ML061840302

Audit of the Licensee'S Management of Regulatory Commitments

ML061840302
Person / Time
Site:	Fermi
Issue date:	07/21/2006
From:	Jaffe D NRC/NRR/ADRO/DORL/LPLIII-1
To:	Cobb D Detroit Edison
D. Jaffe LPL3-1
References
TAC MC8824
Download: ML061840302 (16)

Text

July 21, 2006 Mr. Donald K. Cobb Assistant Vice President - Nuclear Generation Detroit Edison Company Fermi, Unit 2 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC8824)

Dear Mr. Cobb:

The Nuclear Regulatory Commission (NRC) staff is required to audit a licensees commitment management program once every 3 years, in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. LIC-105, which is publicly available electronically (as Accession No. ML042320463) from the Agencywide Documents Access and Management System (ADAMS) from within the public Electronic Reading Room on the Internet at the NRC web site, provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes.

An audit of the commitment management program of Detroit Edison Company (the licensee) for Fermi 2 (Facility Operating License No. NPF-43) was performed at the Facility from May 8, 2006 to May 11, 2006. Based on this audit, the NRC staff concludes that: (1) the licensee had implemented NRC commitments in a timely basis; and (2) the licensee had implemented an effective program for managing NRC commitment changes. However, in Section 2.1.2 of the enclosed audit report, the NRC staff notes that, in one case (Regulatory Action and Commitment Tracking System [RACTS] 87238), the licensee lost the documentation of a commitment that was made orally to an NRC inspector. In other cases, the initiation date of the commitment was misstated (RACTS 20089, 20090, and 20091) but could be inferred from subsequent documentation. In addition, as noted in Section 2.3, the licensee should consider the need to perform audits of the Fermi 2 commitment management process.

D. Cobb There is no need for the licensee to respond to this letter. The NRC staff appreciates the resources that were made available by your staff during the audit. If you have any questions, please have your staff contact me at (301) 415-1439.

Sincerely,

/RA/

David H. Jaffe, Sr. Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Regulatory Commitments Audit Report cc w/encl: See next page

D. Cobb There is no need for the licensee to respond to this letter. The NRC staff appreciates the resources that were made available by your staff during the audit. If you have any questions, please have your staff contact me at (301) 415-1439.

Sincerely,

/RA/

David H. Jaffe, Sr. Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-341

Enclosure:

Regulatory Commitments Audit Report cc w/encl: See next page DISTRIBUTION:

PUBLIC LPLIII-1 R/F RidsNrrPMDJaffe RidsNrrPMKFeintuch RidsNrrLADClarke RidsOgcRp RidsNrrDorlLpl3-1 RidsRgn3MailCenter RidsAcrsAcwnMailCenter RidsNrrDorlDpr ADAMS Accession Number: ML061840302 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/LPL3-1/BC NAME DJaffe KFeintuch DClarke LRaghavan DATE 7/21/06 07/20/06 7/20/06 7/21/06 OFFICIAL RECORD COPY

Fermi 2 cc:

David G. Pettinari Wayne County Emergency Management Legal Department Division 688 WCB 10250 Middlebelt Road Detroit Edison Company Detroit, MI 48242 2000 2nd Avenue Detroit, MI 48226-1279 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Radiological Protection and Medical Waste Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 U.S. Nuclear Regulatory Commission Resident Inspector's Office 6450 N Dixie Highway Newport, MI 48166 Mr. M. V. Yudasz, Jr., Director Monroe County Emergency Management Division 965 South Raisinville Road Monroe, MI 48161 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Ronald W. Gaston Manager, Nuclear Licensing Detroit Edison Company Fermi 2 - 200 TAC 6400 North Dixie Highway Newport, MI 48166 Supervisor - Electric Operators Michigan Public Service Commission 6545 Merchantile Way P.O. Box 30221 Lansing, MI 48909

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY DETROIT EDISON COMPANY TO THE NUCLEAR REGULATORY COMMISSION FERMI 2 DOCKET NO. 50-341

1.0 INTRODUCTION AND BACKGROUND

On September 7, 2004, the U.S. Nuclear Regulatory Commission (NRC) published the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, Managing Regulatory commitments Made by Licensees to the NRC, Revision 1. LIC-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes. The current revision to LIC-105 is publicly available electronically (as Accession No. ML042320463) from the Agencywide Documents Access and Management System (ADAMS) from within the public Electronic Reading Room on the Internet at the NRC web site.

