RS-19-039, Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls

Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls

ML19178A304
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Palisades, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle, Crane
Issue date:	06/26/2019
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-19-039, TMl-19-013
Download: ML19178A304 (74)

Text

200 Exelon Way Exelon Generation ~

Kennett Square, PA 19348 www.exeloncorp.com RS-19-039 TMl-19-013 June 26, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 10 CFR 50.90

U.S. Nuclear Regulatory Commission Exelon Fleet LAR-Common Language for TS HRA Administrative Controls June 26, 2019 Page 2

Subject:

Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-41 O Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Exelon Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS}, which is Appendix A of the renewed facility and facility operating licenses listed above.

EGC proposes a change to the Technical Specifications (TS) 5.0 Administrative Controls, specifically 5.7 "High Radiation Area." Having standard common language for TS 5.7 (numbered 6. 7 for Nine Mile Point, Unit 1, and 6.12 for Limerick and Three Mile Island, Unit 1) across EGC sites will allow for common governing procedures, better alignment and understanding by personnel, and promote a more efficient implementation of radiation protection processes for entering High Radiation Areas.

EGC has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92.

The proposed changes have been reviewed by each station's Plant Operations Review Committee in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests approval of the proposed amendments by June 26, 2020. Once approved, the amendments shall be implemented within 60 days.

This amendment request contains no regulatory commitments.

U.S. Nuclear Regulatory Commission Exelon Fleet LAR-Common Language for TS HRA Administrative Controls June 26, 2019 Page 3 provides an evaluation of the proposed changes. Attachment 2 provides the existing TS pages marked up to show the proposed changes.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the states of Illinois, Maryland, New York and Pennsylvania of this request for changes to the Technical Specifications by transmitting a copy of this letter and its attachments to the designated State officials.

If you have any questions or require additional information, please contact Mr. Frank J. Mascitelli at (610) 765-5512.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 261h day of June 2019.

Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Proposed Technical Specifications Markup Pages cc:

Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector-Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - James A FitzPatrick Nuclear Power Plant

U.S. Nuclear Regulatory Commission Exelon Fleet LAR-Common Language for TS HRA Administrative Controls June 26, 2019 Page4 NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection, PA Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA D. Tancabel, State of Maryland A L. Peterson, NYSERDA

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Exelon Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration 5.4 Conclusion

7.0 REFERENCES

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes

1.0 DESCRIPTION

Page 1 of 17 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) is requesting that the Technical Specifications (TS), which is Appendix A of the renewed facility/facility operating licenses for Braidwood Station, Byron Station, Calvert Cliffs Nuclear Power Plant, Clinton Power Station, Dresden Nuclear Power Station, James A. FitzPatrick Nuclear Power Plant, LaSalle County Station, Limerick Generating Station, Nine Mile Point Nuclear Station, Peach Bottom Atomic Power Station, Quad Cities Nuclear Power Station, R.E. Ginna Nuclear Power Plant and Three Mile Island Nuclear Station, Unit 1 under Renewed Facility/Facility Operating License Nos. NPF-72 and NPF-77; NPF-37 and NPF-66; DPR-53 and DPR-69; NPF-62; DPR-19 and DPR-25; DPR-59; NPF-11 and NPF-18; NPF-39 and NPF-85; DPR-63 and NPF-69; DPR-44 and DPR-56; DPR-29 and DPR-30; DPR-18; and DPR-50, respectively, be amended as proposed to permit changes to the administrative control TS Section 5. 7 "High Radiation Area" (6. 7 for Nine Mile Point-1, and 6.12 for Limerick and Three Mile Island). The proposed changes will provide common language across the fleet creating consistency, procedural alignment, and efficiencies through elimination of wording differences among the sites.

This License Amendment Request (LAR) provides a discussion and description of the proposed TS changes, a technical evaluation of the proposed TS changes and information supporting a finding of No Significant Hazards Consideration.

2.0 PROPOSED CHANGE

The most straightforward means of illustrating the changes for the proposed common language wording is by comparison to the Standard Technical Specifications (STS) wording.

The current LaSalle TS 5. 7 wording is highly consistent with the STS. For the purpose of general discussion, the proposed common language mark-up of the current LaSalle TS 5. 7 wording is provided below. Insertions are shown in red italics and deletions are shown in green single strikeout.

The proposed common language version is consistent with the format of using two main sections - one for high radiation areas and one for locked high radiation areas. The indicated changes are intended to improve readability and clarity by removing redundancy and simplifying the language. The specific TS changes for each station are shown in.

5. 7 High Radiation Area As provided in paragraph 20.1601(c) of Pursuant to 10 CFR Part 20, paragraph 20.1601(c),

in lieu of the requirements of the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and 20.1601(b) of 10 CFR Part 20:

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Page 2of17

5. 7.1 Access to each high radiation area, as defined in 10 CFR 20, in which an individual could receive a deep dose equivalent> 0.1 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation) shall be controlled as described below to prevent unauthorized entry High Radiation Areas with Dose Rates Not Exoeeding 1.0 rem/hour at ao Centimeters from the Radiation Source or from any Surface Penetrated by the Radiation.

a.

Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b.

Access to, and aoti¥ities in, each such area.Entrance shall be controlled by means ofcrequiring issuance of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c.

Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may, for the performance of their assigned duties in high radiation areas, be exempted from the preceding requirements for issuance of an RWP or equivalent while performing radiation surveys in such areas provided-#lat they are otherwise following plant radiation protection procedures for entry into, exit from, and work in such high radiation areas.

d.

Each individual or group of individuals permitted to enter~

such ~areas shall possess, or be accompanied by, one or more of the following:

1. A radiation monitoring device that continuously displays indicates the radiation dose rates in the area.;--er

2. A radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm a preset setpoint is reached, with an appropriate alarm setpoint, or. Entry into high radiation areas with this monitoring device may be made after the dose rate in the area has been determined and personnel have been made knowledgeable of it.

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.,..ef

4. A self reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and,

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Page 3of17 (i)

Be under the surveillance, as specified in the RWP or equivalent, while in the area, of aAn individual qualified in radiation protection procedures, equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by radiation protection supervision. ~that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure with the area, or (ii)

Be under the surveillance, as specified in the RWP or equi11alent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with indi11iduals in the area who are co\\*ered by such surveillance.

e.

Except for individuals qualified in radiation protection proeedures, or personnel eontinuously eseorted by sueh individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These eontinuously escorted personnel will reeeive a pre job briefing prior to entry into sueh areas. This dose rate determination, knowledge, and pre job briefing does not require doeumentation prior to initial effiry.:

5.7.2 In addition to the requirements of Specification 5. 7.1, High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surfaee Penetrated by the Radiation, high radiation areas in which an individual could receive a deep dose equivalent> 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 Mmeter from the Rradiation Ssource or from any Ssurface.Ppenetrated by the Rradiation) shall be provided with a locked or continuously guarded door, or gate, or equivalent to prevent unauthorized entry.

(eontinued)

a.

The Eash entryi.*.iay to such an area shall be eonspieuously posted as a high radiation area and shall be provided with a looked or eontinuously guarded door or gate that prevents unauthorized entry, and, in addition:

1. All sueh door and gate keys to such locked doors or gates, or equivalent, shall be maintained under the administratively controlled in accordance with a program approved by ef the shift supervisor, radiation protection manager, or his or her designee.

b.

Doors and gates, or equivalent, shall remain locked except during periods of access by personnel or equipment entry or exit under an approved RWP, or

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Page 4 of 17 equivalent, to ensure individuals are informed of the dose rate in the immediate work areas prior to entry.

cb.

1\\ccess to, and activities in, each such area shall be controlled by means of an R\\IVP or equivalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c.

Individuals qualified in radiation protection procedures may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas pro\\

1ided that they are otherwise following plant radiation protection procedures for entry to, exit from, and 'Nork in such areas.

d.

Each indi*Jidual or group entering such an area shall possess one of the follo*Ning:

1.

,I\\ radiation monitoring device that continuously integrates the radiation rates in the area and alarms 'l+'hen the device's dose alarm setpoint is reached, with an appropriate alarm setpoint, or

2.

A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area 'Nith the means to communicate with and control every individual in the area, or

3.

A self reading dosimeter (e.g., pocket ionization chamber or electronic dosimeter) and, (i)

Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or (ii)

Be under the surveillance, as specified in the R\\IVP or equi*Jalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area, and with the means to communicate with and control every individual in the area-

4.

In those cases where options (2) and (3), above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Aehievable" principle, a radiation monitoring de-.*1ce that eontinuously displays radiation dose rates in the area.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Page 5of17 Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel \\*Jill receive a pre job briefing prior to entry into such areas. This dose rate determination, kno1.... ledge, and pre job briefing does not require documentation prior to initial entry.

IStlGA-fndividual high radiation areas in which an individual could receive a deep dose equivalent> 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), accessible to personnel, that are located within a larger areas where no enclosure exists for the purpose of to enable locking, or that are not continuously guarded, and where no lockable enclosure can be reasonably b&constructed around the individual area need not be controlled by a locked door or gate, nor continuously guarded, require both of the following access controls:

1. 8l2t Each area shall be barricaded, and conspicuously posted.,-af\\G a

2. A clearly visible flashing light shall be activated at the area as a warning device.

3.0 BACKGROUND

Dose rates in various areas of nuclear power plants accessible to individuals can differ by several orders of magnitude. High radiation areas, where personnel can receive doses more than the regulatory limits in a relatively short period of time, require special controls.

Very high radiation areas require much stricter monitoring and controls since failure to adequately implement effective radiological controls can result in radiation doses that result in a significant health risk. Thus, an important aspect of a nuclear power plant radiation protection program is the institution of a system of controls that includes procedures, training, audits, and physical barriers to inform and protect workers against unplanned exposures in high and very high radiation areas.

Technical Specification (TS) 5.7, "High Radiation Area" (numbered 6.7 for Nine Mile Point, Unit 1, and 6.12 for Limerick and Three Mile Island, Unit 1) specifies requirements for controlling access to high radiation areas. The exact wording of TS 5. 7 (or 6. 7 or 6.12, respectively) is not consistent across the EGC fleet. The intent of the proposed changes is to implement a standard common language High Radiation Area (HRA) TS program to be used at all EGC sites. The proposed TS wording is generally consistent with the STS as described in NUREGs 1430-1434 (Reference 1) with deltas due primarily with the removal of redundant requirements or simplifications of wording. Section 4, Table 4-1, "Summary of Major Changes in HRA TS Wording for Each Site" provides a detailed summary of the

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Page 6 of 17 specific changes associated with each site. Having common TS language for all EGC sites will allow for common governing procedures, better alignment and understanding of requirements, and a more efficient implementation of Radiation Protection (RP) processes for entering HRAs. In addition, during fleet outage support, the proposed common language would prevent radiation protection personnel traveling from site to site from becoming distracted by the differences in the site-specific TS wording.

4.0 TECHNICAL EVALUATION

The significant differences between the existing STS wording currently used at LaSalle and the proposed common language TS wording are as follows:

1. A minimum threshold at which an individual could receive a deep dose equivalent

> 0.1 rem/hour is established as the lower limit for a high radiation area and at which radiation area program controls are required. The STS explicitly establishes high radiation controls to be in effect not to exceed an upper limit of 1.0 rem/hour (1000 mrem/hour). The lower limit in proposed TS 5.7.1 is consistent with the 10 CFR 20 high radiation area definition.

2. Removal of the high radiation limit (1000 mrem/hour = 1 rem/hour) for HRAs from TS 5.7.1 clarifies that the requirements in TS 5.7.2 are in addition to the requirements applicable to areas > 1000 mrem/hour (1 rem/hour).

3. Removed as one of the options to enter a HRA the requirement to possess a self-reading pocket ionization chamber dosimeter. These are no longer used at EGC sites and are an obsolete technology.

4. Removed the requirement to receive a pre-job briefing prior to entering a HRA for personnel continuously escorted by individuals qualified in radiation protection procedures, because such qualified individuals can provide positive radiation protection control over activities in the high radiation area.

5. For locked HRAs, door and gate keys will be administratively controlled in accordance with a program approved by the radiation protection manager in lieu of being administratively controlled by the operations shift supervisor or the radiation protection manager or their designee. The key control program will be in accordance with established regulatory requirements and existing EGC procedural requirements.

(Reference 2).

