View source for BSEP-02-0107, Request for License Amendments Re High Radiation Area Administrative Controls

{{Adams
| number = ML021910359
| issue date = 07/02/2002
| title = Request for License Amendments Re High Radiation Area Administrative Controls
| author name = Keenan J
| author affiliation = Carolina Power &amp; Light Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = DPR-062, DPR-071, NPF-037, NPF-066
| contact person = 
| case reference number = BSEP-02-0107, TSC-2002-04
| document type = Letter type:BSEP, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 30
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:John S. Keenan IreErL rCP&
AProgress Energy Company Vice President Brunswick Nuclear Plant JUL 0 2 2002 SERIAL: BSEP 02-0107                                                            10 CFR 50.90 TSC-2002-04 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS Ladies and Gentlemen:
In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light (CP&L) Company is requesting a revision to the Technical Specifications (TS) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.
The proposed license amendments revise requirements for administrative controls in TS 5.7, "High Radiation Area."
CP&L is providing, in accordance with 10 CFR 50.91(b), the State of North Carolina a copy of the proposed license amendments.
CP&L requests that the proposed changes be approved by January 15, 2003, and once approved, that the proposed license amendments, have an implementation period of 60 days. This would allow timely implementation of the amendments before the next Unit 2 refueling outage.
Please refer any questions regarding this submittal to Mr. E. T. O'Neil, Manager
 - Regulatory Affairs, at (91.0) 457-3512.
Sincerely, PO.Box 10429 Southport, NC28461
   > 910A457.2496 I > 910,457.2803

Document Control Desk BSEP 02-0107 / Page 2 CRE/cre

==Enclosures:==
: 1. Basis for Change Request
: 2. 10 CFR 50.92 Evaluation
: 3. Environmental Considerations
: 4. Page Change Instructions
: 5. Typed Technical Specification Pages - Unit 1
: 6. Typed Technical Specification Pages - Unit 2
: 7. Marked-up Technical Specification Pages - Unit 1
: 8. Marked-up Technical Specification Pages - Unit 2 John S. Keenan, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, and agents of Carolina Power &
Light Company.
Notary (Seal)
My commission expires: Qj-kX3LL 4           -9&#xfd; ,          42b h

Document Control Desk BSEP 02-0107 / Page 3 cc (with enclosures):
U. S. Nuclear Regulatory Commission, Region 11 ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Theodore A. Easlick, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATTN: Ms. Brenda L. Mozafari (OWFN 8G9) (Electronic Copy Only) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Ms. Beverly Hall Director - Division of Radiation Protection North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 02-0107 Enclosure 1 Page 1 of 3 ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS BASIS FOR CHANGE REQUEST

===Background===
On June 12, 1998, the NRC issued Amendments 203 and 233 to the Brunswick Steam Electric Plant (BSEP) Unit 1 and 2 Operating Licenses. These amendments approved conversion to Improved Standard Technical Specifications (ITS), consistent with NUREG-1433, Revision 1, "Standard Technical Specifications for General Electric Plants, BWR 4." As a result of these amendments, Carolina Power & Light (CP&L) Company revised Technical Specifications (TSs) 5.7.1 and 5.7.2 to be consistent with the draft NRC Generic Letter on TS changes to reflect the revisions to 10 CFR 20, which were subsequently approved in TSTF-258, Revision 4, "Changes to Section 5.0, Administrative Controls," and incorporated into NUREG-1433, Revision 2. CP&L has determined that TSs 5.7.1 and 5.7.2 provide unnecessary regulatory burden with respect to the requirements for individuals entering high radiation areas.
Specifically, the existing TSs require these individuals to posses direct-reading dosimetry and be under surveillance by a qualified radiation protection individual, at the work site, equipped with radiation monitoring equipment. The proposed amendments will allow this to be an either/or condition rather than requiring both.
Proposed Changes TS 5.7.1 Current                                                  Proposed
: d. Each individual or group entering such an area shall   d. Each individual or group entering such an area shall:
possess:                                                  1. Possess a radiation monitoring device that
: 1. A radiation monitoring device that continuously           continuously displays radiation dose rates in the displays radiation dose rates in the area                 area ("radiation monitoring and indicating
("radiation monitoring and indicating device"); or       device"); or
: 2. A radiation monitoring device that continuously        2. Possess a radiation monitoring device that integrates the radiation dose rates in the area and       continuously integrates the radiation dose rates in alarms when the device's dose alarm setpoint is           the area and alarms when the device's dose alarm reached ("alarming dosimeter"), with an                   setpoint is reached ("alarming dosimeter"), with appropriate alarm setpoint; or                            an appropriate alarm setpoint; or
: 3. A radiation monitoring device that continuously        3. Possess a radiation monitoring device that transmits dose rate and cumulative dose                   continuously transmits dose rate and cumulative information to a remote receiver monitored by             dose information to a remote receiver monitored radiation protection personnel responsible for            by radiation protection personnel responsible for controlling personnel radiation exposure within           controlling personnel radiation exposure within the area; or                                              the area; or

