05000293/FIN-2017001-01
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Finding | |
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| Title | Concern Regarding Ability to Declare EALs during Loss of Control Room Air Conditioning |
| Description | Inspection Scope The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, and component (SSC) performance and reliability. The inspectors reviewed system health reports, CAP documents, maintenance WOs, and maintenance rule (MR) basis documents to ensure that Entergy was identifying and properly evaluating performance problems within the scope of the MR. For each sample selected, the inspectors verified that the SSC was properly scoped into the MR in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Entergy staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Entergy staff was identifying and addressing common cause failures that occurred within and across MR system boundaries. HPCI stop valve grease on February 17, 2017 (quality control) Main control room ventilation the week of March 6, 2017 9 b. Findings Introduction. The inspectors identified that Entergy made alterations on February 2, 2017, to procedure 2.4.149, Loss of Control Room Air Conditioning, that had the potential to render several emergency action levels (EALs) ineffective. As a result, the NRC opened an unresolved item related to this concern. Description. The inspectors identified a concern regarding Entergys ability to declare several EALs based on the actions required by site procedure 2.4.149, Loss of Control Room Air Conditioning. Specifically, procedure 2.4.149 directs numerous loads to be shed in order to maintain the main control room temperature below 120 degrees Fahrenheit upon loss of control room air conditioning during extended period of outside temperature of 90 degrees Fahrenheit and above, as per FSAR section 7.1.8. Main control room air conditioning is not consider ed important to safety, based on the ability to control the heat up rate in the main control room, through the actions described in procedure 2.4.149. Upon updating the calculation to determine how much load must be shed to ensure design requirements were met, procedure 2.4.149 was updated with an attachment directing which loads that are required to be shed in order to meet the design calculation S&SA056, Control Room and Cable Spreading Room Heatup Calculations, Revision 6. The main control room is required to remain at or below 120 degrees Fahrenheit to ensure the main control room equipment remains operable. Main control room equipment temperatures above 120 degrees Fahrenheit can result in multiple control equipment failures which could result in misleading indications and inadvertent system actuation. The inspectors questioned how the procedure would be implemented, based on the lack of specific guidance in the procedure. The procedure includes the load shedding of numerous components, including both trains of reactor protection system, average power range monitors, intermediate range power monitors, source range power monitors, and process radiation monitors. Inspectors questioned how the site would declare numerous EALs without supporting equipment that has no redundancy or pre- established compensatory measures, as proceduralized in EN-AD-270, Equipment Important to Emergency Response. Inspectors questioned at what point would the operators be required to shed equipment that is required to support the HOT (greater than 212 degrees Fahrenheit) condition EAL classifications. The inspectors questioned whether or not operators would be able to verify that the plant conditions were consistent with applicable EALs at the time the components were removed from service. Entergy is reviewing the calculations to determine when load shedding of loads without compensatory measures would have been required and intends to report the results to the NRC by June 2, 2017. Inspectors verified that the procedure was changed to ensure minimum instrumentation requirements were maintained to declare EALs. The inspectors determined that procedure 2.4.149 had the potential to render EALs ineffective and is an unresolved item pending Entergy completing their evaluation of load shedding impact on the main control room heat up and NRC review of the evaluation and procedure implementation. (URI 05000293/2017001-01, Concern Regarding Ability to Declare EALs during Loss of Control Room Air Conditioning) |
| Site: | Pilgrim |
|---|---|
| Report | IR 05000293/2017001 Section 1R12 |
| Date counted | Mar 31, 2017 (2017Q1) |
| Type: | URI: |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | A Burritt B Pinson E Carfang J Vasquez L Brandt S Elkhiamy S Haney |
| INPO aspect | |
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Finding List (Pilgrim) @ 2017Q1
Self-Identified List (Pilgrim)
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