ML063630039

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License Amendment Request Technical Specification (TS) 6.12 High Radiation Area
ML063630039
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 12/20/2006
From: Gannon C J
Progress Energy Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-06-150
Download: ML063630039 (28)
v • d • e


Text

Cornelius J. Gannon, Jr.Or'4Prog ss EergyVice President~~J ~~Progress Energy HarsNClaroPliant Inc.DEC 2 0 2006 Serial: HNP-06-150 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATION (TS) 6.12 HIGH RADIATION AREA Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power and Light Company (CP&L) doing business as Progress Energy Carolinas, Inc., requests a license amendment for the Harris Nuclear Plant (HNP) to Technical Specification (TS) 6.12 "High Radiation Area." Specifically, the proposed amendment would align the requirements with the revised 10 CFR 20 as described in Regulatory Guide 8.38, Revision 1, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants." The requested License Amendment is also being made to be consistent with NUREG-1 431, "Standard Technical Specifications Westinghouse Plants," and other Progress Energy Nucle Plants.Attachment 1 provides HNP's evaluation of the proposed amendment to the TS and details in accordance with 10 CFR 50.91 (a), the basis for HNP's determination that the proposed amendment to the TS does not involve a significant hazards consideration.

Attachment 2 provides the proposed TS changes.Attachment 3 provides the revised TS pages.With respect to this proposed amendment, there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure.

The proposed change maintains an equivalent level of protection for radiation workers and, thereby, provide reasonable assurance that individuals will not exceed regulatory dose limits. The proposed amendment to the TS meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51 .22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement is required for approval of this application.

Harris Nuclear Plant P.O. Box 165 New Hill, NC 27562 T > 919.362.2502 Ay o F > 919.362-2095 HNP-06-1 50 Page 2 In accordance with 10 CFR 50.91 (b), HNP is providing the State of North Carolina with a copy of the proposed license amendment.

HNP requests that the proposed amendment be issued prior to December, 2007.This document contains no new Regulatory Commitment.

Please refer any question regarding this submittal to Mr. Dave Corlett at (919) 362-3137.I declare, under penalty of perjury, that the attached information is true and correct (Executed on DEC 2 0 2006 )Sincerely, CJG/khv Attachments:

1. Licensee's Evaluation
2. Proposed Technical Specification Changes 3. Revised Technical Specification Pages c: Mr. P. B. O'Bryan, NRC Senior Resident Inspector Ms. B. 0. Hall, N.C. DENR Section Chief Mr. C. P. Patel, NRC Project Manager Dr. W. D. Travers, NRC Regional Administrator Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA LICENSEE'S EVALUATION

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-63 for Shearon Harris Nuclear Power Plant (HNP) Unit 1. The proposed Technical Specification (TS) change updates the reference to 10 CFR 20.203 in TS 6.12, High Radiation Area, with the corresponding reference to 10 CFR 20.1601. The revised 10 CFR 20 requirements became effective on June 20, 1991 and were implemented at HNP prior to the required implementation date as specified in 10 CFR 20.1008. The proposed change to the TS is consistent with the "Standard Technical Specifications Westinghouse Plants" (NUREG-1431, Revision 3), Technical Specification Task Force (TSTF)-258, Revision 4, and previously issued License Amendments as described in the Technical Analysis section. The proposed change will be implemented to maintain consistency in the Administrative Controls TS for High Radiation Areas among Progress Energy Nuclear Plants, which include Brunswick Stea m Electric Plant Units 1 & 2, Crystal River Unit 3, and H. B. Robinson Steam Electric Plant.HNP requests approval of the proposed amendment by December, 2007.Once approved, the amendment shall be implemented within 60 days.Page Al -i of 15 Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA

2.0 PROPOSED CHANGE

The current TS 6.12 states the following:

