NRC-96-0064, Submits Rev to Proposed TS Change (License Amend) for Administrative Controls (TAC M91189) to Be Consistent W/Al 95-06,Improved Standard TS & Pending Changes to Improved Standard Ts,Per Discussions W/Nrc

Submits Rev to Proposed TS Change (License Amend) for Administrative Controls (TAC M91189) to Be Consistent W/Al 95-06,Improved Standard TS & Pending Changes to Improved Standard Ts,Per Discussions W/Nrc

ML20116F269
Person / Time
Site:	Fermi
Issue date:	07/25/1996
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20116F273	List: ML20116F306 NRC-96-0064, Submits Rev to Proposed TS Change (License Amend) for Administrative Controls (TAC M91189) to Be Consistent W/Al 95-06,Improved Standard TS & Pending Changes to Improved Standard Ts,Per Discussions W/Nrc
References
CON-NRC-96-0064, CON-NRC-96-64, RTR-NUREG-1433 AL-95-06, AL-95-6, TAC-M91189, NUDOCS 9608060299
Download: ML20116F269 (21)

Text

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j Douglas R. Gipson Senior Vice President Nuclear Generaten Fermi 2 6400 North Dixie Highway l Newport, Michigan 48166 (313) 586-5249 l

l l

l 10CFR50.90 July 25,19962

NRC-96-0064 I

l U. S. Nuclear Regulatory Commission Attn: Document Control Desk  ;

Washington, D.C. 20555

1

References:

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

2) NUREG 1433," Standard Technical Specifications for General ,

Electric Plants, BWR/4", dated January 1991 t

3) Generic Letter 93-07, " Modification of the Technical  ;

Specification Administrative Control Requirements for Emergency and Security Plans," dated December 28,1993 l 4) Federal Register Notice - Volume 58, No. 245, "... Technical Specifications on Effluents from Nuclear Power Reactors,"  !

i dated December 23,1993 l

l 5) BWOG - 09, Revision 0," Improved Standard Technical Specification Change Traveler", dated January 30,1994 l 6) NRC letter from William T. Russell to the Owners Group Chairpersons of the Improved Standard Technical Specifications (STS) Committees, dated October 25,1993 Federal Register Notice - Volume 59, No.181, " Technical l 7)

Specifications," dated September 20,1994

8) Detroit Edison Letter to NRC, NRC 93-0079 " Proposed i Technical Specification Change (License Amendment) and Quality Assurance Program Change for Audit Program", dated

. September 13,1993 0G0073 so' t 9600060299 960725 i

,,N PDR ADOCK 05000341 / r, p PDR _

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USNRC

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July 25,1996 NRC-96-0064 Page 2 l l

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9) Generic Letter 87-07, "Information Transmittal of Final Rulemaking for Revisions to Operator Licensing-10CFR 55 and Conforming Amendments," dated March 19,1987

10) Draft Generic Letter, " Guidance for Modification of Technical Specifications to reflect ..., ' Technical Specifications on Effluents from Nuclear Power Reactors',...," date filed December 22,1993 (FR Doc. 93-31335) ,

1

11) Detroit Edison Letter to NRC," Proposed Technical Specification Change (License Amendment) for  !

Administrative Controls", NRC-94-0107, dated December 15,1994

12) NRC Administrative Letter 95-06," Relocation of Technical Specification Administrative Controls Related to Quality Assurance"; dated December 12,1995

13) NRC Letter to Detroit Edison," Proposed Changes to Administrative Controls Section of the Fermi 2 Technical Specifications", dated January 24,1996

Subject:

Revision to Proposed Technical Specification Change (License Amendment) for Administrative Controls (TAC No. M91189)

On December 15,1994, Detroit Edison proposed a License Amendment (Reference

11) to change the administrative controls Section 6.0 of the Fermi 2 Technical l Specifications (TS). Subsequent to the submittal of that proposed change, the NRC issued generic guidance in the form of Administrative Letter (AL) 95-06; " Relocation of Technical Specification Administrative Contiols Related to Quality Assurance" dated December 12,1995 (Reference 12). On January 24,1996 the NRC notified Detroit Edison (Reference 13) that it should modify the proposed TS change to be consistent with AL 95-06, the Improved Standard TS (ISTS) and pending changes to the ISTS.

On May 10,1996, a conference call was conducted between Messrs. T. Colburn and T. Tjader of the NRC and Detroit Edison to discuss the NRC request. This letter modifies the original License Amendment request to incorporate changes requested in Reference 13, as clarified by the conference call.

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 (TS). The specific changes being proposed are described in Attachment I to this letter. This attachment replaces the corresponding Attachment 1 in Reference 11 in its entirety.

Detroit Edison has evaluated the proposed TS against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. This conclusion was not affected by the further changes being made by this submittal; therefore, the significant hazards consideration section in Attachment 1 is identical to that submitted

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USNRC July 25,1996 NRC-96-0064 Page 3 with Reference 11. The Fermi 2 Onsite Review Organization (OSRO) has approved and the Nuclear Safety Review Group has reviewed the proposed TS and concurs )

with the enclosed detenninations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.

Attachment 2 provides a mark-up and typed version of the pages from the current TS with the proposed changes incorporated.

In Reference 11 Detroit Edison identified sixteen formal commitments related to the proposed TS Amendment. These commitments are revised and restated below to reflect the changes in this submittal (numbers in parentheses denote the item number in Reference 13):

o Administrative controls on working hours will be retained. Furthermore, Detroit Edison is committed to retaining administrative procedures that control working hours. The administrative controls on working hours, currently included in section 6.2.2.f of the TS, have been deleted in the attached proposed changes and the two paragraphs requested by reference 13 have been added to the proposed changes for TS section 6.8

" Procedures and Programs". (Item 2) o An independent technical review function will be retained. The Independent Safety Engineering Group (ISEG) TS requirements will be relocated intact from the TS to the Quality Assurance Program (QAP).

