Safety Evaluation of the Proposed Yankee Atomic Power Company's Modification of their Technical Specifications Relating to High Radiation Areas

HPPOS-015 PDR-9111210114

See the memorandum from D. G. Eisenhut to K. R. Goller, dated March 16, 1977. Enclosures with the document provided the basis for revised Technical Specifications relevant to entry into high radiation areas. These allow entry controlled by RWP and radiation monitoring, alarming dosimeter, or health physics qualified individual. (It should be noted that new Technical Specifications clarify the requirements for high radiation areas in containment.)

The health physics position was written in the context of 10 CFR 20.203, but it also applies to "new" 10 CFR 10.1601. Enclosure 2 states that in lieu of the "control device" or alarm signal required by paragraph 10 CFR 20.203 (c) (2) [or 10 CFR 20.1601 (a)], each high radiation area in which the intensity of radiation is between 100 and 1000 mrem/hour must be barricaded and conspicuously posted as a high radiation area and entrance controlled by requiring the issuance of a Radiation Work Permit (RWP).

Any individual or group of individuals permitted to enter these areas must be provided with one or more of the following:

1. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into high radiation areas with this type of monitoring device may be made only after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.

3. A health physics qualified individual (i.e., qualified in radiation protection procedures) with a radiation dose rate monitoring device and who is responsible for providing positive control over the activities within the area and performs periodic radiation surveillance at the frequency specified in the RWP and established by the Plant Health Physicist.

Health physics personnel are exempt from RWP issuance requirements during the performance of their assigned radiation protection duties, providing they are following plant radiation protection procedures for entry into high radiation areas.

The above procedures also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr. To prevent unauthorized entry into high radiation areas, locked doors with the keys maintained under the administrative control of the on-duty shift supervisor and/or the Plant Health Physicist must be provided.

Individuals are considered qualified in radiation protection procedures when they are certified as capable of successfully accomplishing the following activities as required by federal regulations, license conditions, and facility procedures pertaining to radiation protection:

1. Conducting and evaluating special and routine radiation, contamination and airborne radioactivity surveys.

2. Establishing protective barriers and posting appropriate radiological signs.

3. Establishing a means of limiting exposure rates and accumulated radiation doses, including the use of protective clothing and respiratory protection equipment.

4. Performing operability checks of radiation monitors and survey meters.

5. Recommending appropriate immediate actions in the event of a radiological problem, and performing necessary activities until the arrival of health physics personnel.

6. Conducting other routine radiological duties as required on backshifts or weekends.

Regulatory references: 10 CFR 20.203, 10 CFR 20.1601, Technical Specifications

Subject codes: 1.7, 4.1, 7.1

Applicability: Reactors