ML15114A445

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Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
ML15114A445
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 05/05/2015
From: Stephen Monarque
Japan Lessons-Learned Division
To: Fessler P
DTE Electric Company
Monarque S, NRR/JLD, 415-1544
References
EA-12-049, EA-12-051, TAC MF0770, TAC MF0771
Download: ML15114A445 (10)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 5, 2015 Mr. Paul Fessler Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, Ml 48166

SUBJECT:

FERMI, UNIT 2 - PLAN FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0770 AND MF0771)

Dear Mr. Fessler:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Issuance of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require, in part, that all holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review Overall Integrated Plans (OIPs), including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A262), DTE Electric Company (the licensee) submitted its OIP for Fermi, Unit 2 (Fermi) in response to Order EA 049. By letters dated August 26, 2013, February 27, 2014, August 28, 2014, and February 23, 2015 (ADAMS Accession Nos. ML13239A121, ML14059A350, ML14241A298, and ML15056A067, respectively), the licensee submitted its first four six-month updates to the OIP.

By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the Fermi interim staff evaluation (ISE) on November 25, 2013 (ADAMS Accession No. ML13229A205), and continues with in'-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A285), the licensee submitted its OIP for Fermi, Unit 2 in response to Order EA-12-051. By e-mail dated June 29, 2013 (ADAMS Accession No. ML 1321 OA220), the NRC staff issued a request for additional information (RAI). By letters dated August 19, 2013, August 26, 2013, February 27, 2014, August 28, 2014, and February 23, 2015 (ADAMS Accession Nos. ML13231A233, ML13239A118, ML14059A277, ML14241A288, and ML15056A067, respectively), the licensee submitted its RAI response and first four six-month updates to the OIP. The NRC staff issued

P. Fessler the Fermi ISE and RAI on November 21, 2013 (ADAMS Accession No. ML13309B129). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audit process, to include the in-office and onsite portions, allows the NRC staff to assess whether it has enough information to make a safety evaluation of the OIPs. The audit allows the NRC staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and other audit questions. Additionally, the NRC staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

This document outlines the on-site audit process that occurs after ISE issuance, as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office audit communications with staff while proceeding towards compliance with the orders.

The NRC staff plans to conduct an onsite audit at Fermi in accordance with the enclosed audit plan from June 22 - 25, 2015.

If you have any questions, please contact me at 301-415-1544 or by e-mail at stephen. monarque@nrc.gov.

Sincerely,

,~~;/,~;LJ;t Monarque, ProZ!nager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No.: 50-341

Enclosure:

Audit plan cc w/encl: Distribution via Listserv

Audit Plan Fermi, Unit 2 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Issuance of Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). Order EA-12-049 directs licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order EA-12-051 requires, in part, that all operating reactor sites have a reliable means of remotely monitoring wide-range SFP levels to support effective prioritization of event mitigation and recovery actions in the event of a BDBEE. The orders require, in part, that all holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs), including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A262), DTE Electric Company (the licensee, DTE) submitted its OIP for Fermi, Unit 2 (Fermi) in response to Order EA-12-049. By letters dated August 26, 2013, February 27, 2014, August 28, 2014, and February 23, 2015 (ADAMS Accession Nos. ML13239A121, ML14059A350, ML14241A298, and ML15056A067, respectively), the licensee submitted its first four six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195).

The purpose of the NRC staff's audit is to determine the extent to which the licensees are proceeding on a path towards successful implementation of the actions needed to achieve full compliance with the order. This audit process led to the issuance of the Fermi interim staff evaluation (ISE) on November 25, 2013 (ADAMS Accession No. ML13229A205), and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A285), the licensee submitted its OIP for Fermi, Unit 2 in response to Order EA-12-051. By e-mail dated June 29, 2013 (ADAMS Accession No. ML 1321 OA220), the NRC staff issued a request for additional information (RAI). By letters dated August 19, 2013, August 26, 2013, February 27, 2014, August 28, 2014, and February 23, 2015 (ADAMS Accession Nos. ML13231A233, ML13239A118, ML14059A277, ML14241A288, and ML15056A067, respectively), the licensee submitted its RAI response and first four six-month updates to the OIP. The NRC staff issued the Fermi ISE and RAI on November 21, 2013 (ADAMS Accession No. ML13309B129). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

Enclosure

The ongoing audit process, to include the in-office and onsite portions, allows the NRC staff to assess whether it has enough information to make a safety evaluation of the OIPs. The audit allows the NRC staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's OIPs, and other audit questions. Additionally, the NRC staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

This document outlines the on-site audit process that occurs after ISE issuance as licensees provide new or updated information via periodic updates, update audit information one-portals, provide preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs), and continue in-office audit communications with staff while proceeding towards compliance with the orders.

