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)