NRC-13-0044, DTE Electric Company'S First Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

DTE Electric Company'S First Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML13239A121
Person / Time
Site:	Fermi
Issue date:	08/26/2013
From:	Conner J DTE Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, NRC-13-0044
Download: ML13239A121 (7)

Text

J. Todd Comier Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MId48166 Tel: 734.5864849 Fax: 734.586.5295 Email: coanerj@dteenergy.con PTE Energy-10 CFR 2.202 August 26, 2013 NRC-13-0044 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

References:

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

2) NRC Order EA-12-049, "Order to Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

3) NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events," Revision 0, dated August 29, 2012

4) NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," Revision 0, dated August 2012

5) DTE Electric Company letter, NRC-12-0061, "Detroit Edison's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 19, 2012

6) DTE Electric Company letter, NRC-13-0009, "DTE Electric Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013

USNRC NRC-13-0044 Page 2

Subject:

DTE Electric Company's First Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 2) to DTE Electric Company (DTE). Reference 2 was immediately effective and directed DTE to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-bases external event. Specific requirements are provided in Attachment 2 of Reference 2.

Reference 2 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 3) and an overall integrated plan pursuant to Section IV, Condition C. Reference 3 endorses industry guidance document NEI 12-06, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference 3.

Reference 5 provided the DTE initial status report regarding mitigation strategies.

Reference 6 provided the DTE overall integrated plan.

Reference 2 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 4 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 2, that delineates progress made in implementing the requirements of Reference 2. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

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

Kirk R. Snyder, Manager, Industry Interface at (734) 586-5020.

S' ce ,

cc: Director, Office of Nuclear Reactor Re atio NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-13-0044 Page 3 I, Kent C. Scott, 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.

Ken . c tt Dire , N clear Production Nuclear eration On this 2 6th day of August, 2013 before me personally appeared Kent C. Scott, being first duly sworn and says that he executed the foregoing as his free act and deed.

Notary Public SHARON S,MARSHALL NOTARY PUBUC, STATE OF MI COUNTY OF MONROE MY COMMISSION EXPIRES Jun 14, 2019 ACTING INCOUNTY OF

Enclosure to NRC-13-0044 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Company's First Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Enclosure to NRC-13-0044 Page 1 DTE Electric Company's First Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (Reference 1 in Section 8),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments None Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date.

The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Revised Target Milestone Completion Stats CoTarget Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started FLEX Strategy Evaluation

Enclosure to NRC-13-0044 Page 2 Revised Target Activity Target Milestone Completion Status Completion Date Date Walk through or Demonstrations Aug 2016 Not Started Perform Staffing Analysis Jul 2015 Not Started Modifications:

Design Engineering Apr 2014 In-progress Dec 2014 Implementation Outage Nov 2015 Not Started Storage Storage Design Engineering Apr 2014 In-progress Dec 2014 Storage Implementation Nov 2015 Not Started FLEX Equipment Procure On-Site Equipment Aug 2014 In-progress Develop Strategies with RRC Oct 2013 In- progress Nov 2014 Procure Staging Location Dec 2013 In-progress Procedures:

Create Procedures Dec 2014 Not Started Training:

Develop Training Plan Jul 2015 Not Started Training Complete Nov 2015 Not Started FLEX Implementation Nov 2015 Not Started Submit Completion Report Jan 2016 Not Started Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

Need for Relief/Relaxation and Basis for the Relief/Relaxation DTE expects to comply with the order implementation date and no relief/relaxation is required at this time.

Enclosure to NRC-13-0044 Page 3 Open Items from Overall Integrated Plan and Draft Safety Evaluation None Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

References The following references support the updates to the Overall Integrated Plan described in this enclosure:

1. DTE Electric's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," NRC-13-0009, dated February 28, 2013.

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.