05000382/FIN-2012005-01
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Finding | |
|---|---|
| Title | Failure to Implement Control Measures to Ensure That Activated Materials Were Not Raised Above or Brought Near the Surface of the Refueling Pool, Causing a Locked High Radiation Area |
| Description | The inspectors reviewed a self-revealing non-cited violation of Technical Specification 6.12.2 which resulted because licensee representatives failed to implement control measures to ensure that activated materials were not raised above or brought near the surface of the refueling pool. This process created a locked high radiation area. As immediate corrective action, the workers backed away from the upper guide structure until their dose rate alarms cleared. The upper guide structure lift continued until it was in a safe condition on the stand in the deep end of the refueling pool. Corrective action to prevent recurrence was determined after licensee personnel documented the occurrence in the corrective action program as Condition Report WF3-2012-05571 and performed a root cause evaluation. To address the root cause, the governing procedure will be revised to reflect the establishment of a waterline on the upper guide structure which indicates the highest elevation it can be raised out of the water and maintain an acceptable amount of shielding. The failure to implement control measures to ensure that activated materials were not raised above or brought near the surface of the refueling pool was a performance deficiency. The performance deficiency was more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation, in that it exposed workers to higher than planned dose rates. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding had very low safety significance because: (1) it was not an as low as is reasonably achievable (ALARA) finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure because the inspectors concluded there was no way to construct a scenario in which a minor alteration of circumstances would have resulted in a violation of the Part 20 limits, and (4) the ability to assess dose was not compromised. This finding reflected current licensee performance and had a cross-cutting aspect in the human performance area, work control component, in that the licensee did not plan work activities appropriately by incorporating risk insights and job site conditions, such as the effects on job site radiation levels when water shielding was reduced |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2012005 Section 2RS1 |
| Date counted | Dec 31, 2012 (2012Q4) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | D Allen W Sifre D Overland C Steely C Speer D Bradley T Skaggs-Ryan L Ricketson P Elkmann M Davis |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Waterford - IR 05000382/2012005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2012Q4
Self-Identified List (Waterford)
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