NRC-12-0087, License Amendment Request to Change Name of Licensee from the Detroit Edison Company to DTE Electric Company

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License Amendment Request to Change Name of Licensee from the Detroit Edison Company to DTE Electric Company
ML13002A037
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 12/21/2012
From: Conner J
Detroit Edison, DTE Energy
To:
Document Control Desk, NRC/FSME
References
NRC-12-0087
Download: ML13002A037 (19)


Text

J. Todd Conner Site Vice President DTE Energy Company 6400 N.Dixie Highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586.5295 Email: connerj@dteenergy.com DTE Energy-10 CFR 50.90 December 21, 2012 NRC-12-0087 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Enrico Fermi Atomic Power Plant, Unit No. 1 NRC Docket No. 50-16 NRC License No. DPR-9
2) Detroit Edison Letter, NRC-12-0083, (Docket 50-341), "License Amendment Request to Change Licensee Name on the Operating License", Dated December 21, 2012

Subject:

Fermi 1 License Amendment Request to Change Name of Licensee from The Detroit Edison Company to DTE Electric Company As of January 1, 2013, The Detroit Edison Company will change its name to DTE Electric Company. Accordingly, in accordance with the provisions of 10 CFR 50.90 of the Code of Federal Regulations, The Detroit Edison Company, sole owner and licensee of the Enrico Fermi Atomic Power Plant, Unit No. 1 (Fermi 1) submits the attached request for amendment of the Fermi 1 Possession-Only license to change its name as referenced in the license, including the Technical Specifications, to "DTE Electric Company." This name change is purely administrative in nature. The Detroit Edison Company is a wholly owned subsidiary of DTE Energy Company. This name change is part of a set of name changes of DTE Energy subsidiaries to conform their names to the DTE brand name. No other changes are contained within this request. This request does not involve a transfer of control over or of an interest in the license for Fermi 1.

A parallel request for amendment of the license for Fermi 2 is being filed in Reference 2.

USNRC NRC- 12-0087 Page 2 Enclosures to this letter are:

1. An evaluation of the proposed amendment
2. A copy of pages of the current Fermi 1 Possession-Only License and Technical Specifications requiring amendment, with the proposed changes marked for information only.
3. A typed copy of the incorporated changes to the License and Technical Specifications.

There are no new regulatory commitments contained in this submittal.

The Detroit Edison Company has reviewed the proposed change against the criteria of 10 CFR 51.22 and has concluded that it meets the criteria provided in 10 CFR 51.22(c)(1 0) for a categorical exclusion from the requirements for an Environmental Impact Statement or an Environmental Assessment.

In accordance with 10 CFR 50.91(a)(1), "Notice for Public Comment," an analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission.

In accordance with 10 CFR 50.91 (b)(1), "State Consultation," a copy of this application and its analysis of no significant hazards considerations is being provided to the designated Michigan State Official.

Should you have any questions or require additional information, please contact Mr.

Zackary Rad of my staff at (734) 586-5076.

Sincerely,

USNRC NRC-12-0087 Page 3

Enclosures:

1. Evaluation of Proposed License Amendment for Fermi 1
2. Proposed Marked Up Amended Pages of Fermi 1 License
3. Typed copy of the changes to the License and Technical Specifications cc: NRC Regional Administrator, Region III T. Smith, NRC (Washington, D.C.)

