ML20197E083

Responds to 781219 Memo Requesting Review of Noncompliance & Licensee'S Objection to Citation Re Access Control to High Radiation Areas.Believes Pursuing Adequacy of Licensee'S Access Control Is Pointless

ML20197E083
Person / Time
Site:	Turkey Point
Issue date:	03/08/1979
From:	Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Sutherland J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 7904100384
Download: ML20197E083 (3)

Text

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. MAR 8 1979 MDDRANDt#4 FOR: J. T. Sutherland. Chief. FFHS Branch, Region Il

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FRD'4: L. B. iiigginbothan, Assistant Director, FFMSI SUNECT: ACCESS C0:iTROL TO IIIGrRADIATION APIAS - TUPJIY POINT (AITS F22049!!3)

In your rece of Decedar 19, 1978 you requested Headquarters review of a citation nade for conditions at Turkey Pcint and the licensee's wFitten objection to the citation. This is in response to your request.

Specifically, the citation was against the technical specification that requires each High Radiation Area in tihich the intensity of radiation is greater than 1,000 creA/hr to be provided with locked doors. The citation identified the regenerative heat exchangers and reactor cavity. filters, which were both within containment, as creating high radiation areas.

The reactor was shut down at this time and the containment door was unlocked

and cpon to provide access.

The licensee responded that they did not believe the conditions cited constituted an iten of nonco,p11ance. They stated that the reactor con-tainmnt was identified as a High Radiation Araa.. was maintained locked except d'uring periods when access was required, and pcrsonnel access was controlled in accordance with 10 CFR 20.203(c)(2)(iii) when the door was not locked.

Additional infomation was obtained froc: review of the inspection report, correspondence between the licensee and the Region, and discussions with one of the inspectors. It was deterr:ined that the reactor containment was posted as a High Fidiation Area; a security guard was positioned near the containment air lock for recording dosisuter number and readings upon entry and exit of individuals into and out of containment; and the two t co::ponents within containment were barricaded and posted as High Radiation Areas. , ,

Interpretation of present NRC regulations and Standard Technical Specif1.

cation (STS) requirements is that a. licensee ray establish controls (i.e.,

locked doors, access control, and posting) at locations beyond the ictediateloundaries of the pertinent radiation fields to take advantage of natural or existing barriers. This, means that one locked door, or one Y { l&

CO:: TACT: L. J. Cunningham 492-S188 } chi 1

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J. T. Sutherland 8W i

control point where positive control over personnel entry is exercised cuy be utilized to establish control over multiple High Radiation Areas.

Although the regulations mfer to "each' High Radiation Area, they do not preclude the iglenentation of controls over a bmader area that enco: passes one or core High Radiation Arcas. We recognfre that there are 11 citations to the application of this "troad area control

• concept; however, these linitations are ra'ther subjective and cust be evaluated in tercs of the degree of access control necessary in light of the cagnitude of radiation fields, accessibility to the radiation fields and other ad .inistrative or physical controls utilized within the "breader area." For exacple, in the case of a small room which contains components that create several discrete High Radiation Artas, barricading and posting at the entrance may be adequate without individually posting and barricading each coponent; in the case of a large area which includes, l several individual High Radiation Areas.. separate barricading and posting of the individual High Radiation Areas may be necessary to provide adequate personnel protection even though the total area is posted and controlled as a High Radiation Ama.

Under the curmnt STS them are no provisions which substitute for 20.203(c)( ( 1,. ill must be i m osed.Therefom, when entry is necessary the cont in20.203( i I!owaver, the positive control required for 20.203 j j; 11i) is not defined. Since the STS does spell out specific controls for High Radiation Areas (i.e posting, barricading, R!fP, and instrument), these controls can be used as a reasonable guide for the

" positive control' which must be 1@lenented in addition to providing access control which serves as a substitute for the locked door.

For situation where a reactor containment structum is designated as a High Radiation Area ('p1,07) cr/hr), access control may be established at -

the access hatch for periods when personnel entries are necessary. The degree of access control eey vary based on how and where the other controls are igleacnted. For example, if the individual High Radiation Areas

(~J1,000 cr/hr) within containnent aru readily recognizcble (e.g., posted and barricaled), less stringent access control is required at the hatch than if theindividual High Radiation Areas are not posted and barricaded.

Also, if personnel are likely to enter radiation fields of 100 to 1,000 cr/hr while in containaent, the requirement for providing individuals l

with a sionitoring device which continuously indicates dose rate (newer .

versions of the STS my allow an integrating /alam device or conitoring provided by an individual qualiffed in radiation protection procedures) nust be imposed at the access hatch.

J. T. Sutherland MAR 81979 Cased on our evaluation of the situation at Turkey Point, we do not support the Region II citation. The licensee is permitted to select the containant access door for locking in order to snet the technical specification which requires locked doors for High Radiation Areas ( 1.033 rs/hr); and the licensee is peraitted to select the containant air lock as the point at which positive access ccatrol to a !!igh Radiation Area is established. 1 Since the inspection report does not document facts to show that these conditions were not being mot, a citation for noncompliance is not appropriate.

Although the Agica appears to have had some concerns about the adequacy of the positive control excrcised over personnel access to and activities within contain. Tnt, this aspect was not adequately developed and the specific citation did not reflect this concern.

In light of the licensee's positive response concerning the control of radiation exposure to their workers and the corrective action which will be taken, we see no benefit in pursuing the adequacy of the licensee's access ccatrol at this time. ,

Having recognized that'there is a need to clarify some aspects of the STS requircaents. FR SI has already initiated discussion with other groups as a preliminary effort to obtain a change to the STS.

Leo B. liigginbotham Assistant Director. FFMSI .

cc: G. H. Snith. RI A. B. Davis, RIII G. D. Erown. RIV

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