ML12150A096
| ML12150A096 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/18/2012 |
| From: | Mahesh Chawla Plant Licensing Branch III |
| To: | Jennifer Davis Detroit Edison, Co |
| References | |
| TAC ME6432, BL-11-001 | |
| Download: ML12150A096 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 18, 2012 Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166
SUBJECT:
FERMI, UNIT 2 - CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NO. ME6432)
Dear Mr. Davis:
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of NRC Bulletin 2011-01 (the bulletin) was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).
The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f).
Detroit Edison provided its responses to the bulletin by letters dated June 10 and July 5, 2011 (ADAMS Accession Nos. ML111610515 and ML111870102). By letter dated November 23, 2011 (ADAMS Accession No. ML113202098), the NRC sent the licensee a request for additional information (RAI) on its July 5, 2011, response.
The licensee responded to the RAI by letter dated December 20,2011 (ADAMS Accession No. ML113550144). The NRC staff has reviewed the information submitted by Detroit Edison and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, NRC staff verified that the licensee provided the information requested in the bulletin. No further information or action is required by the licensee for Bulletin 2011-01 for Fermi 2.
J. M. Davis - 2 If you have any questions regarding this letter, please feel free to contact me at (301) 415-8371 or mahesh.chawla@nrc.gov.
Sincerely, fkJ2~
Mahesh Chawla, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-343
Enclosure:
Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv
SUMMARY
OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW FERMI 2 DOCKET NO, 50-341 1,0 INTRODUCTION On May 11, 2011, the U.S, Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. Bulletin 2011-01 (the bulletin) required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.54(f). The first response was due 30 days after issuance of the bulletin, By letter dated June 10, 2011 (ADAMS Accession No. ML111610515), Detroit Edison provided its response to this first set of questions (first response), The second response was due 60 days after issuance of the bulletin. By letter dated July 5, 2011 (ADAMS Accession No. ML111870102), Detroit Edison provided its response to the second set of questions (second response). By letter dated November 23, 2011 (ADAMS Accession No. ML113202098), the NRC sent a request for additional information (RAI) on the second response. Detroit Edison responded to the RAI by letter dated December 20,2011 (ADAMS Accession No. ML113550144). As summarized below. the NRC staff has verified that Detroit Edison provided the information requested in the bulletin.
2.0 BACKGROUND
On February 25. 2002. the NRC issued EA-02-026. "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). Section B.5.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire.
By letter dated August 23,2007 (ADAMS Accession No, ML072320006). the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by the licensee regarding Section B.5,b of the ICM Order, Along with the SE. the staff issued a conforming license condition to incorporate the B.5.b mitigating strategies into the licensing basis.
On March 27. 2009. the NRC issued 10 CFR 50.54(hh)(2) as a new rule (74 FR 13926), in order to capture the B.5.b mitigating strategies and related license conditions as regulatory requirements for both current and future licensees. At that time, licensee compliance with the conforming license conditions was sufficient to demonstrate compliance with 10 CFR 50.54(hh)(2), so no further actions were required on the part of current licensees.
Enclosure
-2 3.0 30-DAY REQUEST In order to confirm continued compliance with 10 CFR SO.S4(hh)(2), the bulletin requested that licensees address the following two questions within 30 days of issuing the bulletin:
- 1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function?
- 2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff?
The NRC staff reviewed the licensee's first response to determine if it had adequately addressed these questions.
3.1 Question 1: Availability and Capability of Equipment In its first response, the licensee confirmed that the equipment it needs to execute the 10 CFR SO.S4(hh)(2) mitigating strategies is available and capable of performing its intended function. The NRC staff verified that this confirmation covered equipment needed for each of the three phases of B.S.b mitigation strategies. Therefore, the NRC staff finds that the licensee has adequately responded to Question 1.
3.2 Question 2: Guidance and Strategies Can Be Executed In its first response, the licensee confirmed that the guidance and strategies it has implemented for 10 CFR SO.S4(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staff skills. Since Fermi has considered its current facility configuration, staffing levels, and staff skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that the licensee has adequately responded to Question 2.
4.0 50-DAY REQUEST The bulletin required a response to the following five questions within 50 days of issuing the bulletin:
- 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed.
- 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it will function when needed.
- 3. Describe in detail the controls for ensuring that the equipment is available when needed.