NRC Resident Inspector- Fermi 2 P. Lee, NRC Region III T. Strong (Michigan Dept. of Natural Resources and Environment)

USNRC NRC- 12-0087 Page 4 I, J. Todd Conner, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

J. T-dd onner Site ic President, Nuclear Generation On this I - day of eC eV&, 2012 before me personally appeared J. Todd Conner, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S. AASHAI.L NOTARY PUBLIC, STATE OF MI COUNTY OF MONROE MYCOMMIS8ION EXPIRES Jun 14,2013 ACTING INCOUNTY OF Ftc r'r-

Enclosure 1 to NRC-12-0087 Enrico Fermi Atomic Power Plant, Unit No. 1 NRC Docket No. 50-16 NRC License No. DPR-9 Fermi 1 License Amendment Request to Change Name of Licensee from The Detroit Edison Company to DTE Electric Company Evaluation of Proposed License Amendment NRC-12-0087 Page 2 Evaluation of the Proposed License Amendment 1.0 Summary Description This evaluation supports a request to amend the possession-only license for Enrico Fermi Atomic Power Plant, Unit No. 1 (Fermi 1). The proposed amendment will revise the license, including the Technical Specifications, to reflect the new name of the owner and operator, which will change from "The Detroit Edison Company" to "DTE Electric Company."

2.0 Detailed Description The Detroit Edison Company (Detroit Edison) is the sole owner and sole NRC licensee of Fermi 1. DTE Energy Company (DTE Energy), the corporate parent and owner of 100% of the common stock of Detroit Edison, proposes to change the names of its subsidiaries, including Detroit Edison, to orient their names toward the "DTE" brand label. Thus "The Detroit Edison Company" is to be renamed "DTE Electric Company".

On December 21, 2012, the Board of Directors of Detroit Edison approved a change in the name of the corporation from "The Detroit Edison Company" to "DTE Electric Company" to take effect as of January 1, 2013. DTE Energy, the parent company and sole shareholder, approved the name change simultaneously therewith. Upon approval of the name change, Detroit Edison filed the amendment of the Articles of Incorporation with the Bureau of Commercial Services at the Michigan Department of Licensing and Regulatory Affairs, in order to conduct business under the new name. The name change is expected to be effective January 1, 2013. The corporate name is being changed to make the name of Detroit Edison, like those of other DTE Energy subsidiaries, more consistent with the "DTE" name branding of the parent company.

There would not be any other change to Detroit Edison's Articles of Incorporation, nor any form of corporate reorganization. As a result, the license for Fermi 1 will need to be amended solely to reflect the change of the licensee's name from "The Detroit Edison Company" to "DTE Electric Company". No other changes are necessary.

The effect of this proposed change for the Fermi 1 possession-only license and Technical Specifications is shown on the attached markups in Enclosure 2.

3.0 Technical Evaluation The proposed amendment is purely administrative in nature. The Fermi 1 owner-licensee entity will remain the sole owner licensee of Fermi 1, with only its name being changed. No modification will be made to corporate form, and it will retain all the capabilities, rights and obligations of Detroit Edison, including providing decommissioning funding assurance in compliance with 10 CFR 50.75. There will be no ownership or management changes as a result of the name change. The proposed change does not affect the technical or financial NRC-12-0087 Page 3 qualifications of Detroit Edison or alter any technical content of the Fermi 1 possession-only license or any technical content of the Fermi 1 Technical Specifications requirements, nor does it have any programmatic effect on the Quality Assurance Program for Fermi 1 contained in the Fermi 1 Safety Analysis Report. The change will have no impact on the design, function or operation of any plant structure, system or component, either technically or administratively or the decommissioning of the facility.

4.0 Regulatory Evaluation Detroit Edison requests Nuclear Regulatory Commission (NRC) review and approval of an amendment to change the name of the owner-licensee of Fermi 1 from "The Detroit Edison Company" to "DTE Electric Company."

4.1 Applicable Regulatory Requirements Under 10 CFR 50.80, Transfer of Licenses, no license or control of a license for a utilization facility may be transferred, directly or indirectly, to any entity unless the NRC consents in writing. However, licensee name changes do not, by themselves, constitute license transfers.

The proposed amendment is purely a name change and does not involve the transfer of any control over the Fermi 1 license to another entity.

