05000293/FIN-2016004-03
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Finding | |
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Title | Failure to Properly Assess and Manage Risk Associated with Shutdown Transformer Protective Relay Testing |
Description | Green. The inspectors identified a Green NCV of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for Entergys failure to properly assess and manage the increase in risk due to performing protective relay calibration and functional testing associated with the shutdown transformer (SDT) on seven occasions from December 9, 2005, through August 27, 2014. Specifically, Entergy did not identify that the performance of calibration and functional testing of 6 protective relays associated with the SDT would prevent the 4160V safety buses from being automatically powered by other required sources, and consequently, did not properly assess and manage the increase in risk. Entergys corrective action requires the unit to be in an outage to perform the tests. Entergy entered the issue into the CAP under CR 2017-0856. The inspectors determined that this performance deficiency was more than minor because it is associated with the configuration control 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. Additionally, the finding was similar to Example 7e of NRC IMC 0612, Appendix E, Examples of Minor Issues, in that the overall elevated plant risk would have put the plant into a higher licensee-established risk category and would have required additional risk mitigating actions (RMAs). The inspectors evaluated the finding using the Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, issued October 7, 2016. Because the finding involved a maintenance rule risk assessment, it was screened through IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, issued May 19, 2005. The finding screened as very low safety significance (Green) using Flowchart 1 of Appendix K because the incremental core damage probability deficit (ICDPD) was determined to be greater than 1E-6 and less than 1E-5, and three or more RMAs were taken. The inspectors concluded this finding had a crosscutting aspect in the area of Human Performance, Avoid Complacency, in that individuals did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the unavailability of the startup transformer (SUT) and emergency diesel generators (EDGs) during portions of testing was a latent issue that Entergy did not identify, and the associated increase in risk was not assessed and managed. [H.12] |
Site: | Pilgrim |
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Report | IR 05000293/2016004 Section 4OA3 |
Date counted | Dec 31, 2016 (2016Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | A Burritt B Deboer B Dionne B Pinson E Carfang J Deboer J Nicholson J Vasquez N Embert P Cataldo P Ott |
Violation of: | 10 CFR 50.65(a)(4) |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Pilgrim - IR 05000293/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2016Q4
Self-Identified List (Pilgrim)
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