View source for NRC-94-0107, Application for Amend to License NPF-43,proposing Changes to Administrative Controls Section of Ts,Consistent W/Guidance in NUREG-1433 & GL 93-07, Mod of Ts...For Emergency & Security Plans

{{Adams
| number = ML20078R715
| issue date = 12/15/1994
| title = Application for Amend to License NPF-43,proposing Changes to Administrative Controls Section of Ts,Consistent W/Guidance in NUREG-1433 & GL 93-07, Mod of Ts...For Emergency & Security Plans
| author name = Gipson D
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-94-0107, CON-NRC-94-107, RTR-NUREG-1433
| document report number = GL-93-07, GL-93-7, NUDOCS 9412270177
| package number = ML20078R718
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 30
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:--      ~
[_
i                      s                                                .
                                                                                                                                  ~7 2
Dougize R. Olpson .
g_,,,.,      - Sernor Vee Prescent Nuclear Generanon f      Form) 2 6400 North Ome Highway
                  "*gfjja'"*" **'"
December 15, 1994 NRC-94-0107' U. S. Nuclear Regulatory Commission Attn: Document Control Desk Nashington, D.C.           20555

==References:==
: 1)  Fermi 2                                                       ~~
NRC Docket No. 50-341 NRC License No. NPF-43
: 2)  NUREG 1433, Standard Te'chnical-Specifications'for General Electric Plants, BNR/4, dated January 1991
: 3)  Generic Letter 93-07, "Nodification of the                             .
Technical Specification Administrative Control                                   ..
Requirements for Emergency and Security Plans,"                             ,           q dated December 28, 1993
                                                                                                                                  .3
: 4) ' Federal Register Notice - Volume 58, No. 245,                                             .
                                           "  ... Technical Specifications on Effluents from Nuclear Power Reactors," dated December 23, 1993
: 5)    BNOG - 09, Revision 0,       improved Standard Technical Specification Change Traveler, dated January 30, 1994
: 6)    NRC letter from Nilliam T. Russell to the Owners Group Chairpersons of the improved Standard Technical Specifications (STS) Cosaittees, dated October 25, 1993
: 7)    Federal Reg! ster Notice - Volume 59, No. 181,
                                            " Technical Specifications," dated September 20, 1994
: 8)    Detroit Edison Letter to NRC, NRC 93-0079, dated September 13, 1993
: 9)    Generic Letter 87-07, "Information Transmittal of Final Rulemaking for Revisions to Operator Licensing-10CFR 55 and Conforming Amendments,"
dated March 19, 1987 I
9412270177 941215              1 PDR     ADDCK 0500 P
                              - . _       -      __ ..   . _ _ _ _ _ . _ . _ _ . _ _ _ . . . _ . _ ._                             )

USNRC
$ a December 15, 1994                                                            ,
NRC-94-0107-                                                                 j Page 2                                                                       ;
: 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)

==Subject:==
Proposed Technical Specification Change (License Amendment) - 4ministrative 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 (TS).
Except as discussed in Attachment 1, 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).
Detroit Edison is also proposing to make these changes generally consistent with the guidance presented in the recently issued FRN, Volume 59, No.181 (Reference 7), while still meeting the general requirements of 10CFR50 36. Consequently, the specific proposed changes to the subject TS include relocation, revision or deletion of the following TS provisions:     Independent Safety Engineering Group (ISEG), Unit Staff Qualifications, Training, Administrative Controls on Working Hours, 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, Radio.'.ogical Environmental Monitoring Program, Record Retention, Radiation Protection Program, High Radiation Area, and the Process Control Program. Detroit Edison proposes to relocate several of these TS provisions to the appropriate UFSAR chapter, plant procedures or the QA Program.
Detroit Edison has evaluated the proposed TS against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. 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 determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan.
                                                                               /

