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| Q | Significance | CCA | Identified by | Title | Description | |
|---|---|---|---|---|---|---|
| 05000293/FIN-2018003-01 | 2018Q3 | Green | H.9 | NRC identified | Failure to Identify an Adverse Condition Associated with Elevated Standby Gas Treatment System Accumulator Leakage | The inspectors identified a Green non-cited violation (NCV) of Technical Specifications 3.7.B.1.c because Entergy exceeded the TS allowed outage time for the standby gas treatment system (SBGT) when the station did not identify an adverse condition associated with elevated air accumulator leakage in the system. |
| 05000293/FIN-2018002-06 | 2018Q2 | Severity level Minor | Licensee-identified | Minor Violation | This violation of minor significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a minor violation, consistent with the NRC Enforcement Policy. On June 22, 2015, Entergy submitted a licensee event report in accordance with 10 CFR 50.73 that contained information that was not complete or accurate in all material respects, contrary to the requirements in 10 CFR 50.9. Specifically, the licensee submitted Licensee Event Report 2015-004-00 to communicate the failure during testing of time delay Agastat relay 27A-B1X/TDDO intended to provide under-voltage protection for 480V emergency bus B6 by transferring power from bus B1 to bus B2. In the licensee event report, Entergy incorrectly documented that due to the failure, bus B6 would have continued to receive power from bus B1 with degraded voltage. Upon identifying the issue, on March 8, 2016, Entergy submitted a revised licensee event report with the correct information. Enforcement: 10 CFR 50.9 requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on June 22, 2015, Entergy provided information to the Commission that was not complete and accurate in all material respects. In the licensee event report, the licensee documented that due to the failure, bus B6 would have continued to receive power from bus B1 with degraded voltage. However, bus B6 would actually have tripped from bus B1 and lost power completely. This information was material to the NRC because the NRC requires timely and accurate reporting of information related to events in order to evaluate the potential safety significance and required NRC response. Entergy identified the inaccuracy and entered the issue into its corrective action program (CR-PNP-2015-9762). On March 8, 2016, Entergy submitted a revision to the licensee event report (2015-004-01) that corrected the report. This failure to comply with 10 CFR 50.9 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The disposition of this violation closes Licensee Event Report 05000293/2015-004-01. | |
| 05000293/FIN-2018410-01 | 2018Q2 | Green | P.3 | NRC identified | Security | |
| 05000293/FIN-2018002-05 | 2018Q2 | Green | Licensee-identified | Licensee-Identified Violation | This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. Violation: 10 CFR 50.72(b)(3)(v)(C) requires licensees to a notify the NRC within 8 hours any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. Contrary to the above, Entergy did not make a required notification pursuant to 10 CFR 50.72(b)(3)(v)(C). Specifically, on June 20, 2017, secondary containment was declared inoperable due to simultaneous opening of both airlock doors, and Entergy did not make the required notification until June 22, 2017. Significance/Severity: This violation is being treated under the NRCs traditional enforcement process, for impeding the regulatory process, specifically Entergy did not make a required notification, as outlined in Inspection Manual Chapter 0612, Appendix B. The Reactor Oversight Processs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The severity of this violation was determined to be Severity Level IV, as outlined in Example 9 from Section 6.9.d. of the NRC Enforcement Policy. Corrective Action References: CR-PNP-2017-06380 and CR-PNP-2017-07015 The disposition of this finding closes Licensee Event Report 2017-011-00. | |
| 05000293/FIN-2018002-04 | 2018Q2 | Green | Licensee-identified | Licensee-Identified Violation | This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions appropriate to the circumstances and shall be accomplished in accordance with the instructions. Contrary to the above, from January 1994 to June 2017, Entergy modified site surveillance procedure 8.M.3-18, Standby Gas Treatment System Exhaust Fan Logic Test and Instrument Calibration, without prescribing adequate documented instructions for the condition caused by the testing. Specifically, Entergy failed to identify that the procedurally prescribed lineup of the standby gas treatment system resulted in secondary containment being inoperable due to the large opening introduced into the system. Significance/Severity: The inspectors evaluated this finding using Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined that the finding was of very low safety significance. Corrective Action Reference: CR-PNP-2017-11714 The disposition of this violation closes Licensee Event Reports 05000293/2017-013-00 and 05000293/2017-013-01. | |
| 05000293/FIN-2018002-03 | 2018Q2 | Severity level IV | NRC identified | 480V Bus B6 Auto Transfer Function Degraded Due to Time Delay Relay Failure | The inspectors identified a Severity Level IV NCV of TS 3.5.A.2 because a component of the low pressure coolant injection system was inoperable between May 12, 2015, and May 3, 2017, during which time, on occasions, core spray systems were also not operable. Specifically, a relay, used to transfer the power feed for the low pressure coolant injection valves to the backup source in the event of a degraded voltage condition, failed during testing. As a result, under certain conditions, the transfer would not have automatically occurred. This condition existed through the operating cycle, during which time the core spray pumps were also inoperable when removed from service for scheduled maintenance. | |
| 05000293/FIN-2018002-02 | 2018Q2 | Green | H.9 | Self-revealing | Loss of Secondary Containment Integrity due to Simultaneously Opened Airlock Doors | A self-revealed Green finding was identified when personnel did not implement a procedure requiring the closure and verification of doors credited with specific design functions. Procedure 1.3.135, Control of Doors, requires station personnel to ensure closing and latching of doors. Failure to meet this requirement caused the loss of secondary containment integrity and unplanned entry into Technical Specification (TS) condition 3.7.C.1. |
| 05000293/FIN-2018002-01 | 2018Q2 | Green | P.3 | NRC identified | Failure to Properly Implement the Fatigue Management Program Work Hour Controls for Covered Workers | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 26.205(d). During the period December 2017 to April 2018, Entergy did not properly control the work hours of several workers who performed work covered under 10 CFR 26.4(a). Specifically, on eleven occasions, workers exceeded one of the following work hour limits: (1) 16 work hours in any 24-hour period; (2) 72 hours in any 7-day period; or (3) 54 hours per week average over a 6-week rolling time period. |
| 05000293/FIN-2017403-01 | 2017Q3 | Green | P.2 | NRC identified | Security | |
| 05000293/FIN-2017405-01 | 2017Q3 | Green | P.3 | NRC identified | Security | |
| 05000293/FIN-2017405-02 | 2017Q3 | Green | P.2 | NRC identified | Security | |