There is not a transfer of a license or of an interest in a license within the meaning of 10 CFR 50.80. Standard NRC guidance on this subject is contained in the Standard Review Plan on Power Reactor Licensee Financial Qualifications and Decommissioning Funding Assurance (NUREG-1577, Rev. 1, (1999)) which states, in connection with review of applications for license transfers, that: "The reviewer should treat applications involving changes of ownership, mergers, formation of holding companies, and other restructuring proposals that go beyond corporate name changes or internal reorganizations as potential transfers of licenses, directly or indirectly, through transfer of control of the license, as subject to section 50.80 review, and not merely subject to a section 50.90 license amendment review. ... (A name change of a licensee that does not involve license transfer considerations under section 50.80 will be effected by a license amendment issued administratively under section 50.90.)"

4.2 Precedent This application is consistent with previous NRC actions in similar circumstances not involving transfers of ownership or control. In 1999, when Texas Utilities Company, the owner and licensee of the Comanche Peak Steam Electric Station, changed its name to TXU Electric Company without any other corporate reorganization or changes in ownership or control, it submitted its application to the NRC under 10 CFR 50.90 alone, stating that its action was purely administrative in nature. TXU noted in its application that it was taking the corporate actions necessary to effectuate the name change the same day as it filed with the NRC, with the name change to take effect within several days thereafter upon filing with the Texas Secretary of State.

NRC-12-0087 Page 4 The NRC agreed with the TXU analysis, accepted the relative timing of corporate and regulatory actions, and approved the license amendment within four months. (Comanche Peak Steam Electric Station, Units 1 and 2, Issuance of Amendments Re: Change in Corporate Name from "Texas Utilities Electric Company" to "TXU Electric Company" (TAC Nos. MA5551 and MA5552), August 31, 1999 (ADAMS Accession No. ML021820283)).

The NRC also recently approved changing the name of FirstEnergy Nuclear Generation Corp. to FirstEnergy Nuclear Generation, LLC based on the name change being strictly administrative in nature. (Beaver Valley Power Station, Unit Nos. l and 2; Davis-Besse Nuclear Power Station, Unit No. 1; and Perry Nuclear Power Plant, Unit No. 1 - Issuance of Amendments Re: Change of the Name of the Owner/Licensee to FirstEnergy Nuclear Generation, LLC (TAC Nos.

ME8937, ME8938, ME8939, and ME8940), dated October 2, 2012, (ML021820283)).

4.3 No Significant Hazards Consideration Detroit Edison has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below.

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment changes the name of the owner licensee. The proposed amendment is purely administrative in nature. The functions, powers, resources and management of the owner licensee will not change. The Detroit Edison Company, which will be renamed DTE Electric Company, will remain the licensee of the facility. The proposed amendment does not alter the design, function or operation of any plant structure, system or component. As such, the accident analysis contained in the Fermi 1 Safety Analysis Report will not be impacted.

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

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment is purely administrative in nature. The functions of the owner licensee will not change. The proposed amendment does not alter the design, function, or operation of any plant structure, system or component.

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

NRC-12-0087 Page 5

3. The proposed change does not involve a significant reduction in the margin of safety.

The proposed amendment is a name change to reflect the new name of the owner licensee. The proposed amendment is purely administrative in nature. The functions of the owner licensee will not change. The Detroit Edison Company, which will be renamed DTE Electric Company, will remain the licensee of Fermi 1, and its functions will not change. The proposed amendment does not alter the design, function, or operation of any plant structure, system or component. As such, the accident analyses contained in the Fermi 1 Safety Analysis Report will not be impacted.

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

Based on the above, Detroit Edison concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion On the basis of the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by the licensee name change, (2) such activities will be conducted in compliance with the Nuclear Regulatory 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.