- 4. Describe in detail how configuration and guidance management is ensured so that strategies remain feasible.
S. Describe in detail how you ensure availability of offsite support.
- 3 The NRC staff reviewed the licensee's submittals to determine jf it had adequately addressed these questions. The NRC staff also reviewed the August 23,2007, SE to determine what equipment, training, and offsite resources at Fermi were relied upon by NRC staff to conclude that the licensee's actions would ensure compliance with Section B.S.b of the ICM Order and the conforming license condition.
4.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. In its second response, the licensee listed the equipment used to support the 10 CFR SO.S4{hh)(2) mitigating strategies which receives maintenance or testing. For each item, the licensee described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that the licensee listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that the fire truck, portable power supply, hoses, spray nozzles, and communications equipment receive maintenance or testing. The licensee described in its RAI response how it ensures that sufficient fuel is available for the fire truck. The licensee also identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that the licensee described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. The licensee stated in its second response that its 10 CFR Part SO, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending.
Based upon the information above, the NRC staff concludes that the licensee has provided the information requested by Questions 1 and 2.
4.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment, such as inventory requirements, to ensure that the equipment is available when needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested.
The NRC staff verified that the licensee described its process for ensuring that B.S.b equipment will be available when needed. In its second response, the licensee identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified.
Items verified include proper quantity, location, and accessibility of equipment. The licensee states that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable.
The NRC staff verified that the licensee inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second
-4 response, the licensee stated that procured non-permanently installed B.5.b equipment is inventoried in accordance with station procedures. The second response specifically states that the following items are included in the inventory: fire truck and pump; portable power supply; hoses; communications equipment; spray nozzles; connectors; tools; instruments; and firefighter turnout gear. The NRC staff noted that all items listed were inventoried at least quarterly. The licensee also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 3.
4.3 Question 4: Configuration and Guidance Management Question 4 of the 60-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible.
The NRC staff verified that the licensee described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current.
In its second response, the licensee stated that the plant configuration control process requires a review of affected procedures, including the B.5.b mitigating strategies, following issuance of new or revised engineering documents. Fermi states that "any plant configuration changes will be reviewed for their effect on feasibility of the mitigating strategies," and that procedure changes are validated to ensure that the B.5.b mitigating strategies remain viable.
The NRC staff verified that the licensee described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, the licensee identified testing in response to Questions 2 and 4 that demonstrated the ability to execute some strategies. The licensee also states that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews."
The NRC staff verified that the licensee described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, the licensee identified the training provided to its operations personnel, emergency response organization key decision makers, security personnel, and fire brigade. The licensee also identified the frequency with which each type of training is provided and the methods for training evaluating.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 4.
4.4 Question 5: Offsite Support Question 5 of the 60-day request required licensees to describe in detail how offsite support availability is assured.
The NRC staff verified that the licensee listed the offsite organizations it relies upon for emergency response, including a description of agreements and related training. The NRC staff compared the list of offsite organizations that the licensee provided in its second response with
-5 the information relied upon to make conclusions in the SE. The NRC staff noted that the second response (RAI) did not identify any local law enforcement agencies that the licensee relies upon to respond to a B.5.b event. In its RAI response, the licensee provided information on its agreements with local law enforcement agencies. The NRC staff also noted that the second response (RAI) did not include two standing purchase orders for debris removal and other heavy equipment which had been relied upon in the SE. In its RAI response, the licensee provided information about these two purchase orders and also stated that it is a member of the Northwest Ohio and Michigan Mutual Aid District which can provide some similar capabilities.
The licensee's RAI response also corrected the information it previously provided about the training and familiarization it provides to the Frenchtown Fire Department. The licensee stated that it maintains letters of agreement, membership, or standing purchase orders with the offsite organizations listed in its responses, which are reviewed annually, and that these agreements were current at the time of its second response. The licensee also described the training and site familiarization it provides to these offsite organizations. The licensee stated that it reviewed its corrective action program back to 2008 and found no issues involving lapsed agreements related to offsite support for B.5.b events.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 5.
5.0 CONCLUSION
As described above, the NRC staff has verified that the licensee has provided the information requested in Bulletin 2011-01. Specifically, the licensee responded to each of the questions in the bulletin as requested. The NRC staff concludes that the licensee has completed all of the requirements of the bulletin and no further information or actions under the bulletin are needed.
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