1 USNRC i > December 15, 1994 NRC-94-0107 Page 3 l
Additionally, Detroit Edison requests that the proposed TS change        j receive consideration as a " Cost Beneficial Licensing Action (CBLA)"
since as a result of the future TS changes to Section 6 that would be avoided, Detroit Edison can expect to save well in excess of $100,000 over the remaining plant lifetime if this TS change is approved.
Furthermore, if this TS change is approved, it will prevent Detroit Edison from having to submit additional TS changes for NRC approval for those sections being proposed for relocation out of TS. In addition, improvements in safety, efficiency and cost savings associated with changes to relocated administrative controls will be realized sooner.
A summary of the proposed changes, an Evaluation, the Significant Hazards and Environmental Impact Considerations and a Conclusion are provided in Attachment 1.
Attachment 2 provides marked up pages of the existing TS to show the proposed changes and a typed version of the affected TS pages with the proposed changes incorporated. TS 6.5.2.8 (Audits) is also affected by the proposed revision included in Reference 8.
Detroit Edison is proposing sixteen formal commitments in this TS Amendment. These proposed Detroit Edison formal commitments are as follows:
o    Administrative controls on working hours will be retained.
Furthermore, Detroit Edison is committed to retaining administrative procedures that clearly state this objective and to the control of working hours. The administrative controls on working hours, currently included in section 6.2.2.f of the TS will be relocated to Chapter 13 of the UFSAR. When relocated to the UFSAR, the appropriate subsection of Chapter 13 would include a statement / commitment that administrative procedures
                   " ...shall be developed and implemented to limit the working hours of unit staff who perform safety related functions
                        "   This statement, in addition to all of the other "shall" and "should" statements, Will be relocated to the UFSAR.
o    An independent technical review function will be retained.
The Independent Safety Engineering Group (ISEG) TS section currently included in section 6.2 3 of the TS will be relocated to Chapter 13 of the UFSAR.
i            o    The unit staff qualification requirements (i.e., "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971... September 1975.",

T USNRC                                                                      l
   + r December 15, 1994 NRC-94-0107 Page 4 l
l' currently included in section 6.3 of the TS, will be relocated to Chapter 13 of the UFSAR.
o   The review and audit functions, with the exception of TS 6.5.2.8, currently included in section 6.5 of the TS will be relocated to Chapter 13 of the UFSAR. TS 6.5.2.8 will be relocated to the Fermi 2 QA Program.
o   The reportable event requirement for OSRO currently included in section 6.6.1.b of the TS will be relocated to Chapter 13 of the UFSAR under OSRO responsibilities.
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 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 to the Fermi 2 QA Program.
o   The review and approval process for each plant procedure      q required by TS 6.8.1, other than adrrinistrative procedures, currently included in section 6.8.3 of the TS will be relocated to the Fermi 2 QA Program.
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 to Chapter 13 of the UFSAR.                                                       ,
o    The In-Plant Radiation Monitoring Program requirements currently included in section 6.8.5.b of the TS will be relocated to Chapter 12 of the UFSAR.
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 to Chapter 13 of the UFSAR.

c
                                                                                    }
i USNRC
     *~ '* December 15, 1994                                                         j NRC-94-0107                                                               !
Page 5 1
t o     The Radiation Protection Program requirements currently r1 o            kR.
o     The Hfgh Radiation Area requirements currently included in   ;
section 6.12 of the TS will be relocated to Chapter 12 of    ;
the UFSAR.                                                  1 The Process Control Program approval and revision process   I o
requirements currently included in section 6.13 of the TS will be relocated to the Fermi 2 Process Control Program. l Detroit Edison is also proposing three additional changes in this TS     [
i          Amendment. These additional changes proposed by Detroit Edison are as    l follows:
O      The unit staff qualification requirements as specified in   l the H. R. Denton (NRC) letter, dated March 29, 1980 and     !
currently included in section 6.3 of the TS will be deleted and not relocated since 10CFR55 and GL 87-07 (Reference 9) have superseded these requirements.                         l o      The training requirements currently included in section 6.4 ;
of the TS will be deleted and not relocated since the      i 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 i Report and 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       l Attachment 1. If you have any questions, please contact Mr. Glen D.     ,
Ohlemacher at (313) 586-4275                                            I t
j Sincerely, l
l Attachments                                                             ,
f cc:   T. G. Colburn                                                     1 J. B. Martin, NRC Regional Administrator                         .
M. P. Phillips                                                   !
A. Vegel Supervisor, Electric Operators, Michigan Public Service Commission - J. R. Padgett

[.
USNRC
       -*: i   December 15, 1994 NRC-94-0107 f            - Page 6 4
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.
DOUGLAS R.'GIPSON Senior Vice President On this     [h           day of      Latuj e L ., 1994 before me personally appeared Douglas R. Gipson, being first duly sworn and says that he executed the foregoing as his free act and deed.
fdAlw [L. h t/?LCTi~d J Notary Public
                                                  *j         mosAuEAARMEITA q    MPUBUCSTA1E OFMIOBCAN MoNROECDUNTY  ,
                                                  . My e--"W EXP. NOV. M19M C.
                                                                                  )

{
ATTACHMENT _1 PROPOSED TECHNICAL SPECIFICATION CHANGE (LICENSE AMENAMENT) for REVISIONS TO THE ADMINISTRATIVE CONTROLS (SECTION 6.0)
TECIINICAL SPECIFICATIONS l
i l
1 I
                                                            ]

