Technical Specification 5.7,
High Radiation Area, required areas with radiation levels greater than 1,000 millirem (mrem) per hour at 30 centimeters (cm) from the radiation source or from any surface which the radiation penetrates to be provided with locked or continuously guarded doors to prevent unauthorized entry. Contrary to the above, on September 23, 2011, an area with radiation levels greater than 1,000 mrem per hour at 30 cm from the radiation source or from any surface which the radiation penetrates was not locked or continuously guarded to prevent unauthorized entry. The locking method for a
LHRA door leading to the reactor head stand did not prevent unauthorized entry. The padlock used to secure retaining bolts on the doors was supposed to be installed through openings in the bolts preventing them from being removed. Instead, the padlock was installed around the bolts allowing them to be removed. Corrective actions included identifying other
HRA,
LHRA, and
VHRA barriers with the unique locking mechanism, photographing the proper locking method, providing proper instructions to individuals during key issuance, and clarifying procedural guidance on the proper use of the locking mechanism. The corrective actions were documented under
PIP M-11-07009. The violation was evaluated using the
Occupational Radiation Safety Significance Determination Process and was determined to be not more than very low safety significance (Green) because this finding did not have a substantial potential for over-exposure because of additional controls and warnings present such as personal
ED alarming devices and
LHRA posting.
