Additionally, the inspection assessed whether Entergy’s evaluations into these significant deficiencies were of a depth commensurate with the significance of the issue, root and contributing causes of risk-significant deficiencies were identified, and corrective actions were taken to correct immediate problems and to prevent recurrence.This is a example of what I am talking about. If you can't trust them to be accurate and have integrity on the little problems then you can't trust them on the bigger issues. The difference between the last blizzard shutdown and the one before is calling the 23kv line operable or inoperable. They called the 23kv line operable in the 2015 blizzard. The 2013 blizzard was called a full Loss Of Offsite Power ( LOOP) while the 2015 blizzard LOOP was called a partial LOOP. If you wanted to take responsibility for the position you place the plant in you would call the 2015 Blizzard a full LOOP. If you wanted to minimize your responsibilities you would inaccurately call a partial LOOP.
The 23kv line always had way to many uncertainties, as a example Entergy doesn't own or control the quality of the line. There is no equivalencies between a emergency diesel generator and this line. As another example, Entergy because they don't own the line, they have no power to see and understand all the vulnerabilities of the line as in the below NRC example.
Calling the line having the capability to wholly support the plant in a emergency is just a public relation job. You need to always call this line conservatively inop or not available.
NRC Inspection Report 05000293/2014002 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14129A282) documents an NCV (2014002-02) related to an inadequate procedure for determining operability of the shutdown transformer. Specifically, an NSTAR calculation concluded that certain alternative offsite power lines did not satisfy Pilgrim’s minimum voltage criteria for the shutdown transformer, but this information was never incorporated into the degraded 23kV line procedure for determining the operability of the shutdown transformer.Entergy procedure EN-LI-102, “Corrective Action Program,” requires Entergy staff to document the receipt of NRC violations as a CR; however, this did not occur. The inspectors noted that EN-LI-102 would have likely directed performance of an apparent cause evaluation and could have prevented the receipt of a second NCV for a similar issue in 2015. NRC Inspection Report 05000293/2015003 (ADAMS Accession No. ML15317A030) documents an NCV (2015003-03) issued for an inadequate operability assessment of the shutdown transformer because Entergy staff did not appropriately evaluate changes made to the shutdown transformer when an alternate offsite power configuration was used that resulted in the transformer being inoperable. The inspectors noted that the degraded 23kV procedure contained incorrect information at that time, which the operations staff used during the operability evaluation. The inspectors determined that Entergy’s failure to document NCV 2014002-02 as a CR and perform a cause evaluation in accordance with EN-LI-102 was a performance deficiency. Because this issue is an additional contributor to the inadequate operability assessment, and the enforcement aspects of the inadequate operability assessment are already addressed as NCV 2015003-03, this issue is not being documented as a separate finding. Entergyentered this issue into their CAP as CR-PNP-2016-00302 for further evaluation.
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