| 05000293/FIN-2017007-01 | 2017Q3 | Green | NRC identified | Failure to Incorporate the Correct Design Limit for the Condensate Storage Tank Water Temperature | The team identified a finding of very low safety significance (Green) involving a non- cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, in that Entergy did not translate the design basis limit for nil ductility transition (NDT) temperature into plant procedures. Specifically, Entergy specified in their procedures and tank heating setpoint calculation the low temperature limit for the two condensate storage tanks (CSTs) to be a non-conservative value, because it was based on the concern of CST freezing rather than the more limiting material service temperature of the downstream safety-related piping. In response, Entergy staff evaluated and confirmed current operability of the CST, and planned to evaluate and revise the affected procedures and tank heating setpoint calculation. This finding was more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the minimum CST temperature value stated in procedures, based on an incorrect tank freezing assumption, could potentially result in not providing the full margin of protection against brittle fracture behavior in safety-related piping leading to the reactor vessel. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, the team determined the issue screened as having very low safety significance (Green) because it did not represent an actual loss of safety function of the system or train, did not result in the loss of one or more trains of non- technical specification (TS) equipment, and did not screen as potentially risk significant due to seismic, flooding, or severe weather. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance. | |
| 05000293/FIN-2017007-02 | 2017Q3 | Green | H.12 | NRC identified | Inadequate Design Verification of Emergency Diesel Generator Under- Frequency Alarm Setpoint | The team identified a finding of very low safety significance (Green) involving an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, in that Entergy did not adequately verify that the emergency diesel generator (EDG) under-frequency alarm setpoint was in accordance with design basis requirements. Specifically, the EDG under- frequency alarm was set at a value less than the prescribed industry standard to protect equipment, and station procedures did not contain instructions to address the EDG under- frequency condition. In response, Entergy staff evaluated and confirmed current EDG operability and initiated actions to correct the under-frequency range in the alarm setpoint and to provide appropriate operator response guidance in operating procedures. 3 This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, the team determined that this finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in the loss of operability or functionality. The team determined that this finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Entergy did not plan for the possibility of latent issues while processing a plant modification where the bases for EDG alarm functions were incorrect. |
| 05000293/FIN-2017403-02 | 2017Q3 | Green | NRC identified | Security | ||
| 05000293/FIN-2017403-03 | 2017Q3 | Green | Licensee-identified | Licensee-Identified Violation | ||
| 05000293/FIN-2017403-04 | 2017Q3 | Green | Licensee-identified | Licensee-Identified Violation | ||
| 05000293/FIN-2017002-03 | 2017Q2 | Green | P.1 | NRC identified | Inaccurate Suppression Pool Water Level Instrument not Identified during Post-event Prompt Investigation | An NRC-identified Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, was identified because Entergy staff did not identify and correct a condition adverse to quality related to suppression pool water level indication when the A suppression pool wide range instrument provided inaccurate level indication during the inadvertent suppression pool water level increase event on March 31, 2017. As corrective actions, Entergy entered Technical Specification (TS) 3.2.F, Protective Instrumentation - Surveillance Information Readouts, and repaired the instrument. This issue was entered into Entergys corrective action program (CAP) as condition report (CR) 2017-2965. The performance deficiency is more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, inaccurate level indication during off-normal changing level conditions in the suppression pool could result in operator actions not warranted by plant conditions. The finding is also associated with the Initiating Events cornerstone. Using IMC 0609, Appendix A, Exhibit 1, issued June 19, 2012, The Significance Determination Process for Findings At-Power, the inspectors determined the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution - Identification, because the Entergy organization did not demonstrate an appropriately low threshold for entering problems into their CAP. Specifically, Entergys prompt investigation of the inadvertent suppression pool level increase event did not identify that the A suppression pool wide range level instrument was not indicating properly and required corrective maintenance. (P.1) |
| 05000293/FIN-2017002-07 | 2017Q2 | Severity level IV | NRC identified | Untimely 10 CFR 50.72 Notification of a Secondary Containment System Functional Failure | An NRC-identified SL IV NCV of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, was identified because both trains of the SBGTS were made inoperable during surveillance testing, and the condition was not reported to the NRC within eight hours of the occurrence, as required by 10 CFR 50.72(b)(3)(v), Event or Condition that Could Have Prevented Fulfillment of a Safety Function. Specifically, on April 5, 2017, while performing TS SR 4.7.C, trains A and B of the SBGTS were made inoperable leading to the inoperability of the Secondary Containment System (SCS). As a corrective action, Entergy personnel performed a causal evaluation. This issue was entered into the CAP as CR 2017-7446. The inspectors evaluated this performance deficiency in accordance with the traditional enforcement process because the issue impacted the regulatory process, in that a condition that could have prevented a safety function was not reported to the NRC within the required timeframe, thereby delaying the NRCs opportunity to review the matter. Using Example 6.9.d.9 from the NRC Enforcement Policy (the failure of a licensee to make a report as required by 10 CFR 50.72 or 10 CFR 50.73), the inspectors determined that the violation was a SL IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, inspectors did not assign a cross-cutting aspect, in accordance with IMC 0612, Appendix B. | |
| 05000293/FIN-2017002-08 | 2017Q2 | Green | Licensee-identified | Licensee-Identified Violation | 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part, that activities affecting quality shall be accomplished in accordance with documented procedures. Entergy Procedure EN-OP-104, Operability Determination Process, requires that operators have a reasonable expectation of operability when determining the operability of a component. On April 15, 2017, operators did not have a reasonable expectation of operability, as required by EN-OP-104, and incorrectly declared the B SRM operable without reasonable assurance. This resulted in a violation of TS 3.10.B, Core Alterations, which requires, during core alterations, when fuel is in the vessel, at least 2 SRMs shall be operable, one in the quadrant where fuel or control rods are being moved and one in an adjacent quadrant. Entergy entered this issue into the CAP as CRs 2017-3541, 2017-3952, 2017-5294, and 2017-6724. Entergy repaired the B SRM, and performed a causal evaluation on the equipment failure that includes the late inoperability determination by the operators. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix G, Attachment 1, Exhibit 3, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of a system, and did not represent a loss of safety function of a train or system, and did not degrade a functional auto-isolation of RHR on low reactor vessel level. | |
