ML16285A130
| ML16285A130 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/02/2016 |
| From: | NRC/NRR/DIRS/IPAB |
| To: | |
| Anderson M,NRR/DIRS,301-415-8744 | |
| References | |
| Download: ML16285A130 (4) | |
Text
NRC Final Response FAQ 1204, HRA Related Occurrences (Generic)
Plant: Perry Date of Event: June 2, 2012 Submittal Date: August 16, 2012 Contact: John Pelcic Tel/email: 4402805824 jfpelcic@firstenergycorp.com NRC Contact: Mark Marshfield Tel/email: 4402805822 mark.marshfield@nrc.gov Performance Indicator: OR01 Occupational Exposure Control Effectiveness SiteSpecific FAQ (Appendix D)? No FAQ requested to become effective when approved. Approval date is May 8th, 2013.
Question Section NEI 9902 Guidance needing interpretation (include page and line citation):
Page 62, Lines 16 22, and associated footnote Technical Specification High Radiation Area (>1 rem per hour) Occurrence -
A nonconformance (or concurrent nonconformances) with technical specifications or comparable requirements in 10 CFR 20 applicable to technical specification high radiation areas (>1 rem per hour) that results in the loss of radiological control over access or work activities within the respective high radiation area (>1 rem per hour). For high radiation areas (>1 rem per hour), this PI does not include nonconformance with licenseeinitiated controls that are beyond what is required by technical specifications and the comparable provisions in 10 CFR Part 20.
A footnote states that Concurrent means that the nonconformances occur as a result of the same cause and in a common timeframe.
Event or circumstances requiring guidance interpretation:
On June 2, 2012, an equipment failure resulted in resin/water slurry flow into the general area hallway of the Radwaste Building El. 574. Indications of changing radiological conditions were available. However, the Radiation Protection staff did not recognize the need to conduct a new radiological survey of the area, which was posted and controlled as a High Radiation Area (HRA) at the time. The failure to perform a timely radiological survey is a performance deficiency and an NRC Performance Indicator occurrence.
Over the next few days, there were two instances of individuals entering this area without Radiation Protection coverage and one instance where an individual was provided a HRA key but did not enter the area.
On June 7, 2012, a Radiation Protection technician performed a radiological survey of the area in preparation for decontamination activities. The survey identified a floor area where dose rates met the Technical Specification criteria for classification as a Locked High Radiation Area (LHRA).
After the survey, the Radwaste Building El. 574 area was posted and controlled as a LHRA.
This PI counts nonconformances, or concurrent nonconformances, with technical specifications. Concurrent nonconformances are defined as those that occur as a result of the same cause and in a common timeframe. In this case, the three instances were as a result Page 1 of 4 Revised 05/13/2013
NRC Final Response FAQ 1204, HRA Related Occurrences (Generic) of the same cause - the failure of Radiation Protection personnel to recognize the need to perform a new radiological survey. Common timeframe is not defined; however FENOC believes that these three instances meet the intent of a common timeframe. The instances were a result of a single performance deficiency with the same common cause.
The failure to recognize the need to perform a new radiological survey prior to June 7, 2012, was reported as a PI occurrence. Additionally, the three instances of individuals entering the area, or having access without Radiation Protection coverage as a result of the single performance deficiency of not performing the timely survey were conservatively reported pending the outcome of this FAQ.
Since the PI counts nonconformances that result in the loss of radiological control over access or work activities and the nonconformance that led to the three entries was the failure of Radiation Protection to recognize the need to perform a new radiological survey, are the two subsequent entries and one potential entry considered to be concurrent nonconformances bounded by the failure to recognize the need to perform the new radiological survey?
What is the NRC resident inspectors position?
The NRC resident inspector agreed with the facts and recommended that the FAQ process be followed for resolution.
Potentially relevant existing FAQ numbers FAQ 203 addresses the footnote in question. However, in FAQ 203, the causes of the two entries were different; therefore, both occurrences counted. FAQ 203 did not address common timeframe.
Response Section Proposed Resolution of FAQ The failure to recognize the need to perform a new radiological survey represents a loss of control over access into a LHRA. However, since the subsequent three instances without Radiation Protection control were a result of the failure to perform the new radiological survey, and were within a limited common timeframe, they can be considered to be concurrent non conformances. Only one Technical Specification High Radiation Area PI occurrence should be reported.
If appropriate, provide proposed rewording of guidance for inclusion in next revision.
In the footnote defining concurrent, common timeframe should be defined to be within the normal period of time between surveys for the specific area.
NRC Response The proposed FAQ correctly quotes the applicable guidance in NEI 9902 for this event. The performance indicator identifies an occurrence of nonconformance (or concurrent nonconformances) with technical specifications involving a loss of radiological controls over entries to (or work within) a Technical Specification High Radiation Area (TSLHRA, > 1 rem per hour). The FAQ discussion notes that there were three subsequent instances where entries were made without Radiation Protection controls.
