05000293/FIN-2016003-01

Finding

Title

Process Radiation Monitor Subsystems 10 CFR 50.65(a)(2) Not Met

Description

Inspectors identified a Green NCV of 10 CFR 50.65 (a)(2), because Entergy did not adequately demonstrate that the performance of the process radiation monitors (PRMs) was effectively controlled through performance of appropriate preventive maintenance. Specifically, Entergy did not identify and properly account for functional failures of four PRM subsystems in July 2014 and February, April, and July 2015; and did not recognize that the subsystems had exceeded their performance criteria and required a Maintenance Rule (a)(1) evaluation. Entergy entered the issue into the CAP under CR-2016-05564. Entergy performed the Maintenance Rule (a)(1) evaluation, and placed them into (a)(1) where they will be monitored against specific goals. The finding is more than minor because it is associated with the Plant Facilities/Equipment and Instrumentation attribute of the Public Radiation Safety cornerstone and affects the cornerstone objective of ensuring the adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, following the failures of the Main Stack Normal Range subsystem in July 2014, the Reactor Building Closed Cooling Water (RBCCW) subsystem in February 2015, the Shared Components subsystem in April 2015, and the Torus Containment High Radiation Monitoring System (CHRMS) subsystem in July 2015, Entergy did not identify the failures as functional failures, and consequently, did not establish goals and monitoring criteria in accordance with 10 CFR 50.65(a)(1). The inspectors determined that the failures demonstrated that the performance of the subsystems was not being effectively controlled through appropriate preventive maintenance, because the incorrect screenings resulted in exceedance of the subsystems performance criteria and placement in (a)(1) status. The inspectors evaluated the significance of this finding using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process. The finding is of very low safety significance (Green) because the finding was in the Effluent Release Program, but did not result in a failure to implement the Effluent Release Program, and did not result in dose to the public in excess of 10 CFR 50, Appendix I criterion or 10 CFR 20.1301(e) limits. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, in that the organization did not thoroughly evaluate issues to ensure that resolution addressed causes and extent of conditions commensurate with their safety significance. Specifically, Entergy identified all of the failures of the PRM subsystems, however, Entergy did not thoroughly evaluate the failures as maintenance rule functional failures.

01
Site:	Pilgrim
Report	IR 05000293/2016003 Section 1R12
Date counted	Sep 30, 2016 (2016Q3)
Type:	NCV: Green
cornerstone	Pr Safety
Identified by:	NRC identified
Inspection Procedure:	IP 71111.12
Inspectors (proximate)	A Burritt B Fuller B Pinson D Werkheiser E Burket E Carfang J Brand J Pfingstein L Dumont M Fannon M Modes S Rich T Dunn
Violation of:	10 CFR 50.65 10 CFR 50.65(a)(1) 10 CFR 50.65(a)(2)
CCA	P.2, Evaluation
INPO aspect	PI.2
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Finding - Pilgrim - IR 05000293/2016003

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

IR 05000293/2016003: 1 2 3 4

Finding List (Pilgrim) @ 2016Q3

CCA Matrix: 2016Q3

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

Self-Identified List (Pilgrim)

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

[Pilgrim Findings full list]

05000293/FIN-2016003-01

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