NRC-15-0087, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049)

Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-049)

ML15239A798
Person / Time
Site:	Fermi
Issue date:	08/27/2015
From:	Kaminskas V DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NRC-15-0087
Download: ML15239A798 (8)

Text

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OT Energ03y ps August 27, 2015 10 CFR 2.202 NRC-15-0087 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, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ADAMS Accession No. ML12054A735)

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 (ADAMS Accession No. ML12229A174)

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

Implementation Guide," Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)

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 (ADAMS Accession No. ML12296A041)

6) DTE Electric Company letter, NRC-13-0009, "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)," dated February 28, 2013 (ADAMS Accession No. ML1306A262)

USNRC NRC-15-0087 Page 2

Subject:

DTE Electric Company's Fifth 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 fifth 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. Enclosure 1 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.

Christopher Robinson, Licensing Manager at (734) 586-5076.

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

Executed on August 27, 2015 Vito A. Kaminskas Site Vice President

USNRC NRC-15-0087 Page 3

Enclosure:

DTE Electric Companys Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 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 (kindschl@michigan.gov)

Enclosure to NRC-15-0087 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Companys Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Enclosure to NRC-15-0087 Page 1 DTE Electric Companys Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (OIP) (Reference 7.1),

documenting the diverse and flexible strategies (FLEX), in response to Reference 7.2. This enclosure provides an update of milestone accomplishments since submittal of the last six-month update, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2. Milestone Accomplishments The following milestones have been accomplished since the last update and as of July 31, 2015:

• Perform Staffing Analysis

• Procure Staging Location

• Develop Training Plan

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 previous six-month updates. 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 and are current as of July 31, 2015.

Milestone Target Completion Date Activity Status Submit 60 Day Status Report Oct 2012 Complete (Reference 7.3)

Submit Overall Integrated Plan Feb 2013 Complete (Reference 7.1)

Submit 6 Month Updates:

Update 1 Aug 2013 Complete (Reference 7.4)

Update 2 Feb 2014 Complete (Reference 7.5)

Update 3 Aug 2014 Complete (Reference 7.6)

Update 4 Feb 2015 Complete (Reference 7.7)

Update 5 Aug 2015 Complete This document

Enclosure to NRC-15-0087 Page 2

• The strategy validation activity scheduled completion date is modified from August 2016 to November 2015 to support implementation schedule.

• • The Regional Response Centers (RRC) are now named National SAFER Response Centers

4. Changes to Compliance Method Fermi 2 is permanently installing FLEX electrical distribution equipment to convey FLEX 480 VAC power between portable FLEX generators at FLEX Support Facility #1 (FSF1) and essential buses and Motor Control Centers (MCCs) in the Auxiliary Building. The new installation includes an Equipment Chase which is designed to the requirements of Seismic Category I structures. The permanent installation of pre-staged FLEX electrical distribution equipment is an alternative approach to NEI 12-06 (Reference 7.8).

The use of pre-staged permanently installed FLEX electrical distribution equipment facilitates re-energizing the critical plant electrical loads more quickly and efficiently than the use of portable cables and lengthy deployment paths from the portable FLEX Diesel Generators located in the FLEX storage building. This mitigation strategy is acceptable because the FLEX electrical distribution equipment is permanently installed in robust structures designed to adequately withstand all applicable external events and has access pathways that are expected to be clear of debris following the initiating event. The installation constitutes an acceptable alternative approach to the NRC endorsed guidance provided in NEI 12-06. A more detailed evaluation has been provided in a position paper that has been provided to the NRC staff.

FLEX Strategy Evaluation Validation Walk-through or Demonstrations

• Nov 2015 In-progress Perform Staffing Analysis Apr 2015 Complete Modifications:

Design Engineering Dec 2014 Complete Implementation Nov 2015 In-progress Storage Storage Design Engineering Dec 2014 Complete Storage Implementation Nov 2015 In-progress FLEX Equipment Procure On-Site Equipment Aug 2015 In-progress Develop Strategies with RRC **

Feb 2015 Complete Procure Staging Location Apr 2015 Complete Procedures:

Create Procedures Dec 2014 Complete Training:

Develop Training Plan Jul 2015 Complete Training Complete Nov 2015 In-progress FLEX Implementation Nov 2015 In-progress Submit Completion Report Jan 2016 On Target

Enclosure to NRC-15-0087 Page 3

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 The following table provides a summary of the open items documented in the Interim Staff Evaluation (ISE) (Reference 7.9) and the status of each item. An on-site audit, conducted by NRC staff the week of June 22, 2015, closed these three items.

ISE Open Item Status 3.1.1.1.A. Each section of the Integrated Plan describing storage protection from hazards makes reference to Section 11 rather than to the specific protection requirements described in NEI 12-06 for the applicable hazard; that is Section 6.2.3.1 for floods, Section 7.3.1 for wind, etc.

As reported in Reference 7.5, the OIP has been revised to refer to the specific requirements of NEI 12-06. This item was reported as closed following the on-site audit.

3.2.2.A Until the issue of relying on blow-away panels to prevent [over] pressurization of the RB-5 is provided there is no reasonable assurance that the plan will conform with NEI 12-06, Table C-3.

As reported in Reference 7.5, means to vent RB-5 have been added to the Fermi 2 strategy and the OIP has been revised accordingly. This item was reported as closed following the on-site audit.

3.2.3.B Revision 3 to the BWROG EPG SAG is a Generic Concern because the BWROG has not addressed the potential for the revised venting strategy to increase the likelihood of detrimental effects on containment response for events in which the venting strategy is invoked. [Note: For Fermi, containment venting is a backup plan to torus feed and bleed discussed above.]

As reported in Reference 7.5, the NRC generic concerns with the revised venting strategy contained in Revision 3 to the BWROG EPG SAG have been resolved. This venting strategy is being incorporated into the Fermi 2 Emergency Operating Procedures.

At Fermi 2, use of containment venting is a back-up to the primary strategy. This item was reported as closed following the on-site audit.

7. References 7.1 DTE Electric Company letter, NRC-13-0009, DTE Electrics 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 (ADAMS Accession No. ML1306A262)

Enclosure to NRC-15-0087 Page 4 7.2 NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ADAMS Accession No. ML12054A735) 7.3 DTE Electric Company letter, NRC-12-0061, Detroit Edisons 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 (ADAMS Accession No. ML12296A041) 7.4 DTE Electric Company letter, NRC-13-0044, DTE Electric Companys 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), dated August 26, 2013 (ADAMS Accession No. ML13239A121) 7.5 DTE Electric Company letter, NRC-14-0002, DTE Electric Companys Second 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), dated February 27, 2014 (ADAMS Accession No. ML14059A350) 7.6 DTE Electric Company letter, NRC-14-0060, DTE Electric Companys Third 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), dated August 28, 2014 (ADAMS Accession No. ML14241A298) 7.7 DTE Electric Company letter, NRC-15-0014, DTE Electric Companys Fourth 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), dated February 23, 2015 (ADAMS Accession No. ML15056A399) 7.8 NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378) 7.9 NRC Letter, Fermi, Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0770), dated November 25, 2013 (ADAMS Accession No. ML13220A133)