According to LIC-105, which cites the definition from NEI 99-04, a regulatory commitment is an explicit statement to take a specific action agreed to, or volunteered by a licensee, and submitted in writing on the docket to the NRC. LIC-105 further directs the NRR Project Manager to audit the licensees commitment management program by assessing the adequacy of the licensees implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.).

The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS The audit of the Detroit Edison Company (the licensee) commitment management program for Fermi 2 was performed at the Fermi 2 facility, from May 8, 2006 to May 11, 2006. Since no such audit was performed prior to the issuance of LIC-105, the NRC staff defined the scope of audit to obtain a sample of commitments created as a consequence of licensing actions and generic communications, affecting a variety of systems, structures and components, and involving a variety of technical disciplines. The selection of a valid sample for this initial audit covered a period of approximately 15 years prior to the date of the audit.

ENCLOSURE

In accordance with LIC-105, audits consist of two major parts: (1) verification of the licensees implementation of NRC commitments that have been completed, and (2) verification of the licensees program for managing changes to NRC commitments.

2.1 Verification of Licensees Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing actions/activities. For commitments that had not yet been implemented, the NRC staff assessed whether the licensee managed regulatory commitments in an effective program for future implementation.

2.1.1 Audit Scope LIC-105 limits the audit of commitments to those made (or those that should have been made) in writing to the NRC as a result of past licensing actions (amendments, reliefs exemptions, etc.)

or licensing activities (bulletins, generic letters, etc.). Accordingly, the audit excluded the following types of commitments:

• commitments made on the licensees own initiative among internal organizational components

• commitments that pertain to milestones of licensing actions/activities (e.g., response to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

• commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, technical specifications, and updated final safety analysis reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

Prior to the audit, in order to generate a list of items for the audit, the NRC staff performed public, web-based ADAMS searches for commitments. From this list, the NRC staff selected a representative sample of regulatory commitments to audit. The selection of the sample list covered a variety of systems, disciplines and licensing actions important to the NRC staffs decision-making process. This list also included commitment changes. A list of commitments and changes to commitments that were audited is contained in the attached table.

The licensee provided the documentation to support the NRC staffs audit in each of the sample areas discussed above. The licensees documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The attached table summarizes the licensees commitments that were audited by the NRC staff and the current status of the licensees commitments.

2.1.2 Audit Results The licensees commitments are tracked by the RACTS (Regulatory Action and Commitment Tracking System) process, as documented in the licensees procedure MLS10, Revision 11, of the same name. The RACTS process uses a relatively old software technology. The software lacks productivity tools such as spell checking or grammar checking but appears to be able (1) to adequately record activities and (2), because the RACTS identifier (a 5-digit number) is used in other documentation, to provide an adequate method of linking together the specific documents, records and actions affected as a commitment evolves into full completion, partial completion (and the creation of successor RACTS), or on-going closed status. The age of the RACTS platform is a strength in that it provides an institutional memory over time and across successor systems performing similar functions. As an example encountered during the audit, the former document for describing and planning the solution to a problem is the Deviation Event Report (DER), and the current document is the CARD (Condition Assessment Resolution Document). Some regulatory commitments, even those that evolved to a closed condition, spanned the use of both types of documents and associated processes.

The NRC staff, therefore, undertook to ascertain that commitments had not been lost from the system because of multiple processes, aging, and turnover of personnel. During the audit, the NRC staff reviewed documents generated by processes in effect during the scope of the audit, and other documents related to the commitments.