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NRC Final Response FAQ 1204, HRA Related Occurrences (Generic)
A common timeframe as used in the Occupational Radiation Safety guidance in NEI 9902, is not a fixed period of time. It is the elapsed time in which a number of events or occurrences that are associated with each other happen. The events described in this FAQ are all within a common timeframe.
However, the issue demonstrated by this example is not whether the subsequent nonconformances resulting from an ongoing failure to properly control a TSLHRA are within the same (or common) timeframe. The pertinent issue in this example is whether all of the subsequent nonconformances resulted from the same cause.
In those cases where a licensee, for whatever reason (e.g., failure to survey, failure to lock the area, etc.), fails to provide adequate physical controls around a TSLHRA for an extended time, all of the subsequent nonconformances would be concurrent nonconformances as defined in NEI 9902 if they were the result of the same cause. For example, an operational occurrence that created an unrecognized TSLHRA, the subsequent failure to post the area, failure to prevent unauthorized access (possible several entries), entry not controlled per an RWP, etc., are all concurrent nonconformances if they are directly attributable to the original failure to survey. However, if during the time that this TSLHRA is unidentified (or uncontrolled) there is a subsequent failure by the RP Program to take timely action that reasonably would have ended the TSHRA nonconformance (e.g., a failure to perform a routine or directed surveillance that would have identified the nonconformance, or a failure to respond to new information that indicates the potential for the unidentified or uncontrolled TSLHRA), then the subsequent nonconformances are considered a separate PI occurrence based on the failure to reasonably act and correct the condition. In such a case the nonconformances that occurred before the subsequent failure would be concurrent nonconformances (i.e., one PI occurrence) with the initial TS violation. The nonconformances following the failure to act on the new information would be concurrent with this failure to act (i.e., a separate PI occurrence). Once this new information is obtained, subsequent sharing of this new information with other staff, or validation of this new information would be concurrent with the separate PI occurrence. The NRC response to FAQ 203 is a specific example of this general staff position.
The specific example of the resin spill event at Perry referenced in this FAQ was inspected under the NRC Baseline Inspection Program. A complete description of the event is provided in PERRY INSPECTION REPORT 05000440/2012005 AND 07200069/2012002 (ML13038A702). The spill event started on the morning of June 3, 2012, when the Radwaste (RW) Operator notified the Radiation Protection (RP) staff of a potential resin spill. The inspectors identified one selfrevealing green finding with three examples of the licensees failure to perform timely radiological surveys and evaluate the potential radiological hazards. These three failures to survey were related to the following; Failure to adequately respond to the initial notification of a possible resin spill in the Radwaste (RW) building, 574' level: At approximately 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> June 3, the RW operations supervisor observed a larger than expected level decrease in Condensate Backwash Settling Tank (CBST) tank inventory. The RW operations supervisor called the RP control point and informed the RP technicians that he believed there was a failed seal on the CBST transfer pump which could indicate a spill of contaminated resin. RP did not follow up to survey the area.
Failure to take timely action once it was recognized (or should have been recognized) that the radiological conditions in RW 574' were potentially much worse than initially assumed: At approximately 1442 hours0.0167 days <br />0.401 hours <br />0.00238 weeks <br />5.48681e-4 months <br /> June 3, an RP technician, covering another job on the RW 574 looked down the eastwest corridor hallway and observed resin outside the CBST room. Due to an incomplete shift turnover, the dayshift RP technicians, and RP supervisors, were unaware of the Page 3 of 4 Revised 05/13/2013
NRC Final Response FAQ 1204, HRA Related Occurrences (Generic) reported loss of resin inventory, and possible radiological conditions of RW 574'. After leaving the area, the RP technician reported the unexpected material condition of the corridor to the onduty RP supervisor. No subsequent surveys were performed.
Failure to take a timely survey once the decision to perform a survey was made: On Tuesday, June 5, 2012, at about 0630 hours0.00729 days <br />0.175 hours <br />0.00104 weeks <br />2.39715e-4 months <br />, in response to continued concerns expressed the RP technicians about the uncharacterized radiological conditions on RW 574', the RP manager directed that a full survey of RW 574' be performed, including air samples. However, the TSLHRA remained unidentified and inadequately controlled until Thursday, June 7, when the surveys were performed at 1514 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.76077e-4 months <br />.
Each example represents new information or identifies organizational failures to respond in a timely manner that would have ended the ongoing nonconformance to station technical specifications.
Therefore, each of these three failures to take timely action and end the nonconformance with the Technical Specifications represents a separate cause of the subsequent nonconformance and therefore represents a separate reportable PI occurrence.
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