thoroughly evaluate this problem such that the resolutions address the causes and extent of condition. Specifically, Entergy staff did not properly evaluate the use and impact of the radiation bypass switch for the SGBD isolation when considering allowable configurations of the auxiliary feedwater system.
05000247/FIN-2012005-02Licensee-Identified Violation2012Q4Technical specification 3.4.13, RCS Operational Leakage , in part requires RCS operational leakage shall be limited to no pressure boundary leakage. With pressure boundary leakage as a result of two through wall defects identified on the RCS as reported to the NRC in LER 05000247/2012-003-00, and as described in Section 4OA3, TS 3.4.13 requires the plant be shutdown within 6 hours. Contrary to TS 3.4.13, RCS operational leakage existed between April 2010 and March 2012, but Entergy did not implement actions to place the plant in a shutdown condition. Entergy entered this issue into the CAP as CR-IP2-2012-1733. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Loss of Coolant Accident Initiators, because after reasonable assessment of the degradation, the finding could not exceed the leak rate for a small LOCA; and could not have likely affected other systems used to mitigate a LOCA resulting in a total loss of their function.
05000247/FIN-2012007-01Inadequate Design Verification that Bus 6A supply breaker amptector would not inadvertently trip and lockout bus during degraded grid accident Sl load current2012Q4The team identified a finding of very low safety significance involving a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion lll, Design Control, because Entergy had not verified the adequacy of the design with respect to ensuring the Unit 2 480V emergency Bus 64 offsite power supply breaker amptector trip system would not inadvertently trip under accident load during degraded grid conditions. Specifically, Entergy\'s evaluation did not account for the overall accuracy of the amptector long-time over-current trip system and the loop calibration procedures did not verify that the breaker would trip within the assumed trip system tolerance of t4 percent. Entergy entered the issue into their corrective action program to address the design analysis deficiency and evaluate the adequacy of the calibration procedures, and performed an operability evaluation to ensure the breaker would not inadvertently trip during anticipated accident loads. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team evaluated the finding in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, Exhibit 2 - Mitigating Systems Screening Questions. The finding was determined to be of very low safety significance (Green) because it was a design deficiency confirmed not to result in loss of operability. This finding was not assigned a cross-cutting aspect because it was a historical design issue not indicative of current performance. Specifically, the deficiency originated in a 1993 design evaluation.
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