05000416/FIN-2016004-02
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Finding | |
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| Title | Failure to Use Procedures and Engineering Controls to Maintain Occupational Doses ALARA |
| Description | Green. The inspectors identified a non-cited violation of 10 CFR 20.1101(b) for the licensees failure to implement radiation exposure reduction procedures and engineering controls to minimize unplanned and unintended radiation dose to workers and to maintain occupational doses as low as is reasonably achievable (ALARA). Several radiological work permits exceeded initial dose estimates with minimal or no actions taken to evaluate the basis for the dose overrides and to develop mitigating strategies. The primary contributor to the unplanned exposures was elevated dose rates from increased cobalt-60 activity associated with a failure to properly plan and execute spent fuel pool and reactor cavity cleanup operations. In addition, the licensee failed to observe radiological work permit hold points, to initiate ALARA Management Committee meetings, and to perform radiological assessments of radiological work permit dose estimates as procedurally required. As immediate corrective actions, the licensee reviewed the work activity, documented lessons learned, and generated Condition Reports CR-GGN-2016-03151 and CR-GGN-2016-08543 to address these programmatic weaknesses for future outages. The failure to implement procedures and engineering controls to minimize unplanned and unintended radiation dose and to maintain occupational doses as low as is reasonably achievable was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (ALARA planning) and adversely affected the cornerstone objective to ensure the adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, inadequate ALARA planning and radiological controls resulted in unplanned, unintended dose for a number of work activities in which the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined this finding to be of very low safety significance (Green) because the finding involved ALARA planning and controls, and because the licensees latest 3-year rolling average did not exceed 240 person-rem per unit for boiling water reactors. The finding had a cross-cutting aspect in the area of problem identification and resolution, associated with operating experience, in that, the licensees organization failed to systematically and effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner. Specifically, the licensee failed to implement and incorporate relevant internal operating experience from Refueling Outage 18, which was of similar radiological circumstances, to mitigate the effects of cobalt-60 activity in the reactor cavity and unplanned spent fuel pool cleanup outages [P.5]. |
| Site: | Grand Gulf  |
|---|---|
| Report | IR 05000416/2016004 Section 2RS2 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Or Safety |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.02 |
| Inspectors (proximate) | C Young G Warnick J Drake L Carson M Hayes M Young N Day N Greene P Elkmann W Sifre |
| CCA | P.5, Operating Experience |
| INPO aspect | CL.1 |
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Finding - Grand Gulf - IR 05000416/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2016Q4
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