(Item 3) Any future changes will be processed under the criteria for Quality Assurance Program changes 10CFR50.54(a),

o The changes proposed for the unit staff qualification requirements included in section 6.3 have been revised in Attachment 2 as requested by reference 13. Accordingly the commitment made in reference 11 to relocate these requirements is no longer applicable. The proposed changes have been revised to only delete reference to the March 29,1980 NRC letter to all licensees. (Item 4) o The review and audit functions currently included in section 6.5 of the TS will be relocated to the Fermi 2 QAP. (Item 5) o The reportable event requirement currently included in section 6.6.1.b of the TS will be relocated to the Fermi 2 QAP. This will be accomplished by the relocation of all OSRO requirements from section 6.5 to the QAP as discussed above. (Item 1) o The requirement for OSRO to review the Security Plan currently included in TS section 6.5.1.6.j and the requirement for Security Plan implementation procedures, currently included in TS section 6.8.1.e, will be relocated from TS to the respective Fermi 2 security plan.

o The requirement for OSRO to review the Emergency Plan currently included in TS section 6.5.1.6.k and the requirement for Emergency Plan

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USNRC July 25,1996 N'RC-96-0064 Page 4 implementation procedures, currently included in TS section 6.8.1.f, will be relocated to the respective Fermi 2 emergency plan.

o The review and approval process for administrative procedures currently included in section 6.8.2 of the TS will be relocated intact to the Fermi 2 QAP. (Item 6) Any future changes will be processed per 10CFR50.54(a).

o The review and approval process for each plant procedure required by TS 6.8.1, other than administrative procedures, currently included in section  !

6.8.3 of the TS will be relocated intact to the Fermi 2 QAP. (Item 6)

Any future changes will be processed per 10CFR50.54(a).

i o The review and approval process for temporary changes to each TS 6.8.1 plant procedure, currently included in section 6.8.4 of the TS will be relocated intact to the Fermi 2 QAP. (Item 6) Any future changes will be processed per 10CFR50.54(a).

o The In-P: ant Radiation Monitoring Program requirements currently included in section 6.8.5.b of the TS will be relocated to Chapter 12 of l the UFS AR.

o The Radiological Environmental Monitoring Program requirements currently included in section 6.8.5.f of the TS will be relocated to Chapter 11 of the UFSAR.

o The record retention requirements currently included in section 6.10 of the TS will be relocated intact to the Fermi 2 QAP. (Item 8) Any future changes will be processed per 10CFR50.54(a).

o The Radiation Protection Program requirements currently included in section 6.11 of the TS mil be relocated to Chapter 13 of the UFSAR.

o The commitment made in reference 11 regarding the relocation of the High Radiation Area requirements currently included in section 6.12 of the TS, is no longer applicable as this proposed change has been withdrawn. (Item 9) o The Process Control Program approval and revision process requirements currently included in section 6.13 of the TS will be relocated to the Fermi 2 QAP. (Item 7)

The changes to the QAP described in the above commitments will not involve a reduction in commitment because the TS provisions are being relocated intact. These changes, therefore, will be impicmented by Detroit Edison in accordance with 10 CFR 50.54(a) and prior approval of the QAP changes by the NRC will not be required. A copy of the revised plan will be forwarded for information by separate letter.

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i USNRC July 25,1996 NRC-96-0064 Page 5 l

I Detroit Edison is also proposing three additional changes in this TS Amendment.

These changes were also meluded in the reference 11 request. These additional changes proposed by Detroit Edison are as follows:

o The unit staff qualification requirements as specified in the H. R. Denton (NRC) letter, dated March 29,1980 and currently included in section 6.3 l of the TS will be deleted and not relocated since 10CFR55 and GL 87-07 l' (Reference 9) have superseded these requirements.

o The training requirements currently included in section 6.4 of the TS will be deleted and not relocated since the regulations and other Section 6.0 administrative controls provide sufficient control of these training requirements.

o The submittal requirement (i.e., "...within 90 days after January 1...") for the Annual Radioactive Effluent Release Report currently included in section 6.9.1.8 of the TS will be revised to read, "... prior to May 1...".

These commitments and additional changes are further described in Attachment 1. If you have any questions, please contact Mr. Joseph M. Pendergast at (313) 586-1682.

Sincerely, Attachments i cc: M. J. Jordan A. J. Kugler

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H. J. Miller A. Vegel  !

Supervisor, Electric Operators, Michigan Public Service Commission - J. R. Padgett

USNRC July 25,1996 NRC-96-0064 -

Page 6 1

1 I, DOUGLAS R. GIPSON, 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.

I Ofh DOUGLA$ R. GIPSON Senior Vice President On this 88 day of m.Ar ,1996 before me personally appeared Douglas R. GipsonCbeingiirst duly sworn and says that he executed the foregoing as his free act and deed.

h 3lJW '

Notary Public ROSALIE A. ARMETTA l NOTARYPUBUC MONROECOUNTY,Mi MYCOMMISSIONEXPlRES 10nUSS

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Attachment 1 to NRC-96-0064 Page 1 of 21 ATTACIIMENT 1

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PROPOSED TECIINICAL SPECIFICATION CII ANGE (LICENSE AMENDMENT) for i

REVISIONS TO TIIE ADMINISTRATIVE CONTROLS (SECTION 6.0)

TECIINICAL SPECIFICATIONS l

4 1

Attachment 1 to NRC-96-0064 Page 2 of 21 INTRODUCTION This license amendment request proposes changes to the Administrative Controls Section of the Fermi 2 Technical Specifications (TS). The proposed changes are to relocate, revise or delete the following provisions of the Fermi 2 TS:

Existing TS Section Illk 6.2.2.f Administrative Controls on Working Hours 6.2.3 Independent Safety Engineering Group (ISEG) 6.3 Unit Staff Qualifications 6.4 Training 6.5 Review and Audit 6.6 Reportable Event Action 6.8.1.e Security Plan Implementation 6.8.1.f Emergency Plan Implementation 6.8.2 Review and Approval Process (i.e., Administrative Procedures) 6.8.3 Review and Approval Process (i.e., other than Administrative Procedures) 6.8.4 Temporary Change Process 6.8.5.b In-Plant Radiation Monitoring 6.8.5.f Radiological Environmental Monitoring Program 6.9.1.8 Annual Radioactive Effluent Release Report 6.10 Record Retention 6.11 Radiation Protection Program 6.13 Process Control Program Except as discussed below, these changes am generally consistent with the guidelines in NUREG-1433 (Reference 2), Generic Letter (GL) 93-07 (Reference 3), Federal Register Notice (FRN) - Volume 58, No. 245 (Reference 4), Draft Generic Letter (Reference 10) and industry guidance offered in BWOG-09, Revision 0 (Reference 5). Additionally, Detroit Edison is proposing these changes in concert, for the most part, with the NRC letter from William T.

