ML20210T760

Application for Amend to License NPF-43,changing Tech Spec 6.5.1.6, Onsite Review Organization Responsibilities, to Strengthen Organization Responsibilities.Fee Paid

ML20210T760
Person / Time
Site:	Fermi
Issue date:	09/30/1986
From:	Agosti F DETROIT EDISON CO.
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20210T766	List: ML20210T760 ML20210T775
References
VP-86-0138, VP-86-138, NUDOCS 8610090186
Download: ML20210T760 (8)

Text

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ac P eskje t Nuclear Operatons

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Detroit 6400 North Ome Highway Nuclear I n (Newport. Mschigan 48166 atanmS4:m opnmon.

September 30, 1986 VP-86-0138

~ Director of nuclear Reactor Regulation Ms. Elinor C. Adensam, Director Project' Directorate No. 3

, Division of EUR Licensing U.S. Nuclear Regulatory Commission Washington D. C. 20555

Reference:

Fermi 2 MPC Dochet No. 50-341 tiRC License No. MPF-43

Subject:

Proposed Technical Specification Chance-Onnite Revicu Oroanization 6.5.1 Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPP-43 for the Fermi-2 plant by incorporating the nttached change into the Plant Technical Specification G.5.1.6 titled Onsite Review Organization Responsibilities. These changes are being made to strengthen the responsibilition.of the Onsite'Reviou Organization.

Detroit Edison has evaluated the proposed Technical Specification against the criteria of 10CFR50.59 and 10CFR50.92 and determined that an unreviewed safety guention or significant hazards considerations is not involved.

The Fermi-2 Onsite Review Organization has approved and the nuclear Safety Review Group has reviewed this proposed Technical Specification and concurred with the 4 enclosed determinations.

Pursuant to 10CFR170.12 (c) , enclosed with this amendment request is a fee of one hundred fifty dollars ($150.00) .

,s 8610090186 860930 PDR P ADOCK 05000341' O

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Ms. Elinor C. Adencam September 30, 1986 VP-86-0138 Page 2 In accordance with 10CFR50.91, Detroit Edison haa provided a copy of this letter to the State of Michican.

If you have any questions, pleace contact IIr. Steven Frost at (313) 586-4210.

Sincerely,

~Mr &

Enclocure cc: M r . II . D. Lynch Mr. U. G. Rogers Mr. G. C. Wright Supervicor, Advanced Planning and Review Section, Michigan Public Service Commiccion USN3C Document Control Deck, nachington, D.C. 20555

IIs. Elinor G. Adensaa September 30, 1906 VP-06-0138 Page 3 I, FRAMK U. AGOSTI, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of ny knowledge and belief.

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FRANK E. AdOSTI Vice President Nuclear Operations On thin Od day of (DIt/LIAf4) , 1906, before ne personally appeared Fradh E. Agosti, being first duly suorn and says that he executed the foregoing aF his free act and deed.

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Notary Public KAREN M. REED Notary Public, Monroe County, Mb.'s My Commission Expires May 14,19>

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Enclocure to VP-06-0133 Page '1 NCKGPOUZD/DISCUSSIQi Fermi-2 Technical Specifications were developed uning the GE-Standard Technical Specification (GE-STSm?P/4) which included Chapter 6.0 "Mrainistrative Controls".

Incorporated into Chapter 6.0 is a noction outlining the Onsite Poview Organizations (OSTO) function, conposition, responsibilities and other topico concerning OSPD.

In revieuing these recponsibilities (6.5.1.G) there are various administrative functions that reduce the effectivenecc of this organization. The purt >e of this proposed change is to reduce this burden. This problera has been reccgnizcr1 by the IEC which is allowing plcnts with raore recent Technical Specifications to require CGDO to reviou only Mrainistrative Procedures (thoce which control lover tier procedures) eni to perforra cafety evaluations for other ones. The Plant Manager vould be responcibic for ancigning ' individuals for preparing and reviewing cafety evaluations for procedures, or changes to procedures, no longer reviewed by OSFO. The recult would be to enhance the Plant Manager'n and OSPD'n rannagarent overview of cafety raattern while cubstantially reducing the titre and attention required for procedure review activitien.

SAFELIY M TIQi In accordance with ICCFR50.59 Detroit n3ison has revicued the attached proposed Technical Specification cna han concluded that there in no unrevicued cafety quertion.

1) Is the probability of occurrence or the consequences of an accident or rralfunction of equipment irportant to nafety previously evaluated in the safety analysic report increased?

170. Operation of Ferrai-2 in rccordance with the propoced Technical Specification vill not involve an increace in the probability of cccurrence or consecponce of an accident previously evaluated.

The propoced changen are e:pected to enhance cafety and reduce the probability of an cccident.

These proponed changes only affect a:binictrative processec and do not affect any cafety analynic or

e-Enclosure to VP-86-0138 Page 2 equipment presented in the Fermi-2 FSAR, or any accident analysis.

2) Is there a possibility for an accident or malfunction of a different type than evaluated previously in the safety analysis report being created?

I'o . Operation of Fermi-2 in accordance with the pronoced Technical Specification will not create the possibility of a new or different hind of accident from any cccident provicusly evaluated.

