05000333/FIN-2011005-03
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Finding | |
|---|---|
| Title | Failure to Follow Radiation Protection Procedures |
| Description | The inspectors identified a self-revealing NCV of TS 5.4, Procedures, which requires that written procedures be implemented covering the activities in the applicable procedures recommended by Regulatory Guide 1.33, including procedures for RWPs and ALARA reviews. Specifically, as of December 12, 2011, post job reviews for most of the 2010 R-19 RWPs (52 of 55) had not been completed as required by procedure EN-RP-105, Radiological Work Permits, Revision 10. This procedure requires post job reviews to be completed within 90 days from the end of the outage. The performance deficiency could lead to repeating errors and not planning the upcoming R-20 with needed improvements. Since planning for the R-20 outage had already begun, the inspectors concluded that lessons learned in the R-19 outage RWPs may not be incorporated into the R-20 RWPs and additional, avoidable exposure could be received. Entergy staff subsequently developed a tracking schedule to complete the reviews and entered the issue into the CAP as CR-JAF- 2011-04152. The finding was more than minor because it was associated with the Radiation Safety - Occupational Radiation Safety cornerstone attribute of program and process, and affected the cornerstone objective of protecting worker health and safety from exposure to radiation. Specifically, Entergy staff did not complete RWP close out documentation to identify lessons learned and actions to reduce worker exposure in subsequent refueling outages. The inspectors evaluated the finding using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, and determined that the finding was of very low safety significance (Green) because it did not involve: (1) ALARA planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. The finding had a cross-cutting aspect in the area of Human Performance, work practices, because Entergy personnel did not effectively communicate expectations regarding procedural compliance |
| Site: | FitzPatrick  |
|---|---|
| Report | IR 05000333/2011005 Section 2RS2 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71124.02 |
| Inspectors (proximate) | M Gray S Mccarver E Knutson B Bickett B Sienel R Rolph |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - FitzPatrick - IR 05000333/2011005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2011Q4
Self-Identified List (FitzPatrick)
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