ML20076M970

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EA & Fonsi Requesting Exemption from Certain Requirments of Regulations to Licenses NPF-39 & NPF-85 for Operation of Plant,Units 1 & 2.Action Would Allow Implementation of Hand Geometry Biometric Sys of Site Access Control
ML20076M970
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 11/03/1994
From: Stolz J
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20076M973 List:
References
NUDOCS 9411090096
Download: ML20076M970 (5)


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4 7590-01 UNITED STATIS NUCLEAR REGULATORY COMMISSION

.PJtillELELPHI A ELECTRIC COMPANY DOCKET.NOS. 50-352 AND 50-353 LJfiLRICK GENERATING STATION VNITS 1 AND_2 m

DC/LRONMENTAL ASSESSMINT AND FINDJNG OF NO SIGNIFICANT-lMPACT The U.S. Nuclear Regulatory Commission (the Commission) is considering issuance of an exemption from certain requirements of its regulations to Facility Operating License Nos. NPF-39 and NPF-85, issued to Philadelphia Electric Company (the licensee), for operation of the Limerick Generating Station (LGS), Units 1 and 2, located in Montgomery County, Pennsylvania.

DiyjRONMENTAL ASSE1S. MENT Identiikation_of Proposed Action:

The proposed action would allow implementation of a hand geometry biometric system of site access control such that photograph identification badges can be taken offsite.

The proposed action is in accordance with the licensee's application dated August 10, 1994 for exemption from certain requirements of 10 CFR 73.55,

" Requirements for physical protection of licensed activities in nuclear power l

lP ant reactors against radiological sabotage."

The Need for the_.Proposei Action:.

Pursuant to 10 CFR 73.55, paragraph (a), the licensee shall establish and maintain an onsite physical protection system and security organization.

" Access Requirements," of 10 CFR 73.55(d), paragraph (1), specifies that

" licensee shall control all points of personnel and vehicle access into a protected area..."

It is specified in 10 CFR 73.55(d)(5) that "A numbered 9411090096 941103 ADOCK0500g2 PDR P

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picture badge identification system shall be used for all individuals who are authorized access to protected areas without escort."

It also states that an-individual not employed by the licensee (i.e., contractorr) may be authorized access to protected areas without escort provided the indiv, dual " receives a picture badge upon entrance into the protected area which must be returned upon exit from the protected area..."

Currently, unescorted access into protected areas of the LGS is controlled through the use of a photograph on a combination badge and keycard.

(Hereafter, these are referred to as badges).

The security officers at each-entrance station use the photograph on the badge to visually identify the individual requesting access The badges for both licensee employees and i

contractor personnel who have been granted unescorted access are issued upon entrance at each entrance / exit location and are returned upon exit. The badges are stored and are retrievable at each entrance / exit location.

In i

accordance with 10 CFR 73.55(d)(5), contractor individuals are not allowed to take badges offsite.

In accordance with the plants' physical security plans, neither licensee employees nor contractors are allowed to take badges offsite.

The licensee p oposes to implement an alternative unescorted access control system which would eliminate the need to issue and retrieve badges at each entrance / exit loca.lon and aculd allow all individuals with unescorted access to keep their badges with them when departing the site..

An exemption frov. 10 CFR 73.55(d)(5) is required to permit contractors to take their badges offsite instead'of returning them when ex1 ting the site.

The Commission has completed its evaluation of the proposed action.

A Under the proposed system, each individual who is authorized for unescorted entry into protected areas would have the physical characteristics of their hand (hand geometry) registered with their badge number in the access control system.

When an individual enters the badge into the card reader and places the hand on the measuring surface, the system would record the individual's hand image. The unique characteristics of the extracted hand image would be compared with the previously stored template to verify authorization for entry.

Individuals, including licensee employees and contractors, would be allowed to keep their badge with them when they depart the site.

Based on a Sandia report entitled "A Performance Evaluation of Biometric identification Devices" (SAND 91--0276 UC--906 Unlimited Release, Printed June 1991), and on its experience with the current photo-identification system, the licensee demonstrated that the proposed hand georretry system would provide enhanced site access control.

Since both the badge and hand geometry would be necessary for access inta the protected area, the proposed system would provide for a positive verification process.

Potential loss of a badge by an individual, as a result of taking the badge offsite, would not enable an unauthorized entry into protected areas.

The licensee will implement a process for testing the proposed system to ensure continued overall level of performance equivalent to that specified in the regulation.

The Physical Security Plans for both sites will be revised to include implementation and testing of the hand geometry access control system and to allow licensee employees and contractors to take their badges offsite.

The access crocess will continue to be under the observation of security personnel.

A numbered picture badge identification system will continue to be

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. used for all individuals who are authorized access to protected areas without escorts.

Badges will continue to be displayed by all individuals while inside the protected area.

Environmental _Jmpacts of the Proposed Action:

The change will not increase the probability or consequences of accidents, no changes are being made in the types of any effluents that may be released offsite, and there is no significant increase in the allowable individual or cumulative occupational radiation exposure.

Accordingly, the Commission concludes that there are no significant radiological environmental impacts associated with the proposed action.

With regard to potential nonradiological impacts, the proposed action involves features located entirely within the restricted area as defined in 10 CFR Part 20.

It does not affect nonradiological plant effluents and has no other environmental impact.

Accordingly, the Commission concludes that there are no significant nonradiological environmental impacts associated with the proposed action.

Alternatives to the Proposed Action:

Since the Commission has concluded there is no measurable environmental impact associated with the proposed action, any alternatives with equal or greater environmental impact need not be evaluated.

The principal alternati-to the action would be to deny the request.

Such action would not change any current environmental impacts.

The environmental impacts of the proposed action and the alternative action are similar.

Alternative Use of Resources:

This action does not involve the use of any resources not previously considered in the " Final Environmental Statement related to the operation of

, Limerick Generating Station, Units 1 and 2," dated April 1984.

Ag encle tan d Pe r sArts_G.o n_s u l t e d t d

The tiRC staff consulted with the State of Pennsylvania regarding the environmental impact of the proposed action.

The State official had no comments.

EltRIfLOF NQ_SlGMLEICANT liiPACl Based upon the environmental assessment, the Commission concludes that the proposed action will not have a significant effect on the quality of the human environment. Accordingly, the Commission has determined not to prepare an environmental impact statement for the proposed action.

For further details with respect to the proposed action, see the licensee's letters dated August 10, October 7,1994, and Octouer 13, 1994, which are available for public inspection at the Commission's_ Public Document Room, The Gelman Building, 2120 L Street, NW., Washington, DC 20555 and at the local public document room located at Pottstown Public Library, 500 High St eet, Pottstown, Pennsylvania 19464.

Dated at Rockville, Maryland, this 3rd day of Novenber 1994.

For the Nuclear Regulatory Commission

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Adk)fM Johp'F.Stolz,Directph

. Project Directorate I-2 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation 1