6. Eliminated TS 5.7. 2. b, c, d as this is redundant to requirements already required in TS 5.7.1 which have been invoked for TS 5.7.2 with the phrase" in addition to the requirements of Specification 5.7.1" at the beginning of Section 5.7.2.

The proposed revision of TS 5.7.1.b requires HRA entrance be controlled by "a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s)". The use of terminology "RWP or equivalent" allows for the use of other radiological work documents to control access to HRA/LHRA that might not specifically be called "radiation work permits". For example, actual dose rate in the immediate work area may be captured in an RP technician survey or similar acceptable alternative method of informing a radiation worker of the level of radiation in the immediate area.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Exelon Fleet Evaluation of Proposed Changes Page 7 of 17 The significant differences between each site's current TS wording and the proposed common language TS wording are identified and discussed in Table 4-1 below and generally fall into one or more of the above categories.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences (or 6.7.1 or 6.12.1) 5.7.2 Differences (or 6.7.2 or 6.12.2)

Braidwood Removed statement about TS 5. 7 not applying Removed alternate method of direct or (Insert 1) to very high radiation areas.

continuous electronic surveillance in lieu of locked door.

Removed high rad limit (1000 mrem/hour or 1 rem/hour) since these requirements are now Key control changed from administrative control also applicable to areas > 1000 mrem/hour of the Shift Manager on duty or health physics (1 rem/hour).

supervision to administrative control in accordance with a program approved by the Removed requirements for an RWP in lieu of radiation protection manager.

being escorted by qualified personnel.

Removed 5.7.2.d and e because they are Provided an additional alternate HRA entrance redundant to requirements in other sections.

requirement for personnel possessing a monitoring device that continuously transmits dose rate and cumulative dose rate to a remote receiver monitored by a radiation protection personnel.

Byron Same as Braidwood Same as Braidwood (Insert 1)

Calvert Cliffs Adds a new High Radiation Area (HRA)

Adds a new locked HRA (LHRA) section to TS.

(Insert 1) section to TS.

Comments Page 7 of 17 Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Same as Braidwood Calvert Cliffs does not have an existing HRA section in their TS.

Calvert Cliffs is adding new TS requirements to be consistent with the Exelon Fleet. The current requirements are contained in RP-AA-460 (Reference 2).

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences (or6.7.1 or6.12.1) 5.7.2 Differences (or 6.7.2 or 6.12.2)

Clinton Adds clarification that an RWP or equivalent Removes maximum allowable stay time or dose (Insert 1) specifies radiation dose rate and other for a dose rate > 3000 mrem/hour.

appropriated radiation protection equipment and measures.

Removes direct or remote (such as closed-circuit TV cameras) continuous surveillance in lieu of Adds a radiation monitoring device that maximum allowable stay time or dose.

continuously transmits to a remote receiver.

RWP exemption in 5.7.4 moved to new 5.7.1.c without the s 3 rem/hour limitation.

Dresden Provides an additional alternate HRA entrance Removes alternate method of direct or (Insert 1) requirement for personnel possessing a continuous electronic surveillance in lieu of monitoring device that continuously transmits locked door.

dose rate and cumulative dose rate to a remote receiver monitored by a radiation Key control changed from administrative control protection personnel.

of the shift manager on duty or radiation protection supervision to administrative control in accordance with a program approved by the radiation protection manager.

Removes 5.7.2.b, c because it is redundant to requirement in 5. 7.1.

Relocates the 5. 7.3 no lockable enclosure exception to new 5.7.2.c paragraph.

Comments Page 8of17 The RWP exemption can be used for high radiation areas with a dose rate > 3000 mrem/hour.

Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Moved 5.7.3 requirements to 5.7.2.c.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences (or6.7.1 or6.12.1) 5.7.2 Differences (or 6.7.2 or 6.12.2)

Fitz Patrick Revises applicability from not exceeding Key control changed from administrative control (Insert 1) 1.0 rem/hour to > 0.1 rem/hour.

of the shift manager, radiation protection manager, or designee to administrative control in Removes allowance of continuously guarded accordance with a program approved by the entrance.

radiation protection manager.

Removes allowances for self-reading pocket Removes 5.7.2.b, c because it is mostly ionization chamber dosimeter usage (currently redundant to requirements in 5. 7.1.

5.7.1.d.4 and 5.7.2.d.3).

Removes separate requirement for pre-job briefs Removes separate requirement for pre-job to provide knowledge of area dose rate (still briefs to provide knowledge of area dose rate required to be part of RWP in 5.7.1.b}.

(still required to be part of RWP in 5.7.1.b).

LaSalle Revises applicability from not exceeding Key control changed from administrative control (Insert 1) 1.0 rem/hour to > 0.1 rem/hour.

of the shift supervisor, radiation, protection manager, or his or her designee to Removes allowances for self-reading pocket administrative control in accordance with a ionization chamber dosimeter usage (currently program approved by the radiation protection 5.7.1.d.4).

manager.

Removes separate requirement for pre-job Removes 5.7.2.b, c because it is redundant to briefs to provide knowledge of area dose rate requirements in 5. 7.1.

(still required to be part of RWP in 5.7.1.b).

Removes separate requirement for pre-job briefs to provide knowledge of area dose rate (still required to be part of RWP in 5.7.1.b}.

Comments Page 9of17 Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences (or6.7.1 or6.12.1) 5.7.2 Differences (or 6.7.2 or 6.12.2)

Limerick Removes high rad limit (1 rem/hour) since Key control changed from administrative control (Insert 3) these requirements are now also applicable to of radiation protection supervision to areas > 1 rem/hour.

administrative control in accordance with a program approved by the radiation protection Removes allowances for self-reading pocket manager.

ionization chamber dosimeter usage (currently 6.12.1.d.4).

Nine Mile Revises applicability from not exceeding Key control changed from administrative control Point, Unit 1 1.0 rem/hour to> 0.1 rem/hour.

of the Station Shift Supervisor - Nuclear, (Insert 2) radiation protection manager, or his or her Removes allowances for self-reading pocket designee to administrative control in accordance ionization chamber dosimeter usage (currently with a program approved by the radiation 6.7.1.d.4) protection manager.

Removes separate requirement for pre-job Removes 6.7.2.b, c, because it is redundant to briefs to provide knowledge of area dose rate requirements in 6.7.1.

(still required to be part of RWP in 6.7.1.b)

Removes separate requirement for pre-job briefs to provide knowledge of area dose rate (still required to be part of RWP in 6.7.1.b)

Nine Mile Revises applicability from not exceeding Key control changed from administrative control Point, Unit 2 1.0 rem/hour to > 0.1 rem/hour.

of the Station Shift Supervisor - Nuclear or a (Insert 1) designee, or the radiation protection manager or Removes allowances for self-reading pocket a designee to administrative control in ionization chamber dosimeter usage (currently accordance with a program approved by the 5.7.1.d.4) radiation protection manager.

Removes 5.7.2.b, c, because it is redundant to requirements in 5. 7.1 Page 10of17 Comments Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences(or6.7.1 or6.12.1) 5.7.2 Differences (or 6.7.2 or 6.12.2)

Peach Revises applicability from not exceeding 1.0 Key control changed from administrative control Bottom rem/hour to > 0.1 rem/hour.

of the shift supervisor, radiation protection (Insert 1) manager, or his or her designee to Removes allowances for self-reading pocket administrative control in accordance with a ionization chamber dosimeter usage (currently program approved by the radiation protection 5.7.1.d.4).

manager.

Removes separate requirement for pre-job Removes 5.7.2.b, c because it is redundant to briefs to provide knowledge of area dose rate requirements in 5. 7.1.

(still required to be part of RWP in 5.7.1.b).

Removes separate requirement for pre-job briefs to provide knowledge of area dose rate (still required to be part of RWP in 5.7.1.b).

Quad Cities Removes high rad limit (1000 mrem/hour or Removes alternate method of direct or (Insert 1) 1 rem/hour) since these requirements are now continuous electronic surveillance in lieu of also applicable to areas > 1000 mrem/hour locked door.

(1 rem/hour).

Key control changed from administrative control Provides an additional alternate HRA entrance of the Shift Engineer on duty or radiation requirement for personnel possessing a protection supervision to administrative control in monitoring device that continuously transmits accordance with a program approved by the dose rate and cumulative dose rate to a radiation protection manager.

remote receiver monitored by a radiation protection personnel.

Removes 5.7.2.b, c because it is redundant to requirements in 5. 7.1.

Page 11 of 17 Comments Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences (or6.7.1 or6.12.1}

5.7.2 Differences (or 6.7.2 or 6.12.2}

R. E. Ginna Removes high rad limit (1000 mrem/hour or Key control changed from administrative control (Insert 1) 1 rem/hour) since these requirements are now of the Shift Supervisor on duty or radiation also applicable to areas > 1000 mrem/hour protection supervision to administrative control in (1 rem/hour).

accordance with a program approved by the radiation protection manager.

Provides an additional alternate HRA entrance requirement for personnel possessing a Removes direct or remote (such as closed-circuit monitoring device that continuously transmits TV cameras) continuous surveillance in lieu of dose rate and cumulative dose rate to a maximum allowable stay time or dose.

remote receiver monitored by a radiation protection personnel.

Page 12of17 Comments Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Table 4-1: Summary of Major Changes in HRA TS Wording for Each Site Site 5.7.1 Differences (or6.7.1 or6.12.1) 5.7.2 Differences (or 6.7.2 or 6.12.2)

Three Mile Invokes the exception of 10 CFR 20.1601(c)

Island, Unit 1 for alternate requirements in lieu of the control (Insert 3) device and alarm signal requirements of 1 O CFR 20.1601(a) and (b).

Removes high rad limit (1000 mrem/hour or 1 rem/hour) since these requirements are now also applicable to areas > 1000 mrem/hour (1 rem/hour).

Provides for an exemption for requirements for issuance of an RWP for individuals continuously escorted by individuals qualified in radiation protection procedure.

Provides an additional alternate HRA entrance requirement for personnel possessing a monitoring device that continuously transmits dose rate and cumulative does rate to a remote receiver monitored by a radiation protection personnel.

Key control changed from administrative control of the Radiological Controls Supervisor to administrative control in accordance with a program approved by the radiation protection manager.

Page 13of17 Comments The proposed common language is consistent with, and bounds, the control device and alarm signal exceptions.

Key control will be in accordance with a program approved by the radiation protection manager that has been previously accepted by the NRC at an EGC site (Clinton).

Both HRA and LHRA requirements are contained in 6.12.1.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria Page 14 of 17 The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. EGC has determined that the proposed changes do not require any exemptions or relief from regulatory requirements. The following current applicable regulations and regulatory requirements were reviewed in making this determination:

1 O CFR 20. Standards for Protection Against Radiation 10 CFR 20.1101, "Radiation Protection Programs," requires licensees to develop and implement a radiation protection program appropriate to the scope of licensed activities and potential hazards. The proposed changes conform to 10 CFR 20.1101 requirements.

10 CFR 20.2102, "Records of Radiation Protection Programs," requires licensees document radiation protection programs. The proposed changes conform to 10 CFR 20.2102 requirements.

1 O CFR 20.1601, "Control of access to high radiation areas," provides requirements to provide access control features at each entrance or access point to a high radiation area.

The proposed changes conform to 10 CFR 20.1601 requirements.

NUREG-800. Chapter 12.5 Operational Radiation Protection Program This standard review plan provides NRC technical reviewers with guidance for acceptable requirements for an operational radiation protection program, in part, for the physical and administrative measures for controlling access to and work within radiation areas, high radiation areas (HRAs), and very high radiation areas (VHRAs). The proposed changes conform to NUREG-800 Chapter 12.5 requirements for HRAs.

Regulatory Guide 8.38. Rev. 1. Control of Access to High and Very High Radiation Areas in Nuclear Power Plants Regulatory Guide (RG) 8.38, "Control of Access to High and Very High Radiation Area in Nuclear Power Plants," published in May 2006 describes methods that the NRC considers acceptable for complying with the regulations regarding radiation safety and protection and for specifically complying with implementing the requirements of 10 CFR 20 Sections 1101, 2101, 1601and1602. The proposed license amendment conforms to RG 8.38 requirements for HRAs. With regards to HRA barrier key control, an administrative procedure (Reference 2) is in place to address the management oversight and specific control measures needed for entry into high and very high radiation areas, including the control and distribution of keys.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes 5.2 Precedent Page 15of17 The intent of the proposed changes is to implement a standard common language High Radiation Area TS to be used at all EGC sites. The proposed TS rewording is consistent with existing standard TS (STS) format of using two main sections (one for high radiation areas and one for locked high radiation areas}, with edits to remove redundancy and to improve clarity and readability.

