Technical Specification 6.12.1 requires an area with dose rates greater than 100 millirem per hour (mrem/hr) at 30 centimeters (cm) to be barricaded and conspicuously posted as an
HRA. Contrary to this, on January 31, 2015, the licensee identified dose rates in excess of 100 mrem/hr at 30 cm on a five gallon bucket containing drain hoses in a Radiation Area within the U2 Pipe Tunnel, which was not barricaded or posted as a
High Radiation Area (
HRA). A survey of the bucket identified dose rates of up to 120 mrem/hr at 30 cm. Immediate corrective actions included relocating the bucket to a locked location in a designated
HRA. This condition was documented in
AR 02022248. This violation was evaluated using the guidance in
IMC 0609, Appendix C,
Occupational Radiation Safety Significance Determination Process, and was determined to be of very low safety significance (Green) because there was no
substantial potential for overexposure and the licensees ability to assess dose was not compromised. Because this violation was of very low safety significance and was entered
CAP, this violation is being treated as a
NCV, consistent with Section 2.3.2 of the
NRC Enforcement Policy.