Following the licensee's declarations of order compliance, the NRC staff will evaluate the Integrated Plan, as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the NRC staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) developed guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML12242A378), as endorsed, by NRC Japan Lessons-Learned Project Directorate (JLD) interim staff guidance (ISG) JLD-ISG-2012-01 "Compliance with Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"' (ADAMS Accession No. ML12229A174). For Order EA-12-051, the NRC staff will make a safety determination regarding order compliance using the NEI developed guidance document NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC ISG JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation"'

(ADAMS Accession No. ML12221A339). Should DTE propose an alternative strategy or other method deviating from the guidance, additional staff review will be required to evaluate the alternative strategy in reference to the applicable order.

AUDIT SCOPE As discussed, onsite audits will be performed per NRR Office Instruction LIC-111, "Regulatory Audits," to support the development of safety evaluations. Site-specific Integrated Plan and OPDs/FIPs rely on equipment and procedures that apply to all units at a site, therefore, audits will be planned to support the "first unit at each site." On-site audits for subsequent units at a site will be on an as-needed basis.

The purpose of the audits is to obtain and review information responsive to the Fermi Integrated Plan, as supplemented, open and confirmatory items from the mitigation strategies ISE, RAI responses from the SFPI ISE, and to observe and gain a better understanding of the basis for the site's overall programs to ensure the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. These may include, but are not limited to:

  • Onsite review and discussion for the basis and approach for detailed analysis and calculations (Orders EA-12-049, EA-12-051);
  • Walk-throughs of strategies and laydown of equipment to assess feasibility, timing, and effectiveness of a given mitigating strategy or integration of several strategies (Order EA-12-049);
  • Storage, protection, access, and deployment feasibility and practicality for onsite portable equipment (Order EA-12-049);
  • Evaluation of staging, access, and deployment of offsite resources to include Response Center provided equipment (Order EA-12-049); and
  • Review dimensions and sizing of the SFP area, placement of the SFP level instrumentation, and applicable mounting methods and design criteria (Order EA 051).

NRC AUDIT TEAM Title Team Member Lead Project Manager Stephen Monarque Technical Support

  • Brett Titus Technical Support Garry Armstrong Technical Support Prem Sahav Technical Support John Lehning Technical Support Due Nguyen LOGISTICS The audit will be conducted onsite at Fermi on June 22 - 25, 2015. Entrance and exit briefings will be held with DTE at the beginning and end of the audit, respectively, as well as daily briefings of team activities. Additional details will be addressed over the phone. A more detailed schedule is provided below.

A private conference room is requested for NRC audit team use with access to audit documentation upon arrival and as needed.

DELIVERABLES An audit report/summary will be issued to the licensee within 90 days from the end of the audit.

INFORMATION NEEDS

  • Materials/documentation provided in responses to open or confirmatory items and RAls in the Fermi ISEs;
  • OPD/FIP (current version), operator procedures, operator training plans, Response Center (SAFER) playbook; and
  • Materials/documentation for staff audit questions and/or the licensee OIP identified open items as listed in the Part 2 table below To provide supplemental input to the ongoing audit of documents submitted to the NRC and made available via e-portal, the onsite audit will have three components: 1) a review of the overall mitigating strategies for the site, including, walk-throughs of strategies and equipment laydown of select portions; 2) a review of material relating to open or confirmatory items and RAls from the ISEs, staff audit questions, and the licensee open items; and 3) additional specific issues requested by NRC technical reviewers related to preparation of a safety evaluation.

Each part is described in more detail below:

Part 1 - Overall Mitigating Strategies and Program Review:

During the onsite audit, please be prepared to conduct a tabletop discussion of the site's integrated mitigating strategies and SFPI compliance program. This discussion should address the individual components of the plans, as well as the integrated implementation of the strategies including a timeline. The licensee team presenting this should include necessary representatives from site management, engineering, training, and operations that were responsible for program development, and will be responsible for training and execution.

Following the tabletop discussion, please be prepared to conduct walk-throughs of procedures and demonstrations of equipment as deemed necessary by NRC audit team members. Include representatives from engineering and operations that will be responsible for training and execution. At this time we expect, at a minimum, to walk-through the items below. Based on the tabletop presentations and audit activities, this list may change.

