The NRC identified a non-cited violation of
Technical Specification (TS) 6.14,
Offsite Dose Calculation Manual (
ODCM), for failure to evaluate and provide sufficient information to support a change to the
ODCM. Specifically,
LGS revised the
ODCM to allow the
residual heat removal service water (
RHRSW) monitors to be non-functional due to loss of flow for a period of up to
4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before they were required to be declared
inoperable and did not provide sufficient information to support the change including a determination that the change would maintain the level of radioactive effluent release control.
LGS entered the issue into their corrective action program (
CAP) as
Issue Report (IR) 1639697 and revised the applicable alarm response card (ARC-MRC-010 E4) to declare the monitor
inoperable under similar conditions. A dose calculation was also completed that indicated no significant public dose consequences associated with the monitors
inoperable status. The failure to evaluate and provide sufficient information to support a change to the
ODCM, in accordance with the requirements of
TS 6.14 is a performance deficiency. This performance deficiency is more than minor because it affected the
Public Radiation Safety Cornerstone attribute of Plant Facilities/Equipment and Instrumentation. Using
Inspection Manual Chapter 0609, Appendix D,
Public Radiation Safety Significance Determination Process, dated February 12, 2008, the inspectors determined this to be a finding of very low safety significance (Green) because: the finding was in the effluent release program; was not a substantial failure to implement the effluent program; and the dose to the public did not exceed the 10 Code of Federal Regulations (CFR) Part 50 Appendix I criterion or
10 CFR 20.1301(e) limits. This finding was associated with a cross cutting aspect of Human Performance, Design Margins. Specifically,
LGS did not conduct a sufficiently rigorous review of a change in the operability status of a safety-related radiation monitor (
RHRSW radiation monitors) to ensure that the change would not adversely impact the level of radioactive effluent release control.