Russell to the Owners Group Chairpersons of the improved Standard Technical Specifications (STS) Committees, dated October 25,1993 (Reference 6).

Furthermore, Detroit Edison is proposing to make these changes generally consistent with the guidance presented in the FRN, Volume 59, No.181 (Reference 7), while still meeting the general requirements of 10CFR 50.36.

Detroit Edison is also proposing to make changes to certain Administrative Controls TS provisions that are not specifically addressed in the above referenced documentation. However,

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l Attachment 1 to NRC-96-0064 Page 3 of 21 i

these changes are still consistent with the underlying principles of that guidance (i.e., include greater emphasis on human factors principles, transfer of requirements from control by TS requirements to control by other mechanism (e.g., the UFS AR, procedures or the QA Program]

and relocate to other plant controlled documents all specific and prescriptive TS requirements not necessary to achieve performance since present TS is not performance based). These proposed changes are to the following TS provisions: Administrative Controls on Working Hours, Unit Staff Qualifications, and Reportable Event Action, and are further described below in sections 2,4 and 7, respectively. This request incorporates the modifications the NRC asked be made in Detroit Edison's original Reference 11 request as addressed in Reference 13 and May 10,1996 conference call.

DISCUSSION Detroit Edison proposes to delete or revise certain Administrative Controls Section TS I provisions. Additionally, Detroit Edison proposes to relocate other Administrative Controls ,

Section TS provisions to the UFSAR, plant procedures or the QA Program. Relocating these provisions will allow Fermi 2 to administratively control changes to these provisions without l having to submit TS changes for NRC approval. By approving this amendment, the NRC will be relieving Detroit Edison of the regulatory burden. Consequently, Detroit Edison requests that the I proposed TS change receive consideration as a " Cost Beneficial Licensing Action (CBLA)" since Detroit Edison can expect to save well in excess of $100,000 over the remaining plant lifetime if j this TS change is approved. This CBLA figure reflects only the savings realized from not having i to prepare and submit license amendments for NRC review for the TS provisions being proposed for relocation, revision or deletion.

Furthermore, in many cases the NRC requirements for provisions of certain Administrative Controls in the TS is redundant to other NRC regulations (or associated plans). The requirement to maintain these Administrative Controls provisions in the TS is not only redundant, but almost assures conflict at some point in time.

In consideration of the above facts and the commitment of resources required to maintain these Administrative Control provisions in the TS, Detroit Edison requests the NRC to approve this TS amendment request. Additionally, granting this request will allow the NRC and Detroit Edison resources presently associated with developing and processing license amendments to this Administrative Control section to be optimized. Furthermore, improvements in safety, efficiency and cost savings associated with changes to relocated administrative controls will be realized sooner.

Attachment 1 to NRC-96-0064 Page 4 of 21 PROPOSED CII ANGES Consistent with the guidance documents stated above, the following changes to the TS are being proposed. The changes are described in the order in which the associated TS appears in the Technical Specifications.

1. TS INDEX i

j a. Proposed change - Detroit Edison proposes to revise the index to make editorial

. corrections to reflect the relocation of the following provisions from the TS:

Independent Safety Engineering Group (ISEG), Training, Review and Audit, Reportable Event Action, Record Retention, Radiation Protection Program, and 4

the Process Control Program which are further described below. The proposed TS page changes are attached.

2. ADMINISTRATIVE CONTROLS ON WORKING HOURS (6.2.2.f) 3 j Proposed change - Detroit Edison proposes that the requirement for administrative controls on working hours, currently included in section 6.2.2.f of the TS, be relocated to i section 6.8 of the TS and restated as requested by Reference 13. The four specific j guidelines on working hours currently specified in section 6.2.2.f. are currently implemented by Fermi 2 plant procedures. This proposed change to the Technical Specifications would not eliminate or revise these procedures. The change simply i relocates administrative requirements for such controls from the Technical Specifications

! section 6.2.2.f to section 6.8 of the TS.

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} The underlying intent of the cmTent Administrative Controls on working hours is to

ensure that personnel performing safety related functions are physically fit to carry out these duties and responsibilities. The performance based objective is in effect to minimize the potential for errors caused by fatigue and in particular to prevent such errors from i being introduced into operations and maintenance activities. Detroit Edison fully supports i and is committed to this objective. Furthermore, Detroit Edison is committed to retaining i administrative procedures that clearly state this objective and to the control of working

] hours.

! With the relocation of the requirement for administrative controls to section 6.8 of the TS, g any future changes to these requirements would continue to require NRC approval.

The proposed Technical Specification change would allow Detroit Edison to make changes to the specific overtime hour guidelines in the future without prior NRC approval.

The net effect of this Technical Specification change, therefore, is that the safety of facility

operation is unaffected and the Detroit Edison and NRC resources associated with

processing license amendments in the future are optimized.

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Attachrnent 1 to NRC-96-0064 Page 5 of 21 The proposed TS page changes are attached.

3. INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)(6.2.3)

Proposed change - Detroit Edison proposes that the Independent Safety Engineering Group (ISEG) requirements , currently included in TS section 6.2.3, 1 be relocated from the Technical Specifications to the Quality Assurance Program 1

(QAP).

i The function of ISEG, as stated in the Fermi 2 Technical Specifications,is "...to examine unit operating characteristics, NRC issuance's, industry advisories, l Licensee Event Reports, and other sources of plant design ...., which may indicate areas for improving unit safety." Several additional functions and activities thr.t

more specifically describe the current role of the Fermi 2 ISEG are included in

Chapter 13 of the UFSAR.

i j Detroit Edison recognizes the importance of an independent technical review function and is committed to the retention of this function. The current

, requirements in the Technical Specifications, however, are more prescriptive than i necessary and as a result there will undoubtedly be a need for one or more license j amendments in the future. These changes can be made more efficiently in the

. future if the ISEG requirements currently in Section 6.2.3 are relocated to the QAP as proposed.

f The proposed change would not eliminate or significantly revise any of the current ISEG functions described in the Tech Specs or the UFS AR. As stated above the change simply relocates the description of the independent technical review function from Tech Specs to the QAP. With the relocation to the QAP any

changes to the ISEG requirements in the future (and the associated implementing

procedures) would be subject to review in accordance with 10CFR50.54.

