05000324/FIN-2011002-02
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Finding | |
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Title | Failure to follow procedures for analyzing radiological air samples for the presence of alpha emitters |
Description | The inspectors identified a non-cited violation (NCV) of Technical Specification (TS) 5.4.1, Procedures, for the failure of the licensee to perform initial alpha activity analysis of air samples indicating greater than 0.3 Derived Air Concentration (DAC) beta-gamma activity on an approved alpha counter. Section 9.5.12.h of procedure HPS-NGGC-0024, Alpha Monitoring Guidelines, Rev. 3, states that if gamma scan results indicate the airborne activity is equal to or greater than the beta-gamma DAC-Fraction Action level of 0.3 DAC; (1) perform an initial alpha count on the air sample using a counter approved for air samples; and (2) assess and document the results per site-specific procedures. Contrary to this requirement, on March 10, 11, and 21, 2011, the licensee did not perform an initial alpha count on air samples using a counter approved for air samples and assess and document the results for gamma scan results that exceeded 0.3 DAC. Specifically, air samples for those selected work activities identified DAC concentrations of 0.6589, 0.3152 and 1.45. Licensee corrective actions included instructions to workers to ensure procedural adherence for sample analysis and changes to the software program to prompt the workers to do the sample analysis when the threshold limits were met or exceeded. The licensee entered the issue into its corrective action program as NCR 455307. This finding is greater than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of Program and Process (Monitoring and Radiation Protection Controls) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from airborne radioactive material during routine civilian nuclear reactor operation. Failure to identify potentially significant contributors to internal dose could lead to unmonitored occupational exposures. The finding was evaluated using IMC 0609, Appendix C, Occupational Radiation SDP and was determined to be of very low safety significance (Green) because it was not related to As Low As Reasonably Achievable (ALARA) Planning and the ability to assess dose was not compromised during these instances. In addition, it did not involve overexposure or substantial potential for overexposure because of the relatively low alpha source term in the areas where the surveys were performed. This conclusion was drawn from the results of beta/gamma and alpha smear surveys performed at those selected work locations. However, if left uncorrected, unmonitored internal exposure could have occurred. The cause of this finding was directly related to the cross-cutting aspect of maintaining effective interfaces between work groups in the Work Control component of the Human Performance area. |
Site: | Brunswick |
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Report | IR 05000324/2011002 Section 2RS1 |
Date counted | Mar 31, 2011 (2011Q1) |
Type: | NCV: Green |
cornerstone | Or Safety |
Identified by: | NRC identified |
Inspection Procedure: | IP 71124.01 |
Inspectors (proximate) | G Kuzo P O'Bryan R Musser R Williams W Loo W Pursley A Alen A Nielsen D Jones G Kolcum |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Brunswick - IR 05000324/2011002 | ||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Brunswick) @ 2011Q1
Self-Identified List (Brunswick)
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