U.S. Nuclear Regulatory Commission

Access Control to High Radiation Areas - Turkey Point

HPPOS-014 PDR-9111210110

Title: 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

Applicability: Reactors