A self-revealing Green
NCV of
Technical Specification (TS) 6.8.1;
Regulatory Guide 1.33, Appendix A; Radiation Work Permits (
RWP); and as low as reasonably achievable (
ALARA) procedures was identified for Dominions failure to utilize respiratory protection, as required by the applicable
RWP and associated
ALARA evaluation for work on replacement of valve 2-SI-227 on April 20, 2014. This failure resulted in an
unplanned intake of radioactive material for one worker. Dominion subsequently enforced the respiratory protection requirements to complete the work and entered this issue into their corrective action program (
CAP) as condition report (CR) 546439. Failure to use respiratory protection during machining work as required by Dominion procedure was a performance deficiency that was reasonably within Dominions ability to foresee and correct. The inspectors determined that the performance deficiency was more than minor because it affected the Radiation Safety
Occupational Radiation Safety Cornerstone attribute of Program and Process associated with exposure/contamination controls, because it resulted in the unintended internal exposure of a worker. A crosscutting aspect of Human Performance, Conservative Bias, was associated with the finding. Specifically, radiation protection staff did not adhere to the
RWP requirements.