Attachment I to
  ,- NRC-94-0107                                                                                      .
Page 1 of 23 INTRODUCTION i
This license amendment request proposes changes to the Administrative Contmls Section of the     l Fermi 2 Technical Specifications (TS). The proposed changes are to relocate, revise or delete the following provisions of the Fermi 2 T!!:                                                     ,
Existine TS Section         Iille 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                                                     l 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)                                   i 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                   i 6.10                        Record Rettntion                                               l 6.11                        Radiation Prucction Program 6.12                        High Radiation Area                                           .
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 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).
Furthermore, Detroit Edison is proposing to make these changes generally consistent with the guidance presented in the recently issued FRN, Volume 59, No.181 (Reference 7), while still meeting the general requirements of 10CFR 50.36.
I l
i J

Attachment 1 to
, NRC-94-0107 Page 2 of 23 Detroit Edison is also proposing to make changes to cenain Administrative Controls TS provisions that are not specifically addressed in the above referenced documentation.
However, these changes are still consistent with the underlying principles of that guidance (i.e., include greater emphasis on human factors principles, transfer of requirements fmm contml by TS requirements to control by other mechanism [ e.g., the UFSAR, procedures or the QA Program ] and relocate to other plant controlled documents all specific and prescriptive TS requiiements not necessary to achieve performance since piesent TS is not performance based). These proposed changes are to the following TS provisions: Administrative Contmis on Working Hours, Unit Staff Qualifications, and Reponable Event Action, and are funher described below in sections 2,4 and 7, respectively.
DISCUSSION Detroit Edison proposes to delete or revise cenain Administrative Controls Section TS provisions. Additionally, Detroit Edison proposes to relocate other Administrative Controls Section TS provisions to the UFSAR, plant procedures or the QA Program. Relocating these pmvisions will allow Fermi 2 to administratively control changes to these provisions without having to submit TS changes for NRC approval. By approving this amendment, the NRC will be relieving Detmit Edison of the regulatory burden. Consequer.tly, Detroit Edit n requests that the proposed TS change receive consideration as a " Cost Beneficial Licensing Action (CBLA)" since Detmit Edison can expect to save well in excess of $ 100,000 over the remaining plant lifetime if this TS change is appmved. 'Ihis CBLA figure reflects only the savings realized from not having to prepare and submit license amendments for NRC review for the TS pmvisions being proposed for relocation, revision or deletion.
Furthermore, in many caws the NRC requirements for provisions of cenain Administrative Contmis 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.
l
                                                                        -                          J

Attachment I to                                                                                     l
  . NRC-94-0107                                                                                         l Page 3 of 23 PROPOSED CIIANGES Consistent with the guidance documents stated above, the following changes to the TS are being pmposed. The changes are descrihst in the ortler in which the associated TS appears in the Technical Specifications.
: 1. TS INDEX
: 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 Gmup (ISEG), Training, Review and Audit, Recon! Retention, Radiation Pmtection Program, High Radiation Area, and the Process Control Pmgram which are further described below. The              ,
proposed TS page changes are attached.
: 2. ADMINISTRATIVE CONTROLS ON WORKING IIOURS (6.2.2.0 Proposed change - Detroit Edison proposes that the administrative controls on working hours, currently included in section 6.2.2.f of the TS, be relocated to the UFSAR.
The underlying intent of the current 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 fmm being introduced into operations and maintenance activities. Detroit Edison fully supports and is committed to this objective. Furthermore, Detroit Edison is committed to retaining administrative proceduits that clearly state this objective and to the contml of working hours.
The administrative contmls on working hours 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 relocates the current requirement for such controls from the Technical Specifications to the UFSAR. When relocated to the UFSAR, for example, the appropriate subsection of Chapter 13 would include a statement / commitment that administrative procedares "...shall be developed and implemented to limit the working hours of unit staff who perfonn safety related functions ...". This statement, in addition to all of the other "shall" and "should" statements, will be relocated to the UFSAR.

  ' Attachment I to .
. NRC-94-0107 Page 4 of 23 With the relocation to the UFSAR any future changes to the ovenime requirements in Chapter 13 (and the associated implementing procedures) would be subject to review in accortlance with 10CFR 50.59. This ensures that future changes to the overtime contmis would be evaluated to confirm that the change does not involve an unreviewed safety question. In effect this safety evaluation would verify that the underlying objectives of the current controls would not be compromised by the change. The process also ensures that the changes are 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(c) and 10CFR 50.59(b).
The proposed Technical Specification change would allow Detmit Edison to make changes to the overtime controls 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 objectives of minimizing the potential for ermrs through the control of working hours 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 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, be relocated from the Technical Specifications to the UFSAR.                   l The function of ISEG, as stated in the Fermi 2 Technical Specifications, is
                    ...to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources of plant design, which may indicate areas for improving unit safety." Several additional functions and activities that more specifically describe the current role of the Fermi 2 ISEG are included in Chapter 13 of the UFSAR.
Detroit Edison recognizes the importance of an independent technical review            I function and is committed to the retention of this function. The current requirements in the Technical Specifications, however, are more prescriptive           !
than necessary and as a result there will undoubtedly be a need for one or more        l license amendments in the future. These changes can be made more efficiently I