6.12 HIGH RADIATION AREA 6.12.1 Pursuant to Paragraph 20.203(c)(5) of 10 CFR Part 20, in lieu of the"control device" or "'alarm signal" required by Paragraph 20.203(c), each high radiation area, as defined in 10 CFR Part 20, in which the intensity of radiation is equal to or less than 1000 mR/h at 45 cm (18 in.) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g., Health Physics Technicians) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates equal to or less than 1000 mR/h, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area; or b. A radiation monitoring device that continuously integrates 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 been established and personnel have been made knowledgeable of them; or c. 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 who shall perform periodic radiation surveillance at the frequency specified by the Radiation Control Supervisor in the RWP.Page Al1-2 of 15 Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 6.12.2 In addition to the requirem ents of Specification 6.12.1, accessible areas with radiation levels greater than 1000 mR/h at 45 cm (118 in.) from the radiation source or from any surface which the radiation penetrates, shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Superintendent-Shift Operations on duty and/or health physics supervision.

Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of the stay time specification of the RWP, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area. During emergency situations that involve personal injury or actions taken to prevent major equipment damage, continuous surveillance and radiation monitoring of the work area by a qualified individual may be substituted for the routine RWP procedure.

For accessible individual high radiation areas, with radiation levels of greater than 1000 mR/h, that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded and conspicuously posted, and a flashing light shall be activated as a warning device.Page AlI-3 of 15 Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA The proposed amendment would revise TS 6.12 to read as follows: 6.12 HIGH RADIATION AREA As provided in paragraph 20.1601 (c) of110 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: 6.12.1 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 otherwise 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 Page Al -4 of 15 Attachment 1 to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 4. Possess a self-reading dosimeter and 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 radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance; or 5. 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 and indicating device; who is responsible for controlling personnel radiation exposure within the area.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 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 entry.6.12.2 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 locked high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and in addition: 1 .All such door and gate keys shall be maintained under the administrative control of the Superintendent

-Shift Operations 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.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 otherwise following plant radiation protection procedures for entry to, exit from, and work in such areas.Page Al -5 of 15 Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 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, 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; or 4. 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 and indicating device; who is responsible for controlling personnel exposure within the area; or 5. In those cases where the options of Specifications 6.12.2.d.2, 6.12.2.d.3, and 6.12.2.d.4, above, are impractical or determined to be inconsistent with the "As Low As is Reasonably Achievable" principle, possess a radiation monitoring and indicating device.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 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.f. Such individual areas that are within a larger 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, nor continuously guarded, 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.Page Al1-6 of 15 Attachment i to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA

3.0 BACKGROUND

System Desigin The Radiation Protection Program at HNP is described in Chapter 12 of the FSAR. Section 12.3.1.10 describes the administrative requirements for Access Control consistent with TS 6.12 and will be revised to be consistent with this proposed change as part of the implementation of the appr oved License Amendment.

Need for the Amendment TS 6.12 is being revised to be consistent with the revised 10 CFR 20, the guidance provided in Regulatory Guide (RG) 8.38, Revision 1 "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," and current industry technology in controlling access to high radiation areas. The proposed changes include capping dose rates to differentiate a high radiation area from a very high radiation area, additional requirements for groups entering high radiation areas, and clarification of the need for communication with, and control of, workers in high radiation areas. The proposed changes will be implemented to maintain consistency in the Administrative Controls TS for High Radiation Areas among Progress Energy Nuclear Plants, which include Brunswick Steam Electric Plant Units 1 & 2, Crystal River Unit 3, and H. B. Robinson Steam Electric Plant.Page AlI-7 of 15 Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 4.0 TECHNICAL ANALYSIS TS 6.12 provides high radiation access control alternatives pursuant to 10 CFR 20.203(c)(2) (to be revised to 10 CFR 20.1601(c)).