In general, the NRC staff found that the licensees commitment tracking programs had captured the regulatory commitments that were identified by the NRC staff before the audit. However, in one case (RACTS 87238), the licensee lost the documentation of a commitment that was made orally to an NRC inspector. In other cases, the initiation date of the commitment was misstated (RACTS 20089, 20090, and 20091), but could be inferred from subsequent documentation.

The NRC staff also reviewed plant procedures that had been revised as a result of commitments made by the licensee to NRC. The NRC staff noted that some of the new/revised procedures have annotations to refer to commitments. These annotations would serve to prevent future procedure writers from inadvertently deleting or altering an item without having gone through the commitment change process.

The NRC staff noted frequent typographical errors. Most have no technical consequence, except when the identifier for a document referenced in the RACTS narrative is corrupted. Such a failure occurred and consumed time to detect and diagnose the anomaly in the documentation. The licensee promptly corrected the problem when advised.

The incorrect information was changed directly without the use of the corrective action process.

When asked about this approach, the licensee responded that the incident (dating from the late 1980's) was too old to do effective root cause analysis. There is merit to this response and, from a risk-informed approach, the expenditure of resources on this incident may not be justified. However, the need for personal vigilance in error checking is clear, since the DOS-based software platform for RACTS lacks and cannot acquire spell checking capability.

2.2 Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees process for managing commitment changes. The process is documented in procedure MLS10, Revision 11. The analysis and implementation of the proposed changes are documented in Section 6.0 of the procedure and recorded on Forms MLS10002 and MLS10003. Section 6.0 of the procedure specifically refers to NEI 99-04. The forms were compared to similar forms in NEI 99-04, as were MLS10 Revision 11 change process flow charts. The NRC staff verified the consistency of both the forms and flow charts.

A Note in MLS10 Revision 11, Step 6.1.1 discusses the presence of enhancements to facilitate the processing of older commitments.

Use of the change process was observed during the examination of specific RACTS. The change process generally conformed to the guidance in NEI 99-04 and was effective in determining whether another codified change process (such as 10 CFR 50.59, 10 CFR 50.54, or 10 CFR 50.71(e)), or a license amendment process was appropriate.

Therefore, the NRC staff concludes that the procedures and forms used by the licensee to manage commitments and their changes are appropriate and effective.

2.3 Internal Audits of Regulatory Commitment Management MLS10, Revision 11, Step 3.6 contains a statement that RACTS files were not auditable followed by an explanation that the RACTS entries contain the minimum information to determine RACTS status and identify supporting information. The NRC staff interviewed the licensees internal auditing staff to clarify the statement and requested copies of internal audit reports. The internal auditing staff verified that RACTS was not explicitly audited, but would receive auditing attention if it was found to cause the need for corrective action. Based upon the NRC staff review, it appears that the licensees commitment management process has not been audited.

NEI 99-04 emphasizes an outcomes orientation versus a process orientation. The licensees reliance on performance outcome to determine the need for auditing attention to RACTS is consistent with that viewpoint.

For some commitments, RACTS may affect the performance of safety-related equipment.

The Fermi 2 Updated Final Safety Analysis Report, Section 17.2.18.5 Scope and Schedule of Audits, specifically part c, states a need for an internal audit for The results of actions to correct deficiencies in...methods of operation that affect nuclear safety... and may indicate that RACTS performance has a safety-related function and meets the criteria for inclusion in scheduled audits.

As an example, RACTS 87063 was used to process a requalification training related commitment, intended for licensed operators and shift technical advisors, as a corrective measure in Licensee Event Report 87-007. If such commitments are also followed to completion by another audited system (e.g., the corrective action program), then a separate commitment management audit would be unnecessary.

The current MLS10, Revision 11 procedure does not exclude safety-related regulatory commitments from its purpose or scope.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit, (1) the licensee had implemented, and is tracking for future implementation regulatory commitments; and (2) the licensee has implemented an effective program to manage regulatory commitment changes.