t Attachment I to
  .- ' NRC-94-0107 Page 5 of 23                                                                                                   ;
in the fr.ture if the ISEG requirements currently in Section 6.2.3 are relocated to          c the UFSAR as proposed.                                                                       ;
i The proposed change would not eliminate or significantly revise any of the current ISEG functions described in the Tech Specs or the UFSAR. As stated above the change simply relocates and consolidates in the UFSAR the description of the independent technical review function. With the relocation                l to the UFSAR any changes to the ISEG requirements in the future (and the associated implementing procedures) would be subject to review in accortlance 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 independent -
technical review function 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 ISEG requirements in the future without prior NRC approval. The requhed evaluations described above, however, would appropriately limit the extent of such changes and provide assurance that the safety objective of having an effective independent technical review function 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 proposed TS page changes are attached.-
: 4. UNIT STAFF QUALIFICATIONS (6.3)
Proposed change - Detroit Edison proposes that the unit staff qualification requirements (i.e., "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971... September 1975."), currently included in section 6.3 of the TS, will be relocated from the Technical Specifications to Chapter 13 of the UFSAR. UFSAR Chapter 13 currently contains some but not all of these requirements.
With the relocation to the UFSAR, any changes to the unit staff qualification requirements discussed above, 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

  . Attachment 1 to                                                                                        !
. NRC-94-0107                                                                                           ;
Page 6 of 23 effect this safety evaluation would ensure that the underlying purpose of the unit staff qualification mquirements discussed above, 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 Detmit Edison to               i make changes to the unit staff qualification requirements discussed above, 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 effective urdt staff qualification       ,
requirements as discussed above, would still be met. The net effect of this Technical Specification change, therefore, is that the safety of facility operation     l is unaffected and the Detroit Edison and NRC resources associated with processing license amendments in the future are optimized. Detroit Edison, therefore, concludes that the UFSAR will provide sufficient control of the unit staff qualification requirements discussed above, thereby allowing for the             ;
relocation of these TS 6.3 requirements to Chapter 13 of the UFSAR.
Proposed change - Detroit Edison also 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 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           l license. Training and requalification of those positions are as specified in           )
10CFR 55.                                                                              i Detroit Edison, therefore, concludes that 10CFR 55, GL 87-07 and other                  l Section 6.0 administrative controls piovide sufficient contml 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,            1 1980 letter, from TS 6.3 of the Technical Specifications.
The proposed TS page changes are attached.
l

1 l
  ' Attachment I to                                                                                   l
. ' NRC-94-0107                                                                                     H Page 7 of 23                                                                                     ;
l
: 5. TRAINING (6.4)                                                                             j Proposed change - Detmit Edison pmposes that the requirements on training,          l 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                j implemented in other Section 6.0 administrative controls and Chapter 13 of the     ,
UFSAR. TS 6.2.2, " Unit Staff ,". which is retained, pmvides 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 specined in TS 6.2.2. UFSAR Chapter 13 describes the Fermi 2 training program. Also, these changes aiu 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 requalif'ication of those positions are as specified in 10CFR 55.
Furthermore, Section A.1.8 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 contml of these training requirements, thereby allowing for the removal of TS 6.4 fmm the Technical Specifications.
The proposed TS page changes are attached.
: 6. REVIEW AND AUDIT (6.5)
Proposed change - Detroit Edison proposes that the review and audit functions, with the exception of TS 6.5.2.8 (Audits), currently included in section 6.5 of the TS, be relocated to Chapter 13 of the UFSAR. TS 6.5.2.8 (Audits) will be relocated to the Fermi 2 QA Program. The Security and Emergency Plans are discussed below in sections 8 and 9, respectively. This proposal would rely on the UFSAR or QA Program to control the review and audit requirements. The QA Program is contained in Chapter 17 of the UFSAR. The following points summarize Detroit Edison's position on removing the review and audit requirements from TS.

