05000461/FIN-2015002-03
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Finding | |
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| Title | Contract Workers not Monitored for Occupational Radiation Exposure |
| Description | The inspectors identified a finding of very-low safety significance and an associated NCV of Technical Specification (TS) 5.4.1, Procedures, for the failure to monitor the radiation dose received by a group of workers as required by Procedure RPAA210, Dosimetry Issue, Usage, and Control. Specifically, contractor employees who did not wear individual dosimetry were not monitored by the usage of an Area Badging Program and the workers were not excluded from wearing individual dosimetry by the usage of medical isotopes or external radioactivity being detected or a previously performed evaluation by Radiation Protection (RP) Supervision. The licensee documented the issue in the licensees CAP as AR 02452005. The trailer used by the contractors was relocated to a distance further away from the radioactive material storage area. This reduced the radiation dose rate in the trailer. The inspectors determined that the issue of concern was a performance deficiency because the licensee did not monitor a group of workers using one or more methods as required by Procedure RPAA210, Dosimetry Issue, Usage, and Control. The licensee neither assigned radiation dosimetry to each worker, nor was an Area Badging Program in place. The inspectors determined that the cause of the performance deficiency was reasonably within the licensees ability to foresee and correct and should have been prevented. The issue was not subject to traditional enforcement since the concern did not have a significant safety consequence, did not impact the NRCs ability to perform its regulatory function, and was not willful. The performance deficiency was determined to be of more than minor safety significance in accordance with IMC 0612, Appendix B, Issue Screening, issued September 7, 2012, because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Specifically, the licensee could not demonstrate compliance with other sections of 10 CFR Part 20, such as occupational dose limits and records and reporting of individual monitoring results. The inspectors also reviewed the guidance in IMC 0612, Appendix E, Examples of Minor Issues, and did not find any similar examples. In accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, issued August 19, 2008, the inspectors determined that the finding had very low safety significance (Green) because the finding: (1) did not involve as-low-as-is-reasonably-achievable planning and controls; (2) did not involve a radiological overexposure; (3) there was not a substantial potential for an overexposure; and (4) there was no compromised ability to assess dose. This finding has a cross-cutting aspect in the area of Human Performance, Change Management, because the primary cause of the finding was due to inadequate change management. Specifically, licensee supervision incorrectly located the trailer near a posted radiation area without performing an appropriate evaluation to ensure the personnel or area was correctly monitored. [H.3] |
| Site: | Clinton  |
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| Report | IR 05000461/2015002 Section 2RS4 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.04 |
| Inspectors (proximate) | S Bell S Mischke W Schaup A Dahbur C Phillips E Sanchez-Santiago J Bozga K Stoedter |
| Violation of: | Technical Specification - Procedures Technical Specification 10 CFR 20, Standards for Protection Against Radiation |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Clinton - IR 05000461/2015002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2015Q2
Self-Identified List (Clinton)
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