The inspectors identified a finding of very low safety significance and an associated
NCV of Title 10 of the Code of Federal Regulations (CFR), Part 20.1406(c), when the licensee failed to conduct operations to minimize the introduction of residual radioactivity onto the site. Specifically, the licensee failed to identify and evaluate the environmental risk and control work practices with a credible mechanism to prevent spills and leaks from reaching groundwater at the circulating water blowdown (CWBD) area, a radiologically unrestricted area in the licensees owner controlled area. Specifically,
tritium contaminated
sump water was intermittently pumped to the environs. The licensee documented this finding in their corrective action program (
CAP) as
Issue Report (IR) 4020644. The failure to conduct operations and control work practices with a credible mechanism to prevent spills and leaks to reach groundwater and minimize residual radioactivity onto the site represented a licensee performance deficiency. The performance deficiency was of more than minor significance because it was associated with the Program and Process attribute of the
Public Radiation Safety cornerstone and adversely affected the cornerstone objective of ensuring the adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. In accordance with
IMC 0609, Appendix D,
Public Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because the issue involved a radioactive effluent release, but did not: (1) represent a substantial failure to implement the radioactive effluent release program; or (2) result in public exposure that exceeded the dose values in Appendix I to
10 CFR Part 50 and/or
10 CFR 20.1301(e) limits. The inspectors determined that this finding had a cross-cutting component in the area of Human Performance, in the aspect of Challenging the Unknown, because licensee personnel did not stop when faced with uncertain conditions or evaluate and manage risk before proceeding.