5.3 No Significant Hazards Consideration Exelon Generation Company, LLC (EGC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1.

Will operation of the facility in accordance with the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes are administrative in nature and only related to the control of access to high radiation areas for controlling dose to plant personnel. The proposed changes do not impact any accident initiators and do not require any plant modifications which affect the performance capability of the structures, systems and components relied upon to mitigate the consequences of postulated accidents; therefore, there is no impact to the probability or consequences of an accident previously evaluated.

Based on the above, EGC concludes that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Will operation of the facility in accordance with the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed amendments involve changes to radiological program controls for access to high radiation areas, which are administrative in nature and do not impact physical plant systems. These proposed changes do not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed changes do not require any plant modifications which affect the performance capability of the structures, systems and components relied upon to mitigate the consequences of postulated accidents.

Based on the above discussion, EGC concludes that the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes Page 16 of 17

3.

Will operation of the facility in accordance with the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes are administrative in nature and only related to the control of access to high radiation areas to minimize dose to plant personnel. The proposed changes are intended to provide clarity and/or flexibility with respect to the administration and programmatic controls while retaining adequate margin of safety for minimizing dose to site personnel consistent with the requirements of 10 CFR 20, "Standards for Protection Against Radiation," and the guidance of RG 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," published in May 2006. Since there are no associated physical plant changes, the ability of the plant to respond to and mitigate accidents is unchanged by the proposed changes.

Based on the above, EGC concludes that the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation of the three criteria, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 1 O CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment does not change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 1 O CFR 20 and does not change an inspection or surveillance requirement. The proposed amendments only revise Technical Specifications related to the control of access to high radiation areas for controlling dose to plant personnel. The proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, in accordance with 10 CFR 51.22(b}, no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Evaluation of Proposed Changes Common Language for TS HRA Administrative Controls Docket Nos. Exelon Fleet Evaluation of Proposed Changes 7.0 REFERENCES Page 17of17

1. NUREG 1430, Standard Technical Specifications (STS), Babcock and Wilcox Plants, Revision 4, dated April 2012 NUREG 1431, STS, Westinghouse Plants, Revision 4, dated April 2012 NUREG 1432, STS, Combustion Engineering, Revision 4, dated April 2012 NUREG 1433, STS, General Electric BWR/4, Revision 4, dated April 2012 NUREG 1434, STS, General Electric BWR/6, Revision 4, dated April 2012

2. EGC Procedure RP-AA-460, Revision 36, Controls for High and Locked High Radiation Areas Proposed Technical Specifications Markup Pages Exelon Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls Braidwood, Units 1 & 2 Byron, Units 1 & 2 Calvert Cliffs, Units 1 & 2 Clinton Dresden, Units 2 & 3 James A. FitzPatrick LaSalle, Units 1 & 2 Limerick, Units 1 & 2 Nine Mile Point, Unit 1 Nine Mile Point, Unit 2 Peach Bottom, Units 2 & 3 Quad Cities, Units 1 & 2 R. E. Ginna Three Mile Island, Unit 1 TS pages 5.7-1, 2, 3 TS pages 5.7-1, 2, 3 TS pages 5.7-1, 2, 3 TS pages 5.0-20, 21 TS pages 5.7-1, 2 TS pages 5.7-1, 2, 3, 4 TS pages 5.7-1, 2, 3, 4, 5 TS pages 6-20, 20a, 21, 21a TS pages 359, 360, 361 TS pages 5.7-1, 2, 3, 4 TS pages 5.0-23, 24, 25, 26 TS pages 5.7-1, 2 TS pages 5.7-1, 2 TS pages 6-22

High Radiation Area 5.7 5.0 Am!INISIRATIVE CXlNIR0/1\\nsert 1 I 5.7 High Radiation Area This Specificatioo pJ?.:dcs altemate H£thods for COAtrolling access to high radiation areas and does flOt apply to very high radiatioo areas as defiRCd ifl IO CFR 20.

z

~i$'~~;

> 100 mrem/hr but $ l<XXl 111ru1t/ hr at 30 Clft (l~ inches) ff'CJft the radiatioo SOt:lf'CC or ff'Clft BHY surfaoc vAlim the radiatioo peHCtrates, shall be barricaded and COR3piruotJ:Sly J:lffited as a high radiatioo area and em:ranec thereto sltil l be rontrol led by requiring iS.9Uftl1CC of a Radiatioo Worh: Pcmit (".\\IP) or equi*vnlent

:at! =~:z=

!!

::~=~ ifl prutectioo equi(llHtt and llCfl9ttl'eS.

IHdividuals qualified in

~=~=:~z=~~ly csrorted reqttirenent during the perfo111E11Ce of their BS9igHCcl duties iH high radiatioo areas with ~

ffites < l<XXl mremlhr, provided they att atherwise fol lev1ing plBHt radiatioo prutectioo pffleedures for entry into Sl:lC:h high radiatioo areas.

Any iftdividual or grettp of iooividuals permitted to mter such areas shall be pt'O"¢ided with or ~ied by one or fll)f'C of the fol la.*fing:

ft;-

A radiation RVflitoring de'f*icc that coHtiFIUOtl9l)' iHdieates the radiatioo dose f'8te in the area.

A mdiatioo ftl)Jtitoring de'f*icc that COHtifltlOtJ9ly integrates the radiatioo dose rate in the area and alartlB ti'A1eH a pf'CSCt integtatcrl dose is recciYCd. Fntry into StJCh areas with this IOOftitoring device ftl) be HtiCk: after the dose ffite levels in the area have beCft established and pef'SOARCl arc mi,ere of thaH.

BRAIIMOOD - UNI1S 1 & 2 5.7 - 1 Airenchnent 98

5.7 High Radiation Area (eoftt: iAl:ICd)

High Radiation Area 5.7

~

An individtlal qualified in radiffi:ion protection pf'OCffktres with a radiffi:ioo dcX9e rate MlAitoriHg device, *,*,00 is responsible for providiHg J300itivc COAtrol over the activities 'Within the area and shall pcrfonn periodic radiation SUIVCillancc at the freqttCflC)' specified in the RWP or equivalrnt cloc:utefl:.

In addition to the requirateAts of 8f>ccification 5.7.1, areas occcssible to pcf'SOHRCI with radiation levels > lCXX) m1u1t/lu-at 30 OH (12 inches) fIUH the radiation source or fIUH MY surface r+'lhich the radiation penetrates shall require the follooiAg :

fuors shol l be loeh:ed to pre"Vffit liAfillthorii!Cd Cfltfj' and shall flOt prevent imividtlals from leaviAg the area.

lH place of loeldHg the doof', direct or COHtiflt:IOt.IS cleetf'Ollic

i~~ =*is~~

Svr:~!!~~~thc adftinistrative COHtrol of the Shift Mamger on duty or health physics St:JPCFvision:

tr.-

Pef'SOllftCl aeccss and ~

control requi l'Uleflts of activities beiAg pcrfof'ftl'Xi withiH these 0FCffi shal 1 be

~ified By OH ElfJPf'O\\>'Cd R.'JP or equivalCAt cloctlteHt that includes speeifiretiOH of radiation da9c rotes in the illlfOiiatc v.or)< area(s) and other appropriate mdi&tion protection equipocnt and HatSl:lf'CS ;

~

Each J;>CF90H entering the area shal 1 be pl"O'i*ided with an alarmmg radiation JOOHitoriAg dc'-t ice that ront:iHt:IOt19l)*

iflt:egrates the radiatioo da9c mt:c (sttCh as ftH clcctf'Oftic dosiHK!ter). 8ur4'Ci I lance and mdiation lft)flitof'i~ by health physics pcf'SOHflCl ftl:lY be sub9t i tuted for ftH alfl:Ilftlflg do9iH£ter ;

BRAIOOOOD - UNI1S 1 & 2 5.7 - 2 Airenchrent 98

5. 7 High Racliat ion Area High Radiation Area 5.7

=:ci/:tW= 1'!~1~~a!i~~i~ca:6dT:!)

that ore located withiH large areas such as reector

=::"~ =: ::: :!s: ~of eonstf'tlCtcd arotntd the individual area, that individual area shal I be aarrieadecl. COffiJ>iCtlOU9ly Pffitcd, a00 a flashing l ight shal I be acthftted as a warning device ; and BRAIIMOOD - UNI1S 1 & 2 5.7 - 3

5.0 Am!INISIRATIVE CllNIB!lL1nsert 1

5. 7 High Radiation Area High Radiation Area 5.7 12 This ~ific&tioo provides alternate H£t:hoci9 for COHtroll iHg access to high radiatioo areas and 6ecs f10t apply to very high mdiatioo areas as defiHCd in 10 CFR 20.

~;$~;

) 100 lllffllb!Jlr bttt S HXXl mrem/ hr at 30 Elli (12 iHChes) fIUH the radiatiOH SOl:l:f'CC or fRJfl flflY St:lf'facc vAlieh the radiation

==!!d~~~ =i==t;' a high requiriHg issuaftCC of a Radiatioo 'Abrl{ Pef'lllit (IMP) or equi'valent

== =:z=!!ci1: :;;;!!T!!:"r!d:t::es in protection eqttip1ent aH8 llfiJSttl'CS.

lndividtials qualified in

1~~

==~=ly escorted h1;i:tt::i:-~ilh= :t!:!r1:i~:~i~~

they are otherwise follCPNing plant radiatioo pPOteetion pmeedttre:9 for entry iflte Stteh high radiatioo areas.

Any incJh*idual or gF6tJp of ifldividtials pcF111itted to enter 9Uch oreas shal I be pF011idc6 with or ae:nnpanied by one or HK>f'C of the fu1lowiHg:

a-:-

A radiatioo Hl)HitoriHg device that COHtifll:lOtl9ly ifldic&tes the mdiatioo dose mte in the area.

b-:-

A mdiat ien llDli tor iHg de~* ice that COHt iHt10tBly ifttegt ates the radiation dose rate in the area and alarna v.fleH a preset integf'8ted do9e is receh'Cd.

&ttry iHto 9tlCh areas with this Hl)Hitoring device 118)' be lltide after the do9c mte levels in the area have beeH established and pef'SOOflel are aware of them.

BYRON - UNI1S 1 & 2 5.7 - 1

5. 7 High :Radiat: i6fl 1'\\rea (roHt inued)

High Radiation Area 5.7

~

AH individt:Jal qualified in mdiat:ion pmt:ection J:lf'OCCrlttr-e with a radiat:ion cb3e rate HDiitoring dc'iice, '/Ai> is FC:Sp0ft9iblc for providing positi~ control over the activities within the area and shall perform periodic radiat:ion Sttf"..eillanee at the f:reqttellCy specified in the m'.P Of' eqttivalCHt cloctmett.

bl addition to the requil'Cllefits of Specificat:ion 5.7.1, areas acccs.sible to pef'SOflflCl with mdiat:ion lc~ls > I(XX) mra11:/hr at 30 au (12 inches) fran the mdiat:ion source or ff'Clll aH}' stff'facc v.flich the radiation penetmtcs shall require the fol lc1fving:

tr.

Ik>ors shall be lodred to prevCflt t:maUthoriZ"Ctl entl)' and shall rot f>FC\\i'C:Ht iflclh*idt:Jals f1om lca~*iHg the area.

In plare of locldng the doOf', direct Of' eontinuotB electronic StUVCi llflflCe that is ~le of preventing 1::.H'lftUthoriZ"Ctl entry my be tt'3ed.

