05000352/FIN-2012002-02
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | 10 CFR 50.54(q) requires, in part, that a power reactor licensee follow an Emergency Plan that meets the requirements of 10 CFR 50.47(b). 10 CFR 50.47(b) requires, in part, that a standard emergency classification and action level scheme, the bases of which includes facility system and effluent parameters, is in use by the licensee. Contrary to the above, between May 2011 and February 2012, Exelon did not have a documented basis for a useable parameter for the declaration of a General Emergency (GE) using the LGS South Stack effluent radiation monitor. In May 2007, Exelon implemented Revision 11 of EP-AA-1008, Radiological Emergency Plan Annex for Limerick Generating Station, which updated the station emergency action levels (EALs) to the NEI 99-01, Revision 4, standard. The new LGS EAL scheme changed the South Stack GE declaration threshold from 8.84E-2 uCi/cc to 2.71E-1 uCi/cc, yet the Updated Final Safety Analysis Report listed the upper limit of that monitor as 1E-1 uCi/cc. Exelon discovered the discrepancy on February 9, 2012, and entered it into their CAP as IR 1324991. Exelon implemented immediate corrective actions by lowering the GE declaration threshold to 9E-2 uCi/cc, and by contacting the monitor vendor to determine the actual indicating capability of the monitor. The vendor informed Exelon that it believed the monitor was capable of displaying an accurate indication through the entire decade of 1E-1 uCi/cc, that 1E-1 was not the upper limit of indication. Exelon developed a work order and conducted an electronic test of the monitor itself on February 14, 2012, and a system test of the sensor and monitor using a calibrated radioactive source on February 16, 2012. The results of those tests indicated that the monitor was capable of accurately indicating 2.71E-1 uC/cc. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Sheet 1, because, although the licensee had not maintained their EALs as required by 10 CFR 50.47(b), the resultant failure would not have precluded the declaration of any GE event. |
| Site: | Limerick  |
|---|---|
| Report | IR 05000352/2012002 Section 4OA7 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | E Dipaolo J Furia S Barr N Sieller R Nimitz P Krohn E Burket J Hawkins |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2012002 | |||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2012Q1
Self-Identified List (Limerick)
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