NRC-93-0062, Application for Amend to License NPF-43,changing Tech Specs Include Modification to Job Titles Following Mgt Reorganization,Changes to Onsite Review Organization Membership Description & Change to Overtime Requirements

Application for Amend to License NPF-43,changing Tech Specs Include Modification to Job Titles Following Mgt Reorganization,Changes to Onsite Review Organization Membership Description & Change to Overtime Requirements

ML20044G457
Person / Time
Site:	Fermi
Issue date:	05/24/1993
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20044G458	List: ML20044G460 NRC-93-0062, Application for Amend to License NPF-43,changing Tech Specs Include Modification to Job Titles Following Mgt Reorganization,Changes to Onsite Review Organization Membership Description & Change to Overtime Requirements
References
CON-NRC-93-0062, CON-NRC-93-62 NUDOCS 9306030134
Download: ML20044G457 (7)

Text

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Dougtas R, Gipson Gener Vice P esdent tL,ctear Georraten u,-

Detroit. mn,, w, ,-

Newport. Mehman 49166

• • "d Q 13) LHb 249 May 24,1993 NRC-93-0062 U. S. Nuclear Regulatory Ccramission Attn: Document Control Desk Washington, D. C. 20555

References:

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

Subject:

Proposed Technical Specification Change (License Amendment) - Administrative Controls Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications. The proposed changes to the subject Technical Specifications include a modification to job titles following management reorganization; changes to the Onsite Review Organization membership description; and a change to overtime control requirements.

Detroit Edison has evaluated the proposed Technical 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 Nuclear Safety Review Group has reviewed the proposed Technical Specifications and concurs with the enclosed determinations. 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 contact Mr. Glen D. Ohlemacher at (313) 586-4275.

Since rely, Enclosure cc: T. C. Colburn A. B. Davis W. J. Kropp M. P. Phillips Supervisor, Electric Operators, Michigan Public Service Commission - J. R. Padgett g0i i

k9 9306030134 930524 PDR ADOCK 05000341 P PDR

f Us!!RC May 24, 1993 NRC-93-0062 Page 2 I, DOUGLAS R. GIPSON, do hereby af firm that the foregoing statements are based on f acts and circumstances which are true and accurate to the best of my knowledge and belief.

DOUGIliS R. Gl'PSON Senior Vice President On this , day of . . 1993, before me personally appeared Douglas R. Gipson, y>ing first duly sworn and says that he executed the foregoing as his f ree act and deed.

N(L Lt, .

&b Notary Public

..a ROSALE A ARMLTIA NOTARY PUBL!C STATE OF MlOUGAN MONROE CDUNTY My CDyMissiaN DtP. NOV. 20,1996 h

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'. Enclosure to NRC-93-0062 Page 1 INTRODUCTION This license amendment request proposes three changes to.the Administrative Section of the Technical Specifications. Specifically, these changes involve a title change for several management positions; changes to the description of the Onsite Review Organization (OSRO);.

and a change to the overtime control requirements. These proposed-changes are discussed below and are provided in an attachment to this letter:

1. Management title changes have been made throughout'the attached Technical Specification-(TS) changes. The positions of Senior Vice President and Assistant Vice President and Manager - Nuclear Production have been combined into a single position, Senior Vice <

President - Nuclear Generation. The position of Operations Engineer and Vice President Nuclear Engineering and Services are being eliminated. In addition, provisions are included ~to preclude the need to routinely revise the TS for management title ,

changes.

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2. TS Section 6.5.1.2 and 6.5.1.3 are revised with regard to the-description of the OSRO membership and the number of OSRO members.

3 TS Section 6.2.2.f, which covers overtime controls,.has been revised to provide more plant specific details and to eliminate  ;

common points of confusion. ,

EVALUATION Title Changes l.

Detroit Edison has recently completed a Staffing Transition Program'in order to reduce management layers and improve organizational efficiency. As a result of this program and other earlier management' )

changes, some job titles are no longer used and others have been  :

created. Specifically:

o The functions of the Senior Vice President, which was for a short period called Executive Vice President, and the Assistant Vice President and Manager - Nuclear Production have been consolidated under the position " Senior Vice President -

Nuclear Generation".

o The position of Operations Engineer has been consolidated with the Superintendent - Operations position.

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', Enclosure to NRC-93-0062 Page 2 In each of these cases, the functions or requirements described in the TS for the position continue to be carried out by the new position.

This change makes the administrative changes to reflect the new titles.

To avoid future administrative changes of this nature, a new provision is proposed as follows:

An alternative title may be designated for this position. All requirements of these Technical Specifications apply to the position with the alternative title as apply with the specified title. Alternative titles shall be specified in the Updated Final Safety Analysis Report.

This new provision is applied by a footnote to those job titles which typically change. It gives the flexibility to change titles while assuring that the TS requirements continue to be fulfilled.