5.0 Environmental Considerations A review has determined that the proposed amendment would change the licensee's name but make no other changes to the license. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10)(iii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Enclosure 2 to NRC-12-0087 Enrico Fermi Atomic Power Plant, Unit No. 1 NRC Docket No. 50-16 NRC License No. DPR-9 Fermi 1 License Amendment Request to Change Name of Licensee from The Detroit Edison Company to DTE Electric Company Proposed Markups of Affected Operating License and Technical Specifications Pages

0 'UNITED STATES NUCLEAR REGULATORY C01.*MMSS10N WASHINGTON, D.C. 20555-0001 DETROrF EDISON, COMPANY DOCKET NO. 50-16 ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 20 License No. DPR-9

1. The U.S. Nuclear Regulatory Commission (the Commission or the NRC) has found that:

.0)TE"/* ,'

A. The application for amendment by-- s Company (the licensee) dated De. j z.af&28, 2,tZzoI , complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter 1; D. The licensee is technically and financially qualified to engage in the activities authorized by this amended license in accordance with the rules and regulations of the Commission; E. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and F. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, Possession-Only License No. DPR-9 is hereby amended in its entirety to read as follows:

A. This amended license applies to the Enrico omic Power Plant, Unit No. 1 (Fermi 1, or the facility) owned by Company.

C*4 The facility is located at the Lagoona Beach, Frenchtown Township, Monroe, Michigan, and is described in the Fermi 1 Safety Analysis Report as amended.

2 B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Detroit Bdizpr. Company:

D7e 9 cii 0 C (1) Pursuant to Section 104(c) of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities" to possess, but not to operate the facility.

(2) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material" to possess, but not to separate, such byproduct material as may have been produced by operations of the reactor.

(3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," to receive, acquire, possess, use and transfer byproduct material without restriction to chemical or physical form for sample analysis, instrument calibration, or associated with radioactive apparatus, hardware, tools, and equipment, provided the cumulative radioactive material quantity of the byproduct material does not exceed the criteria contained in Section 30.72, Schedule C, Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency Plan for Responding to a Release.

(4) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material" to receive, acquire, possess, use and transfer, but not separate, special nuclear material in a quantity not to exceed 15 grams of U-235, U-233, or plutonium, or any combination thereof and not to exceed plutonium activity of 2 curies. If special nuclear material in quantities exceeding 15 grams or more than 2 curies of plutonium are identified in plant contamination in the future, this license permits possession and transfer of special nuclear material and the additional applicable requirements of 10 CFR Part 70, Part 73, and Part 74 will apply for the amount possessed.

C. This license shall be deemed to contain and is subject to the conditions specified in Part 20, Section 50.59 of Part 50, Section 30.34 of Part 30 of 10 CFR Chapter 1; and is subject to all applicable provisions of the Act, and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional condition specified below:

The Technical Specifications contained in Appendix A, as revised through Amendment No. -2&,-,are hereby incorporated in this license. The licensee shall maintain the facility in accordance with the Technical Specifications.

D. This license is effective as of the date of its issuance and shall expire on March 20, 2025.

E. FACILITY MONITORING SURVEILLANCES I. Radiation Surveillances - Surveillances shall be made to check for the presence of gamma radiation and transferable contamination on a quarterly basis. Gamma radiation measurements using portable survey instruments and contamination checks using smears shall be made of the following areas:

Reactor Building

a. Operating floor
b. Breather pipe
c. Sump pump serving the reactor building annulus (until made inactive)

Fuelkand Repair Building

a. Pool areas (until decontamination of pools is complete)
b. Operating floor access points to contamination areas
2. Inspection of Facility
a. A weekly general walk-through and inspection of the facility shall be performed.
b. A monthly inspection of the facility shall be made and potential problems reported to the Custodian or Delegate.
c. A monthly visual water level check from the top access of all active sumps shall be performed.

F. ADMINISTRATIVE STANDARDS The owner of this facility is Th4 Detrit Adis*en Company.

1. Custodian - The Licensee shall designate a Custodian.

or

2. Staff- The staff is made up of employees of Tho Detroit Edisen Company. Their work may include responsibilities at the adjacent power plants as well as the Fermi 1 facility. Their job titles may be different th.n stated here; their authority and responsibility at the Fermi 1 facility shall, however, correspond to the followingspecifications.
a. Custodian or Delegate - The responsibility of the Custodian or Delegate shall be to coordinate, approve and assign all work being done at the facility.

