ML20207L010
| ML20207L010 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 01/07/1987 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20207L014 | List: |
| References | |
| VP-NO-87-0003, VP-NO-87-3, NUDOCS 8701090587 | |
| Download: ML20207L010 (13) | |
Text
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Nuclear Operations Detroit-b" r.-
Edison BIE9F "
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1 January 7,1987 VP-NO-87-0003 U. S. Nuclear Regulatory Consission ATTN: Document Control Desk Washington, D. C.
20555 Paference: 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) Detroit Edison Letter to NRC, " Reactor Operations Inprovement Plan,"
VP-85-0198, dated October 10, 1985.
- 3) Detroit Edison Letter to NRC, " Response to Request for Information Pursuant to 10CFR50.54(f)," VP-86-0008, dated January 29, 1986.
- 4) Detroit Edison Letter to NRC, " Restart Report," VP-86-0080, dated July 2, 1986.
- 5) Detroit Edison Letter to NRC, "Twchnical Specification Change, hkninistrative Controls," VP-86-0096, dated August 5, 1986.
- 6) Detroit Edison Letter to NRC, " Technical Specification Change, Onsite Review Organization," VP-86-0138, dated Septenber 30, 1986.
Subject:
Proposed Technical Specification Chance-Akninistrative Controls Section 6.0 Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed change into the Plant Technical Specification Section 6.0, "kkninistrative Controls." The changes made accouplish three objectives: a) eliminate the organization charts, b) change various titles to more accurately reflect the f i
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U. S. Ninlear Regulctory Ccunission January 7, 1987 VP-NO-87-0003 Page 2 Fermi 2 Organization, and c) strengthen the responsibilities of the Onsite Review Organization (OSRO). Many of these changes have been discussed over the past several months with the NBC as presented in References 2, 3 and 4, with additional improvements made in References 5 and 6.
In October 1986, Detroit Edison requested the NRC to defer action on References 5 and 6 due to the Fermi 2 reorganization and to allow further refinement of the Onsite Review Organization responsibilities.
Detroit Edison has evaluated the proposed technical specifications against the criteria of 10CFR50.59 and 10CFR50.92 and determined that no unreviewed safety question or significant hazards considerations are involved.
'Ihe Fermi 2 Onsite Review Organization has approved the proposed changes herein. Also, the Nuclear Safety Review Group has reviewed this proposed technical specification change and concurred with the enclosed deterntinations.
Pursuant to 10CFR170.12(c), enclosed with this amendment request is a check for one hundred fifty dollars
($150.00).
In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.
If you have any questions, please cx)ntact Mr. Steven Frost at (313) 586-4210.
Sincerely,
" p g-
-l-S Enclosure cc: Mr. J. J. Stefano Mr. W. G. Rogers Supervisor, Advanced Planning and Review Section, Michigan Public Service Ccunission USNRC Region III l
U. S. Nuclear Regulatory Comnission January 7, 1987 VP-to-87-0003 Page 3
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I, FRAtE E. AGOSTI, do hereby affirm that the foregoing statenents are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
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FRA!E E. AGOE$I Vice President Nuclear Operations On this 7
day of b
- h, 19 g, before me personally appeared Firdnk E. Agoisti, being first duly sworn and says that he executed the foregoing as his free act and deed.
hYs Notary Public MARCIA CUCK Notary Public Washtenaw County, MI My Commission Expires Dec.28,191g dc2 d [d e m
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Enclosure to V N40-87-0003 Page 1 Byunnmm/bwetIGE After the July 2, 1985 rod withdrawal error, the Detroit Edison Company undertook an extensive program of corrective actions. %ese corrective actions were described in previous letters to the Comission (References 2,.3, and 4). Part of the corrective action involved strengthening the Nuclear Operations' Organization by hiring a senior manager with comercial nuclear experience to oversee the Nuclear Operations organization. %is individual fills the position of Group Vice President.
To enphasize and better focus the authority and responsibility for actual plant operation, Detroit Edison established the title " Plant Manager" and eliminated the former " Assistant Manager" title and position. Different organizational titles and positions are now used to indicate more clearly that other Nuclear Operations organizational units exist to support plant operations. % ese changes will be identified either in i
a section-by-section discussion below or be reflected in Chapter 13 of the Fenni 2 PSAR update.
Recognizing the need for continued organizational inprovements and with pending changes yet to be.
implemented, which would again impact the technical specifications figures 6.2.1-1 and 6.2.2-1, Detroit
~
Edison is proposing to eliminate these figures. Se i
figures are redundant to Chapter 13 of the Fermi 2 FSAR which is required (by 10CFR50.71) to be updated annually.
