Licensee Audit
LO-WLO-2016-00037, Bioassay Program, dated November 21, 2016, identified that during Refueling Outage 20, staff reviewing air sample and lapel air sampler results had not been identifying positive results. The audit revealed that two positive lapel air samples from Refueling Outage 20 had not been identified nor had estimated personnel exposures been calculated. In addition, the audit identified seven positive air sample results which had no documented estimated exposures. As a result, dose was not assigned to individuals exposed to airborne radioactivity. As a result of the audit findings, the licensee retroactively assigned dose to three individuals working the October 25, 2015, cavity drain job in the amount of 36 mrem committed effective dose equivalent (
CEDE) and 700 mrem committed dose equivalent (
CDE) to bone surfaces and to one individual working on a November 8, 2015, decontamination job in theamount of 33 mrem
CEDE and 661 mrem
CDE to bone surfaces.Title
10 CFR 20.1703 states, in part, the licensee shall implement and maintain a respiratory protection program that includes: (1) air sampling sufficient to identify the potential hazard and estimate doses, and (2) surveys and bioassays, as necessary, to evaluate actual intakes.Contrary to the above, on November 21, 2016, the licensee failed to implement and maintain their respiratory protection program to include air sampling sufficient to identify the potential hazard and estimate doses, and surveys and bioassays, as necessary to evaluate actual intakes. Specifically, for two jobs and four individuals, the licensee failed to identify positive air sample results and assign internal dose to the subject individuals.In accordance with
Inspection Manual Chapter 0612, Appendix B, Issue Screening, the inspectors determined that the performance deficiency was more than minor. The finding adversely affected the
Occupational Radiation Safety Cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation, in that, the failure to adequately assess internal exposure affects the licensees ability to control and limit radiation exposure to the worker. Using
Inspection Manual Chapter 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process, the inspectors determined that the finding was of very low safety significance (Green) because it did not involve: (1) as low as reasonably achievable (
ALARA) planning and controls; (2) a radiological
overexposure; (3) a substantial potential for an exposure; or (4) a compromised ability to assess the dose.The licensees immediate corrective action was to coach all technicians on surveying airborne areas, ensure all air sample and lapel results were discussed with management, and count all air and lapel samples for alpha and beta to evaluate any potential internal radiation exposure. The licensee entered this issue into their corrective action program as Condition Report
CR-WF3-2016-07300.