BSEP 02-0107 Enclosure 1 Page 2 of 3
: 4. A self-reading dosimeter and,                          4. Possess a self-reading dosimeter and be under the (a) Be under the surveillance, as specified in the        surveillance, as specified in the RWP or RWP or equivalent, of an individual at the            equivalent, by means of closed circuit television, work site, qualified in radiation procedures,         of personnel qualified in radiation protection equipped with a radiation monitoring and              procedures, responsible for controlling personnel indicating device who is responsible for              radiation exposure in the area; or controlling personnel radiation exposure          5. Be under the surveillance, as specified in the within the area, or                                   RWP or equivalent, of an individual at the work (b) Be under the surveillance, as specified in the        site, qualified in radiation procedures, equipped RWP or equivalent, by means of closed                 with a radiation monitoring and indicating device circuit television, of personnel qualified in         who is responsible for controlling personnel radiation protection procedures, responsible          radiation exposure within the area.
for controlling personnel radiation exposure in the area.
TS 5.7.2 Current                                                  Proposed
: d. Each individual (whether alone or in a group)          d. Each individual or group entering such an area entering such an area shall possess:                      shall:
: 1. An alarming dosimeter with an appropriate alarm         1. Possess an alarming dosimeter with an setpoint; or                                              appropriate alarm setpoint; or
: 2. A radiation monitoring device that continuously        2. Possess a radiation monitoring device that transmits dose rate and cumulative dose                   continuously transmits dose rate and cumulative information to a remote receiver monitored by             dose information to a remote receiver monitored radiation protection personnel responsible for            by radiation protection personnel responsible for controlling personnel radiation exposure within           controlling personnel radiation exposure within the area with the means to communicate with and           the area with the means to communicate with and control every individual in the area; or                  control every individual in the area; or
: 3. A direct-reading dosimeter and,                       3. Possess a direct-reading dosimeter and be under (a) Be under the surveillance, as specified in the        the surveillance, as specified in the RWP or RWP or equivalent, of an individual qualified         equivalent, by means of closed circuit television, in radiation procedures, equipped with a              of personnel qualified in radiation protection radiation monitoring and indicating device            procedures, responsible for controlling personnel who is responsible for controlling personnel          radiation exposure in the area, and with the exposure within the area, or                          means to communicate with and control every individual in the area; or (b) Be under the surveillance, as specified in the RWP or equivalent, by means of closed             4. Be under the surveillance, as specified in the circuit television, of personnel qualified in         RWP or equivalent, of an individual qualified in radiation protection procedures, responsible          radiation procedures, equipped with a radiation for controlling personnel radiation exposure          monitoring and indicating device who is in the area, and with the means to                    responsible for controlling personnel exposure communicate with and control every                    within the area; or individual in the area; or                        5. Possess a radiation monitoring and indicating
: 4. A radiation monitoring and indicating device in          device in those cases where the options of those cases where the options of Specifications           Specifications 5.7.2.d.2, 5.7.2.d.3, and 5.7.2.d.4 5.7.2.d.2 and 5.7.2.d.3, above, are impractical or        above, are impractical or determined to be determined to be inconsistent with the "As Low            inconsistent with the "As Low As is Reasonably As is Reasonably Achievable" principle.                   Achievable" principle.

