Access Control to High Radiation Areas - Turkey Point
See the memorandum from L. B. Higginbotham to J. T. Sutherland dated March 8, 1979. A licensee may establish controls at locations beyond the immediate boundaries of a High Radiation Area to take advantage of natural or existing boundaries. The health physics position was written in the context of 10 CFR 20.203, but it also applies to "new" 10 CFR 20.1601.
Headquarters reviewed a citation made for conditions at Turkey Point and the licensee's written objection to the citation. This citation was against the technical specification that requires each High Radiation Area in which the intensity of radiation is greater than 1,000 mrem/hr to be provided with locked doors. The citation identified the regenerative heat exchangers and reactor cavity filters, that were both within containment, as creating High Radiation Areas.
The licensee responded that they did not believe the conditions cited constituted an item of noncompliance. They stated that reactor containment was identified as a High Radiation Area, it was maintained locked except when access was required, and personnel access was controlled in accordance with 10 CFR 20.203 (c) (2) (iii) when the door was not locked. A security guard was positioned near the containment air lock for recording dosimeter numbers and readings upon entry and exit of individuals into and out of containment; and the two above components within containment were barricaded and posted as High Radiation Areas.
The interpretation of present NRC regulations and STS requirements is that a licensee may establish controls to take advantage of natural or existing barriers. This means that one locked door, or one control point, where positive control over personnel entry is exercised, may be utilized to establish control over multiple High Radiation Areas.
Although the regulations refer to "each" High Radiation Area, they do not preclude the implementation of controls over a broader area that encompasses one or more High Radiation Areas. NRC recognizes that there are limitations to the application of this "broad area control" concept; however, these limitations are rather subjective and must be evaluated in terms of the degree of access control necessary in light of the magnitude of radiation fields, accessibility to the radiation fields, and other administrative or physical controls utilized within the "broader area."
Under the current STS there are no provisions that substitute for 10 CFR 20.203 (c) (2) (iii) [or 10 CFR 20.1601 (a) (3)]. Therefore, when entry is necessary, the control specified in 20.203 (c) (2) (iii) [or 20.1601 (a) (3)] must be imposed. However, the positive control required for 20.203 (c) (2) (iii) [or 20.1601 (a) (3)] is not defined. Since the STS does spell out specific controls for High Radiation Areas (i.e, posting, barricading, RWP, and instruments), these controls can be used as a reasonable guide for the "positive control" that must be implemented in addition to providing access control which serves as a substitute for the locked door.
For situations where a reactor containment structure is designated as a High Radiation Area (>1,000 mr/hr), access control may be established at the access hatch for periods when personnel entries are necessary. The degree of access control may vary based on how and where the other controls are implemented. For example, if the High Radiation Areas (>1,000 mr/hr) within containment are readily recognizable (e.g., posted and barricaded), less stringent access control is required at the hatch than if the individual High Radiation Areas are not posted and barricaded. Also, if personnel are likely to enter radiation fields of 100 to 1,000 mr/hr while in containment, the requirement for providing individuals with a monitoring device that continuously indicates dose rate must be imposed at the access hatch.
Based on our evaluation of the situation at Turkey Point, NRC does not support the Region II citation. Although the Region appears to have had some concerns about the adequacy of the positive control exercised over personnel access to and activities within containment, this aspect was not adequately developed and the specific citation did not reflect this concern. In light of the licensee's positive response concerning the control of radiation exposure to their workers and the corrective action that will be taken,
NRC sees no benefit in pursuing the adequacy of the licensee's access control at this time. There is a need to clarify some aspects of the STS requirements and discussion has already been initiated as a preliminary effort to obtain a change to the STS.
Regulatory references: 10 CFR 20.203, 10 CFR 20.1601, Regulatory Guide 8.38, Technical Specifications
Subject codes: 4.1, 4.7