In reviewing the responsibilities of the Onsite Review 4
Organization (6.5.1.6), there are various administrative i
functions which are performed that reduce its effectiveness. % e purpose of this proposed change is to reduce this administrative burden. Se changes are intended to require OSRO to review only Adninistrative Procedures (those which control lower-tier procedures) and to review any safety evaluations required for lower i
tier procedures. % e Plant Manager would be responsible for assigning individuals to prepare and review safety evaluations for procedures, or changes to procedures, and provide technical reviews for those implementing procedures that are no longer reviewed by Osa0. Se result would be to enhance the Plant Manager's and OSRO's management overview of safety matters while substantially reducing the time and attention required i
by OSRO for implementing procedure review activities.
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Enclosura to VP-NO-87-0003 Page 2' A specific section-by-section description of the proposed changes to Chapter 6.0 is as follows:
Index Figures 6.2.1-1 and 6.2.2-1 S ese figures are being deleted since they are redundant to Chapter 13 of the FSAR. S e m figures are required to be updated on an annual basis per 10CFR50.71.
Section 6.1.1 Change the title " Assistant Manager-Nuclear Production" to." Plant Manager". h is reflects the current titles in the Nuclear Operations Organization. The responsibility and authority remain the sane; this is strictly an a&inistrative title change.
Section 6.2.1 Replace the words "... shown on Figure 6.2.1-1." with
"... described in Chapter 13 of the FSAR." %ese figures are redundant and 10CPR50.71 requires the FSAR to be updated annually. his change is consistent with the deleticm of Figures 6.2.1-1 and 6.2.2-1 in the Index Section above.
Section 6.2.2 Replace the words "...shown on Figure 6.2.2-1." with
"... described in Chapter 13 of the FSAR." Same as 6.2.1 above.
Section 6.2.2.f Replace the word "... physicists..." with "... physics
- personnel..." Wis is an achinistrative change to clarify that the positions covered by the requirement to limit overtime includes technicians, who are not Health Physicists.
Section 6.2.2.f i
In the next to the last line of second paragraph change "on major modifications" to "or major modifications."
his corrects a typographical error.
Section 6.2.2.f i
Replace the title "Acsu, tant Manager-Nuclear Production" with " Plant Manager". Replace the words "His Deputy" with "a Section Superintendent er the Radiation Protection Chemical Engineer". The word " deputy" does not exist in the Fermi technical specifications or in any other h = nt in use. S e word does not have any significance to Nuclear Operations personnel. Using "a Section Superintendent or the Radiation Protection Chemical Engineer" to replace the word Deputy, identifies exactly who may act in his behalf.
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Erclosure to VP-NO-87-0003 Page 3 1
I Figure 6.2.1-1 Offsite Organization h is Figure is to be deleted. Fermi 2 FSAR Chapter 13 contains the same Organization Chart and is required to be updated on an annual basis (10CFR50.71). h is is an administrative change for consistency with Sections 6.2.1 and 6.2.2 above.
Figure 6.2.2-1 Unit Organization Same discussion as Figure 6.2.1-1 Section 6.2.3.4 Replace the words "... Assistant Manager-Regulation and Compliance" with "... Group Vice President".
% e Assistant Manager-Regulatico and Coupliance position no longer exists in the Nuclear Operations Organization. h is change ensures ISEG will have appropriate access to the Group Vice President.
Section 6.4.1 Change "...the Director, Naclear Training..." to "...
the Director (s), Nuclear Training...." There are currently two directors in the Nuclear Training Department. One is in charge of operator training and requalification; the other is in charge of the remaining Naclear Training areas. his is an adninistrative change to more accurately reflect Detroit Edison's Nuclear Operations Organization.
Section 6.5.1 Underline and capitalize ONSITE REVIEW ORGANIZATION (OSRD) to be consistent with the rest of the Chapter 6 Technical Specifications Section 6.5.1.1 This section shall read, "% e OSRO shall function to advise the Plant Manager on all matters related to nuclear safety as described in specification 6.5.1.6."
his adninistrative change deletes the title " Assistant Manager-Nuclear Production" which no longer exists and identifies 6.5.1.6 which adds specific guidance as to what is meant by " matters related to nuclear safety."
Section 6.5.1.2 Replace the following titles, " Assistant Manager-Nuclear Production and Superintendent-Itaclear Operations" with
" Plant Manager and Superintendent-Operations." %ese adninistrative changes reflect the current organization at Fermi.
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Enclosura to VP-fD-874003 Page 4 4
i Section 6.5.1.4 4
W is section should be changed to read, "We Osa0 shall meet at least once per calendar month and as convened by the OSRO Oiairman or a Vice Chairman." % e replacement of "or his designated alternate" with "a Vice Chairman" is consistent with Section 6.5.1.2 which specifically identifies the two vice chairmen.
i Section 6.5.1.5 h is section should be changed to read "W e quorm of the OSao necessary for the performanm of the OSRO responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or a Vice Qiairman and four members including alternates" for the same reason as in 6.5.1.4 above.
