NRC-98-0023, Application for Amend to License DPR-9,allowing Util to Possess Contaminated Apparatus & Equipment & Radioactive Sources at Fermi 1 Containing Byproduct Matl Not Produced by Operation of Plant Reactor

Application for Amend to License DPR-9,allowing Util to Possess Contaminated Apparatus & Equipment & Radioactive Sources at Fermi 1 Containing Byproduct Matl Not Produced by Operation of Plant Reactor

ML20199F625
Person / Time
Site:	Fermi
Issue date:	01/28/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-98-0023, CON-NRC-98-23 NUDOCS 9802040058
Download: ML20199F625 (8)

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Tel 313 TM.f,201 F u. 311TM 4172 Detroit Edison January 28,1998 NRC-98-0022 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 0001

References:

1) Enrico Fermi Atomic Power Plant, Unit No. I NRC Docket No. 50-16 NRC License No. DPR 9

2) Detroit Edison Letter, NRC-97-Oll5, dated December 15,1997 Sub. ject:

Proposed License Amendment -

To Allow Possession of Contaminated Annaratus and Sources Pursuant to 10 CFR 50.90, Detroit Edison hereby proposes to amend Possession Only License DPR-C 'or the Fermi I plant by modifying Part 2.B of the License.

This application proposes to allow Detroit Edison to possess contaminated apparatus and equipment and radioactive sources at Fenni I containing byproduct material not produced by the operation of the Fermi 1 reactor. The license already allows possession of byproduct material produced by operation of the Fenni 1 reactor. The application proposes to limit the cumulative radioactivity quantity of byproduct material to the limits in 10 CFR Part 30, Section 30.72, Schedule C,"Quantitics of radioactive materials requiring consideration of the need for an emergency plan for responding to a release."

The requested provision will increase Hexibility by allowing use of tools, apparatus, or equipment previously contaminated at another facility. Also, it will allow use of non-exempt calibration sources. Currently, only instrumentation

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which can be calibrated with small exempt from license sources can be

-m p 5 " " ', u maintained at Fermi 1. This change will decrease costs, while not introducing

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USNRC NRC-98-0023 i

Page 2 any additional hazar6, because contamination control measures are already in place for the byproduct material currently licensed at Fenni 1. The provision is similar to that in many other reactor licenses, with the only unique aspect being the establishment of a limit for cumulative byproduct activity.

The description and evaluation of the changes are included in Enclosure 1 to this letter.

Detroit Edison requests prompt approval of'his request and asks that this amendment be approved with an implementation time period of"within 60 days." This will allow approval of procedure changes needed to implement the amendment. Please note that Reference 2 also submitted an amendment request which affects the same page of the license.

Detroit Edison has evaluated the proposed change against the criteria of 10 CFR 50.92 and detennined that No Significant llazards Consideration is involved. The Fenni 1 Review Committee has reviewed and approved the proposed amendment. In accordance with 10 CFR 50.91, Detroit Edison is providing a copy of this letter to the State of Michigan, if there are any questions, please contact Lynne Goodman, Director Fermi 1 at 734 586-1205.

Sincerely,/Nb Enclosure cc:

A.B. Beach S.W. Brown G.A. liarris J.E. Ilouse, NRC Region 111 D.R. Ilahn (State of Michigan)

USNRC i

NRC.98 0023 Page 3 i

1, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

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DOUGLAS 1. GIPSON Senior Vice President t

On this M

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,1998 before me personally appeared Douglas R. Gipson, Sing first d6 y swom and says that he executed the foregoing as his free act and deed.

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L USNRC NRC-98-0023 Page 4 be:

P.J. Borer D. Ferenez P. Fessler D.R. Gipson L.S. Goodman Li L.K. Layton 1

J.E. Moyers R.J. Beaudry D. Bergmooser D.K. Cobb J.E.Conen R.A. DeLong, Jr.

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R.R. Ebechardt, Jr.

I W.D. Gilbert L

T.W. liaberland R.A. Jansscns f:

E.F. Kokosky R. Laubent'ein u

E.F. Madsen R.L. Matthews R.11, McLenon J.E. Meyers R.A. Neo kirk W.T. O'Connor, Jr.