| 05000293/FIN-2017002-06 | 2017Q2 | Green | H.14 | NRC identified | Secondary Containment Testing not performed per Technical Specifications | An NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, and TS 4.7.C, Containment Systems Secondary Containment, was identified when Entergy performed a surveillance test requiring a refueling outage while online. Specifically, Entergy performed Procedure 8.7.3, Secondary Containment Leak Rate Test, TS Surveillance Requirement (SR) 4.7.C from February 27, 1997, to April 5, 2017. As corrective actions, Entergy re-performed the test during the April 2017 refueling outage prior to refueling. This issue was entered into the CAP as CR 2017-2900. The performance deficiency is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protects the public from radionuclide releases caused by accidents or events. Specifically, Entergy intentionally removed the safety function of standby gas and secondary containment for operational convenience and did not comply with the requirements of TS SR 4.7.C which requires the test to be performed during a refueling outage before refueling. In accordance with IMC 0609.04, Initial Characterization of Findings, issued October 7, 2016, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green), because the finding only represented a degradation of the radiological barrier function provided for the SBGTS. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance - Conservative Bias, in that Entergy personnel did not use decision making-practices that emphasize prudent choices over those that are simply allowable. Specifically, operators did not refer to the TSs to understand the required conditions for a secondary containment surveillance test. Operators followed an inadequate site procedure for the plant conditions at the time and did not question why removal of a safety function for operational convenience was acceptable. (H.14) |
| 05000293/FIN-2017002-01 | 2017Q2 | Green | H.8 | NRC identified | Failure to Follow Procedure Requirements for the Control of a Flood Protection Barrier | An NRC-identified Green finding was identified because Entergy personnel did not follow Procedure 1.3.135, Control of Doors, to adequately control a condenser bay flood protection door. Specifically, on May 22, 2017, Entergy personnel failed to control door 25A, which is designed to mitigate condenser bay flooding to preclude adversely impacting the important to safety instrument air system. Entergys short-term corrective actions included closing the door and providing additional operator training. This issue was entered into the CAP as CR 2017-5746. The performance deficiency is 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. The finding was evaluated using IMC 0609, Appendix A, Exhibit 4, External Events Screening Questions, issued June 19, 2012, with respect to the degraded safety function of the flood barrier door. The finding was determined to be of very low safety significance (Green) because the failure of the flood door was determined to not degrade the instrument air system ability to support the feedwater injection function or the alternate injection through the control rod drive system. This is because the backup diesel driven compressor was available to be started locally and supply the instrument air headers. The finding also did not involve the total loss of any safety function. The finding has a cross-cutting aspect in the area of Human Performance - Procedure Adherence, because Entergy personnel did not follow processes, procedures, and work instructions. Specifically, Entergy personnel did not follow procedural requirements to adequately control flood protection door 25A. (H.8) |
| 05000293/FIN-2017002-02 | 2017Q2 | NRC identified | Reporting of Unplanned Scrams with Complications Performance Indicator for Feedwater Regulating Valve Scram | The inspectors identified an unresolved item (URI) associated with Entergys reporting of Unplanned Scrams with Complications PI data for the third quarter of 2016. Description. On September 6, 2016, PNPS operators initiated a manual reactor scram based on oscillating feed flow as a result of a malfunction with feedwater regulating valve (FRV) A. As a result of high reactor vessel water level, all of the reactor feed pumps tripped, the HPCI and RCIC systems isolated, and a Group 1 isolation signal was present, initiating closure of the MSIVs. In order to maintain pressure control of the reactor, SRV 3B was manually cycled. This event was reported under Licensee Event Report (LER) 05000293/2016-007-00. During the scram response, PNPS operators were required to use an SRV to maintain reactor pressure control, but Entergys submittal of PI data for the third quarter of 2016 does not count the scram as an Unplanned Scram with Complications, which is required by EN-LI-114, Regulatory Performance Indicator Process. This URI is being opened to determine if a performance deficiency exists pending resolution of the differing interpretation of guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guidance, Revision 7, at the next scheduled Reactor Oversight Process Working Group Meeting. (URI 05000293/2017002-02, Reporting of Unplanned Scrams with Complications Performance Indicator for Feedwater Regulating Valve Scram) | ||
| 05000293/FIN-2017002-04 | 2017Q2 | Green | H.8 | Self-revealing | Improper System Restoration Results in Suppression Pool Inoperability | A self-revealing Green NCV of TS 5.4.1.a, Procedures, was identified on March 31, 2017, when operators did not follow procedures and caused an inadvertent increase in the suppression pool water level. The inspectors determined that the operators did not restore the core spray system valve line-up as prescribed in Attachment 11 of Entergy Procedure 2.2.20, Core Spray, and the maintenance safety tag clearance sheet. Operator implementation of these documents is directed by Entergy Procedure EN-OP-102, Protective Caution Tagging, section 5.19(4)(b). As corrective actions, Entergy performed additional management oversight of control room operations and performed a root cause evaluation (RCE). This issue was entered into the CAP as CR-2017-2785. The performance deficiency is more than minor because it is associated with the equipment reliability attribute of the Mitigating Systems cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the out of specification conditions on March 31, 2017, impacted suppression pool reliability because the suppression pool was not maintained within parameters required to ensure operability. Additionally, significant analysis was necessary to show the suppression pool and associated supports remained functional when TS requirements were not met. Using IMC 0609, Appendix A, Exhibit 2, issued June 19, 2012, The Significance Determination Process for Findings At-Power, the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating structure, system, or component (SSC), the finding did not represent a loss of system and/or function, the finding did not represent an actual loss of a function of a single train for greater than the TS allowed outage time (AOT), and the finding did not represent an actual loss of a function of one or more non-TS trains of equipment. Specifically, the suppression pool, including downcomers and supports, remained functional following the influx of water. The finding has a cross-cutting aspect in the area of Human Performance - Procedure Adherence, because Entergy personnel did not follow processes, procedures, and work instructions. Specifically, Entergy personnel did not follow procedures and work instructions during the restoration of the core spray system. (H.8) |
