05000247/FIN-2013005-01
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | Unit 2 Technical Specification, 5.4.1.a., Procedures, requires in part that written procedures shall be established, implemented, and maintained covering the applicable requirements and recommendations of Appendix A of Regulatory Guide 1.33, Revision 2. Appendix A of Regulatory Guide 1.33 includes administrative procedures for safety-related equipment control, e.g. locking and tagging. EN-OP-102, Protective and Caution Tagging, was an Entergy administrative procedure for locking and tagging. Step 5.11[6] required that the tagout holder shall ensure a walk down of the applicable portion of the tagout is performed prior to starting work. Contrary to this requirement, on April 15, 2013, the tagout holders for disassembling a diesel fuel valve, DF-17-4, did not walk down the associated tagout. The DF-17-4 tagout was not hung and a walk down would have identified that adequate boundaries for personnel and equipment protection were not established. Work performed on DF-17-4 rendered the 21 and 22 EDGs inoperable for about 90 minutes while the 23 EDG was tagged-out for maintenance on DF-17-5. Entergy operations personnel identified this issue on April 16, 2013, when they noted the work order for DF-17-4 was completed with the tagout for the associated work not established. Entergy entered this issue into the CAP as CR-IP2-2013-01366. Entergy personnel reported this condition that could have prevented the fulfillment of the safety function of the onsite EDGs to the NRC in LER 05000247/2013-002-00 (See Section 4OA3). The issue was more than minor because it was associated with the configuration control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. The inspectors followed the guidance of Inspection Manual Chapter (IMC) 0609, Appendix A, Exhibit 2, step A.2. This states that if the finding represents a loss of system and/or function, go to the Detailed Risk Evaluation section. A senior reactor analyst performed a Detailed Risk Evaluation and determined this issue was of very low safety significance (Green) because of the very short duration (about 90 minutes), the diesel FO day tanks provided at least 53 minutes of 21 and 22 EDG operation, the Unit 2 Station Blackout (SBO)/Appendix R EDG and Unit 3 SBO/Appendix R EDG with its electrical crosstie were available, and maintenance technicians remained at the job site and could have rapidly restored DF-17-4 if an auto-start of the 21 and 22 EDGs occurred. |
| Site: | Indian Point  |
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| Report | IR 05000247/2013005 Section 4OA7 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Burritt A Patel D Orr E Torres J Furia J Kulp J Stewart T Fish T. Lamb |
| Violation of: | Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Indian Point - IR 05000247/2013005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Indian Point) @ 2013Q4
Self-Identified List (Indian Point)
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