The ke}s shal I be ftl:linta:inetl t:mtler the administmtive eontml of the Shift ManagcF on duty Of' health physics supen*ision; lr.-

PcFS011t1Cl access and Gql09l1FC control reqttif'CftCflts of activities being peFfof'ftDi within these areas shaJ l be s~ified by tlfl appt"O't'CCI RWP or CX}Uivalent cloctluait that iocludes speeificat:ion of rediat:ion cb3e rates in the ilfftEdiate *1.orlt area(s) and other BfJPropriate radiation protect ion eqttiFHt and llHtSttf'C9;

~

Eadt J?Cf'SOO CHteriHg the area shall be flffivided with an al8f'lfttHg radiat:ion 1116fl:itoring device that eontitlllOllSly intcgrat:cs the radietion dese: f'flte (suck as an electronic dosinetcr). Sttn'Cillana:: and f'fldiation lfDllitoring B}' health physics personnel my be Stlbstitttted for an ttl8f'lftiHg dosinetcr; BYRON - UNI1S 1 & 2 5.7 - 2 AnEnchnent -100

5. 7 High Radie:tioo Area

~

(cont inuet:I)

High Radiation Area 5.7 that are loe&ted 'WithiH large areas such as reactor

~~.=:::~

shall be barrieadea, conspiCt10tt9ly po9ted, 0fld fl flashing I ight shall be activated as fl '+\\tll'fling dev ice; 0fld BYRON - UNI1S 1 & 2 5.7 - 3

5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area High Radiation Area 5.7 Pursuant to 10 CFR Part 20, paragraph 20.1601(c), in lieu of the requirements of paragraph 20.1601(a) and 20.160l(b) of 10 CFR Part 20:

5.7.1 Access to each high radiation area, as defined in 10 CFR 20, in which an individual could receive a deep dose equivalent > 0.1 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation) shall be controlled as described below to prevent unauthorized entry.

a.

Each area shall be barricaded and conspicuously posted as a high radiation area.

Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b.

Entrance shall be controlled by requ1r1ng issuance of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c.

Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may, for the performance of their assigned duties in high radiation areas, be exempt from the preceding requirements for issuance of an RWP or equivalent provided they are otherwise following plant radiation protection procedures for entry into, exit from, and work in such high radiation areas.

d.

Each individual or group of individuals permitted to enter such areas shall possess, or be accompanied by, one or more of the following:

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 5.7-1 Amendment No.

Amendment No.

5.7 High Radiation Area High Radiation Area 5.7

1. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset setpoint is reached.

Entry into high radiation areas with this monitoring device may be made after the dose rate in the area have been determined and personnel have been made knowledgeable of it.

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.

4. An individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by radiation protection supervision.

5.7.2 In addition to the requirements of Specification 5.7.1, high radiation areas in which an individual could receive a deep dose equivalent > 1.0 rem in one hour Cat 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour Cat 1 meter from the radiation source or from any surface penetrated by the radiation) shall be provided with a locked or continuously guarded door, or gate, or equivalent to prevent unauthorized entry.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 5.7-2 Amendment No.

Amendment No.

5.7 High Radiation Area High Radiation Area 5.7

a.

The keys to such locked doors or gates, or equivalent, shall be administratively controlled in accordance with a program approved by the radiation protection manager.

b.

Doors and gates, or equivalent, shall remain locked except during periods of access by personnel under an approved RWP, or equivalent, to ensure individuals are informed of the dose rate in the immediate work areas prior to entry.

c.

Individual high radiation areas in which an individual could receive a deep dose equivalent

> 1.0 rem in one hour Cat 30 centimeters from the radiation source or from any surface penetrated by the radiation), accessible to personnel, that are located within larger areas where no enclosure exists to enable locking, or that are not continuously guarded, and where no lockable enclosure can be reasonably constructed around the individual area require both of the following access controls.

1. Each area shall be barricaded and conspicuously posted.

2. A flashing light shall be activated as a warning device.

CALVERT CLIFFS - UNIT 1 CALVERT CLIFFS - UNIT 2 5.7-3 Amendment No.

Amendment No.

5.0 5.7 ADMINISTRATIVE c~ lnsert 1 I High Radiation A~

High Radiation Area 5.7 zz Pursuant to 10 GFR 20, paragraph 20.leOl(o), in lieu of the requirem.ents of 10 GFR 20.leOl(a), each high radi ation area, as defined in 10 GFR 20, in ',1hioh an individual could reoeive a deep dose equirralent :> 100 m.rem in one hotar (at 30 em.), shall be barrieaded and conspiouously posted as a high radiation area and entrance t hereto sha 1 1 be controlled by requiring issuance of a Radiation Work Perm.it (RWP) or equivalent *

.'\\ny individual OE group of individuals permitted to enter suoh areas shall be provided 11ith 1 or aocom.panied by, one or m.ore of the follo*.1ing ;

.a....

• "* radiation awnitoring device that continuously indicates tho radiation dose rate in tho area.

J\\ raEliatim=i m.onitorif:1g devioe tl=J.at oontinHously integrates the radiation dose rate in rho area and alarm.s 1~en a preset integrated dose is recei*,red.

Entry into such areas *o1ith this m.onitorin§ device ffiay be made after the dese rates in the area have been determined and personnel have been m.ade lm011led§eable of them.

An individual qualified in radia'tion proteetion prooedYres

'*ith a radiation dose rate monitorin§ ele*1ice,

~

individual shall be responsible for providing positive r adiation protection control over the activities *,.*ithin the area and shall perform periodie radiation surveillaRce at the frequency speeified by radiation protectioR supervisioR.

In addition to the requiremefits of Specification §,7,1 1 high radiation areas in 1,*hich an individual could receive a deep dose equivalent ~ 1000 mre'fl! in one ho\\lr (at 30 cm) shall be provided 11ith locked or contifiuously g\\larded eloors to prevent unauthorized entry,

The keys to such locked doors shall be administrath*ely controlled in acoordance 'n'ith a progra'fl! approved by the radiation proteetion manager.

Qoors shall remain looked except durin§ periods of access by personnel under an approved RWP 1 or equivalent, that shal l ensure the individuals are informed of the dose rates in the ifflfflediate 'dork areas.

(oontinued )

CLINTON 5.0-20 Amendment No. -+/--0-S f

High Radiation Area 5.7 5.7 High Radiation Area

~

(continued)

CLINTON Individual high radiation areas in 11hich an individual could receive a deep dose equivalent~ 1000 FRrem in one hour (at ]0 CFR) 1 accessible to personnel, that are located *.:ithin large areas such as roaster sontainment, t1hore no enc 1 osure exists for enabling losking 1 or that are not sontinuously guarded, and 11here no lockable enclosure can be reasonably cons~ruoted around the individual area, sha 1 l be barricaded and conspicuously posted, and a flashing light shall be acth*ated as a *.iarnin§ devise,

In addition to requirements of Specification 5. 7.1 and 5. 7. 2 for high radiation areas, if an individual oould receive a deep dose oqi,Jiualent > 3000 ffirem in one hour (at ]0 CFR) 1 the RWP or oquh*alent shall also specify tho m.aliiEAum a 1 lo*,;able stay tiFRe or dose (on an alarFRing dosiFRotor) for individuals in those areas.

In lieu of tho stay tiFRO or dose speoificaEion of the RWP or equivalent, direct or remote (such as closed oircuit TV cal'!loras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive onposure control over tho activities beinig per form.ad 11i thin tho areas.

Individuals qualified in radiation proteotion procedures or porsonrrnl continuously escorted by such individuals FRay 1 for the perform.ance ef their assigned duties in high radiation areas in 11hich an indi'.*idual could receive a deep dose equivalent :Si.J.00.Q.

fflrem in one hour (at :30 ma) 1 be eJrnmpt froffi the roquireH1ents of SpecificatioR 5. 7, 1 and 5, 7,2 for i ssuaRce of an RWP er equiv:alent provided they are othen<'ise follmdnt.J plant radiation protection procedures for entry inte such high radiation areas.

5. 0-21 Amendment No. ~.{'

5. 0 5.7 ADMINISTRATIVE c?

lnsert 1 I High Radiation A~

12 High Radiation Area

5. 7 As provided iR paragraph 20.1601(c) of 10 CFR Part 20, the followiRg coRtrols shall be applied to high raaiation areas in place of the controls requires by paragraph 20.160l(a) ans (b) of 10 CFR Part 20 :

High Radiation Areas with Dose Rates Not Exceeding 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Raaiation

-a-:-

Each entryiiay to stJch an area shal l be barricaded and conspicuo1;1sly posted as a high raaiation area.

-&ttt:fT barricades may be opened as necessary to permit entry or exit of personnel or equipment.

fr.-

Access to, and activities in, each such area shal 1 be control l ed by means of Radiation Work Permit CRWPl or equivalent that iRcludes specification of radiation dose rates in the immediate wor k area (s ) and other app ropri ate radiation protection equipment and measures.

-E7 Individuals qualified in radiation protection procedures and persoRnel continuously escorted by such individual s may be exempted from the requirement for an RWP or equivalent whi l e performing their assigned duties provided that they are otherwise following plaRt radiation protection procedures for entry to, exit from, and work in such areas.

fr:-

Each i ndi vi dual or group entering such an area si'lal 1 possess.

LaSalle 1 and 2

-l-:-

A radiation monitoring de1,;*i cc that con ti nuousl y displays radiation dose rates in the area; or

~ A radiation monitoring device that continuousl y integrates the radiation Gose rates in the area and alarms when the dev i ce ' s Gose alarm setpoint is reaches,

with an appropriate alarm setpoint, or

~ A radi ati oA moAitori ng devi cc that conti n1;1ous l y transmits dose rate and cumulative dose information to a remote receiver monitored by radiatioR protection personnel respons i ble for controlling personnel radiation exposure within the area, or (cOAtinued )

5.7-1 Amendment No. 161/147

High Radiation Area 5.7 5.7 High Radiation Area

~

High RadiatioA Areas ~dth Dose Rates Not Exceeding 1.0 rem/hour at 30 CeAtimeters from the RadiatioA Source or from any Surface Penetrated by the Radiation (continued)

4. A self reading dosimeter (e.g., pocl(et ionization chamber or electroAic dosimeter) and,

ffi Be under the sur*1ei 11 ance, as specified in the R\\IP or equivalent, while in the area, of aA individual qualified in radiation protection procedures,

equipped with a radiatien monitering device that continuously displays radiation dose rates in the area ; whe is responsible for centrelling personnel exposure with the area, or (ii) Be under the surveillance, as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiatien exposure in the area, and with the means to communicate with individuals in the area whe are covered by such surveillance.

-7 Except for i Adi vi duals qualified in raEli ati on protecti OA proceElures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.

These continuously escorted personnel will receive a pre job briefing prior to entry into such areas.

This dose rate determination,

knowledge, and pre job briefing does not require documentation prior to initial entry.

High Radiation Areas with Dose Rates Greater than 1.0 rem/hour at 30 Centimeters from the Radiation Source or from any Surface Penetrated by the Radiat1on. but less than 500 rads/hour at l Meter from the Radiation Source or from any Surface Penetrated by tf!e RadiatioR

~ Eacfi efltry*,,ay to such an area sha l l be conspicuously posted as a "1i gh radiation area afld shall be provided 1~ith a 1 oclted (continued)

LaSalle 1 and 2 5.7-2 Amendment No. 161/147

High Radiation Area 5.7 5.7 High Radiation Area

~

Hi qh Ra di ati on Areas l!'i th Dose Rates Greater than 1. Q rem/hour at 3Q Centimeters from the Radiation Source or from any Surface Penetrated bv the Radiation. but less than SQQ rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated by the Radiation (continued) or continuously guarded door or gate that prevents unauthorized entry, and, in addition:

h All such door and gate keys shall be maintained under the administrative control of the shift supervisor, radiation protection manager, or his or her designee.

~ Doors and gates shall remain locl<ed e>teept during periods of personnel or equipment entry or e>tit.

fr:-

Access to, and acti'v'ities in, eacl9 suet:! area shall be ccntrol lea by means of an R\\IP or equi \\lal ent that includes specification of radiation dose rates in tt:ie immediate work area(s) and other appropriate radiation protection equipment and measures.

In di vi duals qualified in radiation protection procedtJres may be exempted from the requirement for an RWP or equivalent while performing radiation surveys in such areas provided tt:iat they are ott:ierwise following plant radiation protection procedures for entry to, exit from, and work in such areas.

th-Each i nei vi dual or group entering such aA aFea st:Jal l possess one of the following :

LaSalle 1 and 2 h

A radiatiofl monitoring device that continuously integrates the radiation rates in the area and alarms when the device ' s dose alarm setpoint is reached, with an appropriate alarm setpoint, or

~ A radiation monitoring device tl'lat continuously transmits dose rate and cumulati'o'e dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation cxpos~re within the area witt:i the means to communicate with and control e'v*er,y individual in the area, or (continued) 5.7-3 Amendment No. 161/147

High Radiation Area

5. 7

5. 7 High Radiation Area

~

Hi ah Ra di ati on Areas h'ith Dos e Rates Greater than 1. 0 reffl/hour at 30 Centimeters from the Radiation Source or froffl anv Surface Penetrated by the Radiation. but less than SQQ rads/hour at 1 Meter from the Radiation Source or from any Surface Penetrated bv the Radiation (continued) 3-7 A self reading dosimeter (e.g., pocl(et ionization chamber or electronic dosimeter) and,

(i) Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation mon i toring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel exposure within the area, or Ci i ) Be under the survei 11 ance, as specified in the R\\IP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for control ling personnel raeiation exposure in the area,

and with the means to communicate with and control every individual in the area.

