ML20076J627
| ML20076J627 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/27/1983 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Clark R, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 365, NUDOCS 8307060042 | |
| Download: ML20076J627 (3) | |
Text
8 VINGINIA ELECTHIC AND PowsH CoxPAxy RIcnwoxn,VINGINIA 2026I W.L. STEWART Vics P=mernm=T weci.=*= or = =4no==
June 27, 1983 Mr. Harold R. Denton, Director Serial No. 365 Office of Nuclear Reactor Regulation N0/JHL:acm Attn:
Mr. Robert A. Clark, Chief Docket Nos. 50-338 Operating Reactors Branch No. 3 50-339 Division of Licensing License Nos. NPF-4 U. S. Nuclear Regulatory Commission NPF-7 Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS. 1 AND 2 REQUEST FOR INTERPRETATION OF 10 CFR 20
SUMMARY
Pursuant to Title 10, Code of Federal Regulations, Part 20.6, the Virginia Electric and Power Company (VEPCO) hereby requests a written interpretation of the requirements set forth in 10 CFR 20.202(b)(2) and 10 CFR 20.203(b).
The NRC Office of Inspection and Enforcement, Region II, has issued to VEPC0 a Notice of Violation pertaining to an interpretation of these requirements.
VEPC0 has denied this violation, pending your written interpretation of these requirements.
BACKGROUND 10 CFR 20.203(b) states in part:
"Each radiation area shall be conspicuously posted with a sign or signs... ".
Also, 10 CFR 20.202(b)(2) states in part that: a radiration area ".... means any area, accessible to 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 millirems".
VEPC0 has complied with 10 CFR 20.202(b)(2) and 10 CFR 20.203(b) by posting the routine entrance to the Auxiliary Building with a sign bearing the radiation caution symbol and the words:
" CAUTION RADIATION AREA".
All other entrances are under administrative control and are conspicuously posted with a sign bearing the radiation caution symbol and the word.i:
" CAUTION RADIATION AREA" and/or " CONTROLLED AREA AUTHORIZED ENTRY ONLY".
VEPCO's rational for posting the entrance to the Auxiliary Building as a radiation area, rather than individual areas within the Auxiliary Building, are:
1.
The Auxiliary Building is maintained as a Restricted Control Area for the purpose of radiation protection. Access is limited to personnel needing to gain entry for work surveillance, inspections, etc.
hg O
VamotxtA EXECTRIC AND Powra COMPANY TO Harold R. Denton 2
2.
Radiological surveys are performed on a daily basis within the building.
This information is used to update the radiological status boards located adjacent to the Auxiliary Building. entrance and in the preparation of Radiation Work Permits that include the radiological conditions for specific work locations.
3.
Health Physics personnel are assigned within the building to provide coverage of special maintenance work, as well as assuring that areas are monitored and posted (e.g.
" CAUTION:
HIGH RADIATION AREA", " AIRBORNE RADI0 ACTIVITY AREA", etc.) in accordance with 10 CFR 20 and consistent with the North Anna Power Station Health Physics and ALARA programs.
4.
Access to the Auxiliary Building is normally controlled through a single q
entrance door adjacent to the Health Physics office area.
The entrance N
is conspicucusly posted with a " CAUTION RADIATION AREA" sign to inform workers that they are entering a radiation area and that they shall conduct themselves accordingly.
Special case entry through other antrances are administrately controlled by health physics and issuance.of a odiation Work Permit is required.
5.
By virtue he radiation area posting, all personnel entering the Auxiliary Buildh g are required to wear self-reading pocket dosimeters in conjunction with their regularly assigned personnel monitoring device, thus providing additional means of radiation exposure control.
6.
The Auxiliary Building has multiple radiation sources that vary in intensity according to the condition of the plant.
The multiple radiation sources produce radiation fields varying in intensity according to reactor power level and the operation of individual systems and components in a way that makes posting discrete areas within the building impractical.
VEPCO' believes that our conservative pclicy of posting the entire Auxiliary Building 'as a single radiation area fully reets the requirements of 10 CFR 20.203(b).
NRC I & E Report Nos. 50-338/83-12 and 50-359/83-12 included a Notice of Violation stating that:
"....two separate areas of the Auxiliary Building were not posted as a radiation area bearing the words: CAUTION RADIATION AREA...."
as required by 10 CFR 20.203(b).
The Virginia Electric and Power Company's written response to the Notice of Violation denies that this is a violation, pending a written interpretation from the Nuclear Regulatory Commission.
REQUEST Therefore, it is. requested that NRC issue a written interpretation which verifies that the Virginia Electric and Power Company's interpretation of 10 CFR 20, paragraphs 202(b)(2) and 203(b), as-applied to the North Anna Power Station Auxiliary Building, is correct.
L
o VanO x A Eucrate AND Powra COMPANY TO Harold R. Denton 3
Should you require additional information in order to resolve this matter, please contact us.
Very truly yours
/
t W. L. Stewart cc:
Mr. James P. O'Reilly Regional Administrator Region II Mr. M. B. Shymlock NRC Resident Inspector North Anna Power Station i
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