Technical Specification 6.8.1 requires the procedures recommended in
RG 1.33 to be established, implemented, and maintained.
Regulatory Guide 1.33 requires implementation of an
RWP system. Specifically,
RWP #1014, Task 4, Valve Maintenance RCB (No
HRA Access), required
HP to be notified prior to the start of work and for
HP to be present and perform surveys when breaching a contaminated system. Contrary to these
RWP requirements, on November 22, 2013, two workers entered the containment building and cut out two primary
CS valves (CS-761 and 762) without having
HP present to perform surveys when breaching a contaminated system. After they exited containment,
HP discovered the valves on the ground with removable beta-gamma contamination levels up to 200,000 dpm/100 cm2. This finding was of very low safety significance (Green) because there was no
substantial potential for overexposure. This was due to the fact that the external dose rates were low and the contamination levels were not high enough to constitute a
substantial potential for overexposure. The inspectors noted that no personnel were contaminated as a result of this event. The licensee entered the event into their corrective action program as
AR #648061.