Also being deleted is the number of alternates for the minimum quorum since it is redundant with technical i
4 specification 6.5.1.3 which allows a maximum of two j
alternates to vote at any one time.
Section 6.5.1.6.a.
Replace the existing statement with, " Review of all Plant Adninistrative Procedures and changes thereto;".
21s change is consistent with MIC philosophy in that it was not the intent that OSa0 review every change to every implementing procedure. W e current technical specification requires OSao to review every inplementing procedure and change. 21s activity conamnes valuable time that could be used to perform other needed l
activities. By making this change, OSRO will still review the adninistrative procedures but will leave the review of implementing procedures to the individuals as discussed in Section 6.5.3.
1 Section 6.5.1.6.e I
Add a new 6.5.1.6.e. to read, " Review of the safety-evaluations for plant procedures and changes thereto l
coupleted under the provisions of 10CFR50.59." his will require OSa0 to review the Safety Evaluations for i
those inplementing procedures that require a safety evaluation to be performed.
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Enclosura to VP-NO-87-0003 Page 5 Renumber the rest of 6.5.1.6 as follows:
CLD NEN 6.5.1.6.e 6.5.1.6.f
'6.5.1.6.f 6.5.1.6.g 6.5.1.6.g 6.5.1.6.h 6.5.1.6.h 6.5.1.6.1 6.5.1.6.1 6.5.1.6.j 6.5.1.6.j 6.5.1.6.k 6.5.1.6.k 6.5.1.6.1 6.5.1.6.1 6.5.1.6.m section 6.5.1.6.f (old 6.5.1.6.e)
Change "... Manager-Ntaclear Operations..." to "...Vice President-Nuclear Operations...." h is is a title change. Se Manager-NLaclear Operations title no longer exists at Fermi 2.
Section 6.5.1.6.1 (Old 6.5.1.6.h)
Change "... Assistant Manager-Wclear Operations..." to
... Plant Manager...".
See Section 6.1.1 above.
Section 6.5.1.6.j. (Old 6.5.1.6.1)
Delete, "...and implementing procedures;".. h is is consistent with the new 6.5.1.6.a to review the plant administrative procedures and 6.5.1.6.e as applicable.
Iglementing procedures will be reviewed in accordance with section 6.5.3 or 6.8.2 as appropriate.
Section 6.5.1.6.k (Old 6..l.6.j)
Delete, "...and iglementing procedures,"; same as item 6.5.1.6.j above.
Section 6.5.1.6.1 (Old 6.5.1.6.k)
Change the wording to, " Review of every unplanned onsite release of radioactive material to the environs including...." 2 ese words are to clarify this statement and is consistent with other BWR technical specifications.
Section 6.5.1.6.m (Old 6.5.1.6.1)
Change this to read, "... Process Control Program, the OFFSITE DOSE CAIfUIMION MANUAL, and maior modifications to the radwaste treatment systems." Tne last part of this statement is consistent with other operating plants, as well as consistent with Section 6.15.1 of Fermi 2 technical specifications.
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Enclosura to VP-ND-87-0C03 3
Page 6 4
Section 6.5.1.7a Replace the title " Assistant Manager-Itx: lear Production" with " Plant Manager". See Section 6.1.1 above.
Section 6.5.1.7.b Change.this to read, ".. 6.5.1.6.a through 6.5.1.6.f_..".
h is administrative change makes this Section consistent with the numbering in Section 6.5.1.6 above.
Section 6.5.1.7.c Change the title of " Manager-Nuclear Operations" to "Vice President-Nuclear Operations" and the " Assistant Manager-Nuclear Production" to " Plant Manager" for the same reasons as above.
Section 6.5.1.8 Change the title of " Manager-Nuclear Operations" to t
"Vice President-Nuclear Operations." Samejustification as above.
Section 6.5.2.1.f Change " Radiological Safety" to " Radiological Controls." W is reflects a broader, more forward-looking scope of radiological review actually performed by the Fermi 2 NSPG.
Section 6.5.2.1 (Last sentence)
Change the title of "Vice President-Nuclear Operations" to " Group Vice President." This is a title change to reflect the current Fermi Organization.
Section 6.5.2.2 Change the title of "Vice President-Nuclear Operations" to " Group Vice President". Same justification as Section 6.5.2.1 above.
Section 6.5.2.8.g Change the title of "Vice President-Nuclear Operations" to " Group Vice President." Same justification as Section 6.5.2.1 above.
i Section 6.5.2.9.a Change the title of "Vice President-Nuclear Operations" to " Group Vice President." Same justification as Section 6.5.2.1 above.
Section 6.5.2.9.b Change the title "Vice President-Nuclear Operations" to
" Group Vice President." Same justification as Section 6.5.2.1 above.
