The inspectors evaluated an issue concerning the licensees failure to maintain sufficient control over keys to posted
VHRAs (i.e., the C-sump) during both the last Unit 1 (U1R24) and Unit 2 (U2R24) refueling outages; the licensee is potentially in violation of
10 CFR 20.1602 requirements. The requirements contained in
10 CFR 20.1602 for control of access to
VHRAs requires, in part, that in addition to the requirements for
10 CFR 20.1601 (control of access to
high radiation areas), the licensee shall institute additional measures to ensure that an individual is not able to gain unauthorized or inadvertent access to
VHRAs. The licensees specific procedures instituted the additional controls necessary to ensure compliance with the requirements of
10 CFR 20.1602. These procedures included the requirements that the C-sump always be treated as a
VHRA and that the
VHRA keys be controlled by the shift supervisor and not be issued to anyone without the permission of the plant manager or his designee. The inspectors preliminary review of this issue determined that during the 2006 refueling outages (U1R24 and U2R24), the C-sump
VHRA keys may have been signed out by
RP supervision over multiple shifts. Subsequently,
RP supervision transferred possession of the keys to containment radiation protection technician (
RPT)
Leads, who then transferred possession of the
VHRA keys from
RPT Lead to
RPT Lead over a period of multiple shifts. The inspectors also noted that non-conservative control of
VHRA keys had been previously identified in the licensees corrective action program, after the spring 2006 (U1R24) refueling outage and prior to beginning the fall 2006 (U2R24) refueling outage (
CAP 01029886, dated May 2006). The licensee was in the process of reviewing its practices for issuance of
VHRA keys and was evaluating the specific circumstances surrounding the control of C-sump keys during the two refueling outages in 2006. As a result, the licensee planned to provide the NRC with additional information to demonstrate compliance with
10 CFR 20.1602. The NRC will review the licensees assessment when it is completed. Therefore, this issue remains under review by the NRC and is categorized as
URI 05000282/2007003-04;
05000306/2007003-04).