The implications of processing safety-related regulatory commitments in a process not subject to internal audit needs further study.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT C. Capps J. Louwers J. Moyers R. Newkirk J. Pendergast Principal Contributors: D. Jaffe K. Feintuch

Audited Fermi-2 Regulatory commitments Subject to Audit RACTS description Identifier for dispositioned RACTS = Regulatory and Commitment Tracking System (the FERMI-2 Auditor's Assessment of the Regulatory commitment Disposition of the RACTS Regulatory system for managing Regulatory commitments) dispostion (adequate, inadequate) commitment DECO = Detroit Edison Company RgCm = abbreviation in table for Regulatory commitment 15-Amd 166-2 For sites possessing both operating and shutdown reactors, licensees should make a regulatory commitment to provide information to the NRC annually (e.g., with its annual submittal in accordance with 10 CFR 5024 20.2206) to support the apportionment of station doses to differentiate between Action carried out No issues - adequate operating and shutdown units. The data will provide the summary distribution of annual whole body doses as presented in Appendix B of NUREG 0713 for each reactor type and for operating and shutdown units.

Licensee Rpt dated 2003-11-10 RACTS NO. 6676 Test Core Spray Pumps two 6676 at a time by Division using more conservative pump performance criteria than Action carried out No issues - adequate the OM-6 Code allows.

Licensee Rpt dated 2003-11-10 RACTS NO. 6696 Pressure Isolation Valve 6696 Action carried out No issues - adequate E11-F009 and E11-F608 will be leal tested together.

Per DCR 96-2834 quoting Detroit Edison will revise the maintenance procedure pertaining to EDG bearing DCR 93-1678 "per gap checks to address occurrence of non-manually-prelubed starts. The Amendment 94, License No.

7650 procedure will require a gap check of upper and lower crankshaft main No issues - adequate NPF-43, This is no longer bearings after every non-manually-prelubed start or 6 months, whichever required". Per DCR 96-2834 occurs first.

RACTS 7650 was deleted.

Licensee Rpt dated 2003-11-10 RACTS NO. 7724 EDG procedure enhanced to 7724 include steps and cautions to make necessary adjustments for EDG output Action carried out No issues - adequate voltage and frequency within thirty seconds of resetting exciter.

04-Amd 152-1 A Future updates to vessel fluence calculations will be 20087 performed in accordance with an approved methodology consistent with the Action carried out No issues - adequate requirements of NRC Regulatory Guide 1.190.

05-Amd 152-2 A Detroit Edison will update neutron fluence calculations for the 20087 Fermi 2 RPV utilizing NRC-approved methodologies consistent with the Action carried out No issues - adequate guidance in RG 1.190 by December 31, 2005.

03-Amd 150-4.3 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and RACTS line 7 should have been 5/23/2002 corresponding to 20089 maintain), an I-131 site survey detection capability, including an ability to Action carried out licensee letter NRC-02-0025 which provides the source of the assess radioactive iodines released to offsite environs, by using effluent commitments, not 9/16/02.

monitoring systems or portable sampling equipment.

02-Amd 150-4.2 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and RACTS line 7 should have been 5/23/2002 corresponding to maintain), a capability for classifying fuel damage events at the Alert level 20090 Action carried out licensee letter NRC-02-0025 which provides the source of the threshold (typically this is 300 µCi/ml dose equivalent iodine). This capability commitments, not 9/16/02.

may utilize the normal sampling system and/or correlations of radiation readings to radioisotope concentrations in the reactor coolant.

01-Amd 150-4.1 Each licensee should verify that it has, and make a regulatory RACTS line 7 should have been 5/23/2002 corresponding to commitment to maintain (or make a regulatory commitment to develop and 20091 Action carried out licensee letter NRC-02-0025 which provides the source of the maintain), contingency plans for obtaining and analyzing highly radioactive commitments, not 9/16/02.

samples of reactor coolant, suppression pool, and containment atmosphere.

