Technical Specification 5.4.1.a required, in part, that written procedures shall be established, implemented, and maintained covering activities recommended in
Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978.
RG 1.33, Revision 2, Appendix A, Section 7 listed Radiation Surveys as an activity that should be covered by written procedures. Duke Health Physics procedure HP/2/B/1006/024, Revision 11, Refueling Outage Controls and Surveillance, Enclosure 5.3, required a daily dose rate survey of the 1202 Area located in the auxiliary building. Contrary to the above, on October 7, 2006, written procedures recommended in
RG 1.33, Revision 2, Appendix A, were not implemented in that a daily dose rate survey of the 1202 Area was not performed as required by Duke Procedure HP/2/B/1006/024, Enclosure 5.3. A Lead Radiation Protection Technician became aware of the missed radiation survey, falsified the contents of a different radiation survey, and submitted the falsified document on October 10, 2006. The underlying technical issue screened as a minor violation using
IMC 0612, Appendix B, Issue Screening, in that the proper radiological controls were established and radiological conditions existed such that the dose to an uninformed worker was not likely to exceed an unplanned dose greater than 10 millirem. The violation did not rise to the level of the SL-IV Health Physics examples from Section 6.7 of the
NRC Enforcement Policy. However, the NRC determined that the violation should be classified as a SL-IV violation because of the willful aspects involved. This violation is being treated as a
NCV in accordance with Section 2.3.2 of the
NRC Enforcement Policy because the licensee identified and reported the violation to the NRC, was an isolated act of an individual in a low-level position without management involvement, and the licensee took significant remedial action. This condition was documented in the licensees
CAP as
PIP M-08-2975.