| 05000293/FIN-2017002-05 | 2017Q2 | Green | P.3 | Self-revealing | Damper Failure Causes Loss of Secondary Containment | A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and TS 3.7.C.2, Containment Systems Secondary Containment, was identified because Entergy did not establish an appropriate interval to overhaul the secondary containment isolation dampers. As a result, the refueling floor supply isolation dampers were operated beyond the recommended overhaul interval and subsequently failed. Entergys corrective actions included cleaning, lubricating, and post-work testing the failed refueling floor supply isolation dampers. This issue was entered into the CAP as CR 2017-0494. The performance deficiency is more than minor because it is associated with the SSC and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Entergys preventative maintenance (PM) for the refueling floor supply isolation dampers was inadequate to ensure the availability and reliability of SSCs required to maintain secondary containment operable. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency only represented a degradation of the radiological barrier function provided by the reactor building and standby gas treatment system (SBGTS). The finding has a cross-cutting aspect in the area of Problem Identification and Resolution - Resolution, in that Entergy personnel did not take effective corrective actions to address issues in a timely manner. Specifically, in 2016, Entergy personnel identified there were deficiencies in the PM program with technical justifications for deferring PMs. Entergy reasonably had the opportunity to identify which PMs were not performed within recommended guidelines and make appropriate changes as needed. (P.3) |
| 05000293/FIN-2016011-12 | 2017Q1 | Green | Licensee-identified | Licensee-Identified Violation | 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with those structures, procedures, and drawings. Entergy procedure EN-DC-148, Vendor Manuals and Vendor Re-Contact Process, Revision 6, requires, in part, that the station update vendor manuals every three years. Contrary to this, in July 2016, PNPS determined through a self-assessment that they had 13 vendor manuals that had not been evaluated for changes within 3 years. The NRC team determined that this finding did not affect the design or qualification of a mitigating structure, system or component; did not represent a loss of a system and/or function; did not result in loss of a train or two safety systems greater than any technical specification allowed outage time; did not result from an actual loss of safety function; and did not involve loss of any external event mitigating system. Consequently, the NRC team determined that this performance deficiency screened as having very low safety significance (Green). PNPS documented this issue in their corrective action program as CR-PNP-2016-05115. | |
| 05000293/FIN-2017001-02 | 2017Q1 | Green | H.8 | NRC identified | Failure to Follow Procedures for Controlled Shutdown | Green. The inspectors identified a Green NCV of TS 5.4.1 Procedures, when Entergy did not follow the site procedures for limiting condition for operation (LCO) entries, Technical Specification (TS) usage, and procedure adherence. Specifically, on March 1, 2017, Entergy did not implement procedure 1.3.6, Technical Specifications-Adherence and Clarifications, and perform the procedural required preparation steps to commence a controlled and orderly shutdown when required by TS LCOs. Additionally, Entergy did not properly exit a TS LCO, based on procedure 1. 3.34.2, Limiting Conditions for Operation Log, requirements. Entergy entered the issue into the corrective action program (CAP) as condition report (CR) 2017-3724. The performance deficiency is more than minor because if left uncorrected, would have the potential to lead to a more significant safety concern. Specifically, the Entergy operations staff exited the LPCI LCO without personal observation by the senior reactor operator (SRO) signing off the work order (WO) that the maintenance postwork testing was complete and failed to implement the procedural required preparation steps to perform a controlled and orderly shutdown when required by TS LCOs. Inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, and determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk significant due to external initiating events. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, in that individuals follow processes, procedures, and work instructions. Specifically, Entergy did not us e procedural guidance explicitly put in place to provide operators clear direction on how to prepare and perform an orderly shutdown upon entering a TS LCO with shutdown requirements. (H.8) |
| 05000293/FIN-2017001-03 | 2017Q1 | Green | P.2 | NRC identified | Untimely Corrective Actions associated with Boraflex degradation in the Spent Fuel Pool | Green. The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, when Entergy did not take timely corrective action to correct a condition adverse to quality. Specifically, when BADGER testing results revealed gaps in 4 neutron absorber material that exceeded spent fuel storage design feature assumptions and therefore did not ensure compliance with TSs, the station did not establish corrective actions to ensure configurations and limitations would meet subcriticality analysis beyond September 2017. Entergy entered this into the CAP as CR 2017-1650 and is performing a root cause evaluation to evaluate options and establish corrective actions to ensure compliance is met beyond this timeframe. The performance deficiency was more than minor because it was associated with the Barrier Integrity cornerstone attribute of configuration control (reactivity control) and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the finding did not adversely affect any of the barrier integrity screening questions. The inspectors determined this finding had a cross-cutting aspect in Problem Identification and Resolution, Evaluation, because the organization did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the casual evaluation written to address the boraflex degradation was focused on restoring compliance and correcting immediate condition, and did not include longer term corrective actions to mitigate the likelihood of recurrence. (P.2) |
| 05000293/FIN-2016011-05 | 2017Q1 | Green | H.1 | NRC identified | Failure to Establish Corrective Actions to Address Scope of Procedure Quality Issues | The NRC team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy implemented inadequate corrective actions to address the procedure quality issues identified in CR-PNP-2016-02058. Specifically, Entergy inappropriately limited their corrective actions to those procedures that increased integrated risk above normal, and did not include other types of safety-related procedures that did not meet their procedure quality standards and resulted in procedure quality being a problem area. Entergy entered this issue into their corrective action program for further evaluation as CR-PNP-2017-00400. The performance deficiency was more than minor because it affected the procedure quality 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 (i.e., core damage). Entergy limited corrective actions to procedures that increased integrated risk above normal or trip sensitive and failed to include other procedures associated with safety-related components that reflected the broader population reviewed during the collective evaluation. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specificationallowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). The NRC team determined that this finding had a cross-cutting aspect related to Human Performance, Resources, because the leaders failed to ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, based on available resources, Entergy chose to limit the scope of safety-related procedures being revised to only those that resulted in high integrated risk or were trip sensitive (H.1). |