RACTS description Identifier for dispositioned RACTS = Regulatory and Commitment Tracking System (the FERMI-2 Auditor's Assessment of the Regulatory commitment Disposition of the RACTS Regulatory system for managing Regulatory commitments) dispostion (adequate, inadequate) commitment DECO = Detroit Edison Company RgCm = abbreviation in table for Regulatory commitment 06-DE Ltr-1 Detroit Edison will provide all the requested information in GL 2003-01, with the exception of information related to confirming that the most limiting unfiltered in leakage into the CRE is no more than the value assumed in 20154 the design basis radiological analyses for CRH, within 180 days of the date of Action carried out No issues - adequate the GL. Information confirming CRE unfiltered inleakage will be provided within 90 days from the date of performing a base line integrated CRE inleakage test of the Fermi 2 control room but no later than December 9, 2004.

07-Amd 159-4.1 Each licensee should verify that it has, and make a regulatory 20159 commitment to maintain, a hydrogen monitoring system capable of diagnosing Action carried out No issues - adequate beyond design-basis accidents.

08-Amd 159-4.2 For plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an 20160 Action carried out No issues - adequate oxygen monitoring system capable of verifying the status of the inert containment. (for applicable plants) 13-Amd 164-1 The licensee provided a commitment that should Fermi 2 channels show conclusive evidence that the control blade shadow corrosion-induced channel bow is occurring at a level that would cause the approved 20172 Action carried out No issues - adequate R-factor uncertainty to be exceeded, Detroit Edison Company would submit a license amendment for Fermi 2. The NRC staff finds this commitment acceptable.

16-Amd 167-1 Detroit Edison will incorporate the revised acceptance criterion 20203 value of 7.5 percent into the TS Bases for Fermi 2 in accordance with the Action carried out No issues - adequate Bases Control Program described in TS 5.5.10.

Licensee Rpt dated 2005-05-31 RACTS NO. 87063: RPS actuation on level 3 RACTS line 7 (Cm date not correct - given as 3/17/87. Should be 87063 Action carried out indication when El IF009 SID Cooling Inboard Isolation Valve is opened. 4/15/87. Subject was LER 87-007.)

Licensee Rpt dated 2005-05-31 RACTS NO. 87238 Revise the hydrogen Not auditable - It was an oral Cm and NRC contact forms were lost 87238 recombiner surveillance test procedure to include visual identification of no Action carried out per information provided to auditors during site audit.

debris on the filters, etc Licensee Rpt dated 2005-05-31 RACTS NO. 89025 Concern with EDG breaker 89025 Action carried out No issues - adequate logic. Procedures were revised to record the output breaker closure time.

RACTS line 7 (Could not identify source document. The date shown Licensee Rpt dated 2005-05-31 RACTS NO. 89098 Unresolved Item 88-037-89098 Action carried out 1/31/1989 is that of the NRC documentation, not the licensees 09: RCIC valves not tested to verify UFSAR commitments.

commitment.)

Licensee initially planned to modify SGP-SRI-01. RACTs narrative indicated that Licensee's methodology for changing MLS13 was both effective licensee replanned to fulfill the and, through the use of the nearby explanatory box, robust. The RgCm by modifying MLS13.

information in the box alerts future authors to the presence of text MLS13 was examined during Licensee Rpt dated 2005-05-31 RACTS NO. 89153 Conduct of ISEG not in affected by a RgCm with background information needed for its 89153 the RgCm Audit and the accordance with Tech Spec. 6.2.3 preservation.

changes were made. Further, See 89153 on Tab 3-Audit Notesheets for problems with RACTS licensee's format provided an recordkeeping and their resolution by the Licensee.

explanatory box near the text which attributed the text to the relevant RgCm number and associated DER, which

RACTS description Identifier for dispositioned RACTS = Regulatory and Commitment Tracking System (the FERMI-2 Auditor's Assessment of the Regulatory commitment Disposition of the RACTS Regulatory system for managing Regulatory commitments) dispostion (adequate, inadequate) commitment DECO = Detroit Edison Company RgCm = abbreviation in table for Regulatory commitment defines the planned approach to addressing the RgCm.

Licensee provided a chain of Licensee Rpt dated 2003-11-10 RACTS NO. 89576 Add RHRSW Hx discharge evidence from RACTS Licensee made oral commitment that was not documented by 89576 check valves to IST pump and valve test program. identifier to DER identifier. docketed correspondence.

