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

HPPOS-180 PDR-9111210282

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