BSEP 02-0107 Enclosure 1 Page 3 of 3 Basis For Proposed Change The existing TSs 5.7.1 and 5.7.2 provide unnecessary regulatory burden in that they require individuals to posses direct reading dosimetry when entering high radiation areas under the surveillance of a radiation protection qualified individual, at the work site, who is equipped with a radiation monitoring and indicating device. Therefore, as provided in paragraph 20.1601(c) of 10 CFR Part 20, CP&L is requesting approval for alternative methods for controlling access to high radiation areas. In essence, the changes to TSs 5.7.1 and 5.7.2 revise the requirements such that individuals entering a high radiation area do not need direct-reading dosimetry provided they are the under the surveillance of a radiation protection qualified individual, at the work site, who is equipped with a radiation monitoring and indicating device.
CP&L has determined that the proposed changes maintain an equivalent level of protection for radiation workers and, thereby, provide reasonable assurance that individuals will not exceed regulatory dose limits. The proposed changes are consistent with: (1) the guidance of Regulatory Guide (RG) 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," Section C, Regulatory Position 2.4, Alternative Methods for Access Control, with the exception that "should" has been changed to "shall"; (2) the BSEP TSs prior to conversion to ITS; and (3) other nuclear plants' existing TSs, including the Crystal River, H. B. Robinson, and Shearon Harris nuclear plants.

BSEP 02-0107 Enclosure 2 Page 1 of 2 ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS 10 CFR 50.92 EVALUATION Carolina Power & Light (CP&L) Company has concluded that the proposed change to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Technical Specifications (TS) revising requirements for administrative controls in TS 5.7, "High Radiation Area," do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards set forth in 10 CFR 50.92 is provided below.
: 1. The proposed license amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The changes are administrative and affect personnel access control requirements for high radiation areas. The changes do not affect the operation, physical configuration, or function of plant equipment or systems. The changes do not impact the initiators or assumptions of analyzed events; nor do they impact the mitigation of accidents or transient events. Therefore, these changes do not increase the probability or consequences of an accident previously evaluated.
: 2. The proposed license amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The changes are administrative and affect personnel access control requirements for high radiation areas. The changes do not alter plant configuration, require installation of new equipment, alter assumptions about previously analyzed accidents, or impact the operation or function of plant equipment or systems. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. The proposed license amendments do not involve a significant reduction in a margin of safety.
The changes are administrative and affect personnel access control requirements for high radiation areas. The changes do not impact any safety assumptions; nor do the changes have the potential to reduce any margin of safety as described in the BSEP TS Bases. The proposed changes maintain an equivalent level of protection for radiation workers and, thereby, provide reasonable assurance that individuals will not exceed regulatory dose limits. The proposed changes are consistent with: (1) the guidance of Regulatory Guide (RG) 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," Section C, Regulatory Position 2.4, Alternative Methods for Access Control, with the exception that "should" has been changed to "shall"; (2) the BSEP TSs prior to

BSEP 02-0107 Enclosure 2 Page 2 of 2 conversion to Improved Standard Technical Specifications; and (3) other nuclear plants' existing TSs, including the Crystal River, H. B. Robinson, and Shearon Harris nuclear plants.
Based on the above, these changes do not involve a significant reduction in a margin of safety.

BSEP 02-0107 Enclosure 3 Page 1 of 1 ENCLOSURE 3 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS ENVIRONMENTAL CONSIDERATIONS Carolina Power & Light (CP&L) Company has concluded that the proposed change/changes to the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Technical Specifications (TS) revising requirements for administrative controls in TS 5.7, "High Radiation Area," are eligible for categorical exclusion from performing an environmental assessment. In support of this determination, an evaluation of each of the three (3) criteria set forth in 10 CFR 51.22(c)(9) is provided below.
I1. The proposed license amendments do not involve a significant hazards consideration, as shown in Enclosure 2.
: 2. The proposed license amendments do not result in a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite. The proposed license amendments do not introduce any new equipment nor require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The proposed license amendments do not alter the function of existing equipment and will ensure that the consequences of any previously evaluated accident do not increase. Therefore, CP&L has concluded that there will not be a significant increase in the types or amounts of any effluent that may be released offsite and, as such, the changes do not involve irreversible environmental consequences beyond those already associated with normal operation.
: 3. The proposed license amendments do not result in an increase in individual or cumulative occupational radiation exposure. The proposed changes maintain an equivalent level of protection for radiation workers and, thereby, provide reasonable assurance that individuals will not exceed regulatory dose limits. The proposed changes are consistent with: (1) the guidance of Regulatory Guide (RG) 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," Section C, Regulatory Position 2.4, Alternative Methods for Access Control, with the exception that "should" has been changed to "shall"; (2) the BSEP TSs prior to conversion to Improved Standard Technical Specifications; and (3) other nuclear plants' existing TSs, including Crystal River, H. B. Robinson, and Shearon Harris nuclear plants.

