NRC-98-0025, Application for Amend to License DPR-9,changing TS on Access Control to Provide Flexibility While Maintaining Similar Controls Over Access

Application for Amend to License DPR-9,changing TS on Access Control to Provide Flexibility While Maintaining Similar Controls Over Access

ML20199F559
Person / Time
Site:	Fermi
Issue date:	01/28/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199F562	List: ML20199H261 NRC-98-0025, Application for Amend to License DPR-9,changing TS on Access Control to Provide Flexibility While Maintaining Similar Controls Over Access
References
CON-NRC-98-0025, CON-NRC-98-25 NUDOCS 9802040039
Download: ML20199F559 (10)

Text

r* .

• lIOUMM N. 6lpWD

.g $rnior G e heddent, % dear Generathu nnni:

f;4* Nort h lhur lin . hewport, Midiigan 4MM Tel 313 TMJcol rat allTM 462 Detroit Edison

~

7 January 28,1998 NRC 98-0025 U. S. Nuclear Regulatory Commission

,1ttn.: Document Control Desk Wash!ngton,D C 20555

References:

1) Enrico Fermi Atomic Power Plant, Unit No.1

, NRC Docket No. 5.0-1,6 NRC License Number DPR 9

2) Detroit Edison Letter, NRC 97-0110, dated October 2,1997

3) Detroit Edison Letter,NRC 98 0027, dated January 30,1998

Subject:

Proposed Technical Specification Change (l.icense Amendment)on Access Control Pursuant to 10 CFR 50.90, Detroit Edison hereby proposes to amend Possession Onlj License DPR 9 for the Fenni i plant by modifying Technical Specification Sections B, E, 1, and Figure B 1.

This application proposes to change the Technical Specifications on access control to provide flexibility while maintaining similar controls over access. Provisions are also established for cases where work is performed on the Protected Area boundary, such that the boundary temporarily will not meet the Technical Specification criteria. Additionally, redundancy between Technical Specification Sections is being climinated.

Figure B-1 is being modified to more accurately show the Protected Area. The current Protected Area building sketches are fairly rough, especially for the Sodium Building complex. The proposed sketch shows the individual buildings and boundaries better.

Also, the location of the Protected Area doors and gates is being deleted from the sketch.

~

. .; . ~ . 7 Ill ,Illlil.ill ll llll 9

9902040039 990128 \y PDR ADOCK 05000016 kO P PDR A IrrE Energy C+nipans I

_)

e .

OSNRC NRC 98 0025 Page 2 This will provide ficxibility if an additional gate needs to be installed in the future to bring equipment into or out of the Protected Area.

The changes will improve efficiency during the Industrial Safety Improvement program.

Currently, c Fermi 1 worker needs to enter the Femii 2 Protected Area first to gain access to Fermi 1. The flexibility gained by this amendment will allow other provisions to be implemented.

The description and evaluation of the specific changes are included in Enclosure I to this letter. Enclosure 2 contains the proposed Technical Specification page revisions.

Please note that Reference 3 is also a proposed Technical Specification change that affects page 5 of the Technical Specifications.

Detroit Edison requests prompt approval of this request and that this amendment be approved with an implementation time period of"within 60 days."

Detrc,it Edison has evaluated the proposed Technical Specification change against the criteria of 10 CFR 50.92 and determined that No Significant flazards Consideration is involved. The Fermi 1 Review Committee has reviewed and approved the proposed Technical Specification changes. In accordance with 10 CFR $0.91, Detroit Edison is providing a copy of this letter to the State of Michigan, if you have any questions, ple e contact Lynne Goodman at 734 5861205.

Sincerely. -

/

Enclosures cc: A.B. Beach S.W. Brown O.A.Ilarris J.E.11ouse, NRC Region 111 D. Nelson, NRC Region 111 D.R. Ilaim (State of Michigan)

USNRC NRC 98 0025 Page 3

. 4

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

DOUGLAS R.'GIPSON Senior Vice President On this N dayof j <tattML'r ,_,1998 before me personally appeared Douglas R. Gipson,)cing first dIily swom and says that he executed the foregoing as his free act and deed, s -k; hL6Wi--

Notary Public ROSAl.tE A. ARMETTA fATARYPUBUC MONROCCOUNTY,tAl MY COUMISSl0N EXPIRES 10/1199

)

USNRC NRC.98 0025 Page4

. O bec: P.J. Borer P. Fessler D.R. Gipson L.S. Goodman L.K. Layton J.E. Moyers R.J. Beaudry 'I D. Bergmooser D.K. Cobb

J.E. Conen R.A. DeLong, Jr.

