Question 423: Standard Technical Specification (STS) 6.12
for nuclear power reactors provides methods for control of
access to high radiation areas that are alternatives to the
methods specified in a CFR Part 20. Power reactor
licensees that have adopted this technical specification
are required to provide additional controls for access to
high radiation areas with dose rates greater than 1 rem/h
in addition to the controls required for access to high
radiation areas with dose rates of 1 rem/h or less.
Providing the additional controls at 1 rem/h is
conservative relative to providing additional controls for
areas having dose rates of 500 rads or more in an hour as
required for very high radiation areas by 10 CFR 20.1602.
Do licensees that have adopted STS 6.12, and that are
providing the additional controls required by this STS for
areas with dose rates greater than 1 rem per hour or less,
have to provide additional controls for very high radiation
areas in accordance with 10 CFR 20.1602?
Answer: Yes, they do. The alternative controls for high
radiation areas in STS 6.12 do not apply to the new
requirement in 10 CFR 20.1602 to provide additional
controls for very high radiation areas. The compensatory
measures in the STS that provide alternative methods of
control for areas with dose rates greater than 100 mrem per
hour but less than 1000 mrem per hour do not constitute
adequate controls over access to very high radiation areas.
(References: 10 CFR 20.1601, 10 CFR 20.1602, Reactor
Technical Specifications)