Each change is strictly adminictrative and in to ,

strengthen rcna9crent control over the plant which i vill enhance cafety. These changes do not alter any physical features of Fermi-2. Thcy also improve the ranagement systems (OSPO) which were put in place by the iscuance of the Fermi-2 Operating Licence.

3) Is the margin of safety as defined in the basis for any Technical Specifications reduced?

170 . Operaticn of Fermi-2 in accordance Uith the propoced Technical Specification will not involve a significant reduction in the rargin of safety.

These propocco changen encure more effective utilization of CCEO and cupport personnel. Daced on the above, thoce propocod changes should enhance and increase the cargin of cafety in the operation, curveillance and raintenance of Fermi-2.

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In accordance uith 10CFn50.92, Detroit n11 con has revieued the attached propoced Technical Specification and has concluded that it does not involve a significant hazards concideration. The bacic for thic conclunion in that the three criteria of 10CFR50.92(c) are not comromiced, a conclusion of which in cupported by our determination rede purcuant to 10CFR50.59 and which in diccucced belou:

1) The propocod change does not involve a cign_ficant increace in the probability or concequencen of an

Enclocure to VP-86-0130 Page 3 accident previously evaluated. As stated above these propoced changen are adminictrative and do not chanac any accuwtions or recults of any cafety analysis previously evaluated for Fermi-2.

2) The propoced change does not create the probability of a new or different kirrl of accident from any previously evaluated. This propoced change doec not involve any modification of harduare or plant operation different than that previously evaluated.

3) The proposed change does not involve a significant reduction in cafety margin. Thece a:1minictrative changec ensure a more effective utilication of OSIO's time and resources thus enhancing safety at Fermi-2.

This change hac been granted to other operating plants. The Fermi-2 changen recatic those from the Callaway Plant Technical Soccifications which have been previoucly approved.

DNIPCU'TN, I"P7CP Detroit D3 icon has reviewed- the proposed Technical Specification againnt the criteria of 10CFR50.22 for environmental conciderationc. Ta shown above, the proposed change concerns alministrative changes to the responsibilitiec of CGPO. This does not involve a cignificant hazards concideration, nor increace the types and amounts of effluents that may be released offaite, nor cignificantly incroace individual or cumulative occupational radiation e>prurec. Dased on t'le forgoing, Detroit n? icon concludes that the propoced Technical Cpecification doec meet the criteria given in 10CFR51.22(c) (0) for a categorical exclusion from the requirement for an Environmental Impact Statorent.

CotCUSIOtt Daced on the evaluationn above: (1) There is reasonable accurance that the health and safety of the public will not be endangered by operation in the pronoced tranner, and (2) cuch activitien will be conducted in comliance

Enclocure to VP-06-0138 Page 4 with the Corraiscion's regulations and thic proposed Amendacnt vill not be inimical to the corron defense and cecurity or to the health and cafety of the public.

As previously stated, Detroit Edison believes that this proposed Technical Specification will add to the cafety of Fermi-2 becauce thic propoced change will not over burden OSTO with reviewing all procedures and will enable them to increase their overview of safety ratters.

INSEPT 6.5.1.6 the CSID chall be recponcible for:

a. Poview of all Administrative Procedures;

b. Pevicu of the cafety evaluationc for (1) procedures, (2) chcnges to procedurec, equipment, cyctems, or facilitiec, and (3) tents or c::perirente conpleted under the provicion of 10CFR50.59 to verify that such actions did not conctitute on unrevicued cafety question;

c. Review of propoced proco3ures or changen to procedures, equipment, cyctems, or facilities which may involve an unreviewed cafety question as defined in 10Tn50.59 or involves a change in Technical Specificationc;

d. Paview of propoced tects or experirents which may involve an unreviewed cafety question as defined in 10CI'R50.59 or requires a change in Technical Specificationc;

c. Pcview of propoced changen to the Technical Specification or the Operating Licence;

f. Investigation of all violationc of the Technical Specification including the forwarding of reports covering evaluation and recortaendations to prevent rccurrence to the Vice President-tbclear Operations cnd to the t'src;

g. Review of reportc of operating abnorr.alalitics, deviations from exnected nerformance of plant equipoent and of unanticipated deficiencico in the

Taclosure.to VP-86-0138 Page 5:

design or operation of structures, cysters, or conponents that affect nuclear safety;

h. Review of all lu.v0 unnLE EvrmS;

i. Revieu of the plant Security Plan.

j. Pcview of' the Paliological Emcrgency Pccponse Plan.

k.. Pcview of changes to the PROCESS CO!nTOL PPIGFNi, the OFFSITE DCE CAICUIATICU I'AIUAL and major modification to Paiwaste Treatment Syste::;

1. Review of any accidental, unplanned or uncontrolled radioactive release imluding the preparation of reports covering evaluation, reco:rendations, and dicpocition of the corrective action to prevent recurrence and the forwarding of thece reports to Vice Precident-tbclear Operations and to the IISIG;

m. Review of Unit operations to detect potential ha::ards to nuclear cafety; and,

n. Investigations or analysis of special cubjects an rec;uested by the Chairman of the 15PG.

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