05000286/FIN-2016004-02
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Finding | |
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Title | Inadequate Operability Evaluation of Leak in Service Water Pump Discharge Pipe |
Description | Green. The inspectors identified an NCV of very low safety significance of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy staff did not perform an adequate operability review under EN-OP-104, Operability, for a service water (SW) piping leak described in CR-IP3-2016-1113. Entergy based the flooding portion of the operability review on the assumption that a non-safety-related sump pump would function to prevent flooding of the room, although under accident conditions it would not have electrical power. Entergy implemented corrective actions to revise their operability evaluation and also installed a housekeeping patch that greatly reduced the leak rate. The performance deficiency was determined to be more than minor because the finding was similar to Example 3j of NRC IMC 0612, Appendix E, Examples of Minor Issues, in that incorrect assumptions of the ability of the Zurn pit sump pump to remove the water resulted in reasonable doubt regarding operability and warranted additional evaluation. This issue impacts the protection against the external factors attribute of the Mitigating Systems cornerstone and impacts its objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Entergy did not properly evaluate the operability impacts of an increase in the leak rate from a preexisting SW leak in the Zurn strainer pit and, therefore, did not implement compensatory measures to prevent internal flooding in the event the installed, non-safety-related sump pump failed. The inspectors determined the finding could be evaluated using the Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings. Because the finding impacted the Mitigating Systems cornerstone, the inspectors screened the finding through IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, using Exhibit 2, Mitigating Systems Screening Questions. The finding required a detailed risk evaluation because it represented the potential loss of the entire SW system. A detailed risk assessment was conducted assuming that a loss of offsite power (LOOP) could challenge the functionality of the SW system due to flooding impacts on the system strainers. The resulting change in core damage frequency was estimated to be in the mid E-6 range, Green. The inspectors concluded this finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Entergy did not recognize and 5 plan for the possibility of latent issues and inherent risk. Entergy had experienced numerous SW system leaks that remained small and did not plan for the possibility that this one would increase. Once the leak had increased significantly, Entergy did not appropriately revise the operability determination to reflect the changed circumstances and take appropriate compensatory measures to promptly restore operability. [H.12 Avoid Complacency] |
Site: | Indian Point ![]() |
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Report | IR 05000286/2016004 Section 1R15 |
Date counted | Dec 31, 2016 (2016Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | B Haagensen C Safouri E Dipaolo G Newman H Gray J D 'Antonio J Deboer J Furia L Mckown M Henrion N Embert P Kaufman S Ric |
Violation of: | 10 CFR 50 Appendix B Criterion V |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Indian Point - IR 05000286/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Indian Point) @ 2016Q4
Self-Identified List (Indian Point)
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