The proposed Technical Specification change would, therefore, allow Detroit Edison to make changes to the ISEG requirements in the future only with prior i NRC approval if these changes involve a reduction in program commitments. The required evaluation however, would appropriately limit the extent of changes made without prior NRC approval and provide assurance that the safety objective of l having an effective independent technical review function would still be met. The i net effect of this Technical Specification change, therefore,is that the safety of ,

facility operation is unaffected and the Detroit Edison and NRC resources  !

j associated with processing license amendments in the future are optimized.

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, The proposed TS page changes are attached.  !

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Attachment 1 to NRC-96-0064 Page 6 of 21 l

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4. UNrf STAFF QUALIFICATIONS (6.3) l Proposed change - Detroit Edison proposes that the unit staff qualification  !

requirements as specified in the H. R. Denton (NRC) March 29,1980 letter and currently included in section 6.3 of the TS, will be deleted since 10CFR 55 and GL l 87-07 (Reference 9) have superseded these requirements. Since 10CFR 55 now contains the requirements there is no need to restate them in TS.

Additionally, TS Table 6.2.2-1 describes the minimum shift crew composition and  ;

delineates which positions require an Operator license or Senior Operator license. )

1 Training and requalification of those positions are as specified in 10CFR55. l Detroit Edison, therefore, concludes that 10CFR 55, GL 87-07 and other Section

6.0 administrative controls provide sufficient control of these qualification requirements, thereby allowing for the removal of the unit staff qualification requirements, as specified in the H. R. Denton (NRC) March 29,1980 letter, from TS 6.3 of the Technical Specifications. I

The proposed TS page changes are attached. I 3

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Attachment 1 to NRC-96-0064 Page 7 of 21 l

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5. TRAINING (6.4)

Proposed change - Detroit Edison proposes that the requirements on training, currently included in TS section 6.4, be deleted from the TS on the basis that they are adequately addressed by the regulations (i.e.,10CFR 55) as implemented in other Section 6.0 administrative controls and Chapter 13 of the UFSAR. TS 6.2.2,

" Unit Staff ," which is retained, provides adequate requirements to assure an acceptable, competent operating staff. Each member of the Fermi 2 staff is required to meet or exceed the minimum qualifications acceptable to the .NRC staff, as specified in TS 6.2.2 and 6.3.1. UFSAR Chapter 13 describes the Fermi 2 training program. Also, these changes are consistent with Reference 6.

Additionally, TS Table 6.2.2-1 describes the minimum shift crew composition and delineates which positions require an Operator license or Senior Operator license.

Training and requalification of those positions are as specified in 10CFR 55.

Furthermore, Section A.I.8 of the UFSAR currently states Detroit Edison's conformance to Regulatory Guide 1.8, Revision 1-R which endorses ANSI N18.1-1971, which contains the retraining and replacement training program referred to in TS 6.4. Detroit Edison, therefore, concludes that the regulations, other Section 6.0 administrative controls, and the UFSAR provide sufficient control of these training requirements, thereby allowing for the removal of TS 6.4 from the Technical Specifications. l l

The proposed TS page changes are attached.

6. REVIEW AND AUDIT (6.5)

Proposed change - Detroit Edison proposes that with the exception of the Security and Emergency Plans, the review and audit functions, currently included in section 6.5 of the TS, be relocated intact to QAP. The Security and Emergency Plans are discussed below in sections 8 and 9, respectively. This proposal would rely on the QAP to control the review and audit requirements.

The following points summarize Detroit Edison's position on removing the review and audit requirements from TS.

The OnSite Review Organization (OSRO) function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority and records are proposed to be covered in the QAP.

The off-site review group (i.e., Nuclear Safety Review Group [NSRG) )

requirements are also proposed to be covered in the QAP.

1 Attachment 1 to NRC-96-0064 Pago 8 of 21 er p The audit requirements are proposed to be covered in the QAP since it will 3 provide Detroit Edison more ilexibility in that QA oversight efforts can be better

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focused based on performance and plant activities. An additional advantage of contrn11ing the audit requirements in the QAP is that the QA Program can be revioed more efficiently than the TS, saving NRC and Detroit Edison resources. In Reference 8, Detroit Edison previously requested relocation of audit frequencies, I

this change was subsequently issued as Amendment 104.

The technical review and control requirements are also proposed to be relocated intact to the QAP.

The proposed change would not eliminate or revise any of the current OSRO functions, NSRG functions or audit requirements described in the Tech Specs, UFSAR or QAP. As stated above the change simply relocates to the QAP review and audit functions currently included in section 6.5 of the TS. With the relocation to the QAP any changes to the review and audit functions (and the associated implementing procedures) in the future would be subject to review in accordance with 10CFR 50.54 (for QAP).

The proposed Technical Specification change would allow Detroit Edison to make changes to the review and audit functions in the future that involve a reduction in commitment only with prior NRC approval. The net effect of this Technical Specification change, therefore, is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing license amendments in the future are optimized.

Proposed change - Detroit Edison proposes to revise TS page 6-14 as a result of relocating the review and audit functions currently included in section 6.5 of the TS, from TS to the QAP. The proposed wording for TS Section 6.7.1.a on TS page 6-14 will be to spell out NSRG as follows: "...and the Nuclear Safety Review Group (NSRG) shall ...".

Proposed change - Detroit Edison proposes to revise TS page 6-14 as a resuk of relocating the review and audit functions currently included in section 6.5 of the TS, from TS to the QAP. The proposed wording for TS Section 6.7.1.b on TS page 6-14 will be to spell out OSRO as follows: "The report shall be reviewed by the Onsite Review Organization (OSRO)."

Proposed change - Detroit Edison proposes to revise TS page 6-24 as a result of relocating the review and audit functions currently included in section 6.5 (i.e.,

specifically section 6.5.1.6.m) of the TS, from TS to the QAP. The proposed change for TS Section 6.14.2.b on TS page 6-24 will be to remove the words

7 Attachment 1 to NRC-96-0064 Page 9 of 21

" review and acceptance by the OSRO and the". TS Section 6.14.2.b will then i read, " Shall become effective after approval of the Plant Manager." l The requirement for OSRO to review changes to the Offsite Dose Calculation Manual (ODCM) is included in the material being relocated to the QAP. Any future changes to this requirement would be subject to the criteria of j 10CFR50.54(a).

The proposed TS page changes are attached.

