ML103050328

Response to RAIs Regarding Fermi 2 Exemption Request for Biennial Emergency Preparedness Exercise - Dated 10/22/10 - ME4459

ML103050328
Person / Time
Site:	Fermi
Issue date:	10/29/2010
From:	Mahesh Chawla Plant Licensing Branch III
To:	Hassoun A Detroit Edison
Chawla M, NRR/DORL, 415-8371
References
TAC ME4459
Download: ML103050328 (3)

Text

From: Chawla, Mahesh Sent: Friday, October 29, 2010 11:59 AM To: Alan I Hassoun Cc: Norris, Michael; Anderson, Joseph

Subject:

Response to RAIs regarding Fermi 2 Exemption Request for Biennial Emergency Preparedness Excercise - Dated 10/22/10 - ME4459

Sam, You provided the above response to address the staff RAIs. After the review, the NRC staff has provided the following comments. Please arrange a teleconference so we can discuss these comments with your representatives. I am going to be out of the office on Nov. 1 and 2. We can do it after that in the middle of the week. Thanks NRC STAFF COMMENTS:

10 CFR 50 App. E IV.F.2.b states in part, the licensee shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills Regulatory Issue Summary (RIS) 2006-03, states:

A licensee request for an exemption should include a list of all drills, exercises, and other training activities conducted since the previous biennial exercise and all drills, exercises, and other training activities scheduled before the next biennial exercise. The list helps establish a basis for assurance that the licensee has regularly exercised its emergency response strategies and personnel in coordination with offsite authorities, that postponing the biennial exercise will not pose an undue risk to public health and safety, and that a good faith effort has been made to satisfy the underlying purpose of the rule. [bold/italics added]

In our review of the exemption request and subsequent RAI responses, we have noted discrepancies in the information provided regarding drills conducted since the last biennial emergency preparedness exercise. The following is a summary of those discrepancies:

1. In the original exemption request, NRC-10-0061 (ADAMS No. ML102230442), the licensee states in the enclosure, Basis for the Exemption Section (#2) that Eighteen (18) drills have been conducted since the last biennial evaluated exercise.

2. In NRC-10-0061, Attachment 2, under the drills section, the licensee states, 13 drills were conducted since the last biennial evaluated exercise and were performed on the following dates. Following this line stating that 13 drills were conducted are 18 dates.

3. The final date listed in the drills section of Attachment 2 to NRC-10-0061 is 06/09/2010. This date is three days after the tornado of June 6, 2010, one day after the

scheduled (and subsequently canceled) biennial evaluated emergency preparedness exercise, and one day after the conduct of the limited scope biennial exercise with full offsite participation.

4. The licensees RAI response, NRC-10-0074 (ADAMS No. ML102950490) states that its Enclosure 2 provides drill critique summaries for drills conducted since the last biennial exercise. Enclosure 2 to NRC-10-0074 includes 8 Drill/Exercise Critique Summaries vice the 18 referenced in NRC-10-0061 or the 13 referenced in Attachment 2 to NRC 0061.

5. The dates of the Drill/Exercise Critique Summaries provided in Enclosure 2 to NRC-10-0074 correspond to 7 of the 18 dates provided in Attachment 2 to NRC-10-0061. The 12/09/2009 date of the Drill/Exercise Critique Summary provided in Enclosure 2 to NRC-10-0074 is not listed in Attachment 2 to NRC-10-0061.

These discrepancies need to be resolved and an accurate accounting of drills conducted since the last biennial emergency preparedness exercise needs to be reviewed in order to properly evaluate whether the licensee has, per 10 CFR 50 App. E IV.F.2.b, taken actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills and whether, based in part upon the drills conducted, postponing the 2010 biennial exercise would increase risk to public health and safety. Please provide an accurate and complete listing of drills conducted since the last evaluated biennial exercise and associated drill critique summaries for the staffs review to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises.

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Subject:

Response to RAIs regarding Fermi 2 Exemption Request for Biennial Emergency Preparedness Excercise - Dated 10/22/10 - ME4459 Sent Date: 10/29/2010 11:48:54 AM Received Date: 10/29/2010 11:59:00 AM From: Chawla, Mahesh Created By: Mahesh.Chawla@nrc.gov Recipients:

hassouna@dteenergy.com (Alan I Hassoun)

Tracking Status: None Michael.Norris@nrc.gov (Norris, Michael)

Tracking Status: None Joseph.Anderson@nrc.gov (Anderson, Joseph)

Tracking Status: None

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Files Size Date & Time MESSAGE 13418 10/29/2010 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received: