ML17334B300

Application for Amends to Licenses DPR-58 & DPR-74,allowing Posting of Designated Individuals to Substitute for Locked Doors for High Radiation Areas Required by Tech Spec 6.12.2. Justification & Analysis Encl

ML17334B300
Person / Time
Site:	Cook
Issue date:	03/14/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17334B301	List: ML17334B300 ML17334B302
References
AEP:NRC:1039, NUDOCS 8903220176
Download: ML17334B300 (9)

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ACCELERATED II+RIBUTI0% DEMON ST TIDY SYSTEM 4

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8903220176 DOC.DATE: 89/03/14 NOTARIZED: NO DOCKET PT FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Xndiana & 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana & 05000316 AUTH. NAME AUTHOR AFFILIATION ALEXICH,M.P. . Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECXP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to Licenses DPR-58 & DPR-74,allowing posting of individuals to substitute for locked doors.

DISTRIBUTION CODE: A001D COPXES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPXENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 0 PD3-1 PD 2 2 STANG,J 1 1 D INTERNAL: ARM/DAF/LFMB 1 0 NRR/DEST/ADS 7E 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SICB 1 1 NRR/DOEA/TSB 11 1 1 NU~GS ABS CT 1 1 OGC/HDS1 1 0 LE 01 1 1 RES/DSIR/EXB 1 1 EXTERNAL LPDR 1 1 NRC PDR 1 1 NSXC 1 1 D

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D NOTE 'IO AXZ- "RZDS" RZCZPIENIS.

S PIZASE HELP US 1O REDUCE WASTE.'GNI'ACT 'IHE DOCUMEMI'GNIROL DESK, ROOM Pl-37 (EXT. 20079) KO EIZMZNATE YOUR NAME FRY DISTIKBVTIGN LISTS FOR DOCUMENIS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 16

Indiana Michigan Power Company

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P.O. Box 16631 Columbus, OH 43216 AEP:NRC:1039 Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 T/S CHANGE REQUEST ON LOCKING OF HIGH RADIATION AREAS U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: T. E. Murley March 14, 1989

Dear Dr. Murley:

This letter constitutes an application for amendment to the Technical Specifications (T/Ss) for the Donald C. Cook Nuclear Plant Units 1 and 2. Specifically, we are proposing to allow the posting of designated individuals to substitute for the locked doors for high radiation areas required by T/S 6.12.2 ~ A detailed description of the proposed change and our analysis concerning significant hazards considerations are contained in Attachment 1. The proposed revised T/S pages are contained in Attachment 2.

We believe that the proposed change will not result in (1) a significant change in the types of effluents or a significant increase in the amount of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.

These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and will be reviewed by the Nuclear Safety and Design Review Committee at their next regularly scheduled meeting.

In compliance with the requirements of 10 CFR 50.91(b)(1), copies of this letter and its attachments have been transmitted to Mr. R. C. Callen of the Michigan Public Service Commission and Mr. G. Bruchmann of the Michigan Department of Public Health.

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89'03220176 PDR ADOCK 85'0314 05'000325 PDC

Dr. T. E. Murley AEP:NRC:1039 This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

Sincerely, M P. Al xich Vice President CEM/eh Attachments cc: D. H. Williams, Jr.

W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman A. B. Davis - Region III

ATTACHMENT 1 TO AEP:NRC:1039 REASONS AND 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNIT NO. 1 AND UNIT NO. 2 TECHNICAL SPECIFICATIONS

1 Attachment 1 to AEP:NRC:1039 Page 1 DESCRIPTION OF CHANGE Technical Specification (T/S) 6.12.2 requires that locked doors be provided to prevent unauthorized entry into high radiation areas in which the intensity of radiation is greater than 1000 mrem/hr. We are proposing to allow the posting of a designated individual to serve as a substitute for a locked door in those instances in which providing a locked door is not possible or not practical due to area size or configuration.

We have noted the concerns raised in NRC Information Notice 88-79, "Misuse of Flashing Lights For High Radiation Area Controls." The majority of the examples of misuse cited in this information notice involved using the flashing lights (1) when constructing a lockable enclosure was a reasonable alternative or (2) when locking an existing enclosure was possible. As noted above, we intend to use the proposed alternative of posting a designated individual only when it is not possible or not practical to provide locked doors.

As explained in the T/Ss, the intent of the locked doors is to prevent unauthorized entry into the subject area. We believe that

'posting a designated individual provides a level of protection for preventing unauthorized entry that is equivalent to or better than the protection provided by the flashing lights allowed by the current Westinghouse standard T/Ss and the T/Ss of some other nuclear plants.

Per 10 CFR 50.92, a proposed amendment will not involve a significant hazards consideration if the proposed amendment does not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident Erom any accident previously analyzed or evaluated, or (3) involve a significant reduction in a margin of safety.

Criterion 1 Changing the access control requirements for high radiation areas does not impact any of the previously analyzed accidents.

Therefore, we beli<":e chat this change will not involve a significant increas'n the probability or consequences of an accident previously valuated.

to AEP:NRC:1039 Page 2 Criterion 2 The proposed change does not involve a change in plant'configuration or operation and will not place the plant in an unanalyzed condition; therefore, we believe the change will not.create the possibility of a new or different kind of accident from any previously analyzed or evaluated.

Criterion 3 We believe that posting a designated individual is equivalent to or better than the alternative (flashing lights) allowed by the Westinghouse standard T/Ss and the T/Ss of some other nuclear plants. Based on this and since we believe that the designated individuals will provide adequate protection against unauthorized entry, we believe the change will not involve a significant reduction in a margin of safety.

The Commission has provided guidance concerning the determination of significant hazards by providing certain examples (48 FR 14780) of amendments considered not, likely to involve significant hazards considerations. We believe the proposed change is less likely than the sixth example in the above guidance to involve a significant hazards consideration. Specifically, we believe the proposed change will not result in an increase in the probability or consequences of a previously analyzed accident or reduce a margin of safety, since we believe that posting a designated individual will provide adequate protection against unauthorized entry for those instances for which providing a locked enclosure is not possible or not practical. Therefore, we believe this change does not involve a significant hazards consideration as defined in 10 CFR 50.92.