WALK-THROUGH LIST:

1. Walk-through a sample of strategies that will be delineated by specific NRC staff audit team members
2. Walk-through of portable (FLEX) diesel generator procedures, to include power supply pathways, areas where manual actions are required, and electrical isolation
3. Walk-through of building access procedures, to include any unique access control devices
4. Strategy walk-through of transfer routes from staging and storage areas to deployment locations for both onsite and offsite equipment
5. Strategy walk-through for core cooling and reactor coolant system inventory, to include portable pumping equipment, flow paths, and water storage locations and the related reactor systems analysis and calculations
6. Walk-through of communications enhancements, described in the licensee's submittal dated October 29, 2012, and the NRC staff's assessment for Fermi, dated June 17, 2013 (ADAMS Accession No. ML13156A266).
7. Walk-through of SFP area, SFPI locations, and related equipment mounting areas Part 2 - Specific Technical Review Items:

During the visit, the following audit items will be addressed from the Fermi ISEs (open items),

confirmatory items, and SFPI RAls; Fermi audit question list; the licensee's OIP, as supplemented, open items; and draft staff evaluation additional questions. Please provide documents or demonstrations as needed to respond to each item.

Part 3 - Specific Topics for Discussion:

1. Draft of Fermi OPD/FIP
2. Training
3. Portable (FLEX) equipment maintenance and testing
4. Response (SAFER) Plan for Fermi

Proposed Schedule for Fermi Audit Onsite Day 1, Monday June 22, 2015 0800 Check in at site, Badging 0930 Entrance meeting 0945 DTE Presentation of strategies 1230 Lunch 1330 NRC Audit Team Activities

  • Technical area break-out discussions between NRC and DTE staff in the areas of reactor systems, electrical, balance of plant/structures, and others.
  • Review documents relating to open or confirmatory items, request for additional items, codes, analyses, etc.

1400 Dosimetry 1430 Continue NRC Audit Team Activities 1630 NRC Audit Team meeting 1700 Team lead daily debrief/next day planning with DTE Onsite Day 2, Tuesday, June 23, 2015 0800 Continue NRC Audit Team Activities:

  • Review documents relating to open or confirmatory items, RAls, codes, analyses, etc.
  • Mitigating Strategies/SFPI walk-throughs with DTE 1200 Lunch 1300 Continue NRC Audit Team Activities 1630 NRC Audit Team meeting 1700 Team lead daily debrief/next day planning with DTE

Onsite Day 3, Wednesday, June 24, 2015 0800 Continue NRC Audit Team Activities 1200 Lunch 1300 Continue NRC Audit Team Activities 1630 NRC Audit Team meeting 1700 Team lead daily debrief/next day planning with DTE Onsite Day 4, Thursday, June 25, 2015 0800 Continue NRC Audit Team Activities 1200 Lunch 1300 Continue NRC Audit Team Activities 1400 NRC/DTE pre-exit meeting 1700 Audit closeout/departure

P. Fessler the Fermi ISE and RAI on November 21, 2013 (ADAMS Accession No. ML13309B129). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audit process, to include the in-office and onsite portions, allows the NRC staff to assess whether it has enough information to make a safety evaluation of the OIPs. The audit allows the NRC staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and other audit questions. Additionally, the NRC staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

This document outlines the on-site audit process that occurs after ISE issuance, as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office audit communications with staff while proceeding towards compliance with the orders.

The NRC staff plans to conduct an onsite audit at Fermi in accordance with the enclosed audit plan from June 22 - 25, 2015.

If you have any questions, please contact me at 301-415-1544 or by e-mail at stephen.monarque@nrc.gov.

Sincerely, IRA!

Stephen Monarque, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No.: 50-341

Enclosure:

Audit plan cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorllp3 1-1 Resource JLD R/F RidsNrrLASLent Resource RidsAcrsAcnw_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrPMFermi Resource SMonarque, NRR/JLD BTitus, NRR/JLD Blee, NRR/JLD Jlehning, NRR/JLD PSahay, NRR/JLD ADAMS Accession No. ML15114A445 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JOMB/BC NRR/JLD/JOMB/PM NAME SMonarque Slent MHalter SMonarque DATE 05/04/15 04/27/15 05/05/15 05/05/15 OFFICIAL AGENCY RECORD

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