This specification has been significantly revised as a result of the changes to 10 CFR 20, the guidance provided in Regulatory Guide (RG) 8.38, Revision 1 "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants," and current industry technology in controlling access to high radiation areas. The proposed changes include capping dose rates to differentiate a high radiation area from a very high radiation area, additional requirements for groups entering high radiation areas, and clarification of the need for communication with, and control of, workers in high radiation areas.The changes reflect the revisions to 10 CFR 20, and were subsequently approved in TSTF-258, Revision 4, "Changes to Section 5.0, Administrative Controls," and incorporated into NUREG-1 431, Revision 3, "Standard Technical Specifications Westinghouse Plants." There are several minor editorial deviations from the exact wording of TSTF-258 and NUREG-1 431 in this License Amendment Request. These minor wording changes were made to be consistent with terminology in use at HNP and do not change the intent or understanding of TS 6.12 for High Radiation Area. These editorial changes are described below: 1. The word "accessible" was added to "each entryway" in 6.12.1 .a and 6.12.2.a.This is consistent with the approved TS 5.7 for Brunswick Steam Electric Plant Units 1 & 2 (Reference 4).2. In TS 6.12.1.d.1 and 6.12.1.d.2, a radiation monitoring device that continuously displays radiation dose rates in the area and a radiation Page Al1-8 of 15 Attachment i to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA monitoring device that continuously integrates the radiation dose rates and alarms when the device's dose alarm setpoint is reached, are defined as a radiation monitoring and indicating device and an alarming dosimeter, respectively.

This is a clarification which utilizes the common terminology in place at HNP. This wording is also incorporated throughout the remainder of TS 6.12.3. The word "locked" was added to the posting requirements in TS 6.12.2.a to more accurately describe the area being posted.4. The titles of personnel responsible for controlling locked high radiation area in accordance with TS 6.12.1.a.1 were changed to Superintendent

-Shift Operations and Radiation Control Supervisor to be consistent with titles in use at HNP.5. The words "or guarded" were added to TS 6.12.2.a.2.

This is consistent with the requirements listed in TS 6.12.2.a, above.6. The words "as a high radiation area" were added to the posting requirements and the word "conspicuous" was added to the description of the flashing light in TS 6.1 2.2.f to clarify these requirements.

The only deviation from the intent of TSTF-258 and NUREG-1431 pertains to the requirements for individuals entering high radiation areas. Specifically, the existing TS language as presented in TSTF-258 and NUREG-1431 requires 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 amendment will allow this to be an either/or condition rather than requiring both. As documented in Brunswick Steam Electric Plant letter dated July 2, 2002 (Accession Number: MLO21 91 03590), Progress Energy has concluded that the requirements of subparagraph d.4 of TS 5.7.1 and Page AlI-9 of 15 Attachment 1 to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA TS 5.7.2 [of NUREG-1 431] are too restrictive and constitute a regulatory burden.NUREG-1431, TS 5.7.1 and 5.7.2 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 equi pped with a radiation monitoring and indicating device. 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 TS 5.7.1 and TS 5.7.2 (as incorporated into HNP TS 6.12.1 and TS 6.12.2) 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. In the Safety Evaluation dated January 13, 2003 (Accession Number: ML0301505280), the NRC concluded that these proposed changes are consistent with the guidance provided in RG 8.38, Section C, Regulatory Position 2.4, and are therefore acceptable.

These alternate controls relate to the. protection of plant personnel from high radiation hazards during normal plant operations.

As such, the proposed changes have no impact on protection of the public from the consequences of and design basis accident (DBA) or transient.

Page Al-10 of 15 Attachment i to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 5.0 REGULATORY ANALYSIS 5.1 10 CFR 50.92 NO SIGNIFICANT HAZARDS EVALUATION A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. Harris Nuclear Plant (HNP) has evaluated the proposed amendment and determined that it involves no significant hazards consideration.