. R.R. Eberhardt, Jr.

W.D. Gilbert T.W. Haberland R.A. Janssens E.F. Kokosky J. Korte R. Laubenstein E.F. Madsen R.L. Matthews J.E. Meyers R.A. Newkirk W.T. O'Connor, Jr.

E.M. Page 1 - J.H. Plona -

T.L. Schehr l K.W. Sessions j E.M. Wilds l D.R. Williams

- Infor.aation Management (116 NOC) Fermi 1 Records NRK Chron File (Licensing)

NRC Notebook (Fermi 1)

Enclosure 1

, NRC-98-0025

. Page1 l

I 4

ENCLOSURE 1 DESCRIPTION AND EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGES Enrico Fermi Atomic Power Plant, Unit 1 NRC Docket No. 5016 ' - -

NRC License NO. DPR-9 e

. _ _ - , - -,m . . . . , . , _ . _ , . _ , . . ,_ . .-.- , . .

Enclosure 1

. NRC 98-0025 Page 2 INTRODUCTION He purpose of this proposed amendment is to modify Technical Specifications to:

• Permit the Fermi 1 key currently maintained by the Custodian as a reserve key (only to be used for extenuating circumstances), to be issued by the Custodian or delegate for normal access.

• Delete Section 1.5. Add portions of1.5 that were not redundant to Section B.

• Revise the requirement in Section B for access to the facility to allow access b be through locked gates in the fencing or locked doors.

• Delete the requirement for locked doors in the building walls making up part of the perimeter to be locked from the inside, e Add the provision that doors in the building walls making up part of the perimeter may be secured from the inside vs. locked.

• Reword sentences in Section B to climinate redundancy.

• Allow temporary moddications to the Protected Area boundary shown in Figure B 1," Facility Plan," provided the boundary continues to meet the requirements of Section A for the Physical Barrier and any access points meet the requirements in Section B.

• Add provisions to use a posted individual in the vicinity or observing the area remotely using a camera capable of viewing the affected area in case of work on a Protected Area fence or wall which degrades the boundary such that the boundary requirements will temporarily not be met, and there is no work in progress or personnel within the Protected Area, e Modify Figure B 1," Facility Plan," to better show the buildings within the Protected Area and to delete the locations of the Protected Area gates and doors and a building and equipment outside the Protected Area which are planned to be removed in the future.

Additionally, spelling and format corrections were made to the Technical Specification pages being retyped for this proposed change.

EVALUATIQN As a whole, these changes will increase flexibility, while still ensuring only authorized individuals will be issued a key to access Fermi 1. A key will still be needed to access the Fermi 1 Protected Area. The flexibility will mainly be increased by allowing the current reserve key to be used, allowing doors in walls to be locked without specifying whether from the inside vs. outside, allowing temporary modifications to the Protected Area boundary, and deleting locations of doors and gates so that a new gate or door could be installed without requiring additional Technical Specification changes. Each change will be individually evaluated in the following paragraphs.

Currently, only the Radiation Protection Control Point at Fermi 2 can issue the Fermi 1 key for normal access. The Custodian also has a key, but it can only be used under extenuating circumstances. With the increased activity expected during the Industrial Safety Improvement Program, increased productivity

Enclosure !

', NRC 98-0025 Page 3 can be gained if the Custodian's key can be used. His change proposes to allow the Custodian or

'dclegate to issue the Fermi i key. A key will still be maintained at the Radiation Protection control point. Issuance of either key will still only be to authorized individuals and record. will still be kept of key issuance, ne revised wording does not specify that there will be exactly two keys, one at each location, which the current wording does. The revision would allow another key to be made, but requires the Custodian (or delegate) and Penni 2 Radiation Protection to be responsible for the keys and only permit key use by authorized persons. Herefore this change will still maintain the key control provisions which ensure only authorized individuals have control of the Fermi 1 key.

Section 1.5 in the Administration Controls Section of the Technical Specifications covers control of access to the facility, items covered are key control, approval of unescorted access to the Protected Area and that all gates to the facility shall be locked except when personnel are within. Section B," Facility,"

also covers access to the facility, including in part, that gates and doors shall be locked and may be opened by an authorized person for use when work is in progress. Rather than have two sections address access, this change proposes to consolidate the facility access control measures in Section F. This change will help prevent a user from only referring to one of the Sections on access control and making decisic.1s based on only some of the requirements. his is a human factors improvement.

