Health Physics Questions and Answers - Question 423
Question 423: Standard Technical Specification (STS) 6.12 for nuclear power reactors provides methods for control of access to high radiation areas that are alternatives to the methods specified in a CFR Part 20. Power reactor licensees that have adopted this technical specification are required to provide additional controls for access to high radiation areas with dose rates greater than 1 rem/h in addition to the controls required for access to high radiation areas with dose rates of 1 rem/h or less. Providing the additional controls at 1 rem/h is conservative relative to providing additional controls for areas having dose rates of 500 rads or more in an hour as required for very high radiation areas by 10 CFR 20.1602. Do licensees that have adopted STS 6.12, and that are providing the additional controls required by this STS for areas with dose rates greater than 1 rem per hour or less, have to provide additional controls for very high radiation areas in accordance with 10 CFR 20.1602?
Answer: Yes, they do. The alternative controls for high radiation areas in STS 6.12 do not apply to the new requirement in 10 CFR 20.1602 to provide additional controls for very high radiation areas. The compensatory measures in the STS that provide alternative methods of control for areas with dose rates greater than 100 mrem per hour but less than 1000 mrem per hour do not constitute adequate controls over access to very high radiation areas.
(References: 10 CFR 20.1601, 10 CFR 20.1602, Reactor Technical Specifications)