According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3. Involve a significant reduction in a margin of safety.The basis for this determination is presented below.Proposed Change In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power and Light Company (CP&L) doing business as Progress Energy Carolinas, Inc., requests a license amendment for the Harris Nuclear Plant (HNP) to Technical Specifications (TS) 6.12, "High Radiation Area." The changes reflect the revisions to 10 CFR 20, and the guidance in Regulatory Guide 8.38, Revision 1"Control of Access to High and Very High Radiation Areas." These changes are consistent with NUREG-1 431, Revision 3, "Standard Technical Specifications Westinghouse Plants," and NRC Safety Evaluation dated January 13, 3003 concerning "Issuance of Amendment Re: Administrative Controls for High Radiation Areas" for Brunswick Steam Electric Plants Units 1 and 2.Page Al -11 of 15 Atrtachment 1Ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA Basis 1 .Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.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. Does the proposed change create the possibility of a new of different kind of accident from any accident previously evaluated?

Response:

No.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. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.Page Al1-12 of 15 Attachment 1ito SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 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 HNP 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";and (2) other nuclear plants' existing TSs such as those at Brunswick Steam Electric Plant Units 1 & 2. Based on this evaluation, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, HNP concludes that the proposed amendment involves no significant hazards consideration under the standards set forth in 10 CFR 50.92, and a finding of "no significant hazards consideration" is justified.

5.2 Applicable

Regulatory Requirements/Criteria 10 CFR 20 contains "Standards for Protection Against Radiation." Specific requirements applicable to controlling access to high radiation areas are found in 10 CFR 20.1601, and additional requirements to prevent unauthorized or inadvertent entry into very high radiation areas are found in 10 CFR 20.1602. Regulatory Guide 8.38, Revision 1 described methods that the NRC staff finds acceptable for implementing these requirements.

The proposed amendment is consistent with the requirements of 10 CFR 20 and the guidance found in Regulatory Guide 8.38.Page AlI-13 of 15 Attachment i to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 60-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 6.0 Environmental Considerations A review has determined that the proposed amendment changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does 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 individual or cumulative occupational radiation exposure.

The proposed changes meet the requirements of 10 CFR 20 and are consistent with the guidance of RG 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants." Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 References

1. Regulatory Guide 8.38, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants, "Revision 1, dated May 2006.2. NUREG-1 431, "Standard Technical Specifications Westinghouse Plants," Revision 3.0, dated March 31, 2004.3. TSTF-258-A, Revision 4, Section 5.7 "Administrative Controls," approved by the NRC June, 1999.Page AlI-14 of 15 Attachment i to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA 4. Letter from the U. S. Nuclear Regulatory Commission to Mr. J. S. Keenan,"Brunswick Steam Electric Plant, Units 1 and 2 -Issuance of Amendment Re: Administrative Controls for High Radiation Areas" dated January 13, 2003, Brunswick Steam Electric Plant, Units 1 and 2, Accession No: ML03O1 505280.5. Letter from the U. S. Nuclear Regulatory Commission to Mr. Harold W. Kiser,"Hope Creek Generating Station -Issuance of Amendment Re: Revision to Technical Specification 6.12, "High Radiation Area"". dated January 30, 2003, Hope Creek Generating Station, Accession No: ML-03031 0075.6. Letter from the U. S. Nuclear Regulatory Commission to Mr. Roy A. Anderson,"Salem Nuclear Generating Station, Unit Nos. 1 and 2, Issuance of Amendment Re: Revision to Technical Specification 6.12, "High Radiation Area" dated April 10, 2003, Salem Nuclear Generating Station, Accession No: ML0307901 80.The proposed TS is meets the requirements in RG 8.38 (Reference
1) and is consistent with the intent of NUREG-1 431, "Standard Technical Specifications Westinghouse Plants," Revision 3.0, dated March 31, 2004 and TSTF-258, Revision 4 (i.e., References 2 and 3), with one change as approved in Brunswick Steam Electric Plant, Units 1 and 2, Amendments 225 and 252, respectively (i.e. Reference 4).References 5 and 6 are similar amendments issued for Hope Creek and Salem Nuclear Generating Stations.Page Al1-15 of 15 Attachment 2 to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA PROPOSED TECHNICAL SPECIFICATION CHANGES Page A2-1 of 6 A-DMINISTRATIVE CONTROLS 6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved.maintained, and adhered to for all operations involving personnel radiation e x p o s u r e ............................

