05000440/FIN-2011013-02
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Finding | |
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| Title | The Licensee Failed to Appropriately Identify and Assess the Radiological Hazards when retracting a Source Range Monitor |
| Description | The NRC identified a finding and three apparent violations of NRC requirements associated with the removal of a source range monitor from the reactor vessel. Specifically, the inspectors identified an apparent violation of Title 10 of the Code of Federal Regulations (CFR) part 20.1501 Surveys and Monitoring, because licensee failed to appropriately evaluate and assess the radiological hazards associated with retracting a source range monitor from the reactor vessel. The inspectors also identified examples of apparent violations of Technical Specifications requirements 5.4. Procedures and 5.7. High Radiation Area associated with this finding. Following this event, the licensee instituted several corrective actions including procuring a new shielded retrieval and transport cask, retracting the source range monitor (SRM) detector and cable into the cask from the carousel instead of the sub-pile room floor, and implementing changes to plant procedures and the plant planning process to more effectively control this work. Additionally, a root cause evaluation was initiated under condition report (CR) 11-932471. The inspectors reviewed the guidance in NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, and did not identify any examples similar to the performance deficiency. However, in accordance with IMC 0612, the inspectors determined that the performance deficiency was more than minor because it could be viewed as a precursor to a significant event. Therefore, the performance deficiency was a finding. The finding did not involve as low as reasonably achievable (ALARA) planning or work controls and there was no overexposure. However, the inspectors determined that a substantial potential for an overexposure did exist, in that, it was fortuitous that the resulting exposure did not exceed the limits of 10 CFR Part 20. The event did not occur in a very high radiation area, nor was the licensees ability to access dose compromised. Consequently, the inspectors concluded that the finding was preliminarily determined to be of White safety significance. The finding had a cross-cutting aspect in the area of human performance related to the cross-cutting component of decision making, in that, the licensee did not use conservative assumptions when developing the work package and authorizing the work for the removal of SRM-C. |
| Site: | Perry  |
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| Report | IR 05000440/2011013 Section 4OA5 |
| Date counted | Jun 30, 2011 (2011Q2) |
| Type: | Violation: White |
| cornerstone | Or Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | B Dickson J Cassidy M Mitchell M Phalen P Lee S Reynolds V Myersr Zimmermans Orth K O'Brien M Satoriusa Garmoeg Hansen J Furia J Jandovitz M Kunowski M Phalen P Cardona Morales R Lerch R Ruiz |
| Violation of: | 10 CFR 20, Standards for Protection Against Radiation Technical Specification |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Perry - IR 05000440/2011013 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2011Q2
Self-Identified List (Perry)
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