On January 25, 2004, a contract foreman and three contract workers were assigned to conduct outage work associated with a valve located in the reactor building. In preparation for the work, the foreman signed in on a radiation work permit (
RWP) associated with entry into
HRAs located in the turbine and auxiliary buildings but not for entry into the Unit 1 reactor building raceway described below. The three contract workers signed in on a pre-outage
RWP associated with minor maintenance activities which did not permit entry into
HRAs. During a walk down of the work, the contract workers could not locate the valve, and the foreman took the contract workers into a posted
HRA in the Unit 1 reactor building raceway to locate the valve. Prior to entering the
HRA, at least one of the contract workers told the foreman that the contract workers were not signed in on an
RWP that permitted entry into
HRAs. Before entering the
HRA, two of the contract workers were aware that they had not received a briefing by radiation protection personnel for the
HRA, a prerequisite for entry into
HRAs. Therefore, the actions of the foreman and two contractor workers are considered a willful violation, representing careless disregard of requirements, and the violation has been categorized in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (
Enforcement Policy),
NUREG-1600 at
Severity Level III.
