Green . A self -revealing Green non- cited violation (
NCV) of
10 CFR 20.1501(a)(2) was identified for the licensees failure to conduct an adequate area radiation survey in Room 619 of the auxiliary building (waste gas decay tank (WGDT) room). Specifically, on April 19, 2016 , a
high radiation area (
HRA) was identifi ed near WGDT A in the WGDT room when a worker entering the area received a dose rate alarm on his electronic dosimeter (
ED) and follow -up surveys revealed dose rates as high as 110 mrem/hr at 30cm. Also, as a result of the licensees failure to perform a survey, the area was not barricaded and posted in accordance with plant
Technical Specification (TS) 5.7.1, High Radiation Area. The licensee immediately barricaded and posted the area as an
HRA, performed an apparent cause evaluation to determine additional long term actions and entered the issue into their corrective action program as Nuclear Condition Report (
NCR) 02021742. The licensees failure to conduct an area radiation survey to evaluate the magnitude and extent of radiation levels near WGDT A was a performance deficiency. This finding was determined to be more than minor because it was associated with the occupational radiation safety cornerstone attribute of human performance and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, failure to identify, post and control
HRAs could allow workers to enter
HRAs without knowledge of the radiological conditions in the area and receive unintended occupational exposure. The finding was evaluated using
Inspection Manual Chapter (IMC) 0609 Appendix C,
Occupational Radiation Safety Significance Determination Process. The finding was not related to the a s low as reasonably achievable (
ALARA) planning, did not involve an
overexposure or
substantial potential for overexposure, and the ability to assess dose was not compromised. Therefore, the inspectors determined the finding to be of very low safety significance (Green). This finding involved the cross -cutting aspect of avoid complacency in the area of human performance because the possibility of significant dose rate changes in the WGDT room during startup was a latent issue for which the licensee failed to recognize and plan. (H.12)
