05000353/FIN-2016001-06
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Finding | |
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| Title | Failure to Implement Procedures for Control of Potentially Contaminated Clean Systems |
| Description | The inspectors identified a Green NCV of technical specification 6.8.1 because Exelon failed to implement procedure CY-AA-170-210, Potentially Contaminated System Control Program, for the evaluation and control of potentially cross-contaminated systems. Specifically, Exelon did not implement CY-AA-170-210 for the evaluation and control of a potentially cross-contaminated system when samples collected from the Unit 2 service air system, a non-contaminated system, indicated the potential presence of contamination on June 16, 2015. Exelon entered this issue into the corrective action program (IR 2556568), restricted use of the service air system, conducted a 10 CFR 50.59 screening and radiological evaluation of the system, conducted bounding radiation dose analyses for both occupational workers and members of the public, conducted an extent of condition review, decontaminated the system, and subsequently modified operation of the service air system to preclude re-contamination. This finding is more-than-minor because it is associated with the program and process attributes of the occupational and public radiation safety cornerstones and adversely affected both cornerstone objectives to ensure adequate protection of worker and public health and safety from exposure to radioactive material. Specifically, during the time the service air system was contaminated but not recognized as such and not restricted in use, the potential existed to inadvertently contaminate workers and release radioactive material to the environment. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not involve an as low as is reasonably achievable (ALARA) issue, was not an overexposure, did not result in a substantial potential for an overexposure, and did not compromise the ability to assess dose. In addition, using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, the inspectors determined that the issue did not involve a substantial failure to implement the effluent release program and did not result in public doses exceeding 10 CFR 50, Appendix I or 10 CFR 20.1301 (e) and thus was of very low safety significance (Green). The inspectors determined this finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Resolution, because Exelon did not take effective corrective actions when service air system issues were identified. |
| Site: | Limerick  |
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| Report | IR 05000353/2016001 Section 4OA3 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Or Safety, Pr Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | D Schroeder J Furia J Richmond M Fannon R Nimitz S Barber S Rutenkroger J Schussler |
| Violation of: | Technical Specification - Procedures 10 CFR 50.59 10 CFR 20.1301, Radiation Dose Limits for Individual Members of the Public Technical Specification 10 CFR 50 Appendix I |
| CCA | P.3, Resolution |
| INPO aspect | PI.3 |
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Finding - Limerick - IR 05000353/2016001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2016Q1
Self-Identified List (Limerick)
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