NRC-14-0075, First Six Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

First Six Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)

ML14352A174
Person / Time
Site:	Fermi
Issue date:	12/18/2014
From:	Kaminskas V DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NRC-14-0075
Download: ML14352A174 (7)

Text

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, M1 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy-December 18, 2014 10 CFR 2.202 NRC-14-0075 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-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013 (Accession No. ML13130A067)

3) NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events," Revision 0, dated November 14, 2013 (Accession No. ML13304B836)

4) NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 7, 2013. (Accession No. ML13316A853)

5) DTE Electric Company letter, NRC-14-0043, "DTE Electric's Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014 (Accession No. ML14182A203)

USNRC NRC-14-0075 Page 2

Subject:

DTE Electric Company's First Six Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109)

On June 6, 2013, 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 install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are provided in Attachment 2 of Reference 2.

Reference 2 required submission of a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D.1. Reference 3 endorses industry guidance document NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference

3. Reference 5 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. References 3 and 4 provide 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 D.3, of Reference 2, that delineates progress made in implementing the requirements of Reference 2. Enclosure 1 provides an update of milestone accomplishments since the submittal of Reference 5, 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.

Kevin Burke, Manager, Industry Interface at (734) 586-5148.

I declare under penalty of perjury that the foregoing is true and correct.

E 7 ec on December 18, 2014 K tC. cott Die - Work Management For Vito A. Kaminskas Enclosure

USNRC NRC-14-0075 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission, Regulated Energy Division (kindschlmichigan.gov)

Enclosure to NRC-14-0075 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-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Enclosure to NRC-14-0075 Page 1 DTE Electric Company's First Six Month Status Report for the Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

1. Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (OIP) (Reference 8.1),

documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 8.2. This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2. Milestone Accomplishments None

3. Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. Target completion dates provided in this section include updates from 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.

Milestone Target Activity Comments Completion Status Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Submit 6 Month Updates:

Update 1 Dec 2014 Complete Update 2 Jun 2015 Not Started Update 3 Dec 2015 Not Started Update 4 Jun 2016 Not Started Update 5 Dec 2016 Not Started Modifications:

Hold preliminary/conceptual design meeting Jun 2014 Complete Design Change Package issued for Cycle Mar 2015 In progress See Note.

17/RF 17 Design Change implementation Cycle 17 Aug 2015 Not Started

Enclosure to NRC-14-0075 Page 2 Milestone Target Activity Comments Completion Status Date Design Change implementation RF 17 Nov 2015 Not Started Design Change Package issued for RF 18 Mar 2016 Not Started Design Change implementation RF18 Apr 2017 Not Started Walk Through Demonstration/Functional Jun 2017 Not Started Test Procedure Changes Operations Procedure Changes Developed Dec 2016 Not Started Site Specific Maintenance Procedure Dec 2016 Not Started Developed Procedure Changes Active May 2017 Not Started Training:

Training Complete Feb 2017 Not Started Completion HCVS Implementation Apr 2017 Not Started Submit Completion Report Jun 2017 Not Started Note: Design package for original scope was issued in September 2014. Following submittal of the OIP, some RF18 scope was rescheduled into RF17. Design package for rescheduled scope to be issued in March 2015. The revised milestone target completion date does not impact the order implementation date.

4. Changes to Compliance Method No changes in the compliance method for Fermi 2 have been made since the submittal of the phase 1 Overall Integrated Plan.

5. 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.

6. Open Items from Interim Staff Evaluation (ISE)

The following table provides a summary of the open items documented in the Phase 1 Overall Integrated Plan and the status of each item.

Enclosure to NRC-14-0075 Page 3 Overall Integrated Plan Phase 1 Open Item Status

1. Confirm thermal environment for actions using Evaluations of the thermal Gothic. environment using Gothic are on-going.

2. Confirm radiological environment Evaluation of the radiological environment is on-going.

3. Confirm suppression pool heat capacity. Existing suppression pool heat capacity calculations are being reviewed and revised as needed.

4. Define tornado missile protection for Reactor Review of tornado missile Building 5 th floor (RB5) components. protection methods for RB5 components is in-progress.

After the ISE is issued by the NRC, the status of ISE open items will be provided in future six-month updates.

7. Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

8. References The following references support the updates to the Phase 1 Overall Integrated Plan described in this enclosure:

8.1 DTE Electric Company letter, NRC-14-0043, "DTE Electric's Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014 8.2 Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013.

8.3 NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013.

8.4 NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 2013 (Accession No. ML13304B836).