Perry Station
TS 5.7.1 states in part, that each
HRA shall be barricaded and conspicuously posted as an
HRA and entrance thereto shall be controlled by issuance of an
RWP. The TS further requires that entry into such areas be made after dose rate levels in the area have been established and personnel are aware of them. Contrary to the above, on May 1, 2007, on two occasions while performing a
fire watch, a security officer entered a controlled, posted, and barricaded
HRA in the turbine building
lube oil room without being on a
RWP which permitted access into the area. Additionally, the officer had not received a briefing from the radiation protection staff such that the officer was aware of the radiological conditions prior to entering the area. Specifically, when the officer opened the north door to the area, the officer observed a posted
HRA boundary. The officer immediately shut the door and proceeded to the south door of the area and observed a similar posted
HRA boundary. Although the officer was not on an
RWP which allowed access into the area, the officer decided to finish the
fire watch and proceeded across the boundary. The officer also entered the same area during a second
fire watch tour later that day. Based on an
OI investigation (
OI Case No. 3-2007-021), the NRC staff concluded that the officers second entry into the
HRA was a willful violation. However, because the violation had no actual radiological significance and minimal potential significance, the violation involved the acts of a low-level individual resulting from an isolated action without management involvement, there was no economic or other advantage gained as a result of the violation, and adequate remedial action was taken, the violation was categorized at
Severity Level IV. Because the violation is of very low safety significance, it meets the additional criteria in Section VI.A.1 of the
NRC Enforcement Policy, and it has been entered into the corrective action system (CR 19784), it is being treated, after consultation with the Director, Office of Enforcement, as an
NCV