7. REPORTABLE EVENT ACTION (6.6)

Proposed change - Detroit Edison proposes to delete TS section 6.6.1. As noted in Reference 13, TS 6.6.1.a is redundant to 10CFR50.73.

Detroit Edison proposes to relocate the OSRO reportable event action requirement currently included in TS 6.6.1.b to the QAP. This review requirement is redundant to the OSRO review responsibility currently listed as item 6.5.1.6.g which is being relocated to the QAP as discussed in section 6 above. The TS 6.6.1.b requirements for reporting the results of the review of reportable events to the NSRG and Senior Vice President are also redundant to other requirements in Section 6. Specifically Section 6.5.1.8 (which is also being relocated to the QAP as discussed above) ensures that records of OSRO reviews are provided to the l NSRG and the Senior Vice President. Therefore, there is no need to restate these l responsibilities in the TS. Detroit Edison, therefore, concludes that the OSRO responsibilities section in the QAP will provide sufficient control of this reportable ,

event action requirement, thereby allowing for the removal of TS 6.6.1.b from the j Technical Specifications.

The proposed TS page changes are attached.

8. SECURITY PLAN IMPLEMENTATION (6.8.1.e)

Proposed change - Detroit Edison proposes that the requirement for OSRO to review the Security Plan currendy included in TS section 6.5.1.6.j and the requirement for Security Plan implementation procedures, currently included in TS section 6.8.1.e, be relocated from TS to its respective Fermi 2 Security Plan in '

accordance with Generic Letter 93-07. Since the Security Plan requirements are specified in 10CFR 50.54,10CFR 73.55 and 10CFR 73.56, the NRC staff has  !

proposed in this Generic Letter to remove the requirements from the TS and relocate them to the respective security plan. Also, the NRC recommended relocation of these requirements in Reference 6.

Attachment 1 to NRC-96-0064 Page 10 of 21 The NRC staff has concluded that other regulatory requirements provide sufficient l control of these provisions and removing them from TS is acceptable.

The proposed TS page changes are attached. )

9. EMERGENCY PLAN IMPLEMENTATION (6.8.1.f) l Proposed change - Detroit Edison proposes that the r quirement for OSRO to review the Emergency Plan currently included in TS sntion 6.5.i.6.k and the requirement for Emergency Plan implementation proce hies. ;urrently included in TS section 6.8.1.f, be relocated from the TS to its respcctim Fermi 2 Emergency Plan in accordance with Generic Letter 93-07. Since the Emergency Plan requirements are specified in 10CFR 50.54 and 10CFR 50, Appendix E, Section V, the NRC staff has proposed this Generic Letter to remove the requirements <

from the TS and relocate them to the respective Emergency Plan. Also, the NRC recommended relocation of these requirements in Reference 6.

The NRC staff has concluded that Other regulatory requirements provide sufficient control of these provisions and removing them from TS is acceptable.

The proposed TS page changes are attached.

10. REVIEW AND APPROVAL PROCESS [i.e., ADMINISTRATIVE PROCEDURES] (6.8.2)

Proposed change - Detroit Edison proposes to relocate both the review and approval process for administrative procedures, currently included in TS section 6.8.2, from TS to the QAP. This proposal is based on the existence of the following requirements.

The requirement for procedure control is mandated by 10CFR 50, Appendix B, Criterion V and Criterion VI. ANSI N18.7-1976, which is an NRC staff-endorsed document used in the development of muy licensee QAPs, also contains specific requirements related to procedures. Detroit Edison has committed to follow ANSI N18.7-1976 as a means to comply with 10CFR 50, Appendix B. ANSI N18.7-1976, Section 5.2.2 discusses procedure adherence. This section clearly states that procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing. ANSI N18.7-1976, Section 5.2.15 describes the review, approval and control of procedures. This section describes the requirements to provide measures to control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities affecting quality. ANSI N18.7-1976, Section 5.2.15 further states that each procedure shall

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Attachment 1 to NRC-96-0064 i Page 11 of 21 be reviewed and approved prior to initial use. The required reviews are also described.

I Detroit Edison proposes to continue to implement the requirements of 10CFR 50, Appendix B, regarding administrative procedures without duplicating the procedure review and approval requirements in the facility TS. Safe operation of the plant will continue to be maintained, and therefore, the requirements for administrative procedures and their control should not be re-addressed in TS.

Duplication of the provisions related to administrative procedures is not necessary in the TS to assure safe operation of the facility. Additionally, Detroit Edison will continue to implement a QAP in accordance with the requirements of 10CFR 50, Appendix B, which provides appropriate controls for the review and approval of procedure changes. Also, Detroit Edison's commitment to ANSI N18.7-1976 is unaffected by relocating the TS 6.8.2 requirements to the QAP.

With the relocation to the QAP, any changes to the review and approval process for administrative procedures in the future would be subject to review in i accordance with 10CFR 50.54(a). This ensures that any future changes would be  !

evaluated to confirm that they do not involve a reduction in commitment without prior NRC approval. In effect this evaluation would ensure that the underlying purpose of the review and approval process for administrative procedures would  ;

be retained. The process also ensures that the changes would be documented and I included in the UFS AR revisions and the description of QA Program changes that are submitted to the NRC as required by 10CFR50.71(e) and 10CFR50.54(a).

The proposed Technical Specification change would allow Detroit Edison to make changes to the review and approval process for administrative procedures in the future without prior NRC approval. The required evaluations described above, would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective review and approval process for administrative procedures would still be met. The net effect of this Technical Specification change, therefore, is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing license ,

amendments in the future are optimized. Also, the NRC recommended relocation of these requirements in Reference 6 and 12. Detroit Edison concludes that these regulatory requirements provide sufficient control of these provisions thereby allowing for the relocation of TS 6.8.2 from the Technical Specifications to the QAP. The TS nequirements will be relocated intact to the QAP.

The proposed TS page changes are attached.

i Attachment 1 to NRC-96-0064 4 Page 12 of 21 l

, 11. REVIEW AND APPROVAL PROCESS [i.e., EACH PLANT PROCEDURE REQUIRED HY TS 6.8.1 OTHER TIIAN ADMINISTRATIVE PROCEDURES]

(6.8.3) i i

Proposed change - Detroit Edison proposes to relocate both the review and approval process for each plant procedure required by TS 6.8.1, other than administrative procedures, currently included in TS section 6.8.3, from TS to the QAP. This proposalis based on the existence of the following requirements.