6.12 HIG RADIATION AR 6.12.1 Purs nt to Paragra 20.203(c)(5I of 10 CFR Par 20, in lieu the 1.control devic " or "alarm s nal" require by Paragraph

.203(c), each igh r diation area, s def -ined in CFR Part 20, in which the 'tensity of ra 'ation is equa to or less th n 1000 mR/h a 45 cm (18 in. from the radi ion source o from any surf e which the diatinpnttssalb bar ric ded an consp uously poste as a high ra nico (d* tion area an entrance thereto hall be contr lled by requi .ng issuance oa Radiation rk Permit (RWP). I ividuals qua *fied in radia ion protectio proceduire s (e. .,. Health Physics Te nicians) or p sonnel conti ously escorte by such indi 'duals may be exemp from the RWP 'ssuance requi ment duri1ng e performance f heir assigne duties in hig radiation are s with expo su rates equal o or I s than 1000 /h, provided ey are othe r *se following ant radiatio pro ection proce es for entry .nto such high adiation are .Any ind 1 dual or group of individual permi tt ed t o nter such are shall be p rov i dwith or acc panied by one or more of th following:

a. radiation m itoring devic that continu sly indicates the r diation dose te in the ar or b. A ra iation mon Ito
  • ng device tha continuousl y 'ntegrates th radia *on dose rate .the area an alarms when a reset integr ed dose is eceived. Ent into su ch a as with this onitor ing dev ce may be ma eafter the d e rate levels in the area h ye been estab-lished and ersonnel have een made kno edgeable of em; or c. n individual ualified in r iation prote ion procedure with a r diation dose te monitorin device, who i responsible r pro-vi .ng pstive c ntrol over th activities wi hin the area d who shal perform penl ic radiation urveilla.nce athe frequenc speci 'ed by the Ra *tion Control upervisor in he RWP.6.12. In addition to the requir ents of Speci ication 6.12..acsil area s ith radiation evels greater than 1000 mR/ at 45 cm (18 in.) from the radijati source or f r any sur face hich the radi tion penetra t .shall be Srovided ith locked do s to prevent authorized e ry. and t he ks shall SHEARON HARRIS -UNIT 1 6-26 Amendment No. '-?"

.ADMINISTRATIVE CONTROLS lcamd s)c continuosg verillancesmysmd by personeundequalifi ed in radiat n protection pr edures to provi positive expo e control overt activiti being performe ithin the area. During emeorgenc situations that involve pe onal injury or a ions taken to p vent major equi ent damage.continuous seillance and ra 'ation monitorin of the work are by a qualified indivi ual may be subs ituted for the r tine RWP proced Fo accessible ndi 'dual high radiati n areas, w ith r iation levels o grea than 1000 mR/h. that are locate within large ar s, such as PWR contain nt, where no en osure exists fo urposes of loc g and where no enclosure an be reasonabl constr ucted aro d the individua rea. that individual ea shall be bar *caded and conspi ously posted, a a flashing light shall be ctivated as a ning device.6.13 PROCESS CONTROL PROGRAM (PCP)A Changes to the PCP: a. Shall be documented and records of reviews performed shall be retained as required by FSAR Section 17.3. This documentation shall contain: 1) Sufficient information to support the change together with the app'ropriate analyses or evaluations justifying the change(s) and 2) A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal. State, or other applicable regulations.

b. Shall become effective after review and acceptance by the PNSC and the approval of the Plant General Manager.6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)Changes to the ODCM: a. Shall be documented and records of reviews performed shall be retained as required by FSAR Section 17.3. This documentation shall contain: 1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and SHEARON HARRIS -UNIT I 6-27 SHERONHARIS-UIT1 627Amendment No. tt--etete, Ad~en~tA 6.12 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 CER Part 20: 6.12.1 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 otherwise 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 4. Possess a self-reading dosimeter and 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 radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance; or 5. 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 and indicating device; who is responsible for controlling personnel radiation exposure within the area.

