The following violations of very low safety significance (Green) or
Severity Level IV were identified by the licensee and are violations of NRC requirements which meet the criteria of the
NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation.
TS 6.12.1 requires that entryways into
HRAs with dose rates not exceeding 1 rem/hour at 30cm be barricaded. Contrary to this, on May 31, 2011, and again on June 16, 2011,
HRA entryways into U2 Containment were not barricaded. In both examples, the accessible areas of U2 Containment contained dose rates >100mrem/hr at 30cm, but less than 1 rem/hr at 30cm. On May 31, without
HP present, workers in the area repositioned the
HRA swing gates to facilitate the installation of rail track into U2 Upper Containment. In the second example, on June 16, the
HRA swing gate to U2 Lower Containment was propped open with scaffold leveling legs during demobilization. In both cases, the boundary re-positioning was such that the swing gates no longer provided adequate barriers to check the advance of an oncoming worker. These violations were discovered by HPTs performing their normal radiological control duties. Immediate corrective actions were taken upon discovery and documented in PERs 379547 and 390159. Although these events involved the failure to maintain proper controls for
HRAs, this finding is of very low safety significance because there was no evidence of unauthorized worker entry into the affected areas, nor any unexpected radiation exposures to licensee personnel
