NRC-90-0105, Application for Amend to License NPF-43,changing Title of Vice President - Nuclear Operations to Assistant Vice President & Manager - Nuclear Production, to Reflect Util New Onsite Nuclear Organization

Application for Amend to License NPF-43,changing Title of Vice President - Nuclear Operations to Assistant Vice President & Manager - Nuclear Production, to Reflect Util New Onsite Nuclear Organization

ML20058M835
Person / Time
Site:	Fermi
Issue date:	08/01/1990
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058M840	List: ML20058M842 NRC-90-0105, Application for Amend to License NPF-43,changing Title of Vice President - Nuclear Operations to Assistant Vice President & Manager - Nuclear Production, to Reflect Util New Onsite Nuclear Organization
References
CON-NRC-90-0105, CON-NRC-90-105 NUDOCS 9008130085
Download: ML20058M835 (7)

Text

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August 1,1990 N1C-90-0105 2.

U. S. Ibclear Regulatory Cmanission Attn Docunent Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NIC Docket No. 50-341 100 License No. NPF-43

2) Detroit Ddison Letter to NIC, " Proposed Technical Specification (License Anendnent) Change -

Mminictrative Controls", NIC-89-0160, dated July 24, 1989

Subject:

Proposed Technical Specification Change (License Anendnent) - Mministrative Controls (Section 6)

Pursuant to 1(CFR50.90, Detroit Elson Conpany hereby proposes to anend Operating License iPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Tecimical Specifications. The proposed changes to the subject 'Nchnical Specifications change thei title of "Vice President - Ibclear Operations" to " Assistant Vice President and Manager - !bclear Production" to reflect Detroit Mison's new onsite nuclear organization. Mditionally, a second change proposed herein nodifies the nenbership requirenents for the

!bclear Safety Review Group (NSRG) . This letter proposal will allow the Senior Vice President - Ibclear Generation note flexibility in

@ pointing' qualified NSRG nenbera.

Please note that mterence 2 propos(d changes to sme of the attachcd pages. If the Reference'2 is @ proved prior to @ proval of this request the.forTratting effects of Reference 2 changes on the attached pages nust be considered.

Detroit Fdison has evaluatcd the proposed 'Achnical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review Organization has approved and the Ibclear Safety Review Group has reviewed the proposed Technical Specifications and corcurs with the enclosed determinations. In accordance with 10:TR50.91, Detroit dison has provided a copy of this letter to the State of Michigan.

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August 1,.1990 NIC-90-03 05 Page 2 If you have any questions, please contact Mr. Gorclon 1 trier at (Til3) 586-4513.

i Sincerely, Dclosure cca A. B. Davis R. W. DeFap tte W. G. Rogers J. F. Stang Supervisor, Electric Operators, Michigan Public Service Ccunmission - J. Padgett l

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. . UStac August 1,1990 10C-90-0105 Page 3 l

., WILLIAM S. ORSER, do hereby affirm that the foregoing statenents are based on facts and circunstances which are true and accurate to the best of my knowledge and belief.

r de WILLIAM S. ORSER Senior Vice President On this day of 4t' .._, 1990, before me personally appeared William S. Ors'er/being first duly sworn and says that he executed the foregoing as his free act and deed.

M-I4obary Publid

.O ROSALIE A Ar<MMA

% Public Nh MonroedWesJon.11,1992 County, M i

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Enclosure'to NIC-90-0105 Page l' IMtMIMETimi This anerdnent request consists of two changes to the Administrative Section of the Technical Specifications (TSs) . Specifically, the title of "Vice President - Nuclear Operations" has been proposed to be changed to "Assistmt Vice President and Manager - !bclear Production" to reflect Detroit Edison's new onsite nuclear organization. This title change @ pears throughout the proposed TSs (attached). A second change proposed by this unendnent request nodifies the nenbership requirenents for the Nuclear Safety Review Group (NSE).

EMd1RTIGI The functional responsibility for operation, maintenance, nodification, training, outage nanagenent, security, radiation protection and technical engineering of Detroit Mison's nuclear power plants previously belonged to the individual with the title of Vice President - tbclear Operation. As a result of recent upper managenent personnel changec Detroit Mison's Board of Directors changed the title of Vice President - NucJear Operations to Assistet Vice President and Manager - lbclear Production. 'Ihis title change does not alter the authority, function or responsibility of the subject position as it relates to any TS requirenent. The individual in this position will continue to report directly to the Senior Vice President

- tbclear Generation. Please note that subsequent to the Board of Directors decision to change the title of Vice President - Nuclear Operations to Assistant Vice President and Manager - tbclear Production the functional responsibility for security of Detroit Edison's nuclear power plants has been transferred to the General i Director - Nuclear Assurance. This organization chmge is not related i to any specific Technical Specification requirenent. Ttus, because this 1.itle change is only administrative in nature all the proposed functions of the Vice President - tbclear Operations as outlined in TS Section 6 have been proposed to be changed to Assistmt Vice President and Manager - tbclear Production. Please note that any future changes j in the function, authority or responsibility of this position will i have to be appropriately evaluated.

