05000353/FIN-2015003-01
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Finding | |
|---|---|
| Title | Inadequate Procedure for RWCU Backwashing Operations |
| Description | A self-revealing Green NCV of Technical Specification (TS) 6.8.1.a, Procedures and Programs, occurred because Exelon failed to establish, implement, and maintain an adequate procedure for the control of radioactivity and limiting personnel exposure during operation of a solid radioactive waste system. Specifically, the procedure for the conduct of reactor water cleanup (RWCU) filter media backwashing and collection was inadequate to ensure a sufficient receiving tank volume prior to transferring waste media. On June 28, 2015, this resulted in the overflow of a Unit 2 RWCU collection tank and back up of the reactor building floor drain system, causing high levels of radioactive contamination in accessible portions of the Unit 2 reactor building, and resulting in radioactive contamination of personnel. Exelon controlled access, decontaminated affected areas and personnel, conducted bounding dose assessments, performed extent of condition reviews, and revised affected procedures to address the issue. Exelon placed this issue into the corrective action program as issue report (IR) 2520732. This issue is more-than-minor because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to effectively control and manage radioactive material could result in significant unplanned, unintended occupational radiation exposure of workers. 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 reasonable 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. The inspectors determined this finding has a cross-cutting aspect in the area of Human Performance, Avoiding Complacency, because Exelon did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes, and therefore did not implement appropriate error reduction tools. Specifically, Exelon operated the backwash receiving tank (BWRT) to routinely accept high level alarms with associated potential for system overflow. Consequently, although this mode of operation of the system was longstanding, the issue reflects present performance. |
| Site: | Limerick  |
|---|---|
| Report | IR 05000353/2015003 Section 2RS1 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | B Bollinger F Bower J Ayala J Nicholson L Cline M Fannon N Floyd R Nimitz S Garry S Hammann S Rutenkroger |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - Limerick - IR 05000353/2015003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2015Q3
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