Attachment I to
  . NRC-94-0107 Page 8 of 23 The OnSite Review Organization (OSRO) function, composition, alternate membership, meeting frequency, quomm, responsibilities, authority and mcords are proposed to be covered in the UFSAR Chapter 13.
The off-site review group (i.e., Nuclear Safety Review Group [NSRG) )
requirements are also proposed to be covered in the UFSAR Chapter 13.
Currently, UFSAR Chapter 13 contains some but not all of these requirements.                 ,
                     'Ihe audit requirements are proposed to be covered in the QA Pmgram since it will provide Detroit Edison more flexibility in that QA oversight efforts can be better focused based on performance and plant activities. An additional advantage of contmiling the audit requirements in the QA Progam is that the                  t QA Pmgram can be revised more efficiently than the TS, saving NRC and Detmit Edison resources. In Reference 8, Detroit Edison has previously                        :
requested relocation of the detailed audit descriptions.
l The technical review and control requirements are pmposed to be covered in the UFSAR Chapter 13.
1 The proposed change would not eliminate or revise any of the current OSRO                    l functions, NSRG functions or audit requirements described in the Tech Specs, UFSAR or QA Pmgram. As stated above the change simply relocates to the UFSAR or the QA Program the review and audit functions currently included in section 6.5 of the TS. With the relocation to the UFSAR or QA Program 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 50.59 or 10CFR 50.54 (for QA Program). This ensures that any future changes would be evaluated to confirm that they do not involve an unreviewed safety question for UFSAR Chapter 13 changes (or reduction in commitment for QA Program changes). In effect this safety evaluation would ensure that the underlying purpose of the review and audit ftmetions would be retained. The process also ensures that the changes would be documented and included in the 4
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), as well as the QA Program change submittals as required by 10CFR 50.54(a).
l The proposed Technical Specification change would allow Detroit Edison to make changes to the review and audit functions 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 effective review and audit functions would still be met. The net effect of this Technical Specification change, therefore, is that the

Attachment I to
. NRC-94-0107 Page 9'of 23 safety of facility operation is unaffected and the Detroit Edison and NRC resources associated with pmcessing license amendments in the future am optimized. Also, the NRC recommended relocation of these requirements in Reference 6.
Preposed 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 Chapter 13 of the UFSAR. The pmposed wording for TS Section 6.7.1.a on TS page 6-14 will be to spell out NS~RG as follows: "...and the Nuclear Safety Review Group (NSRG) shall ...".
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 Chapter 13 of the UFSAR. The proposed wortling 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 Chapter 13 of the UFSAR. The proposed change for TS Section 6.14.2.b on TS page 6-24 will be to remove the words " review and acceptance by the OSRO and the". TS Section 6.14.2.b will then read, " Shall become effective after approval of the Plant Manager."
The proposed TS page changes are attached.
: 7. REPORTABLE EVENT ACTION (6.6)
Proposed change - Detroit Edison proposes to relocate the OSRO reportable event action requirement currently included in TS 6.d.l.b to Chapter 13 of the UFSAR under OSRO Responsibilities. Refer to the OSRO relocation discussion in section 6 above. Consequently, since TS section 6.6.1.b is simply a repeat of an OSRO responsibility proposed for relocation into Chapter 13 of the UFSAR there is no need to restate this responsibility in TS. The same is trne for reporting the results of the review of reportable events to the NSRG and Senior Vice President. Reportable events are covered in the NSRG responsibilities being relocated into Chapter 13 of the UFSAR. The requirement that results of NSRG reviews be reported to the Senior Vice President is also being relocated. Therefore, there is no need to restate thece responsibilities in the TS. Detroit Edison, therefore, concludes that the OSRO and NSRG rtsponsibilities section in Chapter 13 of the UFSAR will provide

[
Attachment 1 to
  . NRC-94-0107 Page 10 of 23 sufHcient control of this reportable event action requirement, thereby allowing for the removal of TS 6.6.1.b from the Technical SpeciHcations.
The proposed TS page changes are attached.
: 8. SECURITY PLAN IMPLEMENTATION (6.8.1.e)
Proposed change - Detroit Edison proposes that the equirement 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, be relocated from TS to its respective Fermi 2 security plan in accordance with Generic Letter 93-07. Since the security plan requirements am specified in 10CFR 50.54,10CFR 73.55 and 10CFR 73.56 the NRC staff has proposed this Generic letter to remove the requirements fmm the TS and relocate them to the respective security 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 pmposed TS page changes are attached.
: 9. EMERGENCY PLAN IMPLEMENTATION (6.8.1.f)
Proposed change - Detroit Edison proposes that 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 implementation procedures, currently included in TS section 6.8.1.f, be relocated fmm the TS to its respective Fermi 2 emergency plan in accordance with Generic letter 93-07. Since the emergency plan requirements am 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 pmvide sufGeient control of these provisions and removing them from TS is acceptable.
The proposed TS page changes are attached.
J

Attachment I to
. 7 NRC-94-0107 Page 11 of 23 i
: 10. REVIEW AND APPROVAL PROCESS [i.e., ADMINISTRATIVE PROCEDURES] (6.8.2)
Proposed change - Detroit Edison proposes to relocate both the review and             ,
appmval process for administrative procedums, currently included in TS section 6.8.2, from TS to the QA Program. This proposal is based on the existence of the following requirements.                                                            :
i 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 many licensee QA programs, also contains specific requirements related to procedures. Detroit Edison has 4
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 pmcedures 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 pmvide 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        3 to initial use. The required reviews are also described.
Detroit Edison pmposes to continue to implement the requirements of 10CFR 50, Appendix B, regarding administrative pmcedures 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 contrul should not be re-addressed in TS.
Duplication of the provisions related to administative procedures is not necessary in the TS to assure safe operation of the facility. Additionally, Detroit Edison will continue to implement a QA Program in accordance with the requirements of 10CFR 50, Appendix B, which pmvides 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 QA Program.
With the relocation to the QA Program, any changes to the review and approval process for 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 approval process for             ,
i

