NRC-10-0061, Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b

Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b

ML102230442
Person / Time
Site:	Fermi
Issue date:	08/03/2010
From:	Plona J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-10-0061
Download: ML102230442 (50)

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 DTE Energy" 10 CFR 50.12 August 3, 2010 NRC-10-0061 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

Reference:

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

Subject:

Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b Pursuant to 10 CFR 50.12, Detroit Edison, the licensee for Fermi 2, requests the Nuclear Regulatory Commission (NRC) approval of an exemption from the requirement of 10 CFR 50, Appendix E, Section IV.F.2.b for conducting a biennial emergency preparedness exercise. Specifically, Detroit Edison is requesting an exemption from conducting the 2010 emergency preparedness biennial evaluated exercise. The enclosure to this letter provides details regarding this request.

As discussed in the Enclosure and in accordance with 10 CFR 50.12(a)(1),

the requested exemption is authorized by law, would not result in undue hazard to life or property, and is consistent with the common defense and security. This exemption request also meets the special circumstances criteria, as set forth in 10 CFR 50.12(a)(2).

Detroit Edison requests NRC approval of this exemption request by October 29, 2010.

USNRC NRC-10-0061 Page 2 Should you have any questions, please contact, Mr. Rodney W. Johnson, Manager - Nuclear Licensing of my staff, at 734-586-5076.

Sincerely, ff./q44--'

Enclosure:

Exemption Request Sequence of Events for Alert Declaration Drills and Training activities since the 2008 biennial Exercise Actual Event Objective Critique Summary Evaluated Exercise Actual Event Objective Review Drill / Exercise Component Checklist Drill and Exercise Opportunities for the Actual Event -

Classifications and Notifications Corrective Actions as a Result of the Actual Event cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission

Enclosure to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b

Enclosure to NRC-10-0061 Page 1 Purpose This Enclosure provides justification pursuant to 10 CFR 50.12 for an exemption from the requirement of 10 CFR 50, Appendix E, Section IV.F.2.b to conduct a biennial Emergency Preparedness Exercise. Specifically, this exemption request applies to special circumstances that were unavoidable, due to a tornado strike on the plant site two days prior to the scheduled biennial exercise date. Two events were declared, an Unusual Event and an Alert which resulted in the activation of the Emergency Preparedness Plan.

Detroit Edison is requesting NRC approval of an exemption from conducting a biennial exercise in 2010. Response to the actual event on June 6, 2010 provided an opportunity to fully demonstrate the objectives of the exercise. This request provides details for crediting the response to the actual event in lieu of the 2010 exercise.

Background

Detroit Edison's Fermi 2 biennial evaluated exercise was scheduled to be conducted on June 8, 2010. However, on June 6, 2010 at 0217 hours0.00251 days <br />0.0603 hours <br />3.587963e-4 weeks <br />8.25685e-5 months <br />, a tornado warning was issued for Monroe County due to a storm front moving through southeast Michigan. At 0238 hours0.00275 days <br />0.0661 hours <br />3.935185e-4 weeks <br />9.0559e-5 months <br />, a tornado swept across the Fermi 2 property..

At 0253 hours0.00293 days <br />0.0703 hours <br />4.183201e-4 weeks <br />9.62665e-5 months <br />, the Shift Manager declared an Unusual Event (UE) based on reports of storm damage within the protected area, including loss of both 345kVV lines for Division 2 of offsite power supply, and the loss of two out of three 120kV lines for Division 1 of offsite power supply.

The Emergency Call Out System (ECOS) was activated at 0353 hours0.00409 days <br />0.0981 hours <br />5.83664e-4 weeks <br />1.343165e-4 months <br /> to supplement on shift personnel to assist in damage assessment. At 0417 hours0.00483 days <br />0.116 hours <br />6.894841e-4 weeks <br />1.586685e-4 months <br />, the Emergency Director declared an Alert due to confirmed structural damage to the Auxiliary Building. At 0430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br />, ECOS was activated for the Alert. The Emergency Response Organization (ERO) members arrived on-site and activated the Emergency Response Facilities. Assembly and accountability was performed and was completed at 0439 hours0.00508 days <br />0.122 hours <br />7.258598e-4 weeks <br />1.670395e-4 months <br />.