| 05000293/FIN-2016011-02 | 2017Q1 | Green | H.8 | NRC identified | Failure to Establish Corrective Actions to Preclude Repetition of a Significant Condition Adverse to Quality | The NRC team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not implement CAPRs for a significant condition adverse to quality identified in root cause evaluation CR-PNP-2016-00716, Implementation of the Corrective Action Program, Revision 2. Specifically, the team identified that CAPRs for Entergys continued weaknesses in the implementation of the corrective action program were inadequate. Entergy entered this issue into their corrective action program for further evaluation as CR-PNP-2017-00053, CR-PNP-2017-00410, and CR-PNP-2017-01134. The performance deficiency was more than minor because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to preclude repetition of this significant condition adverse to quality could result in continuing weaknesses in implementation of the corrective action program, which was designated as a fundamental problem, and thus a contributing factor for PNPS Column 4 performance. Additionally, weaknesses with corrective action program implementation could result in equipment issues where operability is not maintained. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specificationallowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). The NRC team determined that the finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because individuals did not follow processes, procedures, and work instructions. Specifically, Entergy did not follow procedure EN-LI-102, which provides the station standards for crafting a corrective action and states, in part, that the corrective action descriptions must be worded to ensure that the adverse condition or cause/factor is addressed (H.8). |
| 05000293/FIN-2017001-01 | 2017Q1 | NRC identified | Concern Regarding Ability to Declare EALs during Loss of Control Room Air Conditioning | 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) | ||
| 05000293/FIN-2016011-07 | 2017Q1 | Severity level IV | NRC identified | Failure to Report Condition Prohibited by Technical Specifications and a Safety System Functional Failure | The NRC team identified a Severity Level IV non-cited violation of 10 CFR 50.73, Licensee Event Report System, associated with Entergys failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria. Specifically, on September 28, 2016, Entergy identified the A emergency diesel generator was inoperable. The NRC team determined that the condition was prohibited by technical specifications and the inoperability of the A emergency diesel generator existed for a period of time longer than allowed by Technical Specification 3.5.F, Core and Containment Cooling Systems. This was also reportable as a safety system functional failure. Entergy entered this issue into the corrective action program as CR-PNP-2016-09552. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, the NRC team evaluated the performance deficiency using traditional enforcement. The violation was evaluated using Section 2.3.11 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. In accordance with Section 6.9.d, Example 9, of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, the NRC team did not assign a cross-cutting aspect to this violation, in accordance with IMC 0612, Appendix B. | |
| 05000293/FIN-2016011-03 | 2017Q1 | Green | H.8 | NRC identified | Failure to Issue Appropriate Corrective Actions to Preclude Repetition for the Causes of the September 2016 Scram | The NRC team identified a Green finding because Entergy did not issue appropriate CAPRs in accordance with Entergy procedure EN-LI-102, Corrective Action Process, Revision 28. Specifically, Entergy did not issue adequate CAPRs associated with Root Cause 1 of the feedwater regulating valve failure in September 2016 that resulted in a manual scram. As a result of the NRC teams questions, Entergy issued procedure 1.13.2, Vendor and Technical Information Reviews, Revision 0, as continuous use to ensure that planners will always have the checklist in-hand when planning work to ensure that appropriate vendor technical information is always included in applicable work instructions. Entergy entered the NRC teams concerns in the corrective action program as CR-PNP-2017-00687 and CR-PNP-2017-00936. The performance deficiency was more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if left uncorrected, the performance deficiency could have the potential to result in repetition of a significant condition adverse to quality, loss of control of feedwater regulating valve 642A and a manual scram. The NRC team evaluated the finding using Exhibit 1, Initiating Events Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not cause a reactor trip or the loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. Therefore, the NRC team determined the finding was of very low safety significance (Green). The NRC team determined that the finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because individuals did not follow processes, procedures, and work instructions. Specifically, Entergy did not follow procedure EN-LI-102, which provides the station standards for crafting a corrective action and states, in part, that the corrective action descriptions must be worded to ensure that the adverse condition or cause/factor is addressed (H.8). |
| 05000293/FIN-2016011-11 | 2017Q1 | Green | H.3 | NRC identified | Failure to Adequately Develop and Implement Targeted Performance Improvement Plans | The NRC team identified a Green finding because Entergy did not adequately develop and implement a CAPR of a root cause related to a Category A CR, as required by Entergy Procedure EN-LI-102, Corrective Action Program. Specifically, Entergy did not adequately develop and implement the Targeted Performance Improvement Plans, which were designated as a CAPR for the root cause for the Nuclear Safety Culture Fundamental Problem. Entergy documented this issue in the corrective action program for further evaluation as CR-PNP-2017-00406. The performance deficiency was more than minor because if left uncorrected, it could lead to a more significant safety concern. Specifically, inadequate implementation of the Targeted Performance Improvement Plans could result in recurrence of a culture in which leaders are not holding themselves and their subordinates accountable to high standards of performance, resulting in continuing performance issues at the station. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specification-allowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Resources, Change Management, because leaders did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. In this case, PNPS leaders did not apply sufficient rigor in development and implementation of the Targeted Performance Improvement Plans such that they would be an adequate method to drive and sustain positive changes in the stations safety culture (H.3). |
| 05000293/FIN-2016011-08 | 2017Q1 | Green | P.2 | NRC identified | Failure to Adequately Monitor the Performance of Maintenance Rule Scoped Components | The NRC team identified a Green non-cited violation of 10 CFR 50.65(a)(2), Requirements for monitoring the effectiveness of maintenance at nuclear power plants. Specifically, Entergy did not demonstrate that the performance of 18 maintenance rule scoped components was effectively controlled through the performance of appropriate preventive maintenance, and did not establish goals and monitoring in accordance with 10 CFR 50.65(a)(1). Entergys immediate corrective action was to initiate a CR to evaluate moving the affected systems to 10 CFR 50.65(a)(1) monitoring requirements. Entergy entered this issue in the corrective action program as CR-PNP-2017-00401. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Entergy failed to demonstrate that the performance of the 18 maintenance rule scoped components was being effectively controlled through the performance of appropriate preventive maintenance which adversely impacts the reliability of those systems. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specificationallowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). The finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, in that Entergy failed to thoroughly evaluate and ensure that resolution of the identified issue, maintenance not being performed on maintenance rule scoped components, included reclassifying the components as necessary. Specifically, Entergy failed to demonstrate that the performance of Maintenance rule scoped components was effectively controlled through the performance of appropriate preventive maintenance, or through performance goals and monitoring. (P.2). |
