The inspectors identified a Green non-cited violation (
NCV) of
10 CFR 20.1501(b) for the licensees failure to ensure that area radiation monitors (
ARMs) used for quantitative measurements were calibrated. The licensee failed to complete the detector sensitivity verification with an appropriate radioactive source during the previous two calibrations of the
reactor coolant (NC) filter area
ARMs. The licensee initiated Problem Investigative Process(
PIP) M-09-4036 to evaluate this issue. The finding is greater than minor because it was associated with the
Occupational Radiation Safety cornerstone attribute of Plant Facilities/Equipment and Instrumentation and adversely affected the cornerstone objective in that the failure to properly calibrate the
ARMs could compromise the evaluation of radiological hazards causing unintended dose to radiation workers. The finding was determined to be of very low safety significance (Green) because it was not related to
ALARA planning, did not involve an
overexposure or
substantial potential for overexposure, and did not compromise the ability to assess dose. The finding had a cross-cutting aspect of maintaining long term plant safety in the area of Human Performance, under the Resources component, because the licensee did not ensure procedures and other resources were available and adequate to assure nuclear safety by maintenance of design margins (i.e. appropriate calibration) and minimization of preventative maintenance deferrals (i.e. allowing for critical steps to be marked N/A, effectively deferring the calibration until the next calibration cycle)
H.2(a).
