05000352/FIN-2012004-06
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Finding | |
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Title | Licensee-Identified Violation |
Description | Limerick Unit 1 and Unit 2 TS 6.8.4.d. required that: 1) a Radioactive Effluent Controls Program be provided for the control of radioactive effluents, 2) the program be contained in the ODCM, and 3) that the program be implemented. Limerick Station ODCM, Revision 25, Section 4.2.2.3, requires that cumulative organ doses due to iodine, tritium, and particulates with half-lives greater than 8 days, be determined at least once per 31 days. Contrary to TS 6.8.4 and the ODCM, cumulative total dose to organs was not calculated during the period of approximately November 23, 2010 through October 2011, due to loss of dose factors from a software package. Exelon subsequently calculated bounding dose values after re-loading the factors and determined the projected doses to be well within applicable dose limits. Exelon also provided an update to its 2010 annual effluent release report. This finding was assessed for significance using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, and determined to be of very low safety significance because: there was no spill or release event; the issue was contrary to Technical Specifications and a radioactive effluent release program deficiency; secondary radioactive effluent monitoring and controls program elements provided for control of effluents releases; although organ doses were slightly underestimated, projected doses did not exceed applicable limits, including ALARA design specifications of 10 CFR 50, Appendix I; there was no effluent monitor calibration issue; and the licensee had data by which to assess dose to a member of the public. Because this issue was determined to be of very low risk significance (Green), and Exelon has entered this issue into the CAP as IR 1297197, this issue is being characterized as a licensee identified NCV. |
Site: | Limerick |
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Report | IR 05000352/2012004 Section 4OA7 |
Date counted | Sep 30, 2012 (2012Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Licensee-identified |
Inspection Procedure: | |
Inspectors (proximate) | E Burket E Dipaolo J Hawkins J Laughlin P Krohn R Nimitz |
INPO aspect | |
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Finding - Limerick - IR 05000352/2012004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2012Q3
Self-Identified List (Limerick)
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