E.M. Page J.ll. Plona T.L. Schehr K.W. Sessions E.M. Wilds D.R. Williams Inforrnation Management (116 NOC)- Fermi 1 Records NRR Chron File (Licensing)

NRC Notebook (Fermi l';

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Enclosure !

NRC-98-0023 Page1-n ENCLOSURE 1 DESCRIPTION AND EVALUATION OF PROPOSED LICEhi2 AMENDMENT Enrico Fermi Atomic Power Plart, Unit 1 I

NRC Docket No. 50-16 h

NRC License No. DPk-9 r

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• !!nclosure1 NRG.98-0023 Page 2 INTRODUCTION The purpose of this proposed amendment is to modify the Fermi 1 license to allow possession of byproduct material without restriction to chemical or physical form for sample analysis and instrument calibrations, or if the byproduct material is associated with radioactive apparatus, tools, hardware, or equipment at Fermi ! Oen the byproduct material was not produced by the Fermi 1 reactor.

r Many other reactor licenses have a similar provision allowing byproduct material when not produced at that particular facility. Without such a provision, a literal reading of the license prevents possession of

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calibntion sources containing more than exempt quantities of byproduct material. It prevents receipt of empiy slightly contaminated shipping containers for radioactive waste shipments. it prevents use of tools or apparatus that have been left contaminated from radiological work at another facility, it prevents use of protective clothing containing residual contamination from Fermi 2.

. The r, aric9:n to possess only Fermi i produced byproduct material doesn't cause much o a pro em if f

bl nornu urveillances are the only activities being conducted. When maintenance or other activities are in

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. progress, this limitation creates logistici problems and increases cost. For example, separate protective clothing and laundry proces:,ing are needed for Fermi 1 instead of being able to use Fermi 2's protective clothing. Special arrangements need to be made for radiologically clean radwaste shipping containers.

This alone, added several weeks to the shipping schedule for a planned shipment last fall. Nuclear vendors who perform work at multiple facilities would need to povide clean tools for work at Ferrai 1.

Instrumentation used at Fermi i needs to be retumed to Fermi 2 for source checks, calibration, and 3

maintenance, unless small exampt quantity sources can be used. These types of constraints add cost, time and inefficiency to planning and executing Fermi 1 activities.

To improve fiexibility and efficiency, Detroit Edison proposes to add a subpart 3 to Part 2.B of the Fermi i license, reading as follows:

(3) Pursucnt to the Act and 10 CFR Part 30," Rules of General Applicability to Domestic Licensing of Byproduct Material," to receive, acquire, possess, use and transfer byproduct material without restriction to chemical or physical form for sample analysis, instrument calibration, or associated with radioactive I

apparatus, hardware, tools, and equipment, provided the cumulative radioactive material quantity of the byproduct material does not exceed the criteria contained in Section 30.72, Schede'e C," Quantities of Radinactive Materials Requiring Consideration of the Need for an Emergency Plen for l

Responding to a Re ease."

EVALUATION The proposed amendment adds flexibility and efficiency, while reducing potential costs at Fermi 1.

Detroit Edison clready is licensed "nder 10 CFR Part 30 to poness byproduct material produced by operation of the reactor, so this avendment is not a new type oflicense for Fermi 1. Part 2.C of the i

license specifically states the applicability of 10 CFR Part 20 to the facility. Therefore, the infrastructur-to properly handle contaminated appa r.tus, toc'.s, hardware and equipment and non-exempt radioactive sourcea exists. Also, Fermi i uses the Fermi 2 Radiation Protection Program, so program requirements for proper handling of sealed sources have already been established.

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• Enclosure 1 NRC.98 0023 Page3 Since Fermi 1 was an experimental breeder reactor facility,10 CFR Pan 50 requirements also apply.

The facility was per:nanently shutdown 25 yests ago and it is in SAFSTOR status, with no fuel remaining onsite. Based on the radioactiv;.

term and the accident analyses, no offsite protective measures are r.eeded for any postulated accident. -Therefore, no emergency plan is needed or established for Fermi 1.