Attachment 1 to                                                                                      l
. NRC-94-0107 Page 12 of 23                                                                                       )
I administrative procedures would be retained. The process also ensures that the        i changes would be documented and included in the UFSAR revisions and the                i I
description of QA Program changes that are submitted to the NRC as required by 10CFR 50.71(e) and 10CFR 50.54(a).                                                 j The proposed Technical Specification change would allow Detroit Edison to '         l make changes to the review and approval process for administrative procedures       :
in the future without prior NRC approval. The required evaluations described above, however, would appmpriately limit the extent of such changes and -             r provide assurance that the safety objective of having an effective review and appmval process for administrative procedures would still be met. The net effect of this Technical Specification change, therefore, is that the safety of   .t 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      l' control of these provisions thereby allowing for the relocation of TS 6.8.2 from the Technical Specifications to the QA Program.
The proposed TS page changes are attached.
: 11. REVIEW AND APPROVAL PROCESS [i.e., EACH PLANT PROCEDURE                                      ;
REQUIRED BY TS 6.8.1] (6.8.3)
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 proceduies, currently included in TS section 6.8.3, from TS to the QA Program. 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 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 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

      ' Attachment 1 to
    . NRC-94-0107 Page 13 of 23 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 appmval 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 procedures is not necessary in the TS to assure safe operation of the facility. Additionally, Detmit iklison will continue to implement a QA Program in accordance with the requirements of 10CFR 50, Appendix B, which provides -
appropriate controls for the review and approval of procedure changes. Also,'
Detmit Edison's commitment to ANSI N18.7-1976 is unaffected by relocating the TS 6.8.3 requirements to the QA Program.
With the relocation to the QA Program any changes to the review and approval process for each plant pmcedure 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 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 10CFR 50.71(e) and 10CFR 50.54(a).
The pmposed Technical Specification change would allow Detroit Edison to make changes to the review and approval pmcess for each plant procedure required by TS 6.8.1, other than administrative procedures, in the future without prior NRC approval. The required evaluations describcd 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 pmcedures, 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 1

Attachment I to
   .                   NRC-94-0107 Page 14 of 23 thereby allowing for the relocation of TS 6.8.3 fmm the Technical Specifications to the QA Program.
l The pmposed TS page changes are attached.                                            )
: 12. TEMPORARY CHANGE PROCESS (6.8.4)
Proposed change - Detroit Edison proposes to relocate both the review and           -l approval process for temporary changes to each plant pmcedure required by TS          l 6.8.1, currently included in TS section 6.8.4, from TS to Chapter 13 of the           !
UFSAR. This proposal is based on the existence of very similar requirements currently included in Section 13.5.2 of the UFSAR. Themfore, since TS                !
section 6.8.4 is virtually a repeat of that currently included in Section 13.5.2 of the UFSAR, there is no need to mstate the requirements in the TS.
With the relocation to the UFSAR, 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 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 review and approval pmcess for             s 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 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 review and approval process for temporary changes to each plant pmcedure 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 pmcess 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 a. sociated with processing license amendments in the future are           r optimized. A'so, the NRC recommended relocation of these requirements in Reference 6. Deroit Edison, therefore, concludes that the UFSAR provides sufficient control of Me review and appmval process for temporary changes to each plant procedure, quired by TS 6.8.1, thereby allowing for the relocation of TS 6.8.4 requirements to Section 13.5.2 of the UFSAR.

1 Attachment I to
  . NRC-94-0107                                                                                                 i Page 15 of 23                                                                                               l l
l The proposed TS page changes are attached.                                                  l t
    - 13. IN-PLANT RADIATION MONITORING (6.8.5.b)                                                             ;
Proposed change - Detroit Edison proposes to miocate the In-Plant Radiation                 l Monitoring Program requirements, currently included in TS section 6.8.5.b,                  l from TS to Chapter 12 of the UFSAR. Tlw In-Plant Radiation Monitoring                       :
Program provides controls to ensure the capability to accurately determine the              !
airbome iodine concentration in vital areas under accident conditions. This                 I 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.                                   l 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                 I accordance with 10CFR 50.59. This ensures that any future changes would be evaluated to confirm that they do not involve an umeviewed safety question. In              l effect this safety evaluation would ensure that the underlying purpose of the In-           !
.                  Plant Radiation Monitoring Program mquirements 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 In-Plant Radiation 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 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.
d i
                                                     -                 ,                ..- _ . , ,._  -n , ,

