Request for Comments on Responses to Licensee Questions on High Radiation Area Controls
See the memorandum from J. Wigginton to W. J. Pasciak (and others) dated June 21, 1989.
This memo provides guidance on the temporary use of lead shielding as a long-term solution in reducing radiation levels and states that magnetic computer cards meet the locking requirements of 10 CFR 20.203 (c) (2) (iii). The health physics position also applies to "new" 10 CFR 20.1601 (a) (3).
The NRC was asked to provide guidance to a licensee concerning implementation of 10 CFR Part 20 and Technical Specifications (Administration Section 6) requirements for high radiation area controls. The licensee had questions concerning IEIN-88-79 that alerted licensees to several instances where plants had not properly controlled areas having greater than 1000 mR/hr (improper use of the "flashing light" option). Specifically, the licensee asked whether temporary shielding may be used as a long-term solution in reducing radiation levels below 1000 mR/hr (to avoid locking an area >1000 mR/hr). The licensee also requested guidance concerning the use of a computer card (magnetic card) used in lieu of a classical, physical key-lock to meet the locking requirements of 10 CFR 20.203 (c) (2) (iii) [or 10 CFR 20.1601 (a) (3)].
The NRC stated that other techniques to reduce source term should be used (e.g., chemical decon, permanent shielding); however, as long as reasonable progress is made toward the long-term fix (and an effective system to preclude unauthorized removal of temporary shielding exists), the judicious use of temporary shielding could be justified on an interim basis. In general, the radiation source in-growth rate should allow for prudent and timely compensatory action to avoid frequent use of temporary shielding for this purpose.
An access control system governed by computer mag-cards is acceptable and meets the STS and 10 CFR 20.203 (c) (2) (iii) [or 10 CFR 20.1601 (a) (3)] requirements for locking high radiation areas pursuant to the security requirements of 10 CFR 73 [Physical Protection of Plants and Material, Paragraph 73.2 (m)]. However, the licensee must maintain positive control over each entry and satisfy all other existing entry and surveillance requirements for high radiation areas.
Regulatory references: 10 CFR 20.203, 10 CFR 20.1601, Technical Specifications
Subject codes: 4.1, 5.3