A self-revealing
NCV of
Technical Specification (TS) 5.7.1,
High Radiation Area (
HRA), was identified for the failure to barricade and conspicuously post
HRAs inside Unit 2 lower containment. The inspectors determined that the failure to adequately control
HRAs was a
PD. The
PD was more than minor because it was associated with the cornerstone attribute of Program & Process (
RP controls) and negatively affected the cornerstone objective in that
HRAs must be posted and properly controlled to avoid unnecessary worker exposure. The finding was was determined to be of very low safety significance (Green) because it was not related to As Low As Reasonably Achievable (
ALARA) planning and the ability to assess dose was not compromised. The cause of this finding was directly related to the cross-cutting aspect of appropriately planning work activities in the Work Control component of the Human Performance area because the potential job site conditions (radiological hazards) associated with down-posting large areas of lower containment were not adequately identified.
