05000293/FIN-2010005-01
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Finding | |
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Title | Failure to Manage a Yellow Risk Condition During HPCI Testing from the Alternate Shutdown Panel |
Description | The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65 paragraph (a)(4) for Entergy\'s failure to correctly assess and manage a Yellow risk condition for planned testing of the High Pressure Coolant Injection (HPCI) system from the Alternate Shutdown Panel (ASP). Specifically, Entergy considered HPCI available by crediting multiple manual actions to restore the automatic function. However, these actions were not few or simple and would not have restored the HPCI automatic function in a timeframe consistent with guidance discussed in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. In addition, HPCl\'s automatic function would not have been restored in a timeframe consistent with Pilgrim\'s Updated Final Safety Analysis Report (UFSAR), Section 6.4.1, which specifies 90 seconds for HPCI to reach its required design flow rate. Corrective actions included issuing a standing order to alert Operators of the specific requirements to maintain a system available during maintenance and testing. Corrective actions planned include revising Entergy\'s Risk Assessment Procedure to verify systems credited as available have clear and simple direction to restore automatic functional status during maintenance and testing. This finding was determined to be more than minor because Entergy\'s elevated plant risk would put the plant into a higher risk category and require additional risk management actions, namely protecting the Reactor Core Isolation Cooling system. In addition, the finding affected the Human Performance attribute of the Mitigating System\'s cornerstone objective to ensure the availability of systems to respond to initiating events and prevent undesirable consequences. The inspectors performed an evaluation in accordance with IMC 0609, Significance Determination Process, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, because the finding related to Entergy\'s assessment and management of risk. The finding was determined to be of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the unavailability of HPCI for the duration of the activity was less than 1.0E-6 per year (approximately 2.6E-9 per year). The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Entergy did not correctly plan and coordinate work activities by incorporating appropriate risk insights H.3(a). (Section 1R13) |
Site: | Pilgrim |
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Report | IR 05000293/2010005 Section 1R13 |
Date counted | Dec 31, 2010 (2010Q4) |
Type: | NCV: Green |
cornerstone | Miscellaneous |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.13 |
Inspectors (proximate) | D Jones T Burns R Rolph B Smith M Schneider R Latta P Prescott D Jackson |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Pilgrim - IR 05000293/2010005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2010Q4
Self-Identified List (Pilgrim)
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