ML20031D308
| ML20031D308 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/07/1981 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NO-81-1650, NUDOCS 8110130231 | |
| Download: ML20031D308 (3) | |
Text
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mpat Carolina Power & Light Company October 7, 1981 File: NG-3514(B)
Serial No.: NO-81-1650
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' 3, Office of Nuclear Reactor Regulation ATTN:
Mr. T. A. Ippolito, Chief f )* -
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g Operating Reactors Branch No. 2 j'
United States Nuclear Regulatory Cotrmission
,f Washington, D.C.
20555 OJ h
BRUNSWICK STEAM ELECTRIC PLANT,' UNIT NOS. 1 AND 2
)r DOCKET NOS. 50-325 AND 50-324
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LICENSE NOS. DPR-71 AND DPR-62
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REQUEST FOR INTERPRETATION OF 10CFR20 f
Dear Mr. Ippolito:
Summary Pursuant to Title 10, Code of Federal Regulations, Part 20.6, Carolina Power & Light Company (CP&L) hereby requests a written inter-pretation of the requirements set forth in 10CFR20.203(b) and 10CFR20.202(b)(2). NRC Of fice of Inspection and Enforcement, Region II, has issued to CP&L a Notice of Violation pertaining to an interpretation of these requirements. CP&L has denied this violation, pending your written interpretation of these requirements.
Background
10CFR20.203(b) states "Each radiation area shall be conspic-uously posted with a sign or signs..."
Also, 10CFR20.202(b)(2) states that a radiation area "...means any area, accessible te personnel, in which there exists radiation...at such levels that a major portion of the whole body could receive in any one hour a dose of 5 millirem, or in any 5 consecutive days a dose in excess of 100 millirem;..."
l CP&L has complied with 10CFR20.203(b) and 10CFR20.202(b)(2) hy posting the entrances to the Brunswick Steam Electric Plant reactor buildings with " Caution: Radiation Area" signs.
CP&L's reaaons for posting the entrances to reactor buildings as radiation areas, rather i
than individual areas within the reactor buildings, are:
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1.
The reactor buildings have multiple radiation sources that vary in intensity according to the condition of the plant.
The multiple radiation sources produce radiation fields which interact and vary in intensity according to the reactor power level and the operation of individual systems and components in a way that makes posting discrete areas within the building inappropriate.
2.
The entire roactor buildings are maintained as vital security areas and radiation control (restricted) areas. Access is limited to personnel needing to gain entry for work, inspections, etc.
3.
Radiological surveys are performed on a daily basis within the buildings. This information is used in the preparation of Radiation Work Permits that include the radiological conditions for specific work places.
4.
Health Physics personnel are assigned to each building to provide coverage of special maintenance work, as well as assuring that areas are monitored and posted (i.e., " Caution, High Radiation Area," " Hot Spot," " Contaminated Area," etc.) in accordance with 10CFR20 and consistent with CP&L Health Physics and ALARA programs.
5.
Access to each building is normally controlled through a single locked entrance / exit air-lock.
The air-locks are conspicuously posted with " Caution: Radiation Area" signs to inform workers that they are entering a radiation area and that they shall conduct themselves accordingly.
6.
By virtue of this radiation area posting, all personnel entering the reactor buildings are required to wear personal monitoring devices, thus providing an additional means of radiation exposure control.
CP&L believes that our conservative policy of posting the entire reactor buildings fully meets the requirements of 10CFR20.203(b) and is an integral part of our program to provide a work place that is conducive to keeping radiation exposures as low as reasonably achievable.
However, NRC I&E letter dated April 27, 1981 (Refer to RII: JRW 50-325/80-45; 50-324/80-43) included a Notice of Violation stating that,
" numerous areas accessable to personnel within the reactor buildings of Units 1 and 2 which met the radiation area criteria of 10CFR20.202(b)(2) were not posted as required by 10CFR20.2.13(b). The antrances to the reactor buildings were posted as radiation areas."
Carolina Power & Light Company's written response (dated May 20, 1981) denied that this was a violation, pending a written interpretation from NRC.
Request Therefore, it is requested that NRC issue a written interpretation which verifies that Carolina Power & Light Company's interpretation of 10CFR20, paragraphs 202(b)(2) and 203(b), as applied to the Brunswick Steam Electric Plant reactor buildings, is correct.
Should you need supplemental infernation in order to resolve this matter, please do not hesitate to con-et us.
Yours very truly, W# '
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E4 E. Utley Executive Vice President Power Supply and Engineering 6 Construction EEU/lr (6354) cc:
Mr. J. P. O'Reilly
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