Question 92: At power reactor facilities, when the reactor
is at power, very high radiation areas (due to neutron and
N-16 gamma radiation fields) can exist inside the primary
containment. At some facilities, these areas inside
containment are not readily locked, without substantial
plant modifications to make them lockable. In recognition
of this situation, the following controls are planned to
meet the requirements of 10 CFR 20.1602 as it relates to a
PWR or de-inerted BWR containment at power: When the
reactor is at power and entry is not required, the primary
containment access hatch (and any other access way) will be
locked and posted as a very high radiation area. The key
control access and special radiation work permit for entry
will be in accordance with, or provide protection
equivalent to, the guidance in draft Regulatory Guide
DG-8006. When the reactor is at power, and entry is
required, a qualified (in accordance with the applicable
ANSI standard) radiation protection technician will
accompany and provide continuous job coverage to each
(small) group of workers assigned to perform a particular
task (e.g., surveillance). Do the preceding controls meet
the intent of 10 CFR 20.1602?
Answer: Yes. The controls outlined are an example of one
way (but not the only way) to comply with 10 CFR 20.1602 in
this situation. (References: 10 CFR 20.1003, 10 CFR
20.1602).