]'

The requirement for procedure controlis mandated by 10CFR 50, Appendix B, Criterion V and Criterion VI. ANSI N18.7-1976, which is an NRC staff-endorsed f document used in the development of many licensee QA Programs, also contains specific requirements related to procedures. Detroit Edison has committed to follow ANSI N18.7-1976 as a means to comply with 10CFR 50, Appendix B.

ANSI N18.7-1976, Section 5.2.2 discusses procedure adherence. This section j clearly states that procedures shall be followed, and the requirements for use of

procedures shall be prescribed in writing. ANSI N18.7-1976, Section 5.2.15 describes the review, approval and control of procedures. This section describes the requirements to provide measures to control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities

)'

affecting quality. ANSI N18.7-1976, Section 5.2.15 further states that each procedure shall be reviewed and approved prior to initial use. The required reviews are also described.

Detroit Edison proposes to continue to implement the requirements of 10CFR 50, Appendix B, regarding each plant procedure required by TS 6.8.1, other than administrative procedures, without duplicating the procedure review and approval I

requirements in the facility TS. Safe operation of the plant will continue to be maintained, and therefore. the requirements for procedures and their control should not be re-addressed in TS. Duplication of the provisions related to i procedures is not necessary in the TS to assure safe operation of the facility.

, Additionally, Detroit Edison will continue to irnplement a QAP in accordance with the requinments of 10CFR 50, Appendix B, which provides appropriate controls )

i for the revi+ v end approval of procedure changes. Also, Detroit Edison's

commitment to ANSI N18.7-1976 is unaffected by relocating the TS 6.8.3  ;

requirements to the QAP.

i With the relocation to the QAP any changes to the review and approval process

for each plant procedure required by TS 6.8.1, other than administrative procedures, in the future would be subject to review in accordance with 10CFR 50.54(a). This ensures that any future changes would be evaluated to confirm that they do not involve a reduction in commitment without prior NRC approval. In

) effect this evaluation would ensure that the underlying purpose of the review and

Attachment 1 to NRC-96-0064 Page 13 of 21 approval process for each plant procedure required by TS 6.8.1, other than administrative procedures, would be retained. The process also ensures that the changes would be documented and included in the UFSAR revisions and the description of QA Program changes that are submitted to the NRC as required by .

10CFR50.71(e) and 10CFR50.54(a).

The proposed Technical Specification change would allow Detroit Edison to make changes to the review and approval process for each plant procedure required by TS 6.8.1, other than administrative procedures, in the future without prior NRC approval. The required evaluations described above, however, would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective review and approval process for each plant procedure required by TS 6.8.1, other than administrative procedures, would still be met. The net effect of this Technical Specification change, therefore,is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing license amendments in the future are optimized. Also, the NRC recommended relocation of these requirements in Reference 6. Detroit Edison concludes that these regulatory requirements provide sufficient control of these provisions thereby allowing for the relocation of TS 6.8.3 from the Technical Specifications to the QAP. The TS requirements will be relocated intact to the QAP. The QAP will include a commitment to process procedures and procedure changes in accordance with an accepted standard such as ANSI N18.7.

The proposed TS page changes are attached.

12. TEMPORARY CIIANGE PROCESS (6.8.4) -

l Proposed change - Detroit Edison proposes to relocate both the review and approval process for temporary changes to each plant procedure required by TS i 6.8.1, currently included in TS section 6.8.4, from TS to the QAP. With the relocation to the QAP, any changes to the review and approval process for temporary changes to each plant procedure, required by TS 6.8.1 in the future would be subject to review in accordance with 10CFR50.54(a). ,

This ensures that any future changes would be evaluated to confirm that they do not involve a reduction in commitment without prior NRC approval. In effect this evaluation would ensure that the underlying purpose of the review and approval process for temporary changes to each plant procedure required by TS 6.8.1, would be retained. The process also ensures that the changes would be documented and included in the UFSAR revisions and the description of QA Program changes that are submitted to the NRC as required by 10CFR50.71(e) v and 10CFR50.54(a).

Attachment 1 to NRC-96-0064 Page 14 of 21 1

The proposed Technical Specification change would allow Detroit Edison to make changes to the review and approval process for temporary changes to each plant procedure required by TS 6.8.1, in the future without prior NRC approval. The required evaluations described above, however, would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective review and approval process for temporary changes to each plant procedure required by TS 6.8.1 would still be met. The net effect of this Technical Specification change, therefore, is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing license amendments in the future are optimized. The NRC recommended relocation of these requirements in References 6 and 12. Detroit Edison concludes that these regulatory requirements provide sufficient control of these provisions thereby allowing for the relocation of TS 6.8.4 from the Technical Specifications to the j QAP. The TS requirements will be relocated intact to the QAP. l l

The proposed TS page changes are attached.

13. IN-PLANT RADIATION MONITORING (6.8.5.b)

Proposed change - Detroit Edison proposes to relocate the In-Plant Radiation Monitoring Program requirements, currently included in TS section 6.8.5.b, from TS to Chapter 12 of the UFSAR. The In-Plant Radiation Monitoring Program provides controls to ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program was developed to minimize radiation exposure to plant personnel post-accident and has no impact on nuclear safety. The In-Plant Radiation Monitoring Program administrative control does not involve monitoring process variables that are initial conditions for a design basis transient or accident, nor does it involve a primary success path to mitigate a DBA.

With the relocation to the UFSAR, any changes to the In-Plant Radiation Monitoring Program requirements in the future would be subject to review in accordance with 10CFR 50.59. This ensures that any future changes would be evaluated to confirm that they do not involve an unreviewed safety question. In effect this safety evaluation would ensure that the underlying purpose of the In-Plant Radiation Monitoring Program requirements would be retained. The process also ensures that the changes would be documented and included in the UFSAR revisions and the Safety Evaluation Summary Reports that are submitted to the NRC as required by 10CFR 50.71(e) and 10CFR 50.59(b).

The proposed Technical Specification change would allow Detroit Edison to make i changes to the In-Plant Radiation Monitoring Program requirements in the future, without prior NRC approval. The required evaluations described above, however,

Attachment 1 to i NRC-96-0064 i Page 15 of 21 '

would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective In-Plant Radiation Monitoring Program, would still be met. The net effect of this Technical Specification change, therefore, is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing license amendments in the future are optimized. Therefore, based on these considerations, Detroit Edison concludes that the in-Plant-Radiation Monitoring Program administrative control is not necessary in the TS to assure operation of the facility in a safe manner and can be relocated from TS to Chapter 12 of the UFSAR. Also, the NRC recommended relocation of these requirements in Reference 6.

