U.S. Nuclear Regulatory Commission

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).