Three Emergency Response Facilities (the Technical Support Center, the Operational Support Center and the Emergency Operations Facility) were activated. The Joint Information Center (JIC) was not activated since this facility is not normally activated at the Alert level. The State of Michigan, Wayne County, and Monroe County emergency response personnel participated in the response to the event.

Communication with the NRC was established and maintained throughout the actual event up to and including termination.

The Alert was terminated at 0220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> on June 7, 2010 when it was determined that no release of radioactive material had occurred, no damage to safety related

Enclosure to NRC-10-0061 Page 2 equipment was sustained, safety systems in structures damaged by the tornado were not impacted, and offsite electrical power to the site was restored.

Overall performance of the ERO was determined to be satisfactory. The ERO demonstrated the ability to protect the health and safety of the public during the event which included storm damage within the protected area as well as the loss of offsite power.

Basis for the Exemption The underlying purposes forconducting a biennial exercise are to test the adequacy of emergency plans, to ensure that emergency response organization personnel are familiar with their duties, and to identify and correct noted weaknesses.

The following seven attachments are provided with this exemption request to demonstrate how the objectives of the exercise have been met in the response to the actual event on June 6, 2010: : Sequence of Events for Alert Declaration : Drills and Training activities since the 2008 biennial Exercise : Actual Event Objective Critique Summary : Evaluated-Exercise Actual Event Objective Review : Drill / Exercise Component Checklist : Drill and Exercise Opportunities for the Actual Event -

Classifications and Notifications, : Corrective Actions as a Result of the Actual Event, Additional details regarding the information in the attachments are provided herein:

1. The sequence of the actual event that occurred on June 6, 2010 is captured in.

2. Fermi 2 has regularly exercised its emergency response strategies and personnel in coordination with offsite authorities. Eighteen (18) drills have been conducted since the last biennial evaluated exercise. Ten (10) series of re-qualification training sessions have been conducted in 2009 and 2010. The re-qualification.

training sessions included an integrated site table top drill involving all on-site and off-site Emergency Response Facilities. Additional table top drills were conducted for specific task elements. Forty-seven (47) evaluated simulator sessions for Licensed Operators and thirteen (13) table top exercises for Non-Licensed Operators were conducted since the last biennial, evaluated exercise. provides a list of drill and training dates that have been conducted since the 2008 evaluated exercise.

3. A review of the objectives for the planned 2010 Fermi 2 evaluated exercise was conducted based on actions that were demonstrated during the actual event. A

Enclosure to NRC-10-0061 Page 3 post-event drill/exercise component checklist was completed (Attachment 5) identifying the components that were and were not performed during the event.

All objectives except those requiring radiological controls and Joint Information Center activation were exercised during the actual event. Attachment 3 provides a summary of the actual event objective critique. Attachment 4 provides details of the actual event objective review. Attachment 5 provides an exercise component checklist. These three attachments collectively delineate analysis of the exercise objectives versus the actual event.

4. Exercise performance was also analyzed for the actual event. All classifications and notifications were determined to be successful. This represents four successful opportunities of the four possible opportunities that occurred during the actual event. Attachment 6 summarizes the exercise opportunities for the actual event.

5. A post-event critique/debrief session was conducted with the ERO. Issues identified during the event were entered into the corrective action system. provides a list of corrective actions that have been identified during the actual event and the post-event critique/debrief.

6. A limited scope biennial exercise utilizing partial onsite participation and full participation by offsite agencies was conducted on June 8, 2010; however, it only included offsite aspects of the originally planned exercise. FEMA evaluated the offsite aspects of the exercise on June 8, 2010 as originally planned. Therefore, Detroit Edison is not requesting an exemption from 10 CFR 50, Appendix E, Section IV.F.2.c for offsite authority participation.

Analysis of the actions that occurred during the June 6, 2010 actual event versus the activities that are required of an evaluated exercise provides objective evidence of the adequacy of the emergency plans at Fermi 2 and of the capability of the ERO personnel to respond to emergencies. The actual event provided the circumstances to demonstrate that Emergency Response Organization personnel are familiar with their duties and to demonstrate the site's ability to identify and correct weaknesses.

Justification of the Exemption In accordance with 10 CFR 50.12(a)(1), the NRC may grant exemptions from certain requirements of the Part 50 regulations that are authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security.