The proposed TS page changes are attached. i

14. RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (6.8.5.f)

Proposed change - Detroit Edison proposes to relocate the Radiological Environmental Monitoring Program requirements, currently included in TS section 6.8.5.f, from TS to Chapter 11.6 of the UFSAR. The Radiological Environmental Monitoring Program provides controls to monitor radiation and radionuclides in the environs of the plant. This program was developed to identify potential exposure pathways and verify the accuracy of the plant's effluent monitoring program. The Program is a redundant verification of the effectiveness of the effluent monitoring program contained in the ODCM and specified in the administrative controls section of TS.

l With the relocation to the UFSAR, any changes to the Radiological Environmental Monitoring Program requirements in the future would be subject to review in accordance with 10CFR 50.59. This ensures that any future changes would be evaluated to confirm that they do not involve an unreviewed safety question. In effect this safety evaluation would ensure that the underlying purpose  ;

of the Radiological Environmental Monitoring Program requirements would be retained. The process also ensures that the changes would be documented and included in the UFS AR revisions and the Safety Evaluation Summary Reports that are submitted to the NRC as required by 10CFR 50.71(e) and 10CFR 50.59(b).

The proposed Technical Specification change would allow Detroit Edison to make changes to the Radiological Environmental Monitoring Program requirements in the future, without prior NRC approval. The required evaluations described above, however, would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective Radiological Environmental Monitoring Program, would still be met. The net effect of this Technical Specification change, therefore, is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing

~

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Attachment 1 to ,

NRC-96-0064 l Page 16 of 21

)

l license amendments in the future are optimized. Therefore, based on these considerations, Detroit Edison concludes that the Radiological Environmental i Monitoring Program requirements are not necessary in the TS to assure operation j of the facility in a safe manner and can be relocated from TS to Chapter 11.6 of the j UFSAR. Also, the NRC recommended relocation of these requirements in l Reference 6.

Proposed change - Detroit Edison proposes to revise TS page 1-4 as a result of relocating the Radiological Environmental Monitoring Program requirements, from TS to Chapter 11.6 of the UFSAR. The proposed wording for the second sentence of definition 1.24 on TS page 1-4 will be, "The ODCM shall also contain (1) the Radioactive Effluent Controls required by Section 6.8.5 and Radiological Environmental Monitoring Programs and (2) ." Additionally, "... Semiannual Radioactive Effluent Release Report..." will be changed to "... Annual Radioactive Effluent Release Report.. " to be consistent with TS 6.9.1.8.

The proposed TS page changes are attached.

15. ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (6.9.1.8)

Proposed change - Detroit Edison proposes to revise the Annual Radioactive Effluent Release Report submittal date requirement, currently included in TS section 6.9.1.8. The present submittal requirement in the TS (i.e., "...within 90 days after January 1. .") will be revised to read, "... prior to May 1...". This revision to the submittal date requirement is consistent with the NRC guidance provided in the Federal Register Notice (FRN) - Volume 58, No. 245 (Reference

4) and the Draft Generic Letter (Reference 10). This extended submittal date will provide additional time necessary for preparation and review of a report that will contain data gathered over a longer time period, than the previous Semi Annual  ;

Report used to cover.  ;

I The proposed TS page changes are attached.

16. RECORD RETENTION (6.10)

Proposed change - Detroit Edison proposes to relocate the requirements on record retention, currently included in TS section 6.10, from TS to the QAP.

With the relocation to the QAP, any changes to these record retention requirements in the future would be subject to review in accordance with 10CFR50.54(a). This ensures that any future changes would be evaluated to confirm that they do not involve a reduction in commitment without prior NRC approval. In effect this would ensure that the underlying purpose of the record

J i

Attachment 1 to NRC-96-0064 Page 17 of 21 i

retention requirements would be retained. The process also ensures that the changes would be documented and included in the UFSAR revisions and the description of QA Program changes that are submitted to the NRC as required by 10CFR 50.71(e) and 10CFR 50.54(a).

l 1

4 The proposed Technical Specification change would allow Detroit Edison to make changes to the record retention requirements in the future, without prior NRC approval. The required evaluation would appropriately limit the extent of such l 4

changes and provide assurance that the safety objective of having effective record  ;

retention requirements would still be met. The net effect cf this Technical Specification change, therefore, is that the safety of facility operation is unaffected i and the Detroit Edison and NRC resources associated with processing license j

- amendments in the future are optimized. Therefore, based on these considerations, Detroit Edison concludes that the record retention requirements are not necessary

. in the TS to assure operation of the facility in a safe manner and can be relocated from TS to the QAP. Also, the NRC recommended relocation of these requirements in References 6 and 12. The record retention requirements currently included in section 6.10 of the TS will be relocated intact to the Fermi 2 QAP.

1 Proposed change - Detroit Edison proposes to revise TS page 3/4 7-20 as a result of relocating the requirements on record retention, from TS to the QAP. The proposed change to the last sentence of the TS Surveillance Requirement 4.7.5.i, Snubber Seal Replacement Program section on TS page 3/4 7-20 will be to remove the words, "... in accordance with Specification 6.10.3."

Proposed change - Detroit Edison proposes to revise TS page 6-24 as a result of relocating the requirements on record retention, from TS to the QAP. The proposed change to TS 6.14.2.a will be to remove the words, "... in accordance with Specification 6.10.3.n."

J The proposed TS page changes are attached.

I

17. RADIATION PROTECTION PROGRAM (6.11) i Proposed change - Detroit Edison proposes to relocate the requirements for the Radiation Protection Program, currently included in TS section 6.11, from TS to l

, Chapter 13.5 of the UFSAR. The Radiation Protection Program requires procedures to be prepared for personnel radiation protection consistent with the requirements of 10CFR 20. The requirement to have procedures to implement i

Part 20 is also contained within 10CFR 20.1101(b).

