U.S. Nuclear Regulatory Commission

Applicability of 10 CFR 20.203 (c) to Plants With Standard Technical Specifications 6.12

HPPOS-180 PDR-9111210282

Title: Applicability of 10 CFR 20.203 (c) to Plants With

Standard Technical Specifications 6.12

See the memorandum from L. J. Cunningham to R. R. Bellamy

(and others) dated May 9, 1990. The high radiation area

access control Technical Specifications (STS 6.12) provide

an alternate control method "in lieu of the control device"

[10 CFR 20.203 (c) (i)] or "alarm signal" [10 CFR 20.203

(c) (ii)]. This TS does not supersede the other provisions

of 10 CFR 20.203 (c). This health physics position also

applies to "new" 10 CFR 20.1601.

Issues have come up regarding the applicability of 10 CFR

20.203 (c) [or 10 CFR 20.1601] for licensees with High

Radiation Area Access Technical Specifications. In two

cases, licensees have requested unnecessary TS changes to

allow direct surveillance to prevent unauthorized entries

into high radiation areas (instead of locking them) in

accordance with 10 CFR 20.203 (c) (4) [or 10 CFR 20.1601

(b)]. In a third case, questions were asked on whether it

was allowable for a licensee to provide remote surveillance

through a video camera for positive access control of an

unlocked area since it was not in its Technical

Specifications.

In all three cases, the licensees and the inspectors

involved expressed confusion over the relationship of the

High Radiation Technical Specifications and 10 CFR 20.203

(c) [or 10 CFR 20.1601]. The High Radiation Area Access

Control Technical Specifications (STS 6.12) provide an

alternate control method "in lieu of the control device"

[10 CFR 203 (c) (2) (i) and 10 CFR 20.1601 (a) (1)] or

"alarm signal" [10 CFR 20.203 (c) (2) (ii) and 10 CFR

20.1601 (a) (2)]. This TS does not supersede the other

provisions in 10 CFR 20.203 (c) [or 10 CFR 20.1601], and it

does not preclude a licensee from locking a High Radiation

Area (<1000 mR/hr) and controlling access pursuant to 10

CFR 20.203 (c) (2) (iii) [or 10 CFR 20.1601 (a) (3)].

Regulatory references: 10 CFR 20.203, 10 CFR 20.1601,

Technical Specifications

Subject codes: 4.1

Applicability: Reactors