| 05000293/FIN-2016011-09 | 2017Q1 | Green | P.2 | NRC identified | Ineffective Corrective Actions to Address Conditions Adverse to Quality Regarding Components in Contact with or Close Proximity to the Drywell Liner | The NRC team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with Entergys failure to correct a condition adverse to quality affecting safety-related equipment. Specifically, during a previous NRC inspection in August 2016, inspectors identified numerous locations in the drywell where non-seismic equipment was either in contact, or close proximity, with the drywell liner and had caused damage. Entergy initiated CRs and performed an operability evaluation for the identified issues. However, following a review of these CRs, the NRC team determined that Entergy failed to take corrective actions to address the condition adverse to quality. Entergy entered this issue into the corrective action program as CR-PNP-2016-09346 and CR-PNP-2016-09377 to perform an extent of condition review, secure the loose grating that had caused damage to the liner, and evaluate the need for a clearance criteria between components such as floor grating and support structures and the containment liner. The performance deficiency was more than minor because it was associated with the configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, the NRC team determined that this finding was of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment (valves, airlocks, etc.), containment isolation system (logic and instrumentation), and heat removal components. This finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because the engineering evaluation of the degraded condition identified by the inspectors did not thoroughly evaluate the containment liner issues to ensure that resolutions address causes and extents of condition commensurate with their safety significance (P.2). |
| 05000293/FIN-2017001-04 | 2017Q1 | Severity level IV | NRC identified | Failure to Submit a Required 50.72 Notification | Severity Level lV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, because a TS required shutdown was not reported to the NRC within four hours of the occurrence, as required by 10 CFR 50.72(b)(2)(i). Specifically, on December 16, 2016, PNPS initiated a shutdown, as required by TS, as a result of the discovery of leakage associated with main steam isolation valves (MSIVs) 2C and 2D, leadi ng to the required isolation of the C and D main steam lines. Entergy entered the issue into the CAP as CR 2017-3723. Inspectors determined the issue had the potential to affect the NRCs ability to perform its regulatory function, therefore, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy (the failure of a licensee to make a report as required by 10 CFR 50.72 or 10 CFR 50.73), the inspectors determined that the violation was a Severity Level IV violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B | |
| 05000293/FIN-2016011-01 | 2017Q1 | Green | H.12 | NRC identified | Failure to Identify All Root Causes of a Significant Condition Adverse to Quality | The NRC team identified a Green non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not adequately determine all root causes associated with a significant condition adverse to quality related to the failure to identify, evaluate, and correct the A SRVs failure to open upon manual actuation during a plant cooldown on February 9, 2013. Specifically, Entergy did not establish adequate measures to assure that the cause of a significant condition adverse to quality, inadequate shift manager operability determination rigor and its associated causes, were adequately determined and corrective action taken to preclude repetition. Entergys immediate corrective actions included planning to conduct operations management face-to-face conversations with shift manager qualified individuals to reinforce the shift managers responsibility for operability and functionality determination accuracy and rigor. Entergy entered this issue into the corrective action program as CRPNP-2017-00363 and CR-PNP-2017-00828. The performance deficiency was more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if left uncorrected, the performance deficiency could have the potential to result in repetition of a failure to identify, evaluate, and correct an SRVs failure to open or a similar significant condition adverse to quality. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specification-allowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). The NRC team determined that the finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because individuals did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, Entergy incorrectly assumed that CR-PNP-2013-00825 contained inadequate information to determine that the A SRV had not opened, and this assumption ultimately impacted the root cause results documented in CR-PNP-2016-01621 (H.12). |
| 05000293/FIN-2016011-04 | 2017Q1 | Green | H.4 | NRC identified | Programmatic Issue with Implementation of the Operability Determination Process | The NRC team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. Specifically, the NRC team identified a programmatic issue because in some cases, Entergy did not enter the operability determination process when appropriate, and, when the process was entered, did not adequately document the basis for operability, in accordance with Procedure ENOP-104, Operability Determination Process, Revision 11. In each of the examples discussed, though the basis for operability was not adequate, all components were determined to be operable upon further evaluation. Entergy entered this issue into their corrective action program as CR-PNP-2017-00626. The performance deficiency was more than minor because if left uncorrected, could lead to a more significant safety issue. Specifically, the failure to enter and document a basis for operability could lead to not recognizing inoperable safety-related equipment, and place the reactor at a higher risk of core damage in a design basis accident. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specification-allowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance, Teamwork. Specifically, the operations and engineering departments did not demonstrate a strong sense of collaboration and cooperation with respect to holding each other accountable when performing operability determinations to ensure nuclear safety is maintained (H.4). |
| 05000293/FIN-2016011-13 | 2017Q1 | Green | Licensee-identified | Licensee-Identified Violation | 10 CFR 50.54(q)(2) requires, in part, that the licensee follow and maintain the effectiveness of an emergency plan to meet the planning standard of 10 CFR 50.47(b)(4). Specifically, the licensee was to maintain the necessary equipment to support the effectiveness of EALs. Contrary to these requirements, PNPS identified in CR-PNP-2016-01491 that on three past occasions (March 15 through August 8, 2012; September 4 through October 14, 2012; and June 4 through June 14, 2015) both trains of the H2O2 monitors and the Post-Accident Sampling System were unavailable to ensure the effectiveness of EAL 24, Deflagration concentrations exist inside PC, for the potential loss of the containment barrier within the Fission Product Barrier category of the EALs. This issue meets the criteria for very low safety significance (Green) because, due to other EALs, an appropriate emergency declaration could have been made in an accurate and timely manner. | |
