Health Physics Questions and Answers - Question 52
Question 52: Since the technical specification "exemptions" for nuclear power reactors already apply to locking of high radiation areas, does this "exemption" continue to apply pursuant to 10 CFR 20.1008 (d) if a 45-cm 18-inch) survey distance is specified (in technical specifications) versus the rule's 30-cm distance (10 CFR 20.1601 (a))?
Answer: The provisions of power reactor technical specifications for control of high radiation areas are not "exemptions" from the regulations. They are alternative methods of control provided in accordance with the provisions of 10 CFR 20.203 (c) (5). Under the revised Part 20 these technical specifications will continue to apply to the control of high radiation areas (but not very high radiation areas) until they are changed. These technical specifications refer to a high radiation area as defined in Part 20. When revised Part 20 is implemented, the revised definition of a high radiation area, using the 30-cm distance, will apply. Thus to determine the boundaries of the high radiation area, the 30-cm (12-in.) distance will be used. However, within the boundaries of that area the less-restrictive 45-cm (18-in.) distance specified in the technical specifications will be used to determine whether the radiation exposure is less than, equal to, or greater than 1,000 mR/h, the exposure rate used in the technical specifications to define the degree of control required. Changes in the technical specifications to be proposed by the NRC staff will include a change from 45 cm to 30 cm for the specified distance.
(References: 20.1601, 10 CFR 20.1602, Reactor Technical Specifications)