ML20070J678
| ML20070J678 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/18/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20070J676 | List: |
| References | |
| NUDOCS 9407250262 | |
| Download: ML20070J678 (3) | |
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W ASHINGToN, D.C. 20555-0001 SAFETY OlALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.101 TO FACILITY OPERATING LICENSE N0. NPF-43 DETRolT E01 SON COMPANY FERMI-2 DOCKET NO 50-341
1.0 INTRODUCTION
By letter dated May 24, 1993, the Detroit Edison Company (DECO or the licensee) requested an amendment'to the Technical Specifications (TS) appended to facility Operating License No. NPF-43 for fermi-2.
The proposed amendment would make title changes to various management positions, include a provision to allow future title changes without license amendment, revise the description and number of Onsite Review Organization (OSRO) members, revise the overtime requirements and approval authority and change the ISEG reporting requirements.
2.0 EVALVATION The proposed title changes are in conformance with a recent Staffing Transition Program conducted at the Fermi 2 site and are generally acceptable.
The effort was designed to streamline reporting relationships and improve overall operational efficiency.
In many cases, the change was in title only.
For example, the functions of the Senior Vice President, which was for a short period i
called Executive Vice President, and the Assistant Vice President - Nuclear Production have been consolidated under the position of " Senior Vice President -
Nuclear Generation " The licensee also asked by letter dated July 7, 1994, that-the change to TS 6.2.2 9 be withdrawn.
Except as noted below, the requested title changes are acceptable, Certain of the licensee's proposed staffing title changes were not viewed as being changes in title only and are denied.
These' include the proposed change to 15 6,2.3.4 for i.he Independent Safety Engineering Group (ISEG) reporting requiremeiis.
This would change the reporting requirement for recommendations i
for revised pro edures, modifications, maintenance and operations from the "Vice
- President - Nuclear Engineering and Services" to " Nuclear Generation Management "
The proposed chatqe would not achieve the same level of management oversight as-is currently requ ired, i.e.,
vice president.
While the supporting justification of making ISEG re. commendations to the responsible management for the area being-reviewed has merit, this can be achieved by improved interdepartmental
' communications without sacrificing senior management oversight of the ISEG recommendations and related followup activities.
i Also denied is the proposed change to TS 6.2.2.f which defines those unit staff i
- members to which administrative procedures governing overtime limits are -
applicable. The proposed changes would delete the radiation protection 9407250262 940718 PDR ADOCK 05000341 P
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. l technicians (formerly health physicists) from those listed as examples of staff members who work on safety-related equipment.
The proposed amendment is denied because the NRC considers this occupation to be within the scope of those considered as working on safety-related equipment.
The proposed change to TS 6.12.1.c would change the governing authority on a Radiation Work permi_ for specifying the frequency of surveillances from a Radiation Protection Supervisor to e Radiation Protection Technician.
The staff has determined that this authority.should remain at the supervisory level and this proposal is denied.
While future specific title changes would be allowed for this position as a result of another proposed TS change, the level of authority for meeting the specified requirements should remain at the supervisory level.
The licensee also proposed adding a footnote for certain titles to preclude the need for future TS changes for title changes only.
The " alternative title" designated for a position would have all requirements of the TS apply to the alternative title as apply to the specified title.
Alternative titles would be specified in the Updated Final Safety Analysis Report (UFSAR).
The staff finds that the requested change is acceptable so long as the unit staff qualification requirements of TS 6.3 and any related standards or qualifications specified in the UFSAR related to a specified title are also met with respect to the alternate title.
The licensee requested changes to TS 6.5.1 for the designation and composition of the onsite review organization (OSRO). The changes include designation by management functional area rather than title and the provision allowing the OSR0 chairman to designate other members who may serve as vice-chairman of OSR0.
The staff has reviewed these changes and finds them acceptable.
The staff notes that the previous footnote for the listed members and vice-chairman clarifying that a vice-chairman could not serve as both chairman and voting member at the same time has been removed.
The staff has verified that this stipulation is contained, by procedure, in the written designation and also is reinforced by TS 6.5.1.5 which identifies the quorum requirements.
Therefore, this change is also acceptable.
The licensee also requested changes to TS 6.2.2.f for overtime controls.
The proposed change to TS 6.2.2.f.3 would allow a break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> before i
returning to work only if an individual works 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> or more continuously (including shift turnover). This is a significant change to the current requirement that a break of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> be allowed between work periods, including shift turnover.
The staff reviewed this proposed change and the licensee's supporting justification.
The staff does not agree that the proposed TS adequately clarifies the intent of the requirements.
If the proposed TS were approved, there would be no need for TS 6.2.2.f.3 because the previous two TS requirements would make it impossible to meet the first two and violate the
' third.
The purpose for the current TS 6.2.2.f.3 is to ensure adequate rest between work periods regardless of duration. The staff has determined that the licensee has not provided adequate justification for this proposed change and j
this proposed change is denied. The proposed change to TS 6.2.2.f.4 no longer j
specifies the Plant Manager's monthly review of overtime as " individual i
i overtime "
The licensee's supporting justification is that it believes
" management oversight of overtime can be more effectively done by reviewing I
. information which has been previously aggregated and evaluated." Nothing in the current TS requirements prevents the licensee from doing this.
However, the requirement to review individual overtime is based on observing whether individual patterns are occurring which might lead to violations.
The staff finds that the requested change is not sufficiently justified.
The staff, therefore, denies the proposed TS change.
The licensee's proposed change to TS 6.2.2.f has been discussed previously for its proposal to eliminate the radiation protection technicians (formerly health physicists) from the list of those for whom the overtime limits should apply.
The proposed change from applicability "to those who perform safety-related functions" to "those who work on safety-related equipment" is denied.
The staff believes that limiting the overtime controls to those who work directly on safety-related equipment rather than those who also perform safety-r? lated functions could adversely impact safety.
Therefore, this related chtnge is denied.
The staff has reviewed the licensee's proposed change for approval of deviations from the overtime controls from (in addition to the Plant Manager) the "Section Superintendent" to the Plant Manager's designee.
The staff finds that this added flexibility continues to provide adequate oversight, and is therefore, acceptable.
The staff notes that the margin bars for TS 6.5.1.4, 6.5.1.5, 6.13.2, and the footnote at the bottom of page 6-23 did not indicate changes from the current TS.
Therefore, no changes were made.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment changes recordkeeping, reporting, and administrative procedures and requirements.
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
T. Colburn Date: July 18, 1994
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