Enclosure to NRC-10-0061 Page 4

1. This exemption request is authorized by law:

In accordance with 10 CFR 50.12, the NRC may grant an exemption from the requirements of 10 CFR 50, if the exemption is authorized by law. The proposed exemption is authorized by law in that no other prohibition of law exists to preclude the activities which would be authorized by the exemption.

The proposed exemption will continue to serve the underlying purpose of the regulation. The underlying purposes for conducting a biennial Exercise are to test the adequacy of emergency plans, to ensure that emergency response organization personnel are familiar with their duties, and to identify and correct weaknesses.

The activities performed during the actual event at Fermi 2 demonstrate that these underlying purposes of conducting an exercise have been met.

2. This exemption request will not present an undue risk to the public health and safety:

During response to the actual event on June 6, 2010, the Fermi 2 Emergency Response Organization demonstrated the ability to protect the health and safety of the public. The event included tornado damage to plant structures within the protected area as well as the loss of offsite power. The Fermi 2 emergency plans used to respond to the event demonstrated the effectiveness of the plans in protecting the health and safety of the public.

3.

This exemption request is consistent with the common defense and security:

This exemption requests NRC approval using the response to the actual tornado strike event two days before the 2010 scheduled exercise in place of the biennial exercise to meet the requirement of 10 CFR 50, Appendix E, Section IV.F.2.b.

Granting this exemption will maintain focus on nuclear safety and security; therefore, it is ultimately in the interest of common defense and security.

Pursuant to 10 CFR 50.12(a)(2), the NRC will consider granting an exemption from the regulation if special circumstances are present. This exemption request meets this requirement since special circumstances that were present when the plant site was subject to a tornado strike. Specifically, the underlying purpose of the rule has been adequately served in responding to the actual event on June 6, 2010.

Enclosure to NRC-10-0061 Page 5 Environmental impact The scheduled 2010 biennial emergency exercise would not be conducted for Fermi 2, if the requested exemption is approved by the NRC. Whether or not the exercise is conducted would have no effect on the environment since any outdoor activity during an exercise is limited to minimal use of roads and highways. The proposed action would not significantly increase the probability or consequences of an accident, change the types or quantities of radiological effluents that may be released offsite, or result in a significant increase in public or occupational radiation exposure since there would be no change to facility operations that could create a new accident or affect a previously analyzed accident or release path.

Since the proposed action will not have any adverse environmental effects, there are no alternatives available for reducing or avoiding adverse environmental effects.

With regard to non-radiological impacts, no changes would be made to non-radiological plant effluents or activities that would adversely affect the environment.

Therefore, no significant non-radiological impacts are associated with the proposed action.

There are no federal permits, licenses, approvals and other entitlements which must be obtained in connection with the proposed action. The proposed action is not subject to any environmental quality standards or requirements imposed by Federal, State, regional, or local agencies having responsibility for environmental protection.

Alternatives to the Proposed Action

1. Schedule and conduct a biennial exercise in 2010:

The underlying purposes for conducting a biennial exercise are to test the adequacy of emergency plans, to ensure that emergency response organization personnel are familiar with their duties, and to identify and correct weaknesses.

These objectives have been adequately demonstrated during the response of the tornado strike on site.

Since the actual event on June 6, 2010 adequately demonstrated the objectives for conducting the biennial exercise and due to the fact that Fermi 2 has a refuel outage scheduled for the fourth quarter of 2010, this alternative is ruled out.

Enclosure to NRC-10-0061 Page 6

2. Schedule and conduct a biennial exercise in 2011:

The June 6, 2010 tornado required the declaration of an Alert and the activation of the Fermi 2 emergency plan. Additionally, on June 8, 2010 the offsite authorities participated in an exercise that was evaluated by FEMA, as required.

These two activities fulfill the requirements of holding the biennial evaluated exercise as required by 10 CFR 50, Appendix E, Section IV.F.2. Therefore, this alternative is also ruled out.

Neither alternative provides the benefit of relieving Fermi 2 from an unneeded demonstration of the emergency capability that had been adequately demonstrated during the actual event of June 6, 2010.

Conclusion The underlying purposes for conducting a biennial exercise are to test the adequacy of emergency plans, to ensure that emergehcy response organization personnel are familiar with their duties, and to identify and correct weaknesses. Review of the actions that occurred during the June 6, 2010 actual event supplemented