4-:-

In those cases ;;fiere options (2) aAd (3), above, are impractical or determined to be i Aconsi steAt *11i th tfie "As Low As is Reasonably Achievable " principle, a radiatioA monitoring device that conti nuously displays radiation sose rates iA the area.

~ Except for insividuals qualified in radiation protection procedures, or personnel conti nuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry persol'lnel are l<no*.1ledgeabl e of them.

These conti nuousl)'

escorted personAel will receive a pre job briefiAg prior to entry into such areas.

Tfiis ease rate determinat i ol'l,

knowledge, and pre job briefiAg does not require documentatioA prier to iAitial entry.

(contil'lued)

LaSalle 1 and 2 5.7-4 Amendment No. 161/147

5. 7 High Radiation Area High Radiation Area 5.7

~

I-Ii gh Radiation Areas *,ti th Dose Rates Greater tRan 1. O rem/hour at 30 Centimeters from the Radiation Source or from anv Surface Penetrated bv the Radiation. but less than 500 rags/hour at 1 Meter from the Ragiation Source or from any Surface Penetrateg by the Radiation (continued) f-;-

Such individ1;1al areas that are 1within a larger area '*+here no enclosure exists for the p1;1rpose of l ocking and where no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate, nor continuously g1;1arded, but shall be barricaded, conspicuous l y posted, and a clearly visible flashing light shall be activated at the area as a warning device.

LaSalle 1 and 2 5.7-5 Amendment No. 161/147

ADMINISTRATIVE CONTROLS 6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepared con-sistent with the requirements of 10 CFR Part 20 and shall be approved, main-tained, and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA~

l\\.s prouided in parai;praph 20. 101 {c) of 10 CFR Part 20 1 the follm:inq controls shall be applied to high radiaeion areas in plaee of the oontrols required by paragraph 20. 1601(a) and (b) of 10 GFR Part 20 :

e, !2. 1

!Ugh Radiation A£eas *.1ith dose £ates (deep dose equi'Jalent) §Teater than 0, 1 re'fll:/hr and not enceeding 1, 0 rem/hoYr (at ;rn centifflete£s from the radiation soYrces or from any surface penetrated by the radiation) :

a-.-

Each accessible entry1wy to SYch an area shall be barricaded and conspicyously posted as a High Radiation Area.

~

ba£ricades may be opened as necessary to permit entry or enit of personnel or equipment.

LIMERICK -

UNIT 1 6-20 Amendment No. 4-&, ~. ~

ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued) l'.eoess to, and aetivities in, each s1:lch area shall be eontrolled by H1eans of a Radiation Work PeEnit (RWP ) or equi¥alent that inel1:ldes radiation proteotion instr1:lctions 1 job coverage and H\\onitoring requirements.

Radiological information (i.e., dose rates ) is incl1:lded on the radiation surveys associated 11ith the RWP or equiua!.ent,

e-.-

Individ1:lals qualified in radiation protection prooedl:lres and personnel contin1:leusly escorted by such individuals may bG oxoH1pted froH! tl:ie requirm:11ent fer an R-WP o;r equivalent ',1h::le perfonRi ng their assigned d1:lties provieiod that they are fellm:ing plant radiatien protection precedYres fer entry to, e>tit from, and 1rnrk in such areas.

4....

Each inEli"idual or group entering sucl:i an area shall be provided

• .ii th er accewo13anied by ono or mere of the folle11in13 ; r

.. radiation t110Ritoring Elevice chat contin1:lousl;* displays

radiatieR dose :rates in the area ("radiation monitoring and inElicating device" ), OR

• "* radi.atioR E110nitoring Ele*1ice Hi th the capability to display accilltlbllated dose and 11hich coRtin1:lously integrates the radiation dose rates in the area and alafl!ls 11l:ien the devise ' s dose alarm setpoint is reached ("alaFRling desimeter" ), OR

.n, radiation monitering device ',1hh the eapability to display aocYmulated dose and 1.:hich oentimamasly transmits Elose rate and oYmYlatiIJe dose information to a reff\\ote receiver monitored by radiation proteotien persennel :responsible for contrelling personnel radiation exposure 11ithin the area, OR

.n, di:rect reading dosimeter A~m ;

a+

,\\ health physics qualifi ed individual ( i, e.,

qualified in radiaeion pretection proeedures )

• ,Jith a radia... ion dese rate ffl0ni torin9 eevice t~o is respensible for cont rolling perseRnel raEliation exposure Hitain the area, OP.

ae under the surveillance, as specified in Ehe RWP o:r equivalent, by means of closed eirc1:lit television, of a health physics qualified individual (i. e., qualified i n :radiation protection p:recedures ),

responsible f or cont:roll ing personnel radiat i on elfpos1:1;ro i n the a:rea.

et-

!!.Mcept fo:r in.dividuals quali!ied in radiation protection preeedu:res 1 entry into sueh areas shal l be ffiade only after dose rates in the area have been established and entry personnel are knmiledgeable of thet11.

LIMERICK - UNIT 1 6-20a Amendment No. ~

ADMINISTRATIVE CONTROLS MICW R..DL'\\TIGN A.Q,E,'\\ (Continued) a. 12,2 In addition to the requirements of Section e. 12.1 1 Wigh Radiation fu=eas 1 *ith dose rates (deep dose equivaleRt) greater than 1, Q rem/hour (at 30 oenti111eters from the radiation souree or from any surface penetrated by the raEliation), but less than SQQ rad/hr (at 1 meter from tho radiation source or frDHl any surface penetrated by the raEliation souroe) accessible to personne~ shall be controlled as folloHs :

a-..-

Eash aeoessible ant£)" *ay to such an area shall be con spicm:1sly posted as a High Radiation Area and shall be provided Pith a locked door, gate, or guard that pre"ents llilauthorized entry, and in addition :

~

All such door arid gate keys shall be maintained under the administrative control of radiation protection supervision.

Doors and gates shall remain locked or guarded eimept during peri.ods of personnel or eq1olipFE1ent entry er exit.

&r al:leh individual areas that are *.rithin a larger area, Sl:lch as sontairuttent 1 that is oontrolled as a High Radiation,11,,rea,

'.. there no enclosure i;mists for purpose of locking and Hhere no enclosure can reasonable be construoted around the individual area need not be controlled by a locked door or gate,

but shall be barricaded and oonspieuously posteEI as a Migh Radiation.".rea, and a eonspicuous, eloarly visible flashing light shall be acth*ateEI at the area as a 11arning device,

~

l!:aoh individ.ual entering suoh an area shall be provid.ed 'lith or accoH1panied b')' one or more of the follo'>'ing:

It dose rate survey motor and a radiation monitoring device 1.*ith the capability to display acel:lffiulated dose and. an integrating alaER setpoint 1 OR P, radiation JRonitoring devise 'n'ith the eapability to display aecuraulated dose and *.ihich eontimaously integrates the radiation dose rates in tho area and alarFE!s 1.'hen the devise ' s dose ala Fil-I setpoint is reached ("alarFEling dosiFE1eter" ) 1 OR A radiation FE!Onitoring devise ttith tho capability to display acc1::H'Atllatod dose and 11hieh eontinuously transmits dose rate and cUR1ulative dose infoFl!lation to a rm1mte receiver FE!onitored by radiation protection persennel £esponsible for controlling personnel radiation 011posuro *.iithin tho area l'kH:l 'n'ith the means to COR'.nrunicate 1.1ith the individuals in the area, OR A direct reading dosilReter,'\\ND :

LIMERICK - UNIT 1 6-21 Amendment No. 48-, ~

ADMINISTRATIVE CONTROLS HIGM RADIATIO~I,1\\.1(.l!:J\\ (Continued )

a+

A health physios EJYalified individual (i.e.,

~alified in radiation proteotion prooedures )

• .1ith a radiat:.on dose rate 'Rl0nitorin13 de0vice t1ho is responsible for G0Rtrollin13 personP..el radiation exposi:1re *.lithin the area, OR b}

Be

~.mder the swrveillaAoe, as specified iR the RWP or e11Yivalent, by Hl.Oans of closed oirm.,iit telei.*isi on, of a health physics 'lYalifieEi individi:1al (i. e., ql<alified in radiation protection prooedures ) 1 responsible for 00Rt rol l in13 personnel radiaEion exposure in the area, anEI *,*ith the FReans to oo~nicate Hith the imEviduals i n the area,

6.13 PROCESS CONTROL PROGRAM (PCP) 6.13.1 Changes to the PCP:

a.

Shall be documented with the following information:

1.

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and LIMERICK -

UNIT 1 6-2la Amendment No. +3§,.J,+&

6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepared con-sistent with the requirements of 10 CFR Part 20 and shall be approved, main-tained, and adhered to for all operations involving personnel radi ation exposure.

~

6.12 HIGH RADIATION AREA~

As provided in paragr~l=t 20.1601(c) of 10 CFR Part 20, tl=te following controls shall be applied to l=tigh radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:

6.12.1 High Radiation Areas witl=t dose rates (deep dose equivalent) greater than 0.1 rem/hr and not exceeding 1.0 rem/hour (at 30 centimeters f rom the radiatioR sources or from any surface penetrated by ttle radiatioR):

a.

Eacl=t accessible entryway to such an area shall be barricaded and coRspi eu01:1s1 y posted as a High Radiation Area. ~

barricades may be opened as necessary to permit entry or exit of personnel or equipment.

LIMERICK - UNIT 2 6-20 Amendment No. H, -100, 38

HIGH RADIATION AReA (CoRtiRued)

b.

Access to, and activities in, each such area shall be controlled by means of a RadiatiOFt \\l.'orl< Permit (RWP) or equivalent that iRcludes radiatioR protection iRstructioRs, job coverage aRd moRitoring requirements.

Radiological informatioR (i.e., dose rates) is included on the radiation surveys associated with the W.~P or equivaleRt.

IRdividuals qualified in radiatioA protection procedures and persoAnel coRtinuously escorted by such individuals may be exempted from the requirement for aR RWP or equivaleRt while performiRg their assigned auti es pro¥i eled that the~,. are following pl ant radiatioA protection proceelures for entry to 1 exit from, and worl< in such areas.

a.

Each iRdi¥idual or group entering such an area shall be pro¥ided with er accompanied by one or more of the fellowing:

h-A radi atioR moAi toriRg elevi cc that eonti nueusl y displays raeliatioA elese rates in the area ("radiation menitoriRg and indieatiAg device"), OR h

A radiation meAi tori ng device with the capabi 1 i ty to elisplay accumulateel dose and which coAtinuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reacheEI ("alarming dosimeter"), OR

3.

A radi at ion men i tori ng elevi cc with the capabil i ty to display accumulated dose aAd which continuously transmits dose rate and cumulative ease information to a remote receiver monitored by radiation protection personnel responsible fer controlling personnel radiation exposure within the area, OR

4.

A direct reading dosimeter AND:

aj.-

A health physics qualified individual (i.e.,

qualified in raeliation protection procedures) with a radiation close rate Rlonitoring device who is responsible for controlling personnel raeliation exposure within the area, OR Be uRder the surveillaAce, as specified iA the R

1.~P or equivalent, by means of closed circuit television, of a health physics qualified iRdividual (i.e., qualified in raeliatioA protectioA procedures),

respoAsible for controlling personnel radiation exposure in the area.

e-...

Except for i neii vi duals qualified in radiati OR protecti OR procedures, CAtry into such areas shall be fflade only after dose rates in the area have been establisheel aAd entry pc rsonnel are lrnowl edgeabl e of them.

LIMERICK - UNIT 2 6-20a Amendment No. lGG

HICH RA9IATION AREA (Continued) 6.12.2 In addition to the requirements of Section 6.12.l, High Radiation Areas witl'i dose Pates (eleep dose equivalent) greater than 1.0 rem/hour (at 30 centimeters from the Padiation source or from any surface penetrated by the radiation), eut less than SOO rad/hr (at 1 meter from the radiation source or from any surface penetrated by the radiation source) accessible to personnel shall be controlled as follows:

a.

