The inspectors identified a
NCV of
10 CFR 50.9(a), Completeness and Accuracy of Information, that occurred when the licensee failed to report an
Occupational Radiation Safety Performance Indicator (
PI) occurrence to reflect an individual entering on April 22, 2011, a
locked high radiation area in the drywell under vessel area without the appropriate radiological controls in place. The issue was entered into the licensees
CAP as CR 11-00473. Corrective actions included the licensee submitting corrected
occupational radiation safety PI data to the NRC. Violations of
10 CFR 50.9 that potentially impede or impact the regulatory process are dispositioned using traditional enforcement. The inspectors concluded that the licensee. The inspectors identified a finding of very low safety significance and an associated
NCV of
10 CFR 20.1201(c) for the failure to accurately assess occupational dose specific to effective dose equivalent (EDE) determinations. The issue has been entered into the licensees
CAP as CR 11-02336. Corrective actions included a review of applicable guidance and revisions to applicable procedures. The inspectors reviewed a self-revealed finding of very low safety significance and an associated
NCV of
Technical Specification 5.7.1 for the failure of workers to comply with established radiological protective measures as specified for entry into and work within
high radiation areas. The issue has been entered into the licensees corrective action program as condition reports (CR) 11-93976 and CR 11-94374. Corrective actions were implemented to address personal accountability and evaluate the need for procedure improvements. The inspectors reviewed the guidance in
IMC 0612 Appendix E, Examples of Minor Issues, and determined that the issue was more than minor because the performance deficiency was similar to Example 6(h) in the guidance document. Using
IMC 0609 Attachment C for the
Occupational Radiation Safety SDP, the inspectors determined that the finding was of very low safety significance because the finding did not involve: (1) As-Low-As-Is-Reasonably-Achievable (
ALARA) planning and controls; (2) a radiological
overexposure; (3) a
substantial potential for an overexposure; and there was no compromised ability to assess dose. The primary cause of this finding was related to the cross-cutting aspect of problem identification and resolution in the component of the corrective action program in that the licensee failed to take the appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance and complexity. Specifically, the licensee had previously identified issues with the effectiveness of radiological briefs for access to
high radiation areas on four recent occasions.