Pendergast provided copy of Licensee appears to have carried out the stated commitment.

MES20006, Rev. 0., as Further, RACTS explanation box appears to have been updated to requested. MES200006 is the Licensee Rpt dated 2005-05-31 RACTS NO. 93196 To improve the process by show modifications to the commitment that permit joint walkdowns Turnover Checklist referred to 93196 which design changes are incorporated in programs and procedures, a (see reference to NRC 94-0065) in areas of high radiation, heat or in MES20, Rev 14, Page 8, comprehensive turnover checklist will be developed. other significant hazards. Additional modifications (per MLS10)

Section 3.7 and the RACTS allow items to be marked NA if invisible to verifier and requirements explanation box directly before are satisfied by other retrievable information.

Section 3.7.

The Actions taken to respond to NRC Bulletin 95-02 included entry of inspections into the PM Program, modification of the frequency of inspections while within the PM Program, and responses when foreign material was found during inspections. Each of these events and actions caused additional documentation to be created.

Licensee records indicated Referral within the RACTS narrative to other documents became that RACTS 95152 was extensive. Upon review of a sample of the content, the RACTS implemented at its original narrative and the descriptions and actions discussed in the Take actions as a consequence to NRC Bulletin 95-02, which pertained to frequency, and the frequency additional documentation were consistent. The auditor concludes unexpected clogging of a RHR pump strainer while operating in Suppression was modified upon further 95152 that RACTS and its data entry personnel are adequate to manage Pool cooling mode. Actions included inspections during refueling outages. analysis (CARD 01-14733).

RgCm with extensive record keeping needs.

Successor RACTS and CARD actions defined frequency to alternate refuelings. RACTS narrative accurately described the DeCo response The extensive quantity of secondary documentation made walking to finding foreign material in an audit trail difficult. The licensee has been requested to provide the strainers (DER 96-1399).

more direct evidence of RACTS completion (i.e., recent evidence that the inspection is currently continuing to be done at the current committed frequency, including evidence of the response to finding foreign material, if any such material has been found during the past 3 inspections.

09-Amd 160-1. The SLC System Operating Procedure will be revised to 20125 describe the new system function of controlling suppression pool pH post- Action carried out No issues - adequate and 20167 LOCA.

10-Amd 160-2. The Alarm Response Procedure for the Containment High Area 20125 Radiation Monitor will be revised to direct operators to initiate SLC when high Action carried out No issues - adequate and 20167 radiation levels and LOCA symptoms are detected in the primary containment.

11-Amd 160-3. The plant Emergency Operating Procedures will be revised to 20125 clearly direct operators to maintain SLC injection when it is required for Action carried out No issues - adequate and 20167 suppression pool water pH control.

20125 12-Amd 160-4. Operator training will be updated to reflect the pH control Action carried out No issues - adequate and 20167 function of the SLC system.

14-Amd 166-1 Each licensee should make a regulatory commitment to provide to the NRC using an industry database the operating data (for each calender 5024 month) that is described in GL 97-02, by the last day of the month following the Action carried out No issues - adequate and 95170 end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industrys CDE program, currently being

RACTS description Identifier for dispositioned RACTS = Regulatory and Commitment Tracking System (the FERMI-2 Auditor's Assessment of the Regulatory commitment Disposition of the RACTS Regulatory system for managing Regulatory commitments) dispostion (adequate, inadequate) commitment DECO = Detroit Edison Company RgCm = abbreviation in table for Regulatory commitment developed and maintained by INPO).

Part 1 of RACTS 20209 Description 01-Amd 171-A. If any future submittals affect these license pages, Detroit Edison will coordinate the changes to the pages with the NRC Project Manager to ensure proper page control when the associated license amendment Licensee supplied the requests are approved. following evidence. The items 02-Amd 171-B The following equipment protections will be in effect until EDG are listed in chronological 12 is restored to an Operable status: order.