Page 4 Amendment No. 20

b. Health Physicist - The Health Physicist shall review procedures and limits involving the handling of radioactive materials. The Health Physicist shall be responsible to see that all plant discharges and all shipments are within the limitations set forth in the Code of Federal Regulations.

The qualifications for the Health Physicist shall be two years of specialized training in health physics or equivalent and three years of work experience related to radiological health and safety.

3. Health Physics Technician - A person who has received training in health physics techniques and procedures shall be on site and may direct health physics activities whenever radioactive materials are being moved.
4. Review Committee - A Review Committee shall be established for the purpose of reviewing and approving facility monitoring results and procedures for activities at the facility and resolution of LERs.

The membership t e viewy Committee shall be composed of five personnel from within ,:Company or consultants, at least three (3) of whom have had two (2) years or more of experience in a responsible position at an operating nuclear power facility and have had basic health physics training. The Review Committee shall meet at intervals not to exceed 13 months and shall prepare formal minutes of its meetings.

5. Dosimetry - Dosimetry will be provided for personnel as required by monitoring requirements in 10 CFR 20.
6. Procedures - Procedures for the following activities shall be prepared and utilized:
a. Radiation control
b. Facility inspections Procedures shall be reviewed and approved by the Review Committee. The Custodian may temporarily change a procedure by Written Order following determination that the change does not constitute a significant increase in the hazards associated with the operation.
7. Reporting Requirements - An annual report shall be made to the NRC summarizing the activities carried out and the results of the facility surveillance program.

A Licensee Event Report (LER) shall be phoned to NRC Regon fII within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the discovery. A formal report shall be filed for any LER within 30 days of discovery. The report shall include a description of the occurrence together with steps taken to correct the situation.

Page 5 Amendment No. 20

Enclosure 3 to NRC-12-0087 Enrico Fermi Atomic Power Plant, Unit No. 1 NRC Docket No. 50-16 NRC License No. DPR-9 Fermi 1 License Amendment Request to Change Name of Licensee from The Detroit Edison Company to DTE Electric Company Revised Fermi 1 License and Technical Specifications Pages

DTE ELECTRIC COMPANY DOCKET NO. 50-16 ENRICO FERMI ATOMIC POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.

License No. DPR-9

1. The UoS. Nuclear Regulatory Commission (the Commission or the NRC) has found that:

A. The application for amendment by DTE Electric Company (the licensee) dated December 21, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter 1; D. The licensee is technically and financially qualified to engage in the activities authorized by this amended license in accordance with the rules and regulations of the Commission; E. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and F. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, Possession-Only License No. DPR-9 is hereby amended in its entirety to read as follows:

A. This amended license applies to the Enrico Fermi Atomic Power Plant, Unit No. I (Fermi 1, or the facility) owned by DTE Electric Company. The facility is located at the Lagoona Beach, Frenchtown Township, Monroe, Michigan, and is described in the Fermi 1 Safety Analysis Report as amended.

2 B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses DTE Electric Company:

(1) Pursuant to Section 104(c) of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities" to possess, but not to operate the facility.

(2) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material" to possess, but not to separate, such byproduct material as may have been produced by operations of the reactor.

(3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of Byproduct Material," to receive, acquire, possess, use and transfer byproduct material without restriction to chemical or physical form for sample analysis, instrument calibration, or associated with radioactive apparatus, hardware, tools, and equipment, provided the cumulative radioactive material quantity of the byproduct material does not exceed the criteria contained in Section 30.72, Schedule C, Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency Plan for Responding to a Release.