The title of Vice President - Nuclear Engineering and Services has ,

also been eliminated. Currently, the Independent Safety Engineering Group (ISEG) is specified to make their recommendations to this individual.

The ISEG is proposed to make their recommendations to Nuclear Generation management. This better reflects the desirable practice that the ISEG should make recommendations to the responsible management for the area being reviewed.

Description of OSRO Hembership The proposed change in membership description is administrative in nature. The composition of the OSRO is proposed to be identified in the Technical Specifications by the functional and organizational description of its responsibilities rather tnan by formal job title.

The disciplines which previously composed the OSRO membership are still included in this Technical Specification change. The OSRO will be administratively controlled and identified in the UFSAR.

This change allows for revisions to formal job titles to be controlled by administrative procedures rather than by license amendments.

Administrative controls will ensure there is no compromise in the level of expertise or training of OSRO members and no diminishment of the review function of this operational review group. The level of expertise and training is maintained by requiring that OSRO members meet the standards for Supervisors or Managers in ANSI N18.1-1971.

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, Enclosure to NRC-93-0062  :

Page 3 Consequently, this change will allow more flexibility in appointment of OSRO members and will eliminate the need for amendment requests based solely on title changes.

The proposed specification of a minimum of six but not more than eleven OSRO members will provide the minimum number of members necessary to participate in the OSRO review process and the flexibility to add to that number when additional expertise is needed. This change will allow the OSRO Chairman to ensure the necessary expertise is available for OSRO activities, thus providing the proper review of operational activities.

Overtime Controls The provisions of TS 6.2.2.f are proposed to be changed tc provide more plant specific detail and to eliminate common points of confusion. Specifically:

o The description of the scope of the controls has been changed to those who " work on safety-related equipment" instead of~  ;

those who " perform safety-related functions." The term

" safety-related" is one which is applied to equipment not functions. The change more precisely defines those who fall >

under these requirements.

Health Physics personnel are listed in the current Fermi 2 TS, as well as the Standard TS, as an example of the personnel who should fall under these guidelines. These personnel are not included in the proposed examples since they do not routinoly work on safety-related equipment. Due to the reviews applied to radiation protection activities, including those conducted by the workers who are responsible for controlling their own dose, it is not necessary to include radiation protection personnel under these guidelines.

o The examples of those who fall under the scope is proposed to be changed to better reflect Fermi 2 titles. In addition, the term " operating personnel" is replaced with " personnel" to eliminate tne impression that the requirements could apply only to the operations department.

o Overtime guideline number 3, which requires an eight hour break between work periods is clarified. The guideline as written is based upon the assumption that there is one work period in each 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Thus, the guideline assures that sufficient rest is obtained prior to returning to work.

This guideline is less clear when applied to call-in

, Enclosure to NRC-93-0062 Page 4 situations. These are adequately covered by the first two guidelines. As proposed, the new guideline more clearly carries out the guideline's intent.

o The Plant Manager is allowed to establish a designee for review and approval of exceptions to the overtime guidance.

The change replaces the obsolete term "Section Superintendent" with " designee." This allows greater flexibility in establishing appropriate delegation particularly in situations while the Plant Manager is away from the plant site.

o The Plant Manager's monthly review of overtime is no longer specified as " individual overtime." Detroit Edison believes that senior management oversight of overtime can be more effectively done by reviewing information which has been previously aggregated and evaluated. This would not be allowed by the current requirements.

SIGNIFICANT IIAZARDS CONSIDERATION In accordance with 10CFR50.92, Detroit Edison has made a determination .

that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that operation in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) involve a signiricant reduction in a margin of safety.

The proposed changes to the subject Technical Specifications include a modification to job titles following management reorganization; changes to the Onsite Review Organization membership description; and a change to overtime control requirements.

1) The proposed changes do not involve a significant increase in the

• probability or consequences of an accident previously evaluated because the proposed changes are administrative in nature. None of the proposed changes inv]lve a physical modification to the plant, a new mode of operation or a change to the UFSAR transient analyses. No Limiting Condition for Operation, ACTION statement or Surveillance Requirement is affected by any of the proposed changes.

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

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. Enclosure to NRC-93-0062 Page 5 because the proposed changes do not int roduce a new mode of plant operation or involve a physical modification to the plant. The proposed changes are administrative in nature.

3) The proposed changes do not involve a significant reduction in a margin of safety because they are administrative in nature. None of the proposed changes involve a physical modification to the plant, a new mode of operation or a change to the UFSAR transient analyses. No Limiting Condition for Operation, ACTION statement or Surveillance Requirement is affected.

Detroit Edison believes that these changes are similar to example (i) of Examples of Amendments which are considered not likely to involve Significant Hazards Considerations listed in 51FR7751 as they are purely administrative changes to the Technical Specifications.

Based on the above, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.

FNVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental 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 significantly increase individual or cumulative occupational radiation exposures.. Based'on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

CONCLUSION 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 compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or' to the health and safety of the public.

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