The inspectors identified a self-revealing finding of very low safety significance associated with occupational exposure control. During the planned refueling outage, Ginna did not effectively manage its radioactive source term and work activities to prevent unnecessary occupational exposure to workers during B
sump strainer modification and
steam generator inspections. Specifically, the collective occupational radiation dose received by individuals for these two activities exceeded the planned or intended dose that Ginna determined was as low as is reasonably achievable (
ALARA) for the work activities. This finding is more than minor because each of the two work activities exceeded their initial estimates by more than 50 percent and each accumulated more than five person
rem, as described in
Appendix E of IMC 0612, example (6.b). Additionally, the finding affected the program and process attribute of the
Occupational Radiation Safety cornerstone to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operations. This finding is of very low safety significance because the 3-year rolling average exposure for Ginna was less than 135 person-rem. This finding has a crosscutting aspect in the area of human performance work control because Ginna did not effectively coordinate work activities to incorporate actions to address the impact of changes to the work scope or activity that were appropriate under the circumstances (
H.3.b per
IMC 0305)
