The inspectors identified a self-revealing
NCV of
Technical Specification 5.4.1, Procedures, for
FENOCs failure to utilize respiratory protection, as required by the applicable radiation work permit (
RWP), for entry into the 722-foot elevation of the solid radioactive waste building on March 12, 2014. This resulted in the
unplanned internal exposure of one worker. Immediate corrective actions included reestablishing
RWP controls of the area and entering this issue into their corrective action program as condition report 2015-06636. The inspectors determined that the performance deficiency is more than minor because it affected the Program and Process attribute of the
Occupational Radiation Safety cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The inspectors evaluated the finding using NRC
Inspection Manual Chapter 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process, and determined the finding to be of very low safety significance (Green) because it was not related to as low as (is) reasonably achievable (
ALARA), did not result in an
overexposure or a
substantial potential for overexposure, and did not compromise the licensee's ability to assess dose. The finding has a cross-cutting aspect of Human Performance, Conservative Bias, in that individuals did not use decision making-practices that emphasized prudent choices over those that are simply allowable. Specifically, a radiation protection technician did not use conservative decision making practices and make prudent choices when entering an area with unknown radiological conditions. Examples of non-conservative decision making included: failure to wear respiratory protection when entering into unknown radiological conditions, the failure to complete and evaluate an air sample prior to entry, and not taking into account the adverse radiological conditions of the adjoining area above (735 foot elevation). [H.14]
