NRC-11-0057, Response to Request for Additional Information Regarding the 60-Day Response to Bulletin 2011-1, Mitigating Strategies

Response to Request for Additional Information Regarding the 60-Day Response to Bulletin 2011-1, Mitigating Strategies

ML113550144
Person / Time
Site:	Fermi
Issue date:	12/20/2011
From:	Plona J DTE Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NRC-11-0057, BL-11-001
Download: ML113550144 (8)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586,4172 10 CFR 50.54(f)

December 20, 2011 NRC-11-0057 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

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

2) NRC Bulletin 2011-01, "Mitigating Strategies,"

dated May 11, 2011

3) Detroit Edison's Letter to NRC, "Fermi 2 60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies," NRC-11-035, dated July 5, 2011

4) NRC Letter to Detroit Edison, "Fermi, Unit 2 - Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" (TAC No. ME6432),"

dated November 23, 2011

Subject:

Response to Request for Additional Information Regarding the Fermi 2 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" The Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01 (Reference 2), to request each licensee to provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.54(hh)(2). Addressees were required to provide a written response to the NRC in accordance with 10 CFR 50.54(f).

In Bulletin 2011-01, the NRC requested each licensee to submit a written response to the Bulletin. The 60-day response for Fermi 2 was provided in Reference 3. The NRC requested additional information in Reference 4.

USNRC NRC-11-0057 Page 2 The attachment to this letter provides the 30-day response to the NRC request for additional information regarding the Fermi 2 60-Day Response to Bulletin 2011-01, "Mitigating Strategies," dated November 23, 2011 (Reference 4).

There are no new commitments included in this document.

Should you have any questions or require additional information, please contact Mr.

Rodney W. Johnson, Manager - Nuclear Licensing at (734) 586-5076.

Sincerely,

Enclosure:

Response to Request for Additional Information Regarding the Fermi 2 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-11-0057 Page 3 I, Joseph H. Plona, 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.

Jose H. Plona Site Vice President, Nuclear Generation On this C J day of OrCn11r , 2011 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.

MGBARCRONE JYPUBUC -STATE OF MICHIAN 0OUNTY OF MONROE My commisn Expires Aprilt4, 2013 Notar .ublic

Enclosure to NRC-11-0057 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 Response to Request for Additional Information Regarding the Fermi 2 60-Day Response to Bulletin 2011-01, "Mitigating Strategies"

Enclosure to NRC-11-0057 Page 1 Response to Request for Additional Information Regarding the Fermi 2 60-Day Response to Bulletin 2011-01, "Mitigating Strategies" RAI 1: Fuel

1. Describe in detail how you ensure there is sufficient fuel for the pumping source when needed.

The bulletin requested that each licensee describe in detail the maintenance of equipment supporting the mitigating strategies to ensure that it will be functional when needed. The NRC staff could not determine if you performed activities to ensure that sufficient fuel would be available for the pumping source so that it will be functional when needed.

RAI 1 Response:

A fuel management procedure describes steps for refueling pumping equipment for emergency purposes. The fuel management procedure lists diesel fuel sources including the on-site fueling pump station, contract fuel trucks, the on-site Combustion Turbine Generator (CTG) diesel fuel tank, the Emergency Diesel Generator (EDG) fuel tanks, and automobile fuel tanks. The amount of fuel maintained in the CTG fuel tank is normally greater than 400,000 gallons. The four EDG fuel tanks contain more than 140,000 gallons. A hand pump is also available to transfer fuel, if necessary.

The diesel fire truck procured to support the mitigating strategies runs for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> on its 50 gallon tank.

The following provides an update to the "Hand Pump" entry in the table provided in response to NRC Question 1 of the 60-day response to NRC Bulletin 2011-01: Mitigating Strategies (Reference 3):

Equipment Maintenance Periodicity Basis Corrective Action As needed The hand pump is tested Fuel Transfer Program as deficiencies based on annually Hand Pump are identified during test results testing or use

Enclosure to NRC-l1-0057 Page 2 RAI 2: Local Law Enforcement

2. Describe in detail how you ensure the availability of local law enforcement agencies relied upon for emergency response to a B.5.b event.

The bulletin requested that each licensee describe in detail how it ensures the availability of offsite support, including a listing of offsite organizations relied upon for emergency response. Typically, local law enforcement agencies are relied upon for emergency response to a B.5.b event. In response to Question 5 of the bulletin, you did not identify any local law enforcement agencies as being relied upon to respond to a B.5.b event.

RAI 2 Response:

The local law enforcement agencies relied upon for emergency response are listed in the table below. Current agreements are in place for all required support with each of the listed agencies.

Training and agreement validation are performed as listed below.

The following amends the table provided in response to NRC Question 5 of the 60-day response to NRC Bulletin 2011-01: Mitigating Strategies (Reference 3):

Off-site Organization Implementing Validation Training/Familiarization Document and Refresher /Periodicity Periodicity Monroe County Sheriff Hostile Action Reviewed Plant tours and briefings are Memorandum of annually provided for familiarization Understanding biennially (two years).

Michigan State Police Hostile Action Reviewed Plant tours and briefings are Memorandum of annually provided for familiarization Understanding biennially (two years).

Federal Bureau of Hostile Action Reviewed Plant tours and briefings are Investigation Memorandum of annually provided for familiarization Understanding biennially (two years).

Enclosure to NRC-11-0057 Page 3 RAI 3: Heavy Equipment

3. Describe in detail how you ensure the availability of debris removal and other heavy equipment provided by offsite support to respond to a B.5.b event.

The bulletin requested that each licensee describe in detail how it ensures the availability of offsite support, including a listing of offsite organizations relied upon for emergency response. The NRC Safety Evaluation documenting the NRC review of your response to Section B.5.b of the Interim Compensatory Measures Order (EA-02-026) relied upon a statement that you had standing purchase orders with Laramie Crane and NES Equipment to provide debris removal and other heavy equipment. These offsite organizations were not listed in your response to Question 5 of the bulletin.

RAI 3 Response:

Fermi 2 is a member of the Northwest Ohio and Michigan Mutual Aid District (NOMMAD).

Significant fire fighting and damage control resources are available through NOMMAD.

Specialized capabilities are primarily related to fire fighting and spill control, but some debris removal and heavy lift capability exists. A contact list for NOMMAD and for other resources beyond the mutual aid agreements with the Frenchtown Fire Department is maintained in Fermi 2 procedures. NOMMAD is a resource listed in the 60-Day Response to NRC Bulletin 2011-01:

Mitigating Strategies.

The following provides an update to the table provided in response to NRC Question 5 of the 60-day response to NRC Bulletin 2011-01: Mitigating Strategies (Reference 3):

Off-site Organization Implementing Validation Training/Familiarization Document and Refresher /Periodicity Periodicity Laramie Crane Standing purchase None None order NES Equipment Standing purchase None None order

Enclosure to NRC-11-0057 Page 4 RAI 4: Training and Site Familiarization

4. Clarify what training and site familiarization you provide for the Frenchtown Fire Department.

Your response states that the Frenchtown Fire Department receives annual training for "hospital and ambulance personnel." This may by a typographic error since typically firefighters receive training and familiarization.

RAI 4 Response:

The following provides an update to the first entry in the table provided in response to NRC Question 5 of the 60-day response to NRC Bulletin 2011-01: Mitigating Strategies (Reference 3):

Off-site Organization Implementing Validation Training/Familiarization Document and Refresher /Periodicity Periodicity Frenchtown Fire Dept. Letter of Open ended Annual training and Agreement agreement familiarization for firefighters