ENCLOSURE 4 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS PAGE CHANGE INSTRUCTIONS UNIT 1 Removed page             Inserted page 5.0-22                   5.0-22 5.0-23                   5.0-23 5.0-24                   5.0-24 5.0-25                   5.0-25 UNIT 2 Removed page             Inserted page 5.0-21                   5.0-21 5.0-22                   5.0-22 5.0-23                   5.0-23 5.0-24                   5.0-24

ENCLOSURE 5 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS TYPED TECHNICAL SPECIFICATION PAGES - UNIT 1

High Radiation Area 5.7 5.0   ADMINISTRATIVE CONTROLS 5.7   High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:
5.7.1        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)
: a. Each accessible 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 activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) 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 and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual or group entering such an area shall:
: 1. Possess a radiation monitoring device that continuously displays radiation dose rates in the area ("radiation monitoring and indicating device"); or
: 2. Possess a radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached
("alarming dosimeter"), with an appropriate alarm setpoint; or
: 3. Possess 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; or (continued)
Brunswick Unit 1                        5.0-22                   Amendment No. I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.1        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)     (continued)
: 4. Possess a self-reading dosimeter and be under the surveillance, as specified in the RWP or equivalent,   by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area; or
: 5. Be under the surveillance, as specified in the RWP or equivalent, of an individual at the work site, qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel radiation exposure within the area.
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
5.7.2        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 radiation), but less than 500 rads/hour (at I meter from the radiation source or from any surface penetrated by the radiation)
: a. Each accessible entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked door, gate, or guard that prevents unauthorized entry, and in addition:
: 1. All such door and gate keys shall be maintained under the administrative control of the shift superintendent or the radiation control supervisor or designated representative; and
: 2. Doors and gates shall remain locked or guarded except during periods of personnel or equipment entry or exit.
(continued)
Brunswick Unit I                       5.0-23                   Amendment No.      I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2        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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued)
: b. Access to, and activities in, each such area shall be controlled by means of an RWP 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 provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual or group entering such an area shall:
: 1. Possess an alarming dosimeter with an appropriate alarm setpoint; or
: 2. Possess 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 with the means to communicate with and control every individual in the area; or
: 3. Possess a direct-reading dosimeter and be under the surveillance, as specified in the RWP or equivalent, 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; or
: 4. Be under the surveillance, as specified in the RWP or equivalent, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel exposure within the area; or (continued)
Brunswick Unit 1                       5.0-24                   Amendment No. I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2       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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued)
: 5. Possess a radiation monitoring and indicating device in those cases where the options of Specifications 5.7.2.d.2, 5.7.2.d.3, and 5.7.2.d.4, above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle.
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
: f. Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for 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, but shall be barricaded and conspicuously posted as a high radiation area, and a conspicuous, clearly visible flashing light shall be activated at the area as a warning device.
Brunswick Unit 1                       5.0-25                   Amendment No. I

