A self-revealing, Green,
NCV of
Technical Specification (TS) 6.12.1, was identified by health physics inspector(s) for the failure to post a
high radiation area (
HRA). Specifically, on April 6, 2016, the licensee failed to post the area by the exterior wall of the Unit 4 spent fuel pool (
SFP) on the Auxiliary Building roof as a
HRA. This performance deficiency was determined to be more than minor because it was associated with the
Occupational Radiation Safety Cornerstone attribute of Human Performance, and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to post and control
HRAs can allow workers to enter
HRAs without knowledge of the radiological conditions in the area and result in the receipt of unintended occupational exposure. The finding was evaluated using the
Occupational Radiation Safety SDP. The finding was not related to the As Low As Reasonably Achievable (
ALARA) planning, did not involve an
overexposure or
substantial potential for overexposure, and the ability to assess dose was not compromised. Therefore, the inspectors determined the finding to be of very low safety significance (Green). This finding involved the cross-cutting aspect of Human Performance, Work Management (H.7) because the organization failed to implement its process for planning and controlling access to
HRAs on the Auxiliary Building roof when fuel bundle movement were still ongoing. The violation was entered into the licensees
CAP as
AR 02123851.