Each aceessi bl c entryway to s1;1ef:I an area shall be eon spieously posted as a High Radiation Area and shall be provideel with a loel(ed door, gate, or g1;1ard tf:lat prevents unauthorized ent r~*, and i n ad di ti on :

+/--;.

All such door and gate keys shall be maintained 1:1nder the aelministrative control of raeliation protection s1:1pe nl'i s ion.

h Doors and gates shal 1 remain l oel<ed er guareled eiEeept during periods of personnel or eq1;1ipment entry or eKit.

a.

Such individ1;1al areas that are within a larger area, s1;1ch as containment, tf:lat is controlled as a Higf:I Radiation Area, where no enclosure eKists for 131;1rpose of locking anel where no enclos1;1re can reasonable be constructed aro1;1nel tf:le indi*o'id1;1al area need not be controlled by a locked door or gate, but shall be barricaded and eonspic1;1ously posted as a High Radiation Area, and a conspic1;101;1s, clearly visiele flashing 1 i ght shall ee aeti vatcd at the area as a warni n§ de*.. i cc.

Eo Eaef:I individual entering such an area shall be 13rovided with OF' aceom13anied ey one or more of the following:

h A dose rate s1;1rvcy meter anel a radiation fflonitoring device witf:I the capability to dis13lay accumulated dose and an integrating alarffl setpoint, OR h

A radiation monitoring elcvi ce with tl'ie capabi 1 i ty to display accumulated dose and which eontin1;101;1sly integrates the radiation dose rates in the area anel al arms wf:len the de*o'i ce' s dose al arm sct13oi nt is reacl'ied ("alarming dosimeter"), OR h

A radiation monitoring de'o'ice witf:I the capability to display acc1;1m1;1lated elose and which contin1;101;1sly transfflits dose rate anel Cl:lffll:llative dose information to a remote receiver monitorcel by radiation protection 13ersonnel responsible for controlling personnel raeiation expos1;1re witl'iin the area A~D witl'i the means to communi eate with tf:le i ndhii duals in the area, OR

4.

A di reet reading dosimeter A~IO:

LIMERICK - UNIT 2 6-21 Amendment No. H, +/-GO

ADMINISTRATIVE CONTROLS HIGM RADIATION AREA (CoAtiAued) at A heal th physics qualified i Adi vi d1:1al (i. e.,

quali fied iA radiatioA protection proeed1:1res) witl'l a radiatioA dose rate moAitoring device who is respoAsible for controlliAg personAel radiatioA e><posu re within t he area, OR 91-Be l:fnder die su rireil 1 aAce, as speei fied in the R'i'JP or equivalent, by means of closed circuit television, of a health physics qualified individual (i.e., qualified in radiation protection procedures),

responsible for cont rolling personnel radiatioA e><posure in t he area, and wi t h the means to colffmunieate wi t h the individl:fals in the area.

6.13 PROCESS CONTROL PROGRAM CPCP) 6.13.1 Changes to the PCP:

a.

Shall be documented with the following information:

1.

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and LIMERICK - UNIT 2 6-21a Amendment No. +/-ea, +/-33

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High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area rlnsert 1 I IV As provided in paragraph 20.1601 (s) of 1 O CFR Part 20, the following sontrols shall be applied to high radiation areas in plaoe of the oontrols required by paragraph 20.1601(a) and (b) of 10 CFR Part 20.

~

.-4igh Radiation Areas with Dose Rates not E>meeding 1.0 remlhom (at JO oentimeters from the radiation souroes or from an'r surfaoe penetrated bv the radiation)

NMP2 a-:-

Eaoh entryv<<ay to such an area shall be barricaded and conspicuously posted as a high radiation area. Sush barrioades may be opened as nesessary to permit entry or exit of personnel or equipment.

tr.

Access to, and activities in, each sush area shall be controlled by means of a Radiation Work Permit (RWP) or equivalent that includes speoifioation of radiation dose rates in the immediate work area(s) and other appropriate radiation proteotion equipment and measures.

Individuals qualified in radiation protection prooedures and personnel oontinuously esoorted by suoh individuals may be mc:empted fron:i the requirement for an RVIJP or equivalent while pertorn:iing their assigned duties provided that they are following plant radiation proteotion prooedures for entry to, exit fron:i, and work in suoh areas.

Eh Eash individual or group entering suoh an area shall possess at least one of the following:

+.

A radiation n:ionitoring de*Jioe that oontinuously displays radiation dose rates in the area ("radiation monitoring and indioating devise").

~

A radiation n:ionitoring devise that continuously integrates the radiation dose rates in the area and alarn:is when the device's dose alarn:i setpoint is reached

("alarming dosin:ieter"), 'A'ith an appropriate alarn:i setpoint.

a.:-

A radiation monitoring de*l'ioe that oontinuously transmits dose rate and oun:iulative dose to a ren:iote reoei*l'er n:ionitored by radiation proteotion personnel responsible f.or oontrolling personnel radiation exposure within the area.

5.7-1 Amendment 94-

High Radiation Area 5.7

5. 7 High Radiation Area

&.+:-+

High Radiation Areas with Dose Rates not Exseeding 1.0 rem/hour (at JO oentirneters from the radiation sourses or from an*t surfaoo penetrated bv the radiation) (oontinued) 4:-

A self reading dosimeter and,

~ Be under the surveillanoe, as speoified in the RWP or eei1:Ji't'alent, while in the area, of an indi't'id1:Jal at the work site, Ell:Jalified in radiation proteotion prooedures, equipped with a radiation monitoring and indicating device who is responsible for oontrolling personnel radiation exposure within the area, or

~ Be under the surveillanoe, as specified in the RVVP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation proteotion procedures, responsible for controlling personnel radiation exposure in the area.

e-,

E::>mept for individuals qualified in radiation proteotion prooedures, entry into suoh areas shall be made only after dose rates in the area hmm been established and entry personnel are knowledgeable of them.

~

High Radiation Areas with Dose Rates Greater than 1.0 rem!hour (at JO oentimeters from the radiation souroe or from anv surfaoe penetrated by the radiation). but less than 500 rads/hour (at NMP2 1 meter from the radiation souroe or from any surfaoe penetrated by the radiation) a:-

Each entryway to sueh an area shall be eonspieuously posted as a high radiation area and shall be pro*1ided with a looked door, gate, or guard that prevents unauthorized entry, and in addition:

+.

All suoh door and gate keys shall be maintained under the administrative oontrol of the Station Shift Supervisor Nuclear or a designoe, or the radiation proteotion manager or a designeo; and

~

Doors and gates shall remain looked or guarded exeept during periods of personnel entry or exit.

5.7-2 Amendment 9 High Radiation Area 5.7

5. 7 High Radiation Area

~

l=ligh Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 oontimeters froffi tho radiation souroe or from any surtaoe penetrated by the radiation). but less than 600 rads/hour (at 1 NMP2 meter frorn the radiation souroe or from any surfaoe penetrated by the radiation) (oontinued)

~

Aoeess to, and aotivities in, eaoh suoh area shall be oontrolled by means of an RWP or equivalent that inoludes specifieation of radiation dose rates in the irnffiediate work areas(s) and other appropriate radiation protection equiprnent and ffieasures.

s,.

Individuals qualified in radiation protection procedures may be exeffipted frorn the requirement for an RWP or equi\\lalent while performing radiation suJVeys in suoh areas pro.. *ided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.

4:

Each indi.. *idual (whether alone or in a group) entering such an area shall possess at least one of the following:

+.

An alarrning dosimeter with an appropriate alarm setpoint.

~

l\\ radiation monitoring device that oontinuously transrnits dose rate and ournulative dose to a remote reoei'.'er monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area with the means to oomm1:1nioate with and sontrol e*.. ery individual in the area.

~

A self reading dosiffieter and, (a)

Be under the suF\\*eillanoe, as speoif.ied in the RWP or equivalent, while in the area, of an individual qualified in radiation proteotion procedures, equipped with a radiation monitoring and indicating de*t'ice who is responsible for controlling personnel exposure within the area, or 5.7-3 Amendment 94-

High Radiation Area 5.7

5. 7 High Radiation Area

~

High Radiation /\\reas with Dose Rates Greater than 1.0 rem/ho1:1r (at 30 eentimeters from the radiation so1:1roe or from anv suriaee penetrated b*1 the radiation). b1:1t less than 500 rads/hour (at 1 NMP2 meter from the radiation so1:1rce or from any s1:1rface penetrated by the radiation) (oontinued)

~ Be under the surveillanoe, as speoified in the RWP or eq1:1i¥atent, while in the area, by means of olosed oiro1:1it television, of peFSonnel qualif-ied in radiation proteotion prooed1:1res, responsible for sontrnlling personnel radiation e><posure in the area, and with the means to sommunioato with and sontrol mmry individ1:1al in the area.

4:

A radiation monitoring and indioating device in those oases where the options of Specif-isations 5.7.2.d.2 and 5.7.2.d.3, abo¥e, are impraetical or determined to be ineonsistent with the "As Low As is Reasonably Achievable" principle.

e-:-

Exoept for individuals qualified in radiation protootion prosed1:1res, entry into s1:1eh areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.

t Sush individual areas that are within a larger area that is eontrolled as a high radiation area, where no enclos1:1re exists for p1:1rpose of looking and where no enelos1:1Fe oan reasonably be eonstructed aro1:1nd the indi¥id1:1al area need not be oontrolled by a looked door or gate, but shall be barrioaded and oonspiouo1:1sly posted as a high r:adiation area, and a oonspie1:1ous, elearly i.*isible flashing light shall be astivated at the area as a warning de*1iee.

5.7-4 Amendment 9+

5.0 ADMINISTRATIVE CONTROLS

5. 7 High Radiation Areas~ lnsert 1 k?'

Hi gh Radiation Areas 5.7 As provided in paragraph 20.160l (c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601Cal and Cb) of 10 CFR Part 20 :

High Radiation Areas with Dose Rates not Exceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation) :

Each entryway to such an area shall be barricaded and conspicuously posted as a high radiation area.

.£ttEfl.

barricades may be opened as necessary to permit entry or exit of personnel or equipment. :-

Access to, and acti*<<ities in, each s1:Jch area shall be controlled by means of a Radiation Work Permit CRWP) or eql:livalent that includes specification of radiation dose rates in the immediate work area(s) and other appropriate radiation protection equipment and measures.

-c-:-

Individuals qualified in radiation protection procedures and personnel continuously escort ed by such individuals may be exempted from the requirement for an RWP or eql:livalent while performing their assigned duties provided that they are othen/i se foll m1i ng pl ant radiation protection procedures

)"

for entry to, exit from, and work in such areas.

~ Each individual or group entering such an area shall possess:

PBAPS UN IT 2

-+/--:-

A radiation monitoring ele*ti cc tt:iat con ti nuousl y displays radiation dose rates in the area ("raeliation monitoring anel indicating device "), or :-

A radiation monitoring device that continuously integrates t he radiation dose rates in the area and alarms when the device ' s dose alarm setpoint is reached

("alarming dosimeter "), with an appropriate alarffi setpoint, or -:-

A radiation monitoring device tRat continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsibl e for controlling personnel radiation exposure within the area, or 5.0-23 Amendment No. 4G

~ High Radiation Areas High Radiation Areas 5.7

~

High Ra di ati on Areas

~.*ith Dose Rates not E>lceedi n§l 1. 0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated by the radiation):

(continued) 4-:-

A self reafiing dosimet er (e.g., pocket ion chafllber or electronic aosimeter) ana,

+t+

Be under the surveillance, as specified in the RWP

~

or equivalent, while in the area, of an individual qualified in radiation protection procedures, +

equipped with a radiation monitoring device that continuously displays radiation dose rates in the area ; who is responsible for controlling personnel radiation exposure within the area, or (ii) Be under the sur*,reillance, as specified in the RWP

)"

or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsib~

for controlling personnel radiation exposure in the area, ana 1.*ith the means to communicate 1o'ith

{

individuals in the area who are covered by such surveillance.

e-;-

Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined ana entry personnel are knowl edgeable of them.

These continuously escorted personnel shall receive a pre job briefing pri or to entry into such areas.

