The inspectors identified a Green NCVof
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and DraWings, in that Entergy did not initiate corrective action condition reports (CRs)\'for all deficient items identified during
Cooling Tower (
CT) inspections. Entergy entered this issue into their corrective action program (
CAP) and performed an
operability assessment which determined that the safety related function of the
CTs was always available. The inspectors determined that the finding was more than minor because if left uncorrected, it would have the potential to
lead to a more significant safety concern. Specifically, deficiencies might not be tracked to resolution, management attention or other independent reviews would not be appropriately applied, and the need for
operability determinations may be missed. The finding was determined to be of very low safety significance (Green) because the finding did not involve a design or qualification deficiency resulting in loss of operability or functionality, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external
initiating events. This finding had a cross-cutting aspect in the Work Practices component of the Human Performance cross-cutting area because Entergy did not follow procedures and initiate CRs to identify
cooling tower deficiencies as required by operating procedure (OP) 52114. IH.4(b)