05000352/FIN-2013003-02
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Finding | |
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| Title | Failure to adhere to radiation protection procedures for evacuation of the Unit 2 upper drywell in preparation for irradiated component moves |
| Description | The inspectors identified a self-revealing finding of very low safety significance associated with failure to comply with TS 6.8, Procedures and Programs. Specifically, the inspectors identified Exelon personnel failed to implement radiation protection procedure requirements associated with clearance of personnel from the upper levels of the Unit 2 reactor drywell in preparation for removal and movement of irradiated core component from the Unit 2 reactor vessel. Exelon personnel entered this issue into their CAP as IR 1495585. The failure to adhere to TS required radiation protection procedures for personnel exposure control related to irradiated core component movement is a performance deficiency. The performance deficiency was determined to be more than minor because it was related to the Programs and Process attribute of the Occupational Radiation Safety Cornerstone, and adversely affected the cornerstone objective to ensure adequate protection of worker health and safety from exposure to radiation from radioactive material during routine reactor operation. Further, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern if personnel were locked in the area and irradiated hardware dropped above their work location. The finding was not subject to traditional enforcement because it was not associated with a violation that impacted the regulatory process and did not contribute to actual safety consequences. The finding was assessed using IMC 0609, Appendix C, 2 Enclosure Occupational Radiation Safety SDP, dated August 19, 2008, and was determined to be of very low safety significance (Green) because it was not related to As-Low-As-Is-Reasonably-Achievable (ALARA), did not result in an overexposure or a substantial potential for overexposure, and did not compromise the licensee\'s ability to assess dose. This finding was associated with the Work Control aspect of the Human Performance cross-cutting component. Specifically, Exelon staff did not effectively coordinate this work activity by incorporating actions to address the impact of the work on different job activities, and the need for work groups to maintain interfaces and communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance. |
| Site: | Limerick |
|---|---|
| Report | IR 05000352/2013003 Section 2RS1 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | E Dipaolo J Ayala J Hawkins J Tomlinson M Gray O Masnyk Bailey R Nimitz S Hammann T Burns |
| Violation of: | Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2013003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2013Q2
Self-Identified List (Limerick)
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