05000293/FIN-2016003-02

Finding

Title

Inadequate Operability Assessment on EDG B

Description

The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, in that Entergy did not perform an adequate operability evaluation in accordance with EN-OP-104, Operability Determination Process, Revision 10. Specifically, during an instrumented run of emergency diesel generator (EDG) B, the cabinet door was opened, resulting in a non-seismically qualified configuration of protective relays for EDG B. Inspectors determined that Entergy did not adequately assess the operability of EDG B as required by EN-OP-104, Operability Determination Process. Specifically, Entergy did not evaluate the operability of EDG B when opening a cabinet door containing relays that serve a safety function. Entergy entered this issue into the corrective action program (CAP) as condition report (CR)-2016-5779 and CR-2016-7877. Entergy has issued a standing order to assess operability of equipment tested with cabinet doors open prior to performing work or declare the equipment being tested inoperable. This is a performance deficiency that was within Entergys ability to foresee and correct. This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, relays were no longer in a configuration known to operate as required during a seismic event with the cabinet door open. In accordance with IMC 0609.04, initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2013, the inspectors determined that this finding is of very low safety significance (Green) because the performance was not a design or qualification deficiency, did not involve an actual loss of safety function, and did not represent actual loss of safety function of a single train for greater than its technical specification (TS) allowed outage time. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, in that the organization did not systematically and effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner. Specifically, Entergy did not evaluate industry operating experience on control of cabinet doors containing safety-related equipment, which led to operability concerns.

02
Site:	Pilgrim
Report	IR 05000293/2016003 Section 1R15
Date counted	Sep 30, 2016 (2016Q3)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.15
Inspectors (proximate)	A Burritt B Fuller B Pinson D Werkheiser E Burket E Carfang J Brand J Pfingstein L Dumont M Fannon M Modes S Rich T Dunn
Violation of:	10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion V
CCA	P.5, Operating Experience
INPO aspect	CL.1
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Finding - Pilgrim - IR 05000293/2016003

1(0)2(2)3(4)4(6)5(0)6(0)7(2)8(1)9(1)10(2)11(13)12(0)13(0)403(10)404(3)502(0)

IR 05000293/2016003: 1 2 3 4

Finding List (Pilgrim) @ 2016Q3

CCA Matrix: 2016Q3

	Q	CCA	Title
05000293/FIN-2015404-05	2015Q4		Security
05000293/FIN-2016010-02	2015Q4		Falsification of hourly fire watch logs
05000293/FIN-2016010-01	2015Q4		Failure to perform hourly fire watches
05000293/FIN-2015004-04	2015Q4		Inadequate Design Control of MSIV Nitrogen Supply Line Support leads to Scram
05000293/FIN-2015004-03	2015Q4	H.8	Failure to Identify the Cause of a Significant Condition Adverse to Quality
05000293/FIN-2015004-02	2015Q4	P.3	Failure to Properly Implement Procedure Changes in accordance with TS 5.4.1a
05000293/FIN-2015004-01	2015Q4	H.8	Inadequate Implementation of Corrective Action following Winter Storm Juno
05000293/FIN-2015008-01	2015Q4	P.2	Failure to Analyze Reactor Recirculation System Motor Operated Valves for the Post-fire Cold Shutdown Function
05000293/FIN-2015404-04	2015Q4	P.3	Security
05000293/FIN-2015404-03	2015Q4	H.5	Security
05000293/FIN-2015404-02	2015Q4	H.1	Security
05000293/FIN-2015404-01	2015Q4	H.12	Security
05000293/FIN-2016008-01	2016Q1	P.2	Failure to Promptly Identify and Correct Core Spray System Leakage
05000293/FIN-2016404-03	2016Q1		Security
05000293/FIN-2016404-02	2016Q1	P.1	Security
05000293/FIN-2016404-01	2016Q1	H.13	Security
05000293/FIN-2016009-01	2016Q2	P.3	Failure to Correct a Condition Adverse to Quality Associated with the Salt Service Water System
05000293/FIN-2016007-01	2016Q2	P.3	Failure to identify and correct degraded SSW pump discharge piping supports that called into question the operability of both SSW loops
05000293/FIN-2016007-02	2016Q2		Failure to adequately translate SSW support design drawings into the installation work orders to ensure SSW discharge piping was adequately supported
05000293/FIN-2016002-01	2016Q2	H.12	Inadequate Review of Vendor Documents Results in Shear Pin Failure
05000293/FIN-2016003-04	2016Q3	H.8	Failure to Adequately Evaluate the Effect of Degraded Normally Energized Agastat relays on PCIVs Operability
05000293/FIN-2016003-03	2016Q3		Failure to Properly Implement Agastat Control Relays Preventive Maintenance Procedure in Accordance with TS 5.4.1
05000293/FIN-2016003-02	2016Q3	P.5	Inadequate Operability Assessment on EDG B
05000293/FIN-2016003-01	2016Q3	P.2	Process Radiation Monitor Subsystems 10 CFR 50.65(a)(2) Not Met

Self-Identified List (Pilgrim)

	Q	Title
05000293/FIN-2015008-02	2015Q4	Licensee-Identified Violation
05000293/FIN-2016002-02	2016Q2	Licensee-Identified Violation

[Pilgrim Findings full list]

05000293/FIN-2016003-02

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