05000220/FIN-2015002-01
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Finding | |
|---|---|
| Title | Failure to Notify of Changes to Work Scope |
| Description | The inspectors identified a self-revealing NCV of Unit 1 Technical Specification (TS) 6.4.1, Procedures, for failure to follow the planned scaffold erection work scope that resulted in two personnel receiving unplanned internal exposures. Specifically, on January 6, 2015, workers erecting scaffolding changed the work scope that specified the use of new equipment and used unsurveyed highly contaminated scaffold parts instead, without notifying radiation protection staff of the change in work scope that resulted in two workers receiving unplanned, unintended internal radiation exposures. The failure to follow the planned work scope is a performance deficiency. The performance deficiency constitutes a finding that is more than minor because the performance deficiency was associated with the Occupational Radiation Safety attribute of program and process and adversely affected the cornerstone objective in the protection of workers from exposure to radioactive material. Specifically, failure to follow the planned work scope resulted in two personnel receiving unplanned internal exposures. The finding is not subject to traditional enforcement because it did not affect the regulatory process or result in actual safety consequences. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was of very low safety significance (Green) because it did not involve: (1) as low as reasonably achievable (ALARA) occupational collective exposure planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. The cause of the finding is related to the cross-cutting area of Human Performance, Challenge the Unknown, because when workers discovered potentially contaminated scaffold materials in the work area, they did not question whether or not it was appropriate to use the material in their job and did not raise the question to their supervisors or Exelon Generation Company, LLC (Exelon) radiation protection technicians prior to deviating from the planned and briefed work scope. As a result, the radiological risks were not evaluated before proceeding to utilize the unsurveyed highly contaminated components, which resulted in unintended internal radiation exposures to the workers. |
| Site: | Nine Mile Point  |
|---|---|
| Report | IR 05000220/2015002 Section 2RS1 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | C Graves D Schroeder E Miller G Stock K Kolaczyk |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.11, Challenge the Unknown |
| INPO aspect | QA.2 |
| ' | |
Finding - Nine Mile Point - IR 05000220/2015002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Nine Mile Point) @ 2015Q2
Self-Identified List (Nine Mile Point)
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