Attachment I to L
    'NRC-94-0107                                                                                        :
L    Page 16 of 23
: 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 Pmgram provides controls to monitor radiation and radionuclides in the environs of the plant. 'Ihis program was developed to identify potential exposure pathways and verify the accuracy of the plant's effluent monitoring program. The Pmgram 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.
t With the relocation to the UFSAR, any changes to the Radiological                  l Environmental Monitoring Program requirements in the future would be subject to review in accordance with 10CFR 50.59. This ensures that any future             l 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 pmcess also ensures that the changes would be               ;
documented and included ja the UFSAR revisions and the Safety Evaluation           t 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          i make changes to the Radiological Envimamental Monitoring Program                   ,
requirements in the future, without prior NRC approval. The required evaluations described above, however, would appropriately limit the extent of      j such changes and provide assurance that the safety objective of having an          !
effective Radiological Environmental Monitoring Pmgram, 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, Detmit Edison concludes       {
that the Radiological Environmental Monitoring Program requirements are not necessary in the TS to assure operation of the facility in a safe manner and can   j be relocated from TS to Chapter 11.6 of the UFSAR. Also, the NRC recommended relocation of these re , aements in Reference 6.
l l
Proposed change - Detmit 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 pmposed wording for the second sentence of definition 1.24 on TS page 1-4 will be, "The ODCM shall also I

Attachment I to
  . NRC-94-0107                                                                                            ,
Page 17 of 23 contain (1) the Radioactive Effluent Controls required by Section 6.8.5 and              t
    .               Radiological Envimnmental Monitoring Programs and (2) ..." Additionally,
                      ... Semiannual Radioactive Effluent Release Report..." will be changed to              l
                    "... 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.
The proposed TS page changes are attached,                                               i l
: 16. RECORD RETENTION (6.10)                                                                           ,
1 Proposed change - Detroit Edison proposes to relocate the requirements on record retention, currently included in TS section 6.10, from TS to Chapter 13.6 of the UFSAR. Chapter 13.6 of the UFSAR currently contains some but not all of these requirements. Additionally, the relocated record retention              ,
requirements are currently incorporated by reference in the QA Program. This QA Program reference will be modified to refer to the new location proposed (i.e., Chapter 13 of the UFSAR) for these requirements.
With the relocation to Chapter 13.6 of the UFSAR, any changes to these record retention 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 record retention 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).                                                     j l

Attachment I to
  . NRC-94-0107 Page 18 of 33 The pmposed Technical Specification change would allow Detroit Edison to               1 make changes to the record retention requirements in the future, without prior         !
NRC approval. The required evaluations described above, however, would                 t 1
appropriately limit the extent of such changes and provide assurance that the safety objective of having effective record retention requirements would still be      ,
met. The net effect of this Technical Specification change, therefore, is that the     l safety of facility operation is unaffected and the Detroit Edison and NRC            -l resoun es associated with processing license amendments in the future are optimized. Therefore, based on these considerations, Detroit Edison concludes          i 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 fium TS to Chapter 13.6 of the UFSAR. Also, the NRC recommended relocation of these               j requirements in Reference 6.                                                           !
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 Chapter          j 13.6 of the UFSAR. 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."
l Proposed change - Detroit Edison proposes to revise TS page 6-24 as a result of relocating the requirements on record retention, from TS to Cha pter 13.6 of        -
the UFSAR. The proposed change to TS 6.14.2.a will be to rem < ve the                  i words, "... in accordance with Specification 6.10.3.n."
i The proposed TS page changes are attached.
t
: 17. RADIATION PROTECTION PROGRAM (6.11)
Proposed change - Detroit Edison proposes to relocate the requirements for the Radiation Protection Program, currently included in TS section 6.11, from TS to 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 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 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            .

Attachment I to
  . NRC-94-0107 -
Page 19 of 23 purpose of the Radiation Protection Program mquirements 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 Progmm mquirements in the future, without prior NRC approval. The requimd evaluations described above, however, would 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.
The proposed TS page changes are attached.
: 18. HIGH RADIATION AREA (6.12)
Proposed change - Detroit Edison proposes to relocate the requirements for the High Radiation Area, currently included in TS section 6.12, from TS to Chapter 12.3 of the UFSAR. The High Radiation Area administrative control provides access controls for high radiation areas in lieu of those specified in 10CFR 20.1601. Changes to these controls can only be made with prior approval of the NRC consistent with paragraph 20.1601 of 10CFR 20. These controls are developed to ensure nuclear plant personnel safety and have no impact on nuclear safety. Based on these considerations, the High Radiation Area administrative control is not necessary in the TS to assure operation of the facility in a safe manner and can be deleted from Technical Specifications.
10CFR 20.1601(c) provides the appropriate mechanism for licensees wishing to propose alternative controls to those specified in 10CFR 20. Licensees relocating the high radiation control description currently contained in the Administrative Controls Section of TS to Chapter 12.3 of the UFSAR have previously received NRC approval for the alternative controls. Subsequent changes to these controls will be processed in accordance with the applicable regulation, which includes prior NRC approval. Therefore, based on these considerations, Detroit Edison concludes that the High Radiation Area