ENCLOSURE6 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS TYPED TECHNICAL SPECIFICATION PAGES - UNIT 2

High Radiation Area 5.7 5.0   ADMINISTRATIVE CONTROLS 5.7   High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:
5.7.1        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)
: a. Each accessible 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 activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) 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 and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual or group entering such an area shall:
: 1. Possess a radiation monitoring device that continuously displays radiation dose rates in the area ("radiation monitoring and indicating device"); or
: 2. Possess a radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached
("alarming dosimeter"), with an appropriate alarm setpoint; or
: 3. Possess 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; or (continued)
Brunswick Unit 2                       5.0-21                   Amendment No.      I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.1        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)     (continued)
: 4. Possess a self-reading dosimeter and be under the surveillance, as specified in the RWP or equivalent, by means of closed circuit television, of personnel qualified in radiation protection procedures, responsible for controlling personnel radiation exposure in the area; or
: 5. Be under the surveillance, as specified in the RWP or equivalent, of an individual at the work site, qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel radiation exposure within the area.
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
5.7.2        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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation)
: a. Each accessible entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked door, gate, or guard that prevents unauthorized entry, and in addition:
: 1. All such door and gate keys shall be maintained under the administrative control of the shift superintendent or the radiation control supervisor or designated representative; and
: 2. Doors and gates shall remain locked or guarded except during periods of personnel or equipment entry or exit.
(continued)
Brunswick Unit 2                       5.0-22                   Amendment No.      I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2        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 radiation), but less than 500 rads/hour (at I meter from the radiation source or from any surface penetrated by the radiation) (continued)
: b. Access to, and activities in, each such area shall be controlled by means of an RWP 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 provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual or group entering such an area shall:
: 1. Possess an alarming dosimeter with an appropriate alarm setpoint; or
: 2. Possess 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 with the means to communicate with and control every individual in the area; or
: 3. Possess a direct-reading dosimeter and be under the surveillance, as specified in the RWP or equivalent, 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; or
: 4. Be under the surveillance, as specified in the RWP or equivalent, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel exposure within the area; or (continued)
Brunswick Unit 2                       5.0-23                   Amendment No.      I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2       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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued)
: 5. Possess a radiation monitoring and indicating device in those cases where the options of Specifications 5.7.2.d.2, 5.7.2.d.3, and 5.7.2.d.4, above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle.
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
: f. Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for 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, but shall be barricaded and conspicuously posted as a high radiation area, and a conspicuous, clearly visible flashing light shall be activated at the area as a warning device.
Brunswick Unit 2                      5.0-24                   Amendment No.      I

ENCLOSURE 7 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS MARKED-UP TECHNICAL SPECIFICATION PAGES - UNIT I

High Radiation Area 5.7 5.0   ADMINISTRATIVE CONTROLS 5.7   High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:
5.7.1        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)
: a. Each accessible 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 activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) 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 and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual or group entering such an area shall eos~e~A~I1              ~A radiation monitoring device thatthecontinuously area ("radiation displays radiation dose rates in monitoring and indicating device"); or
          .2                    *.Aradiation monitoring device that continuously
                               /integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached
("alarming dosimeter"), with an appropriate alarm setpoint; or
*Po .                     3. t- 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; or (continued)
Brunswick Unit I                         5.0-22                    Amendment No.-R4 I I

High Radiation Area 5.7 5.7   High Radiation Area
-. 5.7.1        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) (continued) self-reading dosimeter and,.         t,
(                             Be under the surveillance, as specified in the RWP or equivalent, of an individual at the work site, qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel radiation exposure within
                               '*      nder the surveillance, as specified in the RWP*
or*equivalent, by means of closedd circuitl Stelevision, of personnel qualified in radiation i      Rprotection procedures, responsible for controlling 3ersonnel radiation exposure in the area-' osr
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
5.7.2        Hieh Radiation Areas with Dose Rates Greater than 1.0 rem/hour (at 30 centimeters from the radiation source or from any surface rads/hour  (at I meter from by penetrated   the the radiation  sourcebutor less radiation),                any 500 from than  surface penetrated by the radiation)
: a. Each accessible entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked door, gate, or guard that prevents unauthorized entry, and in addition:
: 1. All such door and gate keys shall be maintained under the administrative control of the shift superintendent or the radiation control supervisor or designated representative; and
: 2. Doors and gates shall remain locked or guarded except during periods of personnel or equipment entry or exit.
(continued) 5.0-23                         Amendment No.    +6-I Brunswick Unit I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2         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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued)
: b. Access to, and activities in, each such area shall be controlled by means of an RWP 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 provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual fe-theralone.. or in-e group- entering such an area shall possess:
: 1. *Awalarming dosimeter with an appropriate alarm setpoint; or f e2.               __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 with the means to communicate with and control every individual in the area; or P ~       3.  *A-direct-reading dosimeter and
                         +a+ Be under the surveillance, as specified in the RWP or equivalent, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel exposure within the area *or "S                                                 (t-"--a"**
continued) 5.0-24                    Amendment No.       +6- I Brunswick Unit I

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2        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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) (continued) pfCIO$PGC~protection procedures, responsible for controlling 50   . -   radiation monitoring and indicating device in those cases where the options of Specifications 5.7.2.d.2 5.7.2.d.3,above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle.
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
: f. Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for 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, but shall be barricaded and conspicuously posted as a high radiation area, and a conspicuous, clearly visible flashing light shall be activated at the area as a warning device.
Brunswick Unit I                       5.0-25                   Amendment No.-2-4* ii

