ML20212C006

Application for Amend to License NPF-43,revising Tech Specs to Reflect Reorganization of Nuclear Operations Organization to Incorporate Group Vice President & Strengthen Plant Manager Position.Fee Paid

ML20212C006
Person / Time
Site:	Fermi
Issue date:	08/05/1986
From:	Agosti F DETROIT EDISON CO.
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20212C011	List: ML20212C006 ML20212C013
References
VP-86-0096, VP-86-96, NUDOCS 8608070296
Download: ML20212C006 (8)

Text

aP sdont Nuclear Operations DOIIOil re nu Edison ETAE " W an. l August 5, 1986 l VP-86-0096 Office of Nuclear Reactor Regulation Ms. Elinor G. Adensam, Director Project Directorate Mo. 3 Division of BUR Licensing U. S. Nuclear Regulatory Conmission Washington, D.C. 20555

Reference:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Detroit Edison Letter to URC, " Reactor Operations Improvement Plan",

VP-85-0198, dated October 10, 1985

3) Detroit Edison Letter to URC, " Response to Request for Information Pursuant to 10CFR5054(f)", VP-86-0008, dated January 29, 1986

4) Detroit Edison Letter to NRC, " Restart Report", VP-8G-0080, dated July 2, 1986

Subject:

Request for Change in Technical Specifications, Section 6.0,

" Administrative Controls" The Detroit Edison Company has revised the Fermi 2 Nuclear Operations organization to incorporate the Group Vice President, and to strengthen the position of Plant Manager. -These changes have been discussed with the Commission and URC staff in recent months, and were presented in the Reference 2, 3, and 4 letters. Detroit Edison has undertaken additional changes to improve the Nuclear Operations organization. These improvements address concerns expressed by the URC in its letter of December 24, 1985, and recognized by Detroit Edison senior management. Some of these managerial functions are described in the Fermi 2 Technical Specifications.

Therefore, it is necessary for Detroit Edison to request an amendment to the Fermi 2 Technical Specifications to incorporate these organizational changes.

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Ms. Elinor G. Adensam August 5, 1986 VP-86-0096 Page 2 The proposed changes to the Fermi 2 Technical Specifications, and the basis for these changes, are shown in the Attachment. The organizational changes will be incorporated in the Fermi 2 PSAR when it is officially updated under 10CPR50.71(e) in March, 1987.

Detroit Edison has evaluated this request against the criteria of 10CPR50.92 and determined that no significant hazards considerations apply. A summary of the Significant Hazards Considerations is provided in the Attachment.

Detroit Edison has evaluated this request for license amendment against the criteria of 10CFR170.21 and has enclosed a check in the amount of one hundred fifty dollars ($150.00) for the application fee.

In accordance with 10CPR50.91, Detroit Edison has provided a copy of this letter to the State of

!!ichigan. If you have any questions, please contact Mr. R. L. Woolley at (313) 586-4211.

Sincerely, 60E Y cc: Mr. M. D. Lynch Mr. U. G. Rogers Supervisor, Advance Planning and Review Section, Michigan Public Service Commission USURC Document Control Desk Hashington, D.C. 20555

!!s. E. G. Adensam August 5, 1986 VP-86-0096 Page 3 I, FRANK E. AGOSTI, do hereby affirm that the foregoing statements are based on facts and circe"tstances which are true and accurate to the best of my knowledge and belief.

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FRAT!K E. AGOSTI Vice President Nuclear Operations On this day of , 1986, before me personally appeared Frank EV Agosti, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public MARCIA BUCK Netary Public. Washtenaw County, Mi My Commission Expires Dec.28,1937 b /W [h @

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Attachment 1 to VP-86-0096 Technical Basis and Significant Hazards' Consideration for Request to Amend Permi 2 Technical Specifications Section 6.0, " Administrative Controls" Technical Basis for Request After the July 2, 1985 rod withdrawal error, the Detroit Edison Company undertook an extensive program of corrective actions. These corrective actions were described in previous letters to the Commission (References 2, 3, and 4). Part of the corrective action involved strengthening the Nuclear Operations organization by hiring a senior manager with commercial nuclear experience outside Detroit Edison to oversee the Nuclear Operations organization. This individual fills the position of Group Vice President.

To emphasize and better focus the authority and responsibility for actual plant operation, Detroit Edison established the title " Plant Manager" and eliminated the former " Assistant Manager" titles and positions. Different organizational titles and positions are now used to indicate more clearly that other Nuclear Operations organizational units exist to support plant operations.

The Nuclear Quality Assurance (NOA) organization originally reported to the Vice President-Nuclear Operations. As an interim response to concerns of the Independent Overview Committee (IOC), Detroit Edison temporarily elevated the reporting relationship so that NOA reported to the President of Detroit Edison. With the appointment of the Group Vice President, Mr. B. Ralph Sylvia, the reporting relationship of NOA was changed permanently. The Director, N0A now reports to Mr. Sylvia.

In addition, Detroit Edison changed the position of the Independent Safety Engineering Group (ISEG). The ISEG formerly reported to the Assistant Manager, Regulation & Compliance. The ISEG now reports to the Director, NOA. This elevates the reporting authority of the ISEG.

The nuclear Operations Services organization has been eliminated.

Security and the administrative services for the plant have been assigned to the Superintendent of Services reporting to the Plant Manager. This clarifies and enhances the authority of the Plant Manager.

