On February 4, 2008, licensee operations personnel identified an unsecured
HRA in the vicinity of the 1B
RHR corner room. This is contrary to Step 4.2.1 of procedure
RP-AA-460, Controls for High and Very
High Radiation Areas, that requires the staff to barricade and conspicuously Post
HRAs (<1000 millirem per hour at 30 centimeters). Radiation protection staff posted and secured a locked
HRA to support anticipated changing conditions during shutdown and removed the
HRA controls in an adjacent area to conduct that work. An independent verification of the
HRA controls was not performed, resulting in noncompliance for a period of approximately five hours. No individuals entered the area during that time. The violation is of very low safety significance because it did not involve
ALARA planning or work controls, an
overexposure,
substantial potential for overexposure, or the ability to assess radiation dose. This issue was entered into the licensees
CAP as IR 731403.