The proposed amendment limits the cumulative radioactive materia! quantity from byproduct materials to the values in 10 CFR 30.72, Schedule C," Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency Plan for Responding to e. Release. Yhis limitation obviates the need to establish an emergency plan due to any potential release of the radioactive material associated with the contaminated appantus or non-exempt radicactive sources. Section 30.32 (i) only requires an emergency plan if quantities greater than Section 30.72, Schedule C, amounts are possessed.

Except for this limitation, the proposed amendment is similar to provisions many reactors have in their license.

. SIGNIFICANT ll A7,ARDS CONSIDERATION In accordance with 10 CFR 50.92, Detroit Edison has made a determination that the proposed amendment involves no significant 1.azards consideration. Tc make this determination, Detroit Edison must establish that conduct of activities in accordance with the proposed amendment would nat:

(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.

1.

The proposed amendment does not involve a significant increase in the probability or consequences of an accident. Using slightly contaminated apparatus or a small non-exempt radioactive source cannot affect the probability of the analyzed sodium or liquid waste accidems.

He ability to possess such equipment does not in itself change any methods of handling liquid waste or sodium. Use of contaminated equipment cauld potentially increase the consequences of an accident ifit was in use or in the vicinity if an accident occurs. Ilowever, the increase in consequer.ces would not be significant due to the limitations on radioactivity content of such equipment. The limit was selected to be that in 10 CFR Przt 30.72, Schedule C, as the threshold beyond which offsite emergency plans are required. Since the quantity is bMow that requiring an offsite emergency plan, even if all the byproduct material allowed to be possessed by the proposed amendment were released during a postulated accident. the consequences would not be significantly increased. The quantity contained in any specific piece of contaminated apparatus or a source would be expected to be even less. Tinrefore, this amendment does not involve a significant increase in the probability or consequences of an accident.

2.

The proposed amendment does not create the possibility of a new or different type of accident from any previously evaluated. Allowing possession of contaminated apparatus, tools or equipment does not change methods of monitoring tl e facility or operation or surveillance of any systems at Fermi 1. While possession of a different source will permit other instrumentation to be calibra:ed, source checked, or tested at Fermi 1, testing ofinstrumentatics is a routine, ordinary activity. It is not an activity which creates the possibiEty of a new or different type of accide.a.

For these reasons, allowing Detrc.t Edison to possess limited amounts o" yproduci material at Fermi i produced from sources wher than Fermi 1 will not create the possibility of a new or different type of accident.

• Enclosure 1 NRC-98-0023 l

'Page 4 li.

'Ihe proposed amendment does not involve a significant reduction in tiie margin of safety at Fermi 1. No changes to any systems, or the status of any systems or structures, are created by this amendment. Ileing able to have a ' mited amount of additie ial radioactive material at Fermi 1 m the form of contaminated apparatas, tools, equipment or herdware or non-exempt radioactive sources will not significantly reduce the margin of safety because a 10 CFR Part 20 program is already in pac and the amount of radioactive material is being limited below the amount in 10 CFR Part 30.72, Schedule C. For these reasons, this amendment will not significantly reduce

+c margin of safety at Fermi 1.

ENVIRM, '1 ENTAL, lM PACT Detroit Edison has reviewed the proposed amendment against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor significantly change the types or increase the araounts of effluents that may be released effsite, nor significantly increase individual or cumulative occupational radiation expo. cures. The handling of slightly contaminated appaiatus, etc. ard non ev.empt calibration sources is not expected to measurably increase occupational exposures, llased on the foregoing, Detroit Edison concludes that the proposed amendment rrrets the critena given in 10 CFR 51.22 (c) (9) for a categoncal exclusion from the requirements for an Environ:nental Impact Statement.

CONCI,USION 13ased on the evaluations above: (1) there is reasonable assurance that the health aa:1 safety of the public will rnt be endangered by conduct of activities in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the proposed amendment will not be inimical to the common defense and security or the health and sa' N of the public.

Detroit Edison requests that the proposed license amendment be effective within 60 days of approval by the Commission.

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