Currently, Sections B and E require doors allowing access into the Protected Area be locked from the inside or permanently closed when work is not in progress. Gates in the fencing, though, are only required to be locked when work is not in progress or people within. Logistically, this requires an authorized individual to enter through a gate in the fence by unlocking the gate and then entering the building to be worked in through a door opening into the Protected Area. If there is a need to open a building door in an exterior wall, the individual then unlocks the door from the inside. That doorway can then be used for material or personnel entry or exit. When done, that door must be lacked closed from the inside and an individual must exit the Protected Area through a gate in the fence and then lock the gate. There is no obvious reason why doors must be locked from the inside, but gates are locked from the outside. Both provide access into the Protected Area. The proposed Technical Specifications would allow the door to be unlocked while people are working inside to provide for an emergency exit. This chenge, therefore, proposes to only require doors to be locked without specifying from the inside or '

outside. The doors would still provide the same level of access control as do the gates if this change is approved.

Also, the wording is proposed to be changed to allow access through locked gates in the fencing or locked doors. Currently, since doors are locked from the inside, they cannot be unlocked to allow access, ifin the future, doors are locked from the outside, this change would allow entry by unlocking a door vs.

only by unlocking a gate.

Another option to locking doors in the exterior walls is also proposed. He current options are locked from the inside or permanently closed. The option of securing the door fiom the inside is proposed to be added. Securing the door from the inside would provide a similar level of access control as the existing options, but may be easier to implement in some situations. An example of a means of securing a door without locking it is to bar it closed.

In incorporating these changes into Section B, the wording is revised to include the new provisions and eliminate redundancy. Section E also addresses the external access doors specifically into the Fuel and Repair Building. The wording referring to locking or permanently closing such doors is deleted so that all the requirements for locking external access doors are in one place.

i -

Enclosure 1

. NRC 98-0025 Page 4 -

A provision is proposed to be added to Section B to allow temporary odifications to be made to the

' Protect'e d Acca boundary shown in Figure B-1, provided the boundary continues to meet the requirements of a Physit al Barrier, as defined in Section A, and any access points meet the requirements of Section B. This prov.sion would allow a temporary addition to be made to the Protected Area boundary as long as the addition was made of fencing constructed of No. I1 AWG, or heavier, wire fabric, topped by three or more strands of barbed wire on brackets angled outward, with an overall height of not less than seven feet, including the barbed wire, or manmade structures providing an equivalent degree of resistance to penetration, it could be helpful during the Industrial Safety improvement Project to add a small structure to use as an entry point into the Protected Area. Such an area could be used for personnel monitoring prior to exiting the Protected Area, a change room, or other activities.

Temperature and humidity could be controlled to support instrumentation without having to heat or cool large buildings. No decision has been made to install a temporary stmeture, but the proposed provision would allow such an installation it desired. Once the facilities were no longer needed, the structure would be removed. If the structure was temporarily made part of the Protected Area, its walls would become part of the Protected Area boundary or a fence meeting the criteria of Technical Specifications would need to be installed around the structure and the walls or fence would need to merge with the existing boundary. Doors in the boundary would be required to be locked. The requirement that a Physical Barrier is on the perimeter such that the entire facility is a Protected Area would still be met.

The difference would be that the boundary would temporarily be in a different location than shown on Figure B 1, and if a temporary structure was involved, the walls would be different walls than shown on the figure. Since the same requirementa for a Protected Area boundary and access points as apply to the permanent boundary would need to be met, adequate access control would be provided.

This request also proposes to revise Section B to povide compensatory provisions if the Protected Area fence or building walls are being worked on such that the boundary requirements will temporarily not be met. Currently, there are no provisions for compensatory actions if the Protected Area boundary will temporarily not meet requirements. Some example situatiom which could occur include repair of barbed wire or fencing, installation of a new gate, or possibly during work in an underground tunnel.

Currently, if boundary requirements could not be met, a Licensee Event Report would be required, but no compensatory measures would be needed. This change proposes to require an individual be posted in the vicinity or observe the area remotely using a camera capable of viewing the affected area if there is no ongoing work in progress or personnel in the Protected Area. If these compensatory measures are approved and implemented, there would be control over a degraded boundary in the future. If work is ongoing on the boundary, personnel performing the work can control access. Currently, gates can be unlocked when personnel are in the Protected Area, so additional compensatory measures would only be required when the boundary is degraded while personnel are not inside the Protected Area or work is not in progress. Only if the required compensatory action was not implemented, would the Technical Specification be violated and a Licensee Event Report required. Therefore, the proposed change would maintain greater control over the Protected Area boundary than the existing requirements.

