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A self-revealing non-cited violation of 10 … A self-revealing non-cited violation of 10 CFR 20.1701 was identified for the licensees failure to implement adequate processes or engineering controls to control the concentration of radioactive material in air and prevent internal dose to workers. Specifically, on April 14, 2015, the licensee implemented inadequate engineering and radiological controls to remove a pre-filter and Y-connector from a high efficiency particulate air (HEPA) ventilation unit resulting in an airborne radioactivity condition and two intakes. The licensee was alerted to this issue when two radiation protection technicians alarmed PM12 portal monitors upon their exit from the radiologically controlled area. The licensee took immediate corrective actions and instructed these technicians to report to dosimetry for whole body counting and evaluation. The licensee entered this issue into their corrective action program as Condition Report (CR) CR 16-01093. The failure to implement adequate engineering and radiological controls during HEPA unit maintenance in accordance with procedures and the radiological exposure permit requirements was a performance deficiency. The performance deficiency was more than minor because it was associated with the Occupational Radiation Safety attribute of Program and Process and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. This was evident by two workers receiving unplanned intakes. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, issue date 8/19/2008, the finding was determined to be of very low safety significance (Green) because it did not involve: (1) as low as reasonably achievable (ALARA) planning and controls, (2) an overexposure, (3) a substantial potential for an overexposure, or (4) an impaired ability to assess dose. The inspectors concluded that the finding has a Conservative Bias cross-cutting aspect in the Human Performance area because the licensee failed to use decision-making practices that emphasized prudent choices over those that are simply allowable when they changed out the HEPA pre-filter and Y-connector components (H.14).-filter and Y-connector components (H.14).

Discovered date

23:59:59, 31 March 2016 +

Docket

05000530 +

Equipment

Portal monitor +

Event date

23:59:59, 31 March 2016 +

Finding integer

1 +

Finding type

Non-cited violation +

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INPO aspect

DM.2 +

Identified by

Self-revealing +

Inspection Manual Chapter

NRC Inspection Manual 0609/Appendix C, Occupational Radiation Safety Significance Determination Process +

Inspection procedure

IP 71124.04 +

Inspection report

IR 05000528/2016001 +

Inspector

Louis Carson +, Natasha Greene +, Jeffrey Josey +, Dustin Reinert +, Charley Peabody + and David You +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

12:56:13, 25 September 2017 +

Person