A self-revealed finding of very low safety significance (Green) and an associated non-cited violation (
NCV) of
10 CFR 20.1501 was identified on July 14, 2014, for the failure to conduct surveys that may be necessary for the licensee to comply with the regulations in Part 20 of the Code of Federal Regulations (CFR). The inspectors determined that the licensee did not perform adequate surveys to assure compliance with
10 CFR 20.1802, which requires that the licensee control and maintain constant surveillance of licensed material that is in a controlled area or unrestricted areas and that is not in storage. Specifically, on July 14, licensee surveys of the service air compressor
lube oil coolers were not adequate to control licensed material from being unconditionally released from the site. The inspectors determined that this was a performance deficiency, the cause of which was reasonably within the licensees ability to foresee and correct, and should have been prevented. This finding was not subject to traditional enforcement since the incident did not result in a significant safety consequence, did not impact the NRCs ability to perform its regulatory function, and was not willful. This issue was entered into the licensees corrective action program as Condition Report (CR) 2014-11729. Licensee corrective actions included intrusive management actions to address individual performance weaknesses, radioactive material control practices, and sharing lessons learned with applicable station staff. The performance deficiency was determined to be more than minor because it was associated with the
Public Radiation Safety Cornerstone attribute for program and process and affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive material released into the public domain. The finding was determined to be of very low safety significance because the finding was not a transportation issue, did not involve radioactive effluents, and did not involve the Radiological Environmental Monitoring Program. This finding has a cross-cutting aspect in the area of human performance, challenge the unknown, for the radiation protection technicians failure to stop when faced with uncertain conditions and to ensure that risks are evaluated and managed before proceeding (H.11).