(4) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material" to receive, acquire, possess, use and transfer, but not separate, special nuclear material in a quantity not to exceed 15 grams of U-235, U-233, or plutonium, or any combination thereof and not to exceed plutonium activity of 2 curies. If special nuclear material in quantities exceeding 15 grams or more than 2 curies of plutonium are identified in plant contamination in the future, this license permits possession and transfer of special nuclear material and the additional applicable requirements of 10 CFR Part 70, Part 73, and Part 74 will apply for the amount possessed.

C. This license shall be deemed to contain and is subject to the conditions specified in Part 20, Section 50.59 of Part 50, Section 30.34 of Part 30 of 10 CFR Chapter 1; and is subject to all applicable provisions of the Act, and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional condition specified below:

The Technical Specifications contained in Appendix A, as revised through Amendment No.

are hereby incorporated in this license. The licensee shall maintain the facility in accordance with the Technical Specifications.

D. This license is effective as of the date of its issuance and shall expire on March 20, 2025.

E. FACILITY MONITORING SURVEILLANCES

1. Radiation Surveillances - Surveillances shall be made to check for the presence of gamma radiation and transferable contamination on a quarterly basis. Gamma radiation measurements using portable survey instruments and contamination checks using smears shall be made of the following areas:

Reactor Building

a. Operating floor
b. Breather pipe
c. Sump pump serving the reactor building annulus (until made inactive)

Fuel and Repair Building

a. Pool areas (until decontamination of pools is complete)
b. Operating floor access points to contamination areas
2. Inspection of Facility
a. A weekly general walk-through and inspection of the facility shall be performed.
b. A monthly inspection of the facility shall be made and potential problems reported to the Custodian or Delegate.
c. A monthly visual water level check from the top access of all active sumps shall be performed.

F. ADMINISTRATIVE STANDARDS The owner of this facility is DTE Electric Company.

1. Custodian - The Licensee shall designate a Custodian.
2. Staff- The staff is made up of employees of DTE Electric Company. Their work may include responsibilities at the adjacent power plants as well as the Fermi 1 facility. Their job titles may be different than stated here; their authority and responsibility at the Fermi 1 facility shall, however, correspond to the following specifications.
a. Custodian or Delegate - The responsibility of the Custodian or Delegate shall be to coordinate, approve and assign all work being done at the facility.

Page 4 Amendment No.

b. Health Physicist - The Health Physicist shall review procedures and limits involving the handling of radioactive materials. The Health Physicist shall be responsible to see that all plant discharges and all shipments are within the limitations set forth in the Code of Federal Regulations.

The qualifications for the Health Physicist shall be two years of specialized training in health physics or equivalent and three years of work experience related to radiological health and safety.

3. Health Physics Technician - A person who has received training in health physics techniques and procedures shall be on site and may direct health physics activities whenever radioactive materials are being moved.
4. Review Committee - A Review Committee shall be established for the purpose of reviewing and approving facility monitoring results and procedures for activities at the facility and resolution of LERs.

The membership of the Review Committee shall be composed of five personnel from within DTE Electric Company or consultants, at least three (3) of whom have had two (2) years or more of experience in a responsible position at an operating nuclear power facility and have had basic health physics training. The Review Committee shall meet at intervals not to exceed 13 months and shall prepare formal minutes of its meetings.

5. Dosimetry - Dosimetry will be provided for personnel as required by monitoring requirements in 10 CFR 20.
6. Procedures - Procedures for the following activities shall be prepared and utilized:
a. Radiation control
b. Facility inspections Procedures shall be reviewed and approved by the Review Committee. The Custodian may temporarily change a procedure by Written Order following determination that the change does not constitute a significant increase in the hazards associated with the operation.
7. Reporting Requirements - An annual report shall be made to the NRC summarizing the activities carried out and the results of the facility surveillance program.

A Licensee Event Report (LER) shall be phoned to NRC Region III within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the discovery. A formal report shall be filed for any LER within 30 days of discovery. The report shall include a description of the occurrence together with steps taken to correct the situation.

Page 5 Amendment No.