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Enclosura to VP M 7-0003 Page 7 Section 6.5.2.9.c Change the title "Vice President-Nuclear Operations" to
" Group Vice President." Same justification as Section 6.5.2.1 above.
Section 6.5.3.
Add this section to describe how procedures and procedure changes, required by Section 6.8, will be reviewed. h is section is needed to support 6.5.1.6.a as well as resolve the NRC concern that OSRO is reviewing inplementing procedures (see Section 6.5.1.6.a).
h is change will also allow the Plant Manager to assign a qualified individual to perform a technical review prior to the Plant Manager's final approval.
Section 6.6.1.b Change the title "... Manager-}kiclear Operations" to "Vice President-Nuclear Operations." Same justification as Section 6.5.1.6.f above.
Section 6.7.1.a Change the title " Manager-Nuclear Operations" to "Vice President-Nuclear Operations." Same justification as Section 6.5.1.6.f.
Section 6.7.1.c Change the title " Manager-Nuclear Operations" to "Vice President-Nuclear Operations." Same justification as Section 6.5.1.6.f.
Sections 6.8.2 and 6.8.3 Delete the old Section 6.8.2 and insert the new Sections 6.8.2 and 6.8.3 as attached. Again these changes are being made to be consistent with Section 6.5.3. and 6.5.1.6.a above.
Section 6.8.3 (naw 6.8.4)
Renumber this to 6.8.4.
m is is needed due to the addition of the new 6.8.3 Section 6.8.4.c (old 6.8.3.c)
Change this to read, "... reviewed and approved in accordance with either 6.8.2 or 6.8.3 above as appropriate, within 14 days of implementation." his change is for consistency with the other changes made to the above technical specification sections.
l Section 6.8.4 (new 6.8.5)
Renumber this to 6.8.5.
Wis is needed due to the addition of the new 6.8.3 and renumbering of 6.8.3 (new 6.8.4).
Enclosurs to VP-NO-87-0003 Page 8 Sielficant Hazards Consideration In accordance with 10CFR50.92, Detroit Edison has reviewed the attached proposed technical specification and has concluded that it does not involve a significant hazards consideration. 'Ihe basis for this conclusion is that the three criteria of 10CPR50.92(c) are not cocprmised, a conclusion which is supported by our determination made pursuant to 10CFR50.59 and which is discussed below:
- 1) Se proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
h technical specification changes will strengthen the Fermi 2 operating organization, h proposed technical specification changes affect only the adninistration of the Fermi 2 plant and do not affect the safety analyses presented in the Fermi 2 FSAR. h proposed changes are expected to enhance safety and to reduce the probability of an accident. The proposed changes have no relationship to previous accident analyses.
- 2) %e proposed &ange does not create the probability of a new or different kind of accident fra any previously evaluated.
For the reasons described above, each change was determined to be primarily adrainistrative in nature. The organizational changes strengthen managenent control over the plant and will enhance safety.
h organizational changes do not alter the physical features of the plant and are an improvement over the management systems in place at the time the Technical Specifications were issued with the Fermi 2 Operating License.
- 3) The proposed change does not involve a significant reduction in safety margin.
Enclosura to VP-ND-87-0003 Page 9 h e management changes ensure greater involvement of higher level management of Detroit Edison and more effective use of personnel resources at all levels Serefore, the management changes actually increase the nargin of safety in the operation, surveillance and maintenance of Fermi-2.
ENVIR0tMENTAL IMPACP Detroit Edison has reviewed the proposed technical specification against the criteria of 10CFR51.22 for environmental considerations. As shown above, the proposed change concerns the administrative controls under which Fermi 2 will operate. Wis does not involve a significant hazards consideration, nor does it increase the type and amount of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures.
Based on the foregoing, Detroit Edison concludes that the proposed technical specification does meet the criteria given in 10CPR51.22(c)(9) for a categorical exclusion fra the requirement for an Environmental Inpact Statement.
Conclusion 4
Many of the changes made are classified adninistrative (Federal Register Volume 48 No. 67 page 14870 dated April 6,1983) in that they are title changes to reflect the current i
organization. Deletion of the organizational figures fra the technical specifications had previously been submitted by Duke Power Coupany on April 25, 1985 and approved by the NRC on March 19, 1986 as Amendnent No. 52 and No. 33 for McGuire Nuclear Station, atits 1 and 2.
% e changes made to the Fermi 2 OSRO are patterned after the existing Susquehanna Unit 2 Technical Specifications.
Based on the evaluations above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in coupliance with the Coumission's Regulations and this proposed Amen &nent will not be inimical to the connon defense and security or to the Health and Safety of the public.
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Enclosura to VP-NO-87-0003 Pa9e 10 As previously stated, Detroit Edison believes that this prW technical specification will add to I
the safety of Fermi 2 because it will strengthen management control and will enable Osa0 to increase their werview of Safety matters.
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