05000298/FIN-2012002-06

Finding

Title

Failure to Follow Radiation Work Permit Requirements

Description

The inspectors identified two examples of a non-cited violation of Technical Specification 5.4.1, associated with station personnels failure to follow radiation work permit requirements. Specifically, on two separate occasions inspectors observed different workers breaching contaminated systems during planned maintenance activities without radiation protection personnel present as specified by the radiation work permit requirements. This issue was entered into the licensees corrective action program as Condition Reports CR-CNS-2012-00461, and CR-CNS-2012-00763. The inspectors determined that the failure of craft personnel to follow radiation work permit requirements when breaching contaminated systems was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected, the continued failure of craft personnel to follow radiation work permit requirements when breaching contaminated systems could become more significant, in that, it could lead to personnel contamination events and unplanned/unexpected dose, and is therefore a finding. The finding was associated with the Occupational Radiation Safety Cornerstone. Using Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspector determined the finding to be of very low safety significance because: (1) it was not associated with as low as reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. This finding had a cross-cutting aspect in the area of human performance associated with the work practices component, because the licensee failed to use conservative assumptions in decision making and adopt requirements to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action when performing work activities that breached contaminated systems

06
Site:	Cooper
Report	IR 05000298/2012002 Section 1R22
Date counted	Mar 31, 2012 (2012Q1)
Type:	NCV: Green
cornerstone	Or Safety
Identified by:	NRC identified
Inspection Procedure:	IP 71111.22
Inspectors (proximate)	C Henderson J Josey J Laughlin S Garchow V Gaddy
CCA	H.14, Conservative Bias
INPO aspect	DM.2
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v • d • e

Finding - Cooper - IR 05000298/2012002

1(0)2(9)3(16)4(13)5(12)6(0)7(6)8(0)301(1)403(0)404(4)501(0)503(0)801(0)31(0)

IR 05000298/2012002: 1 2 3 4 5 6 7 8 1

Finding List (Cooper) @ 2012Q1

CCA Matrix: 2012Q1

	Q	CCA	Title
05000298/FIN-2011004-01	2011Q3	H.7	Failure to Place the Essential Service Water System Strainers in (a)(1)
05000298/FIN-2011004-02	2011Q3		Failure to Scope Reactor Building Drain Components and Steam Exclusion Doors that Affect Safety-related Systems in the Maintenance Rule Monitoring Program
05000298/FIN-2011004-03	2011Q3	H.8	Failure to Assess and Manage Risk for Maintenance Near Electrical Towers That Could Impact Initiating Events
05000298/FIN-2011004-04	2011Q3	P.3	Failure to Assess and Manage Risk for Maintenance Near an Operating Reactor Feed Pump That Could Impact Initiating Events
05000298/FIN-2011004-05	2011Q3	H.12	Failure to Follow Procedure Results in Personnel Contamination
05000298/FIN-2011004-06	2011Q3	P.2	Failure to Identify, Correct, and Prevent Recurrence of a Significant Condition Adverse to Quality
05000298/FIN-2011004-07	2011Q3		Inadequate Procedure Results in Inoperable Essential Pump
05000298/FIN-2011005-07	2011Q4	H.14	Failure to Perform Required 10 CFR 50.59 Evaluations for Changes
05000298/FIN-2011202-02	2011Q4		Security
05000298/FIN-2011005-06	2011Q4	P.2	Failure to Correctly Translate Design Requirements into Installed Plant Configuration
05000298/FIN-2011005-05	2011Q4	P.1	Failure to Identify Deficient Performance During a Single-Facility Drill
05000298/FIN-2011005-03	2011Q4	H.12	Failure to Follow Procedures for Dose Rate Alarms Received by Two Individuals
05000298/FIN-2011005-02	2011Q4	H.2	Failure to Maintain Control and Continuous Coverage of a Posted Locked High Radiation Area
05000298/FIN-2011005-01	2011Q4	H.2	Failure to Conspicuously Post a High Radiation Area
05000298/FIN-2011005-04	2011Q4		Failure to Provide Complete and Accurate Solid Radwaste Shipment Information in Annual Reports
05000298/FIN-2012002-01	2012Q1	P.2	Failure to Maintain Design Control for Internal Flooding
05000298/FIN-2012002-02	2012Q1	P.2	Failure to Scope Required Components in the Stations Maintenance Rule Monitoring Program
05000298/FIN-2012002-03	2012Q1	H.12	Failure to Appropriately Manage Risk for Maintenance in the Stations Switchyard
05000298/FIN-2012002-04	2012Q1		Failure to Maintain Design Control of Standby Liquid Control System
05000298/FIN-2012002-05	2012Q1	H.7	Unevaluated Pre-conditioning for Core Spray Motor-operated Valves prior to Conducting As Found In-service Surveillance Testing
05000298/FIN-2012002-06	2012Q1	H.14	Failure to Follow Radiation Work Permit Requirements
05000298/FIN-2012002-07	2012Q1		Failure to Furnish Evidence of an Activity Affecting Quality
05000298/FIN-2012002-08	2012Q1	H.2	Failure to Follow Station Procedure Results in Inadequate Work Instructions

Self-Identified List (Cooper)

	Q	Title
05000298/FIN-2011005-08	2011Q4	Licensee-Identified Violation
05000298/FIN-2011005-09	2011Q4	Licensee-Identified Violation

[Cooper Findings full list]

05000298/FIN-2012002-06

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