Figure B 1," Facility Plan," is a sketch showing Fermi 1 building outlines, the Protected Area boundary, and doors and gates in the Protected Area boundary. The outlines of some of the buildings are quite rough and not very accurate and the level of detail varies considerably, with some items on the sketch being difficult to identify. This application proposes to replace Figure B-1 with a simplified sketch that more accurately shows the buildings in the Protected Area and also identifies approximately the existence of underground tunnels in the Protected Area, though the exact pathways of the tunnels are not drawn. The Boilerhouse, which is where a retired oil-fired boiler is located, and the Fermi 1 main unit output transformer are lef1 off the drawing because of plans to remove them in the future. The facility is

Encicome 1

. NRC-98-0035 Page 5 identified in Section B of Technical Specifications as the area within the Protected Area boundary, so it

'is impo'rtant that the buildings within the Protected Area are well identified, but not necessary to include buildings outside the Protected Area. The Boilerhouse and transfonner are outside the Protected Area.

The proposed sketch deletes the locations of doors and gates in the Protected Area boundary. The specific locations are not important to ensure control of access. The requirements of Section B establish the controls over the access points. If during the Industrial Safety improvement Program, there is the need to create a new access point to bring in equipment, a Technical Specification change would be needed at that time if access points were indicated on Figure B 1. Eliminating the specific locations at this time, whde a change to the sketch is already being processed, will obviate the need for a possible foreseeable future change to this Technical Specification figure, without reducing what controls would apply to the access point. For these reasons, deleting the locations of the doors and gates will provide increased flexibility and eliminate the need for a possible prompt Technical Specification change in the future, while not affecting the control requirements for any new access points.

in combination, these proposed changes consolidate existing Technical Specification requirements, add accuracy, increase flexibility, and allow changes to be made to improve efficiency, while still ensuring controls are maintained over Fermi 1 access points and the key and that only authorized personnel will be issued the Fermi 1 key.

Spelling and format changes were made to the Technical Specification pages being retyped for this proposed change. The changes consist of correcting the spelling of the words " locked" and "Thermoluminescent", capitalizing the words " Reactor Building" and " Primary System" to be consistent with how the terms are capitalized elsewhere r the same page, and spelling out the numbers 2 and 3 in Section 1.4. These changes are strictly editorial and change no requirements.

SIGNIFICANT IIAZARDS CONSIDERATION In accordance with 10 CFR 50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that conduct of activities 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,

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident. The proposed changes all involve access control, the Protected Area boundary, or deletion of details from a sketch, including a building and equipment planned for removal, which are outside the Protected Area. The changes still require control over the gates and doors to the Protected Area and that only authorized individuals will be issued the Fermi 1 key. Since the changes do not involve operation of any systems, modifications to any required plant systems, nor eliminate the requirements for control of the Fermi i key and access points, the probability or consequences of an accident will be unaffected.

2. The proposed changes do not create the possibility of a new or different accident from any previously evaluated. The proposed changes will not lead to any different method of operating any systems, nor will they create any tests invoking plant systems. The changes only affect the access control requirements, the Protected Area boundary, and deletion of details from a sketch. Changes of who issues the key, how doors are secured, provisions for temporary modifications to the

/ Enclosure 1

, NRC 98 0025 Page 6 boundary, requirements to observe the Protected Area boundary if degraded, wording consolidation, and more accurate building outlines cannot cause a new or different type of accident. Access points and the Fermi 1 key are still required to be controlled. The Boilerhouse and main unit output transformer are not used to support the Fermi 1 nuclear facility. Removal of the Boilerhouse and main unit output transformer from the drawing will help facilitate future removal plans, but will not cause a new or different accident from any previously evaluated since they provide no support to the Fermi 1 nuclear facility. For these reasons, the proposed changes to the access control requirements and Figure B-1 will not create the possibility of a new or different type of accident.

3. The proposed changes do not involve a significant reductica in a margin of safety. The changes involve access control, the Protected Area boundary, and the sketch of the facility. Doors and gates in the Protected Area boundary will still be required to be secured when personnel are not inside.

The keys will still be required to be controlled and issued only to authorized personnel.

Compensatory measures will be required if the Protected Area boundary is degraded such that the requirements are not met. Therefore, there will not be a significant reduction in the margin of safety.

ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes 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 amounts of effluents that may be released off site, nor increase individual or cumulative occupational radiation exposures. Based on the

' foregoing, Detroit Edison concludes that the proposed Technical Specifications meet the criteria given in -

10 CFR 51.22 (c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

CONCLUSION Based on the evaluations above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by conduct of activities in the pmposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the proposed amendment will not be -

inimical to the common defense and security or the health and safety of the public.

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