The inspectors identified a finding of very-low safety significance and an associated
NCV of
Technical Specification 5.4.1 for the failure to maintain procedures for station vent releases during planned scenarios. Specifically, the inspectors identified multiple procedures that were not updated when the station vent monitors were replaced in 2014. This issue has been entered into the licensees Corrective Action Program as CR201710817. Corrective actions taken included the issuance of a Standing Order for collecting samples during accident conditions, provided Just-In-Time training for chemistry technicians, and revision of the outdated procedures. The performance deficiency was determined to be more-than-minor in accordance with
Inspection Manual Chapter 0612, Appendix B, Issue Screening. Specifically, if left uncorrected, the performance deficiency had the potential to
lead to a more significant safety concern in that the failure to maintain procedures to collect station vent samples under all predicted conditions could result in the inability to measure the amount of gaseous radioactivity leaving the plant and to ensure 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. The finding was assessed using
Inspection Manual Chapter 0609 Appendix D,
Public Radiation Safety Significance Determination Process, and was determined to be of very-low safety significance because the issue involved radioactive effluent releases, but did not: (1) represent a substantial failure to implement the Radioactive Effluent Release Program; or (2) result in public exposure that exceeded the dose values in Appendix I to 10 CFR, Part 50, and/or 10 CFR, Part 20.1301(e) limits. The inspectors determined that the finding had a cross-cutting component in the area of Human Performance, in the aspect of Work Management: specifically, the organization did not implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. [H.5]
