05000445/FIN-2015001-05
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Finding | |
|---|---|
| Title | Failure to Provide an Accurate Shipping Manifest |
| Description | The inspectors identified a non-cited violation of 10 CFR 71.5, pursuant to 49 CFR 172.203(d)(3), and 10 CFR 20.2006(b) for the licensees failure to ship radioactive waste with accurate manifests. Specifically, two radioactive waste shipments departed the site with inaccurate activity information on the manifest shipping papers. After determining that the shipment manifests and the amount of radwaste in the containers were incorrect, the licensee faxed corrected copies of the shipment manifests to the processor, suspended resin shipments, and conducted an apparent cause evaluation. The licensee entered the finding into the corrective action program as Condition Report CR-2015-000124. The failure to ship radioactive material with an accurate shipping manifest in accordance with 49 CFR 172.203(d) and 10 CFR 20.2006 was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (transportation program) attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective. Specifically, incorrect information on shipment documentation could result in incorrect Department of Transportation shipping characterizations or incorrect waste classifications in accordance with 10 CFR 61. Using Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, dated February 12, 2008, the finding was determined to be of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of a package during transit, (3) it did not involve a certificate of compliance issue, (4) it was not a low level burial ground nonconformance, and (5) it did not involve a failure to make notifications or provide emergency information. The finding has a human performance cross-cutting aspect associated with avoid complacency because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the licensees procedure for conducting waste and material characterization did not include precautions related to not accounting for the decay of short lived isotopes or guidance on when it was appropriate to override a default software option to omit decay correction for material sample results [H.12]. |
| Site: | Comanche Peak  |
|---|---|
| Report | IR 05000445/2015001 Section 4OA2 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Pr Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Josey J Kramer J O'Donnell L Carson R Kumana W Walker |
| Violation of: | 10 CFR 71.5 49 CFR |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - Comanche Peak - IR 05000445/2015001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2015Q1
Self-Identified List (Comanche Peak)
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