With the relocation to Chapter 13.5 of the UFSAR, any changes to the Radiation Protection Program requirements in the future would be subject to review in

1 l

Attachment 1 to NRC-96-0064 i Page 18 of 21 I l

l accordance with 10CFR 50.59. This ensures that any future changes would be evaluated to confirm that they do not involve an unreviewed safety question. In effect this safety evaluation would ensure that the underlying purpose of the Radiation Protection Program requirements would be retained. The process also ensures that the changes would be documented and included in the UFSAR revisions and the Safety Evaluation Summary Reports that are submitted to the NRC as required by 10CFR 50.71(e) and 10CFR 50.59(b).

The proposed Technical Specification change would allow Detroit Edison to make changes to the Radiation Protection Program requirements in the future, without j prior NRC approval. The required evaluations described above, however, would i appropriately limit the extent of such changes and provide assurance that the safety objective of having effective Radiation Protection Program requirements would still be met. The net effect of this Technical Specification change, therefore,is that the safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with processing license amendments in the future are optimized. Therefore, based on these considerations, Detroit Edison concludes that the Radiation Protection Program requirements are not necessary in the TS to assure operation of the facility in a safe manner and can be relocated from TS to Chapter 13.5 of the UFSAR. Also, the NRC recommended relocation of these ,

requirements in Reference 6. I The proposed TS page changes are attached.

18. IIIGH RADIATION AREA (6.12) l Proposed change - NO LONGER REQUESTED i 4

19. PROCESS CONTROL PROGRAM (6.13) i 3 Proposed change - Detroit Edison proposes to relocate the Process Control  !

Program (PCP) approval and revision process requirements, currently included in TS section 6.13, from TS to the QAP.

With the relocation to the QAP, any changes to these PCP requirements in the future would be subject to review in accordance with 10CFR50.54(a) This ensures that any future changes would be evaluated to confirm that they do not involve a reduction in commitment without prior NRC approval. In effect this would ensure that the underlying purpose of the PCP requirements would be retained. The process also ensures that the changes would be documented and included in the UFS AR revisions and the description of QA Program changes that are submitted to the NRC as required by 10CFR 50.71(e) and 10CFR 50.54(a).

Attachment 1 to NRC-96-0064

Page 19 0f 21 The proposed Technical Specification change would allow Detroit Edison to make changes to the PCP programmatic requirements in the future, without prior NRC approval. The required evaluation would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective PCP would still be met. The net effect of this Technical Specification change, therefore, is that the safety of facility operation is unaffected and the Detroit Edison and

, NRC resources associated with processing license amendments in the future are

optimized. Therefore, based on these considerations, Detroit Edison concludes

that the PCP programmatic requirements are not necessary in the TS to assure operation of the facility in a safe manner and can be relocated from TS to the QAP.

Also, the NRC recommended relocation of these requirements in References 6 and j 12. The PCP requirements currently included in section 6.13 of the TS will be relocated intact to the Fermi 2 QAP.

The proposed TS page changes are attached.

EVALUATION This proposal relocates certain provisions of the Administrative Controls Section of the Fermi 2

TS to the appropriate UFSAR chapters, plant procedures, or the QA Program Relocating these provisions will allow Fermi 2 to administratively control changes without having to submit TS changes. This proposal also revises or deletes certain Administrative Controls Section TS provisions. These specific changes, in themselves, have no effect on the surveillance or system requirements and so, no effect on plant safety. Additionally, except as discussed above, these changes are generally consistent with the guidelines in NUREG - 1433 (Reference 2), Generic Letter (GL) 93-07 (Reference 3), Federal Register Notice (FRN)- Volume 58, No. 245 (Reference 4), Draft Generic Letter (Reference 10) and recent industry guidance offered in BWOG-09, Revision 0 (Reference 5). Additionally, Detroit Edison is proposing these changes in concert, for the most part, with the NRC letter from William T. Russell to the Owners Group Chairpersons of the improved Standard Technical Specifications (STS) Committees, dated October 25,1993 (Reference 6).

These proposed changes are also consistent with the generic guidance published by Administrative Letter 95-06 (Reference 12).

SIGNIFICANT H AZARDS CONSIDER ATION in accordance with 10CFR 50.92, 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 1 previously evaluated, or (3) involve a significant reduction in a margin of safety.

Attachment 1 to NRC-96-0064 Page 20 of 21 The proposed changes to the subject Technical Specifications includes relocation, revision or deletion of the following TS provisions: Administrative Controls on Working Hours, Independent Safety Engineering Group (ISEG), Unit Staff Qualifications, Training, Review and Audit, Reportable Event Action, Security Plan Implementation, Emergency Plan Implementation, Review and Approval Process for Administrative and Non-Administrative Procedures, Temporary Changes to Administrative Procedures, In-Plant Radiation Monitoring, Annual Radioactive Effluent Release Report, Radiological Environmental Monitoring Program, Record Retention, Radiation Protection Program, and the Process Control Program.

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 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 by any of the proposed changes. Also, these proposed changes, in themselves, do not reduce the level of qualification or training such that personnel requirements would be decreased. Therefore, this change is administrative in nature and does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Further, the proposed changes do not alter the design, function, or operation of any plant component and therefore, do not affect the consequences of any previously evaluated accident.

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 mode of plant operation, surveillance requirement or involve a physical modification to the plant. The proposed changes are administrative in nature. The changes propose to revise, delete or relocate the stated administrative control provisions from the TS to the UFS AR, plant procedures or the QA Program whereby, adequate control of information is maintained. Further, as stated above, the proposed changes do not alter the design, function, or operation of any plant components and therefore, no new accident scenarios are created.

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 i 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. The proposed changes do not involve a significant reduction in a margin of safety. Additionally, the proposed change does not alter the scope of equipment currently required to be OPERABLE or subject to smveillance testing nor does the proposed change affect any instrument setpoints or equipment safety ft nctions.

Therefore, the change does not involve a significant reduction in a marge of safety. I

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Attachment 1 to NRC-96-0064 Page 21 of 21 l

Detroit Edison believes that these changes are similar to example (i) of Examples of Amendments which are considered not likely to involve Significant 11azards Considerations listed in SlFR7751 as they are purely administrative changes to TS.

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

\

Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR 51.22 for environmental considerations. The proposed changes do 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 meet the criteria given in 10CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement. '

CONCI USION Based on the evaluations 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 the proposed amendment will not be inimical to the common defense and security or the health and safety of the public.

In order to accomplish procedure changes associated with this change, Detroit Edison requests that the proposed license amendment be issued with a 90-day implementation period.

l