ENCLOSURE 8 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324/LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS HIGH RADIATION AREA ADMINISTRATIVE CONTROLS MARKED-UP TECHNICAL SPECIFICATION PAGES - UNIT 2

High Radiation Area 5.7 5.0    ADMINISTRATIVE CONTROLS 5.7   High Radiation Area As provided in paragraph 20.1601(c) of 10 CFR Part 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraph 20.1601(a) and (b) of 10 CFR Part 20:
5.7.1        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)
: a. Each accessible 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 activities in, each such area shall be controlled by means of a Radiation Work Permit (RWP) 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 and personnel continuously escorted by such individuals may be exempted from the requirement for an RWP or equivalent while performing their assigned duties provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual or group entering such an area shall
: 1. A-radiation monitoring device that continuously POS'Se-SS   Q,                     displays radiation dose rates in the area ("radiation monitoring and indicating device"); or SS2.                              radiation monitoring device that continuously integrates the radiation dose rates in the area and alarms when the device's dose alarm setpoint is reached
("alarming dosimeter"), with an appropriate alarm setpoint; or
: 3. 4-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; or (continued)
Brunswick Unit 2                        5.0-21                    Amendment No. 43+

High Radiation Area 5.7 5.7   High Radiation Area 5.7.1       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) (continued) 4.=< self-reading dosimeter and~p t&#xfd;- Be under the surveillance, as specified in the RWP SF{*
or equivalent, of an individual at the work site, qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel radiation exposure within the area.,-,v" nder the surveillance,  as specified in the   W oreuivalent, by means of closed circuitl reeision, of personnel qualified in radiation          l rtction      procedures, responsible for controllingl nnel adiaton exosurein the area- ; r               )
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
5.7.2        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 radiation), but less than 500 rads/hour (at I meter from the radiation source or from any surface penetrated by the radiation)
: a. Each accessible entryway to such an area shall be conspicuously posted as a high radiation area and shall be provided with a locked door, gate, or guard that prevents unauthorized entry, and in addition:
: 1. All such door and gate keys shall be maintained under the administrative control of the shift superintendent or the radiation control supervisor or designated representative; and
: 2. Doors and gates shall remain locked or guarded except during periods of personnel or equipment entry or exit.
(continued)
Brunswick Unit 2                          5.0-22                   Amendment No. 233

High Radiation Area 5.7 5.7    High Radiation Area 5.7.2          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 radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation)      (continued)
: b. Access to, and activities in, each such area shall be controlled by means of an RWP 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 provided that they are following plant radiation protection procedures for entry to, exit from, and work in such areas.
: d. Each individual -(whethier a..ene or -ina group) entering such an area shall poseess:
COSS-5s q\1.                      -An-alarming dosimeter with an appropriate alarm setpoint; or S2.&#xfd;*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 with the means to communicate with and control every individual in the area; or (POSs 5e55  L3.                     *direct-reading     dosimeter and' Be under the surveillance, as specified in the RWP or equivalent, of an individual qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device who is responsible for controlling personnel exposure within the area,;or (b)eBe under the surveillance, as specified in the RWP or equivalent, by means of closed circuit teevsin      of pe rsonnel qualified in radiation
                                    ~                                                  (continued)
Brunswick Unit 2                           5.0-23                      Amendment No. f3+

High Radiation Area 5.7 5.7   High Radiation Area 5.7.2       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 radiation), but less than 500 rads/hour (at 1 F. rrtvIOs     meter from the radiation source or from any surface penetrated by "the radiation) (continued) nthe area; or Poss   OLidvda
                        . radiation monitoring and indicating device in those cases where the options of Specifications 5.7.2.d.2 5.7.2.d.3   bove, are impractical or determined to be v   .2A                       inconsisent with the "As Low As is Reasonably Achievable" principle.
: e. Except for individuals qualified in radiation protection procedures, entry into such areas shall be made only after dose rates in the area have been established and entry personnel are knowledgeable of them.
: f. Such individual areas that are within a larger area that is controlled as a high radiation area, where no enclosure exists for 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, but shall be barricaded and conspicuously posted as a high radiation area, and a conspicuous, clearly visible flashing light shall be activated at the area as a warning device.
Brunswick Unit 2                        5.0-24                   Amendment No. 2-  I}}