U.S. Nuclear Regulatory Commission

Request for Comments on Responses to Licensee Questions on High Radiation Area Controls

HPPOS-237 PDR-9111210358

Title: 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

Applicability: Reactors