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 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 entry..6.12.2 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 locked high radiation area and shall be provided with a locked or continuously guarded door or gate that prevents unauthorized entry, and in addition: 1 .All such door and gate keys shall be maintained under the administrative control of the Superintendent

-Shift Operations 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.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 otherwise 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, 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; or 4. 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 and indicating device; who is responsible for controlling personnel exposure within the area; or 5. In those cases where the options of Specifications 6.12.2.d.2, 6.12.2.d.3, and 6.12.2.d.4, above, are impractical or determined to be inconsistent with the"As Low As is Reasonably Achievable" principle, possess a radiation monitoring and indicating device.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 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.f. Such individual areas that are within a larger 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, nor continuously guarded, 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.

Attachment 3 to SERIAL: HNP-06-150 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATIONS (TS) 6.12 HIGH RADIATION AREA REVISED TECHNICAL SPECIFICATION PAGES Page A3-1 of 5 ADMINISTRATIV[

CONTROLS 6.11 RADIATION PROTECTION PROGRAM 6.11.1 Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.6.12 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: 6.12.1 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 eqi upment.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 otherwise 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 dev ice 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 4. Possess a self-reading dosimeter and 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 radiation exposure in the area, and with the means to communicate with individuals in the area who are covered by such surveillance; or SHEARON HARRIS -UNIT 1 62 mnmn o 6-26 Amendment No.

ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued)

5. 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 and indicating device; who i's responsible for controlling personnel radiation exposure wit hin the area.e. Except for individuals qualified in radiation protection procedures, or personnel continuously escorted by such individuals, entry into suc 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 rinor to entry into such areas. This dose rate determination, nowledge.

and pre-job briefing does not require documentation prior to entry.6.12.2 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

ý o sted as a locked high radiation area and shall be provided with a ocked or continuously guarded door or gate that prevents unauthorized entry, and in addition: 1. All such door and gate keys shall be maintained under the administrative control of the Superintendent

-Shift Operations or the Radiation Control Supervisor or designated representative; and 2. Doors and gates shall remain locked or guarded except during periods of personnel or eqiupment entry or exit.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 otherwise 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 SHEARON HARRIS -UNIT 1I-6 mnmn o 6-26a Amendment No.

ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued)

3. Possess a direct-reading dosimeter and 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 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, while in the area , of an individual qualified in radiation protection procedures, equipped with a radiation monitoring and indicating device; who i's responsible for controlling personnel exposure within the area; or 5. In those cases where the options of Specifications 6.12.2.d.2, 6.12.2.d.3, and 6.12.2.d.4 above, are impractical or determined to be inconsistent with the "As Low As Reasonably Achievable" principle, possess a radiation monitoring and indicating device.e. Except for individuals qualified in radiation protection procedures, orcpersonnel continuously escorted by such individuals, entry into suc 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 B nor to entry into such areas. This dose rate determination, rnowledge, and pre-job briefing does not require documentation prior to initial entry.f. Such individual areas that are within a larger 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, nor continuously guarded, but shall be barricaded and conspi .cuously posted as a high radiation area, and a conspicuous, clearly visible flashing light shall be activated at the area as a warning device.SHEARON HARRIS -UNIT 1I-6 mnmn o 6-26b Amendment No.

ADMINISTRATIVE CONTROLS HIGH RADIATION AREA (Continued) 6.13 PROCESS CONTROL PROGRAM (PCP)Changes to the PCP: a. Shall be documented and records of reviews retained as required by PSAR Section 17.3.contai n: performed shall be This documentation shall 1) Sufficient information to support the change together with the appropri .ate analyses or evaluations justifying the change(s) and 2) A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of Federal, State, or other applicable regulations.

b. Shall become effective after review and acceptance by the PNSC and the approval of the Plant General Manager.6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)Changes to the ODCM: a. Shall be documented and records of reviews performed shall be retained as required by PSAR Section 17.3. This documentation shall contain: 1) Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and SHEARON HARRIS -UNIT 1I-7Aenmn o 6-27 Amendment No.
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