TS 5.4.1 requires, that Written procedures shall be established, implemented, and maintained covering the following activities: a. The applicable procedures recommended in
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide (RG) 1.33, Appendix A, identifies Access control to radiation areas, including a Radiation Work Permit (
RWP) system as one of the areas requiring procedural controls. Additionally, procedure VPAP-2101, Radiation Protection Program, Revision 35, Attachment 1,
RCA Work Practices, identifies what workers should know prior to entering the
RCA (minimum requirements). Attachment 1 states, in part, All workers entering the
RCA are required to: 1) Notify
RP prior to entering the
RCA. Contrary to the above requirements, on September 15, 2017, two maintenance workers entered U2 Containment, a posted
High Radiation Area (
HRA), while signed in on an incorrect
RWP, and without checking in at the Health Physics Shift Supervisor window prior to entering containment. The workers signed in on the
RWP they had used earlier in the day which did not allow entry into a
HRA. The containment building had been posted as a
HRA in preparation for lifting the reactor head while the workers were out of containment.
HP personnel in the remote monitoring facility identified that the individuals were on an incorrect
RWP, informed
HP personnel in containment, and the workers exited containment prior to the head lift. This finding was of very low safety significance (Green) because there was no
substantial potential for overexposure and the licensees ability to assess dose was not compromised. The immediate corrective actions were documented in CR 1078223. Corrective actions included a human performance review, coaching of the individuals by
RP Management, and distribution of a site-wide message discussing the incident and reminding site personnel to remain aware of radiological safety.