Detroit Edison believes that these changes strengthen the Nuclear Operations organization. Other changes are being developed to capitalize on these improvements. The other changes do not affect the Technical Specifications. Because the changes described in this letter respond to concerns expressed by the NRC, and shared by Detroit Edison management, Detroit Edison believes that the proposed Technical Specification changes can and should be granted quickly. The proposed changes are described below and provided in the attached markup of the current Fermi 2 Technical Specifications.

i Proposed Changes 6.1 Responsibility Section 6.1.1, line 1; Section 6.2.2.f, paragraph 3, lines 2 and 6, and throughout Section 6.0, wherever the title " Assistant Manager-nuclear Production" appears: Change title only, from " Assistant Manager-Nuclear Production" to " Plant Manager". This does not alter the meaning or intent of any specification.

6.2 Organization

, Section 6.2.2.f, line 4: Change title from " health physicists" to

" health physics _ personnel". This change clarifies that the positions covered by the requirement to limit overtime includes technicians, who are not health physicists.

Figure 6.2.1-1: Replace with attached offsite organization chart. The new chart reflects changes in reporting relationships and titles described elsewhere in this letter.

, Pigure 6.2.2-1: Replace with attached unit organization chart. The new chart reflects changes in reporting relationships and titles described elsewhere in this letter.

6.2.3 Independent Safety Engineering Group Section 6.2.3.4, line 3: Change the reporting authority of the ISEG from the " Assistant Manager, Regulation and Coopliance" to " Director, Nuclear Quality Assurance". This reflects a change in reporting relationship for the ISEG. The proposed change assures ISEG free access to a senior manager with direct access to the Group Vice President.

6.5 Review and Audit 4 6.5.1 Onsite Review Organization Section 6.5.1.1 and 6.5.1.6.h: Change title from the " Assistant Manager-Nuclear Production" to the " Plant Manager". As noted earlier, this change does not alter the meaning or intent of the specification.

Section 6.5.1.6.e: Change title from the " Manager-Nuclear Operations" to the "Vice President-Nuclear Operations". This revision does not

, alter the meaning or intent of the specification.

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Section 6.5.1.2: Change title of the following OSRO members:

Position Old Title New Ti_tle Chairman: Assistant Manager-Nuclear Production Plant Manager Vice Chairman: Superintendent-Nuclear Operations Superintendent-Operations Vice Chairman: Superintendent-Maintenance and no Change Modification Member: Operations Engineer No Change Member: Technical Engineer No Change Member: Radiation Protection-Chemical No Change Engineer Member: Reactor Engineer Ho Change Member: Supervisor Operational Assurance No Change Member: Maintenance Engineer No Change This change in the membership list reflects the new title of " Plant Manager" discussed previously, and a revision to the title Superintendent-Nuclear Operations. Ucither change alters the meaning or intent of the specification.

Section 6.5.1.7: Revise the title of " Assistant Manager-Nuclear Production" to " Plant Manager". Also revise the title of the

" Manager-Nuclear Operations" to be "Vice President-Huclear Operations".

These changes do not alter the meaning or intent of the specification.

Section 6.5.1.8: Revise the title of " Manager-Nuclear Operations" to read "Vice President-Muclear Operations.

6.5.2 Nuclear Safety Review Group (USRG)

Section 6.5.2.1.f: Change title of " Radiological safety" to

" Radiological controls". This reflects the broader, more forward-looking scope of radiological review actually performed by the Fermi 2 NSRG.

In addition, modify the reporting responsibility for the USRG to reflect their reporting to the Group Vice President, in lieu of the Vice President-Nuclear Operations. This revision ensures that the ESRG reports to the senior management representative onsite. This change affects Sections 6.5.2.1, 6.5.2.8.g and 6.5.2.9.

Section 6.5.2.2: Consictent with the revision to the USRG reporting responsibility above, the Group Vice President shall be responsible for appointing NSRG menbers.

6.6 Reportable Event Action 4

Section 6.6.1.b, line 2: Change title of officer reviewing the reportable event from " Manager, Nuclear Operations" to "Vice President, Nuclear Operations". This elevates the reporting relationship to ensure that the significance of every Reportable Event is properly and thoroughly considered.

j 6.7 Safety Limit Violation Section 6.7.1.a and c: Change title of officer notified of and l reviewing Safety Limit Violations from " Manager, Nuclear Operations" to "Vice President, Nuclear Op rations". This elevates the reporting relationship to ensure that the significance of every Safety Limit l Violation is properly and thoroughly considered.

6.8 Procedures and Programs Section 6.8.2 and 6.8.3.c: Revise the title of " Assistant Manager-Nuclear Production" to " Plant Manager". ,

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Significant Hazards Consideration The proposed changes to the Fermi 2 Technical Specifications were reviewed against the criteria of 10CFR50.92 and found to involve no significant hazards considerations.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The Technical Specification changes vill strengthen the Fermi 2 operating organization. The proposed Technical Specification changes affect only the administration of the Fermi 2 plant and do not affect the safety analyses presented in the Fermi 2 PSAR. The 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.

The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

For the reasons described above, each change was determined to be primarily administrative in nature. The organizational changes strengthen management control over the plant and will enhance safety.

The 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.

The proposed changes do not involve a significant reduction in the margin of safety.

The management changes ensure greater involvement of higher level management of Detroit Edison and more effective use of personnel resources at all levels. Therefore, the management changes actually increase the margin of safety in the operation, surveillance and maintenance of Fermi 2.

Based on the foregoing, Detroit Edison concludes that issuance of the proposed license amendment involves no significant hazards considerations.

Environmental Impact Detroit Edison has reviewed the proposed Technical Specification changes against the criteria in 10CFR51.22 for environmental considerations. As described above, the proposed Technical Specification changes concern only administrative procedures and administrative requirements. As shown above, the proposed Technical Specification changes do not involve a significant hazards consideration, nor increase the types or amounts 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 amendment meets the criteria given in 10CFR51.22(c) (10) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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4 Markup of Section 6.0 Technical Specifications I

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