| 05000293/FIN-2017406-01 | 2017Q1 | Severity level IV | NRC identified | Security | ||
| 05000293/FIN-2016011-06 | 2017Q1 | Green | NRC identified | Design Change Not Appropriately Reviewed by Entergy | The NRC team identified a preliminary greater than Green finding and apparent violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with Entergys failure to ensure that design changes were subject to design control measures commensurate with those applied to the original design and were approved by the designated responsible organization. Specifically, Entergy received a new style right angle drive for the A emergency diesel generator radiator blower fan from a vendor but failed to adequately review the differences in the design of the drives to identify potential new failure mechanisms for the part or the need for related preventive measures. Entergy entered this issue into the corrective action program as CR-PNP-2016-07443. The performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. 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, the team screened the finding for safety significance and determined that a detailed risk evaluation was required based on the A emergency diesel generator being inoperable for greater than the technical specification allowed outage time. Region I senior reactor analysts performed a detailed risk evaluation. The finding was preliminarily determined to be of greater than very low safety significance (greater than Green). The risk important sequences were dominated by external fire risk. Specifically, a postulated fire in the B 4 kilovolt (KV) switchgear room with a consequential loss of the unit auxiliary generator power supply, non-recoverable loss of off-site power (LOOP) to both safety buses A5 and A6, loss of the B emergency diesel generator with the conditional failure of the A emergency diesel generator, along with the loss of bus A8 feed (from the shutdown transformer or station blackout (SBO) diesel generator) to safety buses A5 and A6. The internal event risk was dominated by weather related LOOPs, failure of the A emergency diesel generator, with failure of the B emergency diesel generator and SBO diesel generator to run, along with failure to recover offsite power or the emergency diesel generators. See Attachment 1, A Emergency Diesel Generator Cooling Water System Degradation Detailed Risk Evaluation, for a detailed review of the quantitative criteria considered in the preliminary risk determination. The NRC team did not assign a cross-cutting aspect to this finding because the performance deficiency occurred in May 2000. Entergys program has undergone changes since May 2000, and the NRC team did not identify any recent examples of this performance deficiency. Other aspects of Entergys performance related to this issue are further discussed in Sections 5.10.3 and 6.3.4. | |
| 05000293/FIN-2016011-10 | 2017Q1 | Green | H.14 | NRC identified | Failure to Promptly Correct a Condition Adverse to Quality for the Residual Heat Removal System | The NRC team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not take timely corrective action for a previously identified condition adverse to quality. Specifically, Entergy failed to adequately resolve, through repair or adequate evaluation, gasket leakage on the B residual heat removal heat exchanger, which resulted in continued degradation and leakage for the heat exchanger gasket. Entergy did not consider this leakage as a degraded condition, with the potential to impact both the operability of the residual heat removal system, and PNPSs licensing basis with regards to leakage of a closed loop system outside of containment. After the NRC team raised the issue, Entergy performed an operability determination that established a reasonable expectation of operability pending implementation of corrective actions. Entergy entered this issue into their corrective action program as CR-PNP-2016-09725. The performance deficiency was more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correct identified gasket leakage resulted in continued degradation and leakage of the heat exchanger gasket. The NRC team evaluated the finding using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and determined this finding did not affect the design or qualification of a mitigating structure, system, or component; represent a loss of system and/or function; involve an actual loss of function of at least a single train or two separate safety systems for greater than its technical specification-allowed outage time; or represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant. Therefore, the NRC team determined the finding was of very low safety significance (Green). The finding had a cross-cutting aspect in Human Performance, Conservative Bias, because Entergy failed to use decision making practices that emphasize prudent choices over those that are simply allowable (H.14). |
| 05000293/FIN-2016004-05 | 2016Q4 | Green | H.5 | Self-revealing | Feedwater Regulating Valve Failure Results in Reactor Scram | Green. A self-revealing Green finding was identified for the inadequate implementation of a work order on the A feedwater regulating valve (FRV) encoder as required by ENWM- 102. Specifically, Entergy did not install a wire assembly on the A FRV encoder as required by the work instructions located in the vendor manual. The wire loosened, resulting in the A FRV failing open and the operators inserting a manual scram. In response to the loose connection, Entergy added a sealant to the connector to ensure all wires remain in place on both FRVs. Entergy entered the issue into the corrective action program (CAP) under condition report (CR) 2016-6635. The inspectors determined that the finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during a shutdown as well as power operations. Specifically, the performance deficiency affected the reliability and capability of the A FRV which led to a plant scram, tripping of the reactor feed pumps, and closure of the main steam isolation valves (MSIVs). The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, issued October 7, 2016, and IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, issued June 19, 2012, and determined a detailed risk evaluation was required because the A FRV failure caused a reactor trip and partial loss of feedwater (power conversion system). A Region I senior reactor analyst (SRA) used the Standardized Plant Analysis Risk (SPAR) model for Pilgrim, Version 8.24, and SAPHIRE, Version 8.1.4, to complete the detailed risk evaluation. The estimated increase in core damage frequency (CDF) was calculated to be 4E-7/year, or very low safety significance (Green). For issues resulting in an increase in CDF > 1E-7, IMC 0609 requires an evaluation of large early release frequency (LERF) using the guidance of NUREG-1765, Basis Document for LERF Significance Determination Process, and IMC 0609, Appendix H, Containment Integrity Significance Determination Process, issued May 6, 2004. The performance deficiency associated with the failure of the A FRV and resultant reactor trip would be considered a Type A finding and, as such, the calculated increase in CDF value is used in conjunction with an appropriate LERF factor (multiplier) to determine the estimated increase in LERF associated with the issue. In the absence of early core damage sequences for this event, LERF is not a significance risk contributor and the safety significance of this performance deficiency is defined by the estimated increase in CDF (4E-7/year) or Green. This finding has a cross-cutting aspect of Human Performance, Work Management, in that Entergy did not adequately implement the process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, maintenance staff were provided a work order that did not meet station requirements to ensure the work could be adequately performed. Specific steps of the vendor manual were not used to direct work by staff and led to an installation error. The work planning process also did not implement the engineering recommendation to perform a practice installation on the equipment prior to installing equipment in the field. (H.5) |