The purpose of the NSE is to provide independent review and audit of facility operations. The NSM reports to the Senior Vice President -

mclear Generation and acts for him in the review and audit of the safety aspects of nuclear power plant operation. The existing specification requires that NSE menbers have at least a bachelor's degree in engineering or related sciences, and at least 5 years of cunulative professional level experience in one or nore of the following fields:

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Enclosure to l NIC-90-0105 Page 2 l 1

i a) Wclear power plant operations b) Wclear engineering c)- Chemistry d) Metallurgy i e) Instrunentation ard Control j f) Rm31ological Controls  !

g) Mechmical and electrical engineering, ard I h) Quality assurance practices i Detroit R11 son believes these requirenents unnecessarily restrict ,

experienced individuals who do not have a bachelor's degree in  :

engineering or related sciences from being appointed to the NSE. l

'1 NSM nenbers are @ pointed by the Senior Vice President - Wclear i Generation. The Senior Vice President - Nclear Generation is -l responsible for determining that an individual has the expertise and experience comnensurate with the duties of an NSM menber. He should not be prohibited from @ pointing an otherwise qualified individual to the NSE because the individual does not have a bachelor's degree in engineering or related sciences. The proposed TS is written such that individuals who do not have a bachelor's degree in engineering or related sciences nust have at least 10 pars of responsible power plant experience of which a mininum of 3 years shall be nuclear power plant experience. The proposed wording la: consistent with the nost >

restrictive years of experience requirement of ANSI N18.1-1971 "Anerican National Standard Selection and Training of Wclear Power  ;

Plant Personnel". This stmdard is applicable, per TS 6.3.1 (attached), to each nenber of the unit staff except for the ,

Superintendent - Radiation Protection. Therefore, with the addition .

4~ of the proposed wording the Senior Vice President - Nclear Generation +

will not be prohibited from appointing individuals qualified by experience rather than education to the NSRG. The existing requirenent for at least 5 years of cu;.alative experience in one or i

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nore of the specified fields will also wply to individuals neeting the proposed experience criteria. Please note that the Standard Technical Specifications do not specify education or experience requirements for NSE menbers.  ;

EIGEFIchNP L%1EES CGEMEERTION In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed anendaent involves no significant hazards considerations. To make this determination, Detroit Edison nust establish that operation in accordance with the proposed anendnent would not: 1) involve a significant increase in the probability er

consequences of an a

cident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident

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. NIC-90-0105 Page 3 previously evaluated, or 3) involve a significant reduction in a margin of safety.

1) The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluate 5 because the proposed chmges are alministrative in nature. None of the proposed changes involve a physical nodification to the plant, a new mode of operation or a change to the UFSAR tresient  !

analyses. No Limiting Condition for Operation, ACTION statement l or Surveillance Requirement is affected by any of the proposed  ;

changes. The proposed title change from Vice President - Wclear  !

Operations to Assistet Vice President and Meager - Wclear Production does not alter the authority, function or responsibility of the subject position as it relates to any TS l requirenant. The individual in this position will continue to  !

report directly to the Senior Vice President - Nuclear Generation. The proposed change to the NSIG nenbership requirements is consistent with the nost restrictive years of 1 experience requirenent of ANSI N18.1-1971. The existing and proposed NSIG menbership requirements are note restrictive the the Standard Technical Specification. ,

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

because the proposed changes do not introduce a new node of plant operation or involve a physical nodification to the plant. As outlined in Item 1 above the proposed chmges are administrative

• in nature.

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3) The proposed change does not involve a significant reduction in a margin of safety because as outlined in Item 1 above the proposed changes are administrative in nature. None of the proposed changes involve a physical nodification to the plant, a new node 1 of operation or a change to the UFSAR trmsient analyses. No '

Limiting Condition for Operation, AC""ON statement or >

Surveillance Requirement is affecta5. ,

Detroit B31 son believes that these changes are similar to exanple (i) of Exanples of Amerriments which are considered not likely to involw '

Significant Hazards Considerations listed in SlFR7751 as they are purely administrative changes to the Technical Specifications.

Based on the above, Detroit Eklison has determined that the prcposed amendnent does not involve a significant hazards consideration.

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Enclosure to tGC-90-0105 Page 4 m DHCT Detroit Edison has :eviewed the proposed 'Nchnical Specification changes against the criteria of 30CFR51.22 for environnental considerations. The proposed change does not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significmtly increase individual or cunulative occupational ra$1ation exposures. Base $ on the foregoing, Detroit Riison concludes.that the proposed 'Nchnical Specifications do neet the criteria given in 10CFR51.22(c)(9) fer a categorical exclusion from the requirenants for an Environnental Inpact Statenent.

auk 22mmal Based on the evaluation 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 conpliance with the Ccmunission's regulations and proposed '

anendnents will not be inimical to the conaton defense and security or to the health anS safety of the public.

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