This dose rate determination,

kno'n'ledge, and pre job briefing does not require documentation prior to initial entry.

PBAPS UNIT 2 High Radiation Areas 1fith Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour <at 1 meter from the radiation source or from any surface penetrated by the radiation)

Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and, in addi t ion: :-

All such door and gate keys shal 1 be maintained under the administrative control of the shift supervi sor,

radiation protection manager, or his or her designee.

~ Doors and gates shall remain 1 ocked ei(cept during periods of personnel or equipment entry or exit.

5.0-24 Amendment No. -24G

High Radiation Areas 5.7 :- High Radiation Areas

~

High Radiation Areas *11ith Dose Rates Greater than 1.0 reFR/hot:JF Cat 30 centiFReters froFR the radiation source or froFR any surface penetrated by the radiation). but less than 500 rads/hour Cat 1 meter froFR the radiation source or froFR any surface penetrated by the radiation)

(continued)

~ Access to, and activities in, each sucfi area sfial l be controlled by FReans of an RWP or equivalent tfiat includes speci fi ca ti on of radiation dose rates in the 1mFRedi ate *,1ork area(s) and otfier appropriate radiation protection equipFRent and FReasures.

-e..,..

I ndi vi duals qual i fied in rad i ation protection procedures FRay be e>leFRpted froFR the requi reFRent fer an R\\IP or equivalent while performing radiation surveys in such areas provided that they are othen4i se foll OHi ng pl ant radi ati en protection )"

procedures for entry to, exit from, and work in such areas.

Eacfi i ndi vi dual (li'hether al one or in a group) entering such an area shall possess :

PBAPS UN IT 2 A radiation monitoring device that continuousl y integrates the radiation rates in the area and al arms when the device ' s dose al arFR setpoint is reached, with an appropriate alarm setpeint, or b

A radiation meni tori ng device that continuousl y transmi ts dose rate and cuFRulativc dose information to a remote receiver monitored by radiation protection personnel responsibl e for controlling personnel radiation exposure within the area with the means to communicate with and control every individua l i n the area, or A self reading dosiFReter (e.g., pocket ion chamber or electronic dosimeter) and,

.f-4-t Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qua l ified in rad i atioA protectioA procedures, equipped with a radiation monitoriAg device that continual l y displays radiat i oA dose rates in tfie area ; who is responsible for coAtrolliAg personnel exposure withi n the area, or 5.0-25 Amendment No. ~

High Radiation Areas 5.7

~ High Radiation Areas High Radiation Areas with Dose Rates Greater than 1.0 rem/hour Cat 30 centimeters from the radiation source or from any surface penetrated by the radiation). but less than 500 rads/hour Cat 1 meter from the radiation source or from anv surface penetrated bv the radiation)

(continued)

Ci il Be under the surveillance, as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel raaiation exposure in the area, and with the means to communicate with and control every i ndi vi dual in Hie area.

4-c In those cases ;,here the options of Speci fi cations

~

5.7. 2.d. 2 and 5. 7. 2.d.3, above, are impractical or determined to be inconsistrnt it'ith the "As Lo*.~ As is Reasonably Achievable " principle, a radiation monitoring t device that continuously displays radiation dose rates in the area.

e-:-

EJ(Cept for individuals qualified in raEliation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.

These continuously escorted personnel shall receive a pre job briefing prior to entry into such areas.

This dose rate determination,

PBAPS UN IT 2 lrno*.. *l edge. a REI pre job briefing does not require documentation prior to initial entry.

Such individual areas that are within a larger area where no enclosure exists for the purpose of locking and where no enclosure can reasonably be constructed around the individual area need not be controlled by a locked door or gate, nor contiRuously guarded, but sha;1 be barricaded,

conspicuously posted, and a clearly visible flashing light shall be activated at the area as a warning device.

5.0-26 Amendment No. 4it

5.0 5.7 ADMINISTRATIVE CONTROLS High Radiation Areaz-jlnsert 1 It High Radiation Areas 5.7 As pFovided in paFagFaph 20.lGOl(c) of 10 CFR PaFt 20, the following controls shall be applied to high radiation areas in place of the controls Fequired by paFagraph 20.1601(a) and (b) of 10 CFR Part 20:

Hiah RadiatioA AFeas with Dose Rates not ExceediAa 1.0 Fem/hour Eat 30 ceAtimeteFs from the radiation sources OF from any suFface penetFated by the radiation):

a.-

Each eAtry~ay to such aA area shall be barricaded and conspicuously posted as a high radiation aFea. ~

baFricades may be opeAed as necessaFy to peFmit entry oF e><it of personnel oF equipmeAt.

b-.

Access to, and activities in, each such aFea shall be controlleel by means of a Radiation \\'Jori< PeFmit (RWP) or equivaleAt that inclueles specification of radiation close rates iA the immeeliate work area(s) and other appropriate Fadiation protection equipment and measures.

t.

Individuals qual ified iA radiation protection procedures and peFsoAnel continuously escorted by such individuals may be e><empted from the requirement fer an RltJP or equivalent while otherwise performing their assigned duties pFovided that

~

they are following plaAt radiation protection procedures for entry to, e><it from, and work in such areas.

Each individual or group entering such an area shall possess:

PBAPS UNIT 3 h

A radiation monitoring device that coAtinuously elisplays Fadiation dose Fates in the aFea ("Fadiation moni to Fi ng and iF1di cati ng device"), or h

A radi ation monitoring device that continuously integrates the Fadiation dose rates iA the area and alarms when the device's dose alarm setpoint is reached

("alarming dosimeter"), with aA appropriate alarm setpoint, OF

-3.-

A radiation monitoring device that continuously transmits dose rate and cumulative dose infoFmation to a Femote FeceiveF monitored by radiation protection personnel responsible for controlling personnel Fadiation e><posure within the area, or EcontiAued) 5.0-23 Amendment No. ~

High Radiation Areas 5.7

~ High Radiation Areas High Radiation Areas with Dose Rates not E*ceeding 1.0 rem/hour (at 30 centimeters from the radiation sources or from any surface penetrated bv the radiation):

(coAtinued)

A self reading dosimeter (e.g., pocket ion chamber or electronic dosimeter) and, f:i Be under the surveillance, as specified in the RWP or equivalent, while in the area, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring device that continuously displays radiation dose rates in the area; who is responsible for controlling personnel radiation eMposure within the area, or (ii) Be ui=ide r the su rvei 11 ance, as specified in the RWP or equivalent, while in the area, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation eMposure in the area, and with tne means to communi cate with f individuals in the area who are covered by such surveillance.

e-;-

EMcept for iAdivi duals quali fi ea in radiation protection procedures, or personnel continuously escorted by such individuals, entry into such areas shall be made only after dose rates in the area have been determined and entry personnel arc lrnowledgeabl e of them. These continuously escorted personnel shall receive a pre job briefing prior to entry into such areas.

This dose rate determination, knowledge, and pre job briefing does not require documentation prior to initial entry.

PBAPS UNIT 3 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour Eat 30 centimeters from the radiation source or from any surface penetrated bv the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface eenetrated by the radiation)

Each entryway to such an area shall be conspicuously posted as a high radiation area and shall be provi ded with a locked or continuously guarded door or gate that prevents unauthorized entry, ancl, in adclition:

h All such door and gate l<eys shall be maintainecl under the administrative control of the shift supervisor, raaiation protection manager, or his or her designee.

h DooFs and gates shall remain locked e><cept during periods of personnel or equipment entry or exit.

5.0-24 Amendment No. ~

~ High Radiation Areas High Radiation Areas 5.7 High Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation source or from any surface eenetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface eenetrated by the radiation)

(continued)

Access to, and activities in, each such area shal l be controlled by means of an Rv!P or equivalent that includes speci fi cation of radiation dose rates in the immediate wo Fl<

area(s) and other appropriate radiation protection equipment and measures.

t-.

Indi*1iduals qualified in radiation protectioR procedures may be e><empted from the requi remeAt for an W.\\IP or equivalent while performing radiatioA surveys iA such areas provided that they are otherwise following pl aAt radi atioA protection

...-f"'

procedures for eAtry to, e><it from, and work in such areas.

Ead1 individual (whether alone or iR a gro1:Jp) entering s1:Jch an area shall possess:

PBAPS UNIT 3 A radiation monitoring device that continuously integrates the radiation rates in the area and alarms when the device ' s dose alarm setpoint is reached, with an appropriate alarm setpoint, or

~ A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored ey radiation protection personnel responsible for controlling personnel radiation expos1:Jre withiA the area with the means to communicate with and control every individual in the area, or A self reading dosimeter (e.g., pocket ioA chamber or electronic dosimeter) aAd, fi Be uAder the survei 11 ance, as specified in the RvlP or equivalent, while in the area, of an individual qual ified in radiation protection procedures, equipped with a radiation monitoriAg device that continuously displays radi ation dose rates in the area; who is responsibl e for controll ing personnel e><posure within the area, or 5.0-25 Amendment No. -243

+

High Radiation Areas 5.7 rl-High Radiation Areas

~

High Radiation Areas with Dose Rates Greater than 1.Q rem/hot:ir Cat 30 centimeters from the radiation source or from aAy surface peAetrated by the radiatioA), but less thaA SQQ rads/hour Cat 1 meter from the radiatioA source or from aAY surface penetrated by the radiatioA)

(coAtinued)

(ii) Be tinder the st1rvei1l ance, as speci fi eel i A the RWP J,

or equivaleAt, whi l e in the area, by means of closedl circuit television, of persoAnel qualifieel in radiatioA protectioA procedures, respoAsiblc for eoAtrolliAg persoAAel radiatioA exposure in the area, and with the meaAs to commt1Aicate with aAd coAtrol every iAdividtial iA the area.

4-.

IA those cases where the options of Specifications

~

S.7.2.d.2 aAd 5.7.2.d.3, above, are impractical or determined to be inconsistent with the "As Low As is ReasOF1abl y Achievable" pri Rei pl e, a radi atioA meAi toriAg f device that contiAueusl y displays radiation dose rates in the area.

e.

Except for individual s qtialified iA radiatioA protection precedtires, er personAel centinuetisly escorted by such individuals, entry into Stich areas shall be made only after dose rates in the area have been determined and entry personnel are kAewledgeable of them.

These coAtinuously escorted personAel shall receive a pre job briefing prier to eAtry into such areas. This dose rate determiAatien,

knowledge, and pre job briefing does not require documentation pri or to iAitial eAtry.

PBAPS UNIT 3 Such individual areas that are withiA a l arger area where enclosure eHists for the purpose of locking and where no enclosure can reasoAably be constrticted around the individual area Aced not be coAtrolled by a locked door or gate, nor centintiously guarded, but shal l be barri caded, censpicuotisly posted, aAd a clearly visible flashiRg light shall be activated at the area as a warning device.

no 1' 5.0-26 Amendment No. ~

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS 5.7 High Radiation Area d

lnsert 1 I i2 Pursuant to 10 CFR 20, para§raph 20.1601Cc), in lieu of the requirements of 10 CFR 20.1601, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is

> 100 mrem/hr but< 1000 mrem/hr at 30 cm (12 in. ), shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requirin§ issuance of a Radiation Werle Permit CRWP) (or equi 'valent document).

Indi'v'iduals qualified in radiation protection procedures (e.§., radiation protection technicians) er personnel escorted by such individuals may be exempt from the RWP issuance requirement durin§ the performance of their assi§ned duties, provided they are otherwise fol 101.-i n§ pl ar.t radiation 13retecti on procedures for entry i nte hi§h radiation areas.

Any individual or grou13 of individuals permitted to enter such areas shall be provided with or accompanied by one er more of the foll O'n'i n§ :

tt-:--

A radiation meni tori ng de*1i cc that centi nuousl y i Adi cates the radiation dose rate in the area.

tr.-

A radiation monitoring device that continueusl)' inte§rates the radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after the dose rate levels in the area have beer. established and personnel are aware of thef!L

-e-:-

An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveil l ance at the frequency specified in the RWP (or equiva~ent document).

Ir. addition to the requirements of Specification 5. 7.1, areas accessible to personnel with radiation levels> 1000 mrem/hr at 30 cm (12 in. ) from the radiation source or from any surface which the radiation penetrates shall require the following:

tt7 Doors shal 1 be l ocl<ed to prevent ul'lauthori zed er.try and shall net pretv*ent i ndi 'v'i duals from 1 ea vi n§ the area.

