05000461/FIN-2017003-02
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Finding | |
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| Title | Failure to Adequately Control Access in Locked High Radiation Area |
| Description | A finding of very low safety significance and an associated NCV of TS 5.4.1 was self-revealed when individuals failed to adequately control access in locked high radiation areas (LHRAs). Specifically, the failure to meet all of the requirements of Procedure RPAA460, Attachment 5, represented a failure to comply with Radiation Work Permit CL1700518, C1R17 [Drywell] DW Bioshield Inservice Inspection Activities. This resulted in four individuals entering a LHRA that they had not been specifically authorized to enter. These individuals entered the incorrect location and were inside the area for approximately 2-3 minutes before they noticed that they were in the incorrect area. The individuals knew that they were in the incorrect location when they could not find the nozzles that they planned on inspecting. The individuals exited the area and were simultaneously told to exit the area by the radiation protection technician (RPT) providing remote coverage which demonstrated that the four workers were not in the authorized work area. Immediate corrective actions taken by the licensee included immediately suspending the work that was scheduled to take place within the bioshield associated with this job. Electronic dosimeters and dosimeters were immediately collected from the individuals that entered the area so the dose that was received could be known. The licensee also interviewed all the individuals that were involved in this bioshield entry, and the RPT that performed the brief. These interviews were conducted to understand which parts of the process associated with entry into LHRAs failed and led to this event transpiring. The licensee entered this event into their CAP as AR 04012075. As corrective actions the licensee planned to observe high radiation area and locked high radiation area briefs, for both in house and traveling RPTs. The licensee also planned to modify the bioshield as-low-as-reasonably-achievable (ALARA) plan template to label all accessible bioshield doors with elevation and azimuth.The inspectors determined that the performance deficiency was more-than-minor in accordance with IMC 0612, Appendix B, because the finding impacted 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, in that, the workers entered an area that required the radiation dosimeter to be relocated to the workers knee, and the workers were wearing them on the head for the intended work location. The finding was determined to be of very-low safety significance (Green) in accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, because: (1) it did not involve as-low-as-reasonably-achievable planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised.The inspectors determined this finding affected the cross-cutting area of human performance in the aspect of resources, where leaders ensure that personnel,
6 equipment, procedures and other resources are available and adequate to support nuclear safety. Specifically, radiation protection leadership failed to ensure that the RPT was capable of meeting the expectations for performing the LHRA briefing in accordance with station procedure RPAA460, Attachment 5. [H.1] |
| Site: | Clinton  |
|---|---|
| Report | IR 05000461/2017003 Section 2RS1 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71124.01 |
| Inspectors (proximate) | W Schaup E Sanchez-Santiago M Doyle J Wojewoda J Havertape L Rodriguez M Domke G Edwards S Mischke L Kozak |
| Violation of: | Technical Specification |
| CCA | H.1, Resources |
| INPO aspect | LA.1 |
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Finding - Clinton - IR 05000461/2017003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2017Q3
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