03-Amd 171-B.1.Elective maintenance will not be performed on EDGs 11, 13, and 14 or CTG 11 1 1-Plan of the Day (POD) 04-Amd 171-B.2.Elective maintenance will not be scheduled within the 120 kV 060203 (02/03/2006) Licensee supplied the following evidence. The items are listed in and 345 kV switch yards that would challenge the offsite power connections or discussed restricting access to chronological order.

20209 offsite power unavailability. EDG 13, 14 during EDG 12 05-Amd 171-B.3.Elective maintenance will not be performed on the opposite outage. 1-Plan of the Day (POD) 060203 (02/03/2006) discussed restricting train Emergency Core Cooling System (ECCS) equipment. access to EDG 13, 14 during EDG 12 outage.

06-Amd 171-B.4.Elective maintenance will not be performed on equipment in 2-Night Order and Operations the Standby Feedwater (SBFW) System. Log for 02/05/2006 cited 2-Night Order and Operations Log for 02/05/2006 cited 07-Amd 171-C. While in the extended EDG 12 completion time period, overall NRC-06-0010 (the requesting NRC-06-0010 (the requesting document for the amendment) and 20209 (Part 1 plant risk will be managed by the existing Maintenance Rule (a)(4) program. document for the amendment) Amendment 171 as reasons for restrictions on access and contd. from This program evaluates increases in risk posed by potential combinations of and Amendment 171 as operations or EDG 13, 14 and CTG 11-1 (et al).

previous page) equipment out-of-service and potential increases in initiating event frequency reasons for restrictions on and requires that risk recommendations be implemented as appropriate for a access and operations or EDG 3-POD 060206 had references similar to POD 060203.

given plant configuration. 13, 14 and CTG 11-1 (et al).

08-Amd 171-D. Maintenance and testing during the allowed outage time 4-POD 060207 discussed the completion of the EDG 12 outage.

extension will be rescheduled for Fermi 2 as warranted to minimize aggregate 3-POD 060206 had references risk. This will specifically include: similar to POD 060203.

09-Amd 171-D 1.Work performed on safety significant systems and their applicable support systems will be reviewed and rescheduled as necessary 4-POD 060207 discussed the based upon routine and emergent Maintenance Rule 10CFR65 (a)(4) completion of the EDG 12 evaluations. outage.

10-Amd 171-D 2.No work will be performed that could potentially jeopardize the availability of the remaining on site emergency power sources. This will be ensured by restricting and/or controlling access to this equipment via guidance provided in MOP05 (the site procedure for control of equipment).

Part 2 - Continuation from line 10, Amd 171-D 2 11-Amd 171-E The following actions will be taken to provide an increased assurance of grid stability:

12-Amd 171-E 1.No test or maintenance activities that could reduce switch yard reliability will be performed.

13-Amd 171-E 2.At four hour intervals, the projected grid voltage following See comments in RACTS 20209 postulated unit trip will be verified to indicate a stable grid. Assuring the grid See comments in other RACTS 20209 Part 1 20209 Part 1 conditions are expected to remain stable serves to reduce the grid as an initiator for loss of offsite power to the units.

14-Amd 171-E 3.Fermi 2 will contact the system dispatcher to ensure that no short-term activities adversely affecting grid stability are planned or have transpired.

15-Amd 171-E 5.Fermi 2 will confirm that the system dispatcher will notify the control room or Shift Manager in the event of severe weather, system

RACTS description Identifier for dispositioned RACTS = Regulatory and Commitment Tracking System (the FERMI-2 Auditor's Assessment of the Regulatory commitment Disposition of the RACTS Regulatory system for managing Regulatory commitments) dispostion (adequate, inadequate) commitment DECO = Detroit Edison Company RgCm = abbreviation in table for Regulatory commitment degradation, or perturbations do occur so that an appropriate plant response can be determined.

16-Amd 171-F Operations Briefings will be conducted on the use of CTG 11-1 and the utilization of CTG 11-2, CTG 11-3, or CTG 11-4 in conjunction with the auxiliary blackstart diesel to mitigate the consequences of a station blackout or loss of off-site power. These briefings will include review of the associated procedures.