I Attachment I to
. NRC-94-0107                                                                                        l Page 20 of 23 administrative control 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 12.3 of the UFSAR. Also, the NRC recommended relocation of these             ,
requirements in Reference 6.                                                        ,
The proposed TS page changes are attached.
i
: 19. PROCESS CONTROL PROGRAM (6.13)                                                              i Proposed change - Detroit Edison proposes to relocate the Process Control           i Program (PCP) approval and revision pmcess requirements, currently included          l in TS section 6.13, from TS to the Fermi 2 Process Control Program. The PCP         t implements the requirements of 10CFR 20,10CFR 61, and 10CFR 71.
Relocating the PCP approval and revision process requirements from the TS to the Fermi PCP does not affect the safe operation of the facility.
Changes to the Fermi 2 PCP am controlled by an administrative procedure.             l Consequently, any changes to the PCP approval and revision process                  !
requirements in the future would be subject to review in accordance with            j 10CFR 50.59. This ensures that any future changes would be evaluated to              l confirm that they do not involve an unreviewed safety question. In effect this review would ensure that the underlying p wse of the PCP approval and revision process requirements would be tv       xi.
The proposed Technical Specification cha% would allow Detroit Edison to make changes to the PCP appmval and rev'sioni     process requirements in the future, without prior NRC appmval. The required evaluations described above, however, would appropriately limit the extent of such changes and provide assurance that the safety objective of having effective PCP approval and revision process 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 PCP approval and revision process 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 Fermi 2 PCP.
Also, the NRC recommended relocation of these requirements in Reference 6.
The proposed TS page changes are attached.
i l

4 Attachment 1 to
              -. NRC-94-0107 Page 21 of 23 EVALUATION i
This pmposal relocates certain provisions of the Administrative Controls Section of the Fermi    i 2 TS to the appropriate UFSAR chapters, plant procedures, or the QA Program. Relocating these provisions will allow Fermi 2 to administratively control changes to these provisions without having to submit TS changes for NRC appmval. This proposal also revises or deletes certain Administrative Controls Section TS provisions. Dese 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).        :
i 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).
i SIGNIFICANT HAZARDS CONSIDERATION                                                                l t
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 t% pssibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
The proposed changes to the subject Technical Specincations includes relocation, revision or deletion of the following TS provisions: Administrative Contmls 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 Administmtive Procedures, In-Plant Radiation Monitoring, Annual Radioactive Efuuent Release Report, Radiological Environmental Monitoring                 l Program, Record Retention, Radiation Protection Program, High Radiation Area, and the            !
Process Control Program.                                                                         !
: 1)      The proposed changes do not involve a signincant 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 qualincation or training such that personnel      ,
I

Attachment I to
  - NRC-94-0107 Page 22 of 23 i
requirements would be decreased. Theiefore, this change is administrative in nature    '
and does not involve a significant increase in the pmbability 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 pmposed changes do not create the possibility of a new or different kind of accident fmm any accident previously evaluated because the proposed changes do not intmduce a new mode of plant operation, surveillance requirement or involve a physical modification to the plant. The pmposed changes are administrative in nature.
The changes pmpose to revise, delete or relocate the stated administrative contml pmvisions fmm the TS to the UFSAR, plant pmcedures or the QA Program whereby,          j 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.                                      i
: 3)       The pmposed 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. The proposed changes do not involve a significant reduction in a margin of safety. Additionally, the pmposed change does not alter the scope of equipment currently required to be OPERABLE or subject to surveillance testing nor does the proposed change affect any instrument setpoints or    !
equipment safety functions. Therefore, the change does not involve a significant       i reduction in a margin of safety.
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 SIFR7751 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.
i ENVIRONMENTAL IMPACT                                                                            >
Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR 51.22 for envimnmental considerations. The proposed changes do not involve a            s significant hazards considention, 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, Detmit Edison               ,
concludes that the pmposed Technical Specifications meet the criteria given in 10CFR            .

l   Attachment I to
    . NRC-94-0107 Page 23 of 23 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
CONCLUSION i
Based on the evaluations above: (1) there is reasonable assumnce 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      j that the proposed license amendment be issued with a 90-day implementation period.                 '
I I
I 1
1 l
l 1
l I
_ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _                                    __ __.      I}}