+n-pl ace of locking the door, direct or electronic surveillance (continued)

Quad Cities 1 and 2 5.7-1 Amendment No. :99/195

~ High Radiation Area (continLted)

High Radiation Area

5. 7 that is capable of preventing unaLtthorized entry may be

~

The keys st'lall be F11aintained under tMe administrative control of tMe Shift Engineer on duty or radiation protection supervision.

tr.-

Personnel access and e*posure control requirements of act ivities being performed within these areas shall be specified by an approved RWP (or equivalent document).

t-:-

Eacl9 person entering the area sflall be provided *,;iH1 aA alarmiAg radiatioA monitoriAg device t l9at contiAuously integrates the radiation dose rate (sucfl as an electronic dosimeter).

Surveillance and radiation monitoring by a radiation protection technician fllay be substituted for an alarming dosimeter.

For individual high radiation areas with radiation levels of

> 1000 mrem/hr at 30 cm (12 in. ), accessible to personnel, that are located within large areas where no enclosure e*ists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area sMall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning device.

Quad Cities 1 and 2 5.7 -2 Amendment No. 199/195

High Radiation Area 5.7 5.0 ADMINISTRATIVE CONTROLS.--__,

5.7 Insert 1 Pursuant to 10 GFR 20, paragraph 20.1601 (a), in lieu of the requirements of 10 GFR 20.1601(0), eaoh high radiation area, as defined in 10 CFR 20, in whioh the intensity of raeliation is> 100 mremJt:ir b1;1t 4-1000 mrem/hr at a distance of ao om, shall be barrioaded and oonspio1;1ously posted as a high radiation area and entranoe thereto shall be eontrolled by requiring issuanee of a Radiation Work Permit (RWP). lndivid1:1als q1:1alified in radiation proteetion proeedures (e.g., radiation proteotion teohnioians) or personnel continuously esoorted by suoh individuals may be exempt from the R'NP issuance requirement during the performance of their assigned duties in high radiation OFeas witt:I exposure rates ~ 1000 mremtt:ir, prm.iided they are ott:lerwise following plant radiation protection prooed1:1res for entry into suoh high radiation areas.

Any individual or group of individuals perFRitted to enter such areas shall be pro\\*ided with or aoeompanied by one or FR ore of the follo*.ving :

a:

/\\ radiation monitoring elevioe that continuously indioates the radiation dose rate in the area.

tr.

A radiation monitoring de\\*iee that oontinuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is reoeived. Entry into suoh areas with this monitoring devise FRay be maele after the elose rate levels in the area have been establisheel anel personnel are aware of them.

1\\n indivielual qualified in raeliation proteotion prooedures with a radiation dose rate monitoring elO\\'ioe, who is responsible for provieling positive control over the aeti'1ities within the OFea anel shall perform periodio radiation surveillance at the frequenoy speoified by the radiation protection technician in the RWP.

RE. Ginna Nuclear Power Plant 5.7-1 Amendment 80

High Radiation Area 5.7 In addition to the requirements of Specification 5.7.1, areas with radiation le*.*els > 1000 mrem!l=lr at a distance of 30 om shall be pro*1ided with looked or continuously guarded doors to pre*1ent unautl=lori;zed entry and the keys shall be maintained under the administrative eontrol of the Shift Supervisor on duty or radiation protection supervision. Doors shall remain locked except during periods of aoooss by personnel under an approved Rl.6.'P that shall specify the dose rate le*1els in the immediate work areas and the FAaximum allowable stay times for indi*1iduals in tl=lose areas. In lieu of the stay time specification of the RWP, direct or remote (s1:1sh as closed oirc1:1it TV sameras) continuous surveillanoe may be made by personnel qualified in radiation protection procedures to provide positi*1e exposure control 0*1er the aoti'.'ities being performed within the afea:-

In addition to the requirements of Specification 5.7.1, for indi'lidual high radiauon areas with radiation levels of> 1000 mreFAlhr at a distanoe of ao om, accessible to personnel, that are looated within large areas such as reactor containment, where no enclosure exists for p1:Jrposes of looking, or that cannot be sontin1:1ously guarded, and where no enclosure can be reasonably oonstructed around the individual area, that indi'lid1:Jal area shall be barricaded and conspicuously posted, and a flashing ligl=lt sl=lall be aoti¥ated as a waming device.

R.E. Ginna Nuclear Power Plant 5.7-2 Amendment 8G

6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 1 O CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION ARE~

~

In lieu of the "oontrol de*1ioe" or "alarm signal" required by paragraph 20.1601 of 10 CFR 20:

a:-

Eaoh High Radiation Area in Whish the intensity of radiation at ao om (11.8 in.)

is greater than 100 mremthr. deep dose but less than 1000 rnrem/hr shall be barricaded and oonspiouo1:1sly posted as a High Radiation Area, and personnel desiring entrance shall obtain a Radiation VV-0rk Permit (RWP). Any individual or group of indi¥iduals entering a High Radiation,t\\rea shall (a) use a oontinuously indioating dose rate monitoring de.. rioe or (b) use a radiation dose rate integrating de¥ioe whioh alarms at a pre set dose level (entry into sush areas with this monitoring de¥ioe may be made after the dose rate le¥el in the area has been established and personnel have been made knowledgeable of them), or (s) assure that a radiological oontFOI teohnioian pFOvides positi¥e oontFOI over actMties within the area and periodio radiation surveillanoe with a dose rate monitoring instrument.

In addition to the requirements of specification 6.12.1.a:

1. Any area accessible to personnel where an individual could reoei'le in any one hour a deep dose in eMoess of 1000 mrem at ao om (11.8 in.) but less than 500 rads at one meter (a.28 ft), from sources of radioactivity shall be looked or guarded to prevent unauthorizea entry. The keys to these looked barrioades shall be maintained under the administrative control of the respeotive Radiologioal Controls Supervisor.

2 For indi.. *idual high radiation areas v.*here an individual could receive in any one hour deep dose in eMoess of 1000 mrem at ao cm (11.8 in.) but less than 500 rads at one meter (a.28 ft.), that are looated within large areas such as reactor containment, where no enclosure m<ists for purposes of looking, and where no enclosure can be reasonably oonstruoted around the individ1:1al area, that individual area shall ee barrioaded and oonspiouo1:1sly posted, and a flashing light shall be aotivated as a warning de*.*ice.

The Radiation Work Perrnit is not req1:1ired by Radiological Controls personnel during the performance of their assigned radiation protection duties provideei they are following radiological control procedures for entry into High Radiation Areas.

6-22 Amendment Nos. 11, a5, 72, 77, 106, 107, 12Q, 173, 180, 2-1-d

Insert 1 Pursuant to 1 O CFR Part 20, paragraph 20.1601 (c), in lieu of the requirements of paragraph 20.1601 (a) and 20.1601 (b) of 1 O CFR Part 20:

5.7.1 Access to each high radiation area, as defined in 10 CFR 20, in which an individual could receive a deep dose equivalent > 0.1 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation) shall be controlled as described below to prevent unauthorized entry.

a. Each area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b. Entrance shall be controlled by requiring issuance of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may, for the performance of their assigned duties in high radiation areas, be exempt from the preceding requirements for issuance of an RWP or equivalent provided they are otherwise following plant radiation protection procedures for entry into, exit from, and work in such high radiation areas.

d. Each individual or group of individuals permitted to enter such areas shall possess, or be accompanied by, one or more of the following:

1. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset setpoint is reached. Entry into high radiation areas with this monitoring device may be made after the dose rate in the area has been determined and personnel have been made knowledgeable of it.

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.

4. An individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring device. This individual shall

be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by radiation protection supervision.

5.7.2 In addition to the requirements of Specification 5.7.1, high radiation areas in which an individual could receive a deep dose equivalent > 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) shall be provided with a locked or continuously guarded door, or gate, or equivalent to prevent unauthorized entry.

a. The keys to such locked doors or gates, or equivalent, shall be administratively controlled in accordance with a program approved by the radiation protection manager.

b. Doors and gates, or equivalent, shall remain locked except during periods of access by personnel under an approved RWP, or equivalent, to ensure individuals are informed of the dose rate in the immediate work areas prior to entry.

c. Individual high radiation areas in which an individual could receive a deep dose equivalent > 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation),

accessible to personnel, that are located within larger areas where no enclosure exists to enable locking, or that are not continuously guarded, and where no lockable enclosure can be reasonably constructed around the individual area require both of the following access controls:

1. Each area shall be barricaded and conspicuously posted.

2. A flashing light shall be activated as a warning device.

Insert 2 Pursuant to 10 CFR Part 20, paragraph 20.1601 (c), in lieu of the requirements of paragraph 20.1601 (a) and 20.1601 (b) of 1 O CFR Part 20:

6. 7.1 Access to each high radiation area, as defined in 1 O CFR 20, in which an individual could receive a deep dose equivalent > 0.1 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation) shall be controlled as described below to prevent unauthorized entry.

a. Each area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b. Entrance shall be controlled by requiring issuance of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may, for the performance of their assigned duties in high radiation areas, be exempt from the preceding requirements for issuance of an RWP or equivalent provided they are otherwise following plant radiation protection procedures for entry into, exit from, and work in such high radiation areas.

d. Each individual or group of individuals permitted to enter such areas shall possess, or be accompanied by, one or more of the following:

1. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset setpoint is reached. Entry into high radiation areas with this monitoring device may be made after the dose rate in the area has been determined and personnel have been made knowledgeable of it.

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.

4. An individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring device. This individual shall

be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by radiation protection supervision.

6.7.2 In addition to the requirements of Specification 6.7.1, high radiation areas in which an individual could receive a deep dose equivalent > 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) shall be provided with a locked or continuously guarded door, or gate, or equivalent to prevent unauthorized entry.

a. The keys to such locked doors or gates, or equivalent, shall be administratively controlled in accordance with a program approved by the radiation protection manager.

b. Doors and gates, or equivalent, shall remain locked except during periods of access by personnel under an approved RWP, or equivalent, to ensure individuals are informed of the dose rate in the immediate work areas prior to entry.

c. Individual high radiation areas in which an individual could receive a deep dose equivalent> 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation),

accessible to personnel, that are located within larger areas where no enclosure exists to enable locking, or that are not continuously guarded, and where no lockable enclosure can be reasonably constructed around the individual area require both of the following access controls:

1. Each area shall be barricaded and conspicuously posted.

2. A flashing light shall be activated as a warning device.

Insert 3 Pursuant to 1 O CFR Part 20, paragraph 20.1601 (c), in lieu of the requirements of paragraph 20.1601(a) and 20.1601(b) of 10 CFR Part 20:

6.12.1 Access to each high radiation area, as defined in 10 CFR 20, in which an individual could receive a deep dose equivalent > 0.1 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation) shall be controlled as described below to prevent unauthorized entry.

a. Each area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b. Entrance shall be controlled by requiring issuance of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may, for the performance of their assigned duties in high radiation areas, be exempt from the preceding requirements for issuance of an RWP or equivalent provided they are otherwise following plant radiation protection procedures for entry into, exit from, and work in such high radiation areas.

d. Each individual or group of individuals permitted to enter such areas shall possess, or be accompanied by, one or more of the following:

1. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset setpoint is reached. Entry into high radiation areas with this monitoring device may be made after the dose rate in the area has been determined and personnel have been made knowledgeable of it.

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation exposure within the area.

4. An individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring device. This individual shall

be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by radiation protection supervision.

6.12.2 In addition to the requirements of Specification 6.12.1, high radiation areas in which an individual could receive a deep dose equivalent > 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) shall be provided with a locked or continuously guarded door, or gate, or equivalent to prevent unauthorized entry.

a. The keys to such locked doors or gates, or equivalent, shall be administratively controlled in accordance with a program approved by the radiation protection manager.

b. Doors and gates, or equivalent, shall remain locked except during periods of access by personnel under an approved RWP, or equivalent, to ensure individuals are informed of the dose rate in the immediate work areas prior to entry.

c. Individual high radiation areas in which an individual could receive a deep dose equivalent> 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation),

accessible to personnel, that are located within larger areas where no enclosure exists to enable locking, or that are not continuously guarded, and where no lockable enclosure can be reasonably constructed around the individual area require both of the following access controls:

1. Each area shall be barricaded and conspicuously posted.

2. A flashing light shall be activated as a warning device.