A self-revealing
NCV of
Technical Specification 6.8.1, Procedures and Programs was identified for Exelons failure to use respiratory protection, as required in the radiation work permit (
RWP)/as low as reasonably achievable (
ALARA) plan 14-406 for drywell head reassembly work on October 2, 2014. The radiation protection (
RP) supervisor overseeing this work removed the respiratory protection requirement for this work contrary to the RWP/ALARA requirement and without engineering approval. As a result, two workers received an unplanned intake of radioactive material that resulted in unintended internal dose. Upon identification of the intake, Exelon stopped work on this task and subsequently reinstituted the respiratory protection requirements to complete the remaining work and entered this event into their corrective action program as issue report 2390111. This finding is more than minor because it is associated with the
Occupational Radiation Safety cornerstone to ensure adequate protection of the worker from radiation exposure. Specifically, without the use of respiratory protection two workers received unintended internal dose. The inspectors evaluated the finding using inspection manual chapter 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process. The inspectors determined that this finding is of very low safety significance (Green), because it did not result in an
overexposure as defined by
10 CFR 20.1201, there was no
substantial potential for an overexposure, and the ability to assess dose was not compromised. This finding has a cross-cutting aspect in Human Performance, Procedural Adherence, because Exelon did not follow procedures and work instructions. Specifically,
RP supervision instructed the workers that respiratory protection was not required contrary to the applicable RWP/ALARA plan.