| 05000293/FIN-2016004-02 | 2016Q4 | Green | H.6 | Self-revealing | Ineffective Corrective Actions to Correct High Pressure Coolant Injection System Vibrations | Green. A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified in that Entergy did not identify and correct a condition adverse to quality related to high pressure coolant injection (HPCI) pump degraded performance, as required by EN-LI-102, Corrective Action Program. EN-LI-102, requires, in part, that individuals closing corrective actions verify that the required action has been taken ensuring that the response is adequate, answers all aspects of the assigned action, and the intent of the action is met. Specifically, vibrations on the HPCI main pump to speed reducer coupling were not addressed during HPCI system maintenance, despite a degrading trend starting May 21, 2015. This led to the HPCI system being declared inoperable on November 7, 2016, after vibration levels exceeded the in-service testing (IST) action range threshold. Entergys corrective actions included modeling vibrations of the HPCI system during operation and installing a stiffening plate on the HPCI pump support pedestal in order to dampen vibrations associated with the system. Entergy has entered this into their CAP as CR 2016-8657. The inspectors determined that this performance deficiency was more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage.) Specifically, Entergy did not address the increase in HPCI pump vibrations from May 21, 2015, to November 7, 2016, when the vibrations increased into the IST Action range and resulted in pump inoperability. In accordance with IMC 0609.04, Initial Characterization of Findings, issued October 7, 2016, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating structure, system, or component (SSC), represent a loss of system and/or function, involve an actual loss of a function of at least a single train or two separate safety systems for a greater time than allowed by technical specifications (TS), or represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Design Margins, in that the organization operates and maintains equipment within design margins, and margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, Entergy did not demonstrate that the work process supports nuclear safety and maintenance of design margins by minimizing long-standing equipment issues, preventive maintenance (PM) deferrals, and maintenance and engineering backlogs. Entergys failure to effectively manage design margins regarding HPCI system vibrations led to a continuing degradation of the system, and the eventual need to declare the HPCI system inoperable on November 7, 2016. (H.6) |
| 05000293/FIN-2016403-07 | 2016Q4 | Green | Licensee-identified | Licensee-Identified Violation | ||
| 05000293/FIN-2016004-06 | 2016Q4 | Green | Licensee-identified | Licensee-Identified Violation | TS 3.9.B.2 requires that when incoming power is not available from both startup and shutdown transformers, continued operation is permissible, provided both diesel generators and associated emergency buses remain operable, all core and containment cooling systems are operable, and reactor power level is reduced to 25% of design. Contrary to the above, on seven occasions between 2005 and August 27, 2014, for an average of 3.6 hours, Entergy conducted test Procedures 3.M.3-1, A5/A6 Buses 4kV Protective Relay Calibration/Functional Test and Annunciator Verification Critical Maintenance, and 3.M.3-29, Shutdown Transformer and 23kV Relay Calibration and Functional Test, that placed the plant in a condition not allowed by TS 3.9.B.2. Specifically, the testing would have prevented emergency buses A5 and A6 from automatically transferring to their backup power supplies. Entergy entered this condition into their CAP as CR 2016- 2735. A Region I SRA conducted a detailed risk evaluation for this issue using IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, issued June 19, 2012. Using the average time from above, along with operator recovery actions, the SRA calculated the change in core damage probability to be <1E-7, which was considered to be of very low safety significance (Green) | |
| 05000293/FIN-2016004-03 | 2016Q4 | Green | H.12 | NRC identified | Failure to Properly Assess and Manage Risk Associated with Shutdown Transformer Protective Relay Testing | 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) |
| 05000293/FIN-2016403-04 | 2016Q4 | Green | H.14 | NRC identified | Security | |
| 05000293/FIN-2016004-04 | 2016Q4 | Green | H.14 | Self-revealing | Failure to Correct a Condition Adverse to Quality Associated with Main Steam Isolation Valve | Green. A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified in that Entergy did not promptly correct a condition adverse to quality associated with the operability of a MSIV. Specifically, Entergy did not take timely corrective actions to inspect and remove debris from air tubing that supplied air to a valve actuator after the associated MSIV failed a surveillance test on March 29, 2016. This uncorrected condition subsequently led to a repeat failure of the valve on August 16, 2016. Entergy entered these issues into their CAP as CR 2016-2250 and CR 2016-5987 and developed corrective actions to revise associated procedures as needed, replaced the affected MSIV air pack manifold, cleared loose debris from the affected air tubing, and scheduled the replacement of affected air tubing during the next refueling outage. The inspectors determined that this performance deficiency was more than minor because it was associated with the barrier performance attribute of the Barrier Integrity cornerstone and it adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, when MSIV-1C failed to meet its surveillance requirements on March 29, 2016, Entergy did not take corrective actions necessary to adequately identify and resolve the underlying issue of system debris being present in air tubing, which affected the valve actuator and caused a slow closing time for the valve. This inaction led to continued valve inoperability, for a duration greater than that allowed by TS, which presented itself during a subsequent operability test on August 16, 2016. The inspectors screened this finding in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power; using Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the finding did not involve an actual open pathway in the physical integrity of reactor containment or involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined that this issue had a cross-cutting aspect in the area of Human Performance, Conservative Bias, because Entergy did not use decision-making practices that emphasize prudent choices over those that were simply allowable. Specifically, when the MSIV initially failed its surveillance in March 2016, Entergy did not take a conservative approach in their operability determination and immediate response to the issue. This was demonstrated by the fact that, following the March 2016 valve failure, when a cause evaluation identified the likelihood of debris in air tubing affecting valve operability, individuals rationalized that the degraded condition had been resolved on its own and would not recur. Entergy acted on this assumption, rather than making the conservative determination that the effect of present debris could impact continued operability in an unpredictable manner, as it did during the subsequent failed surveillance test in August 2016. (H.14) |
| 05000293/FIN-2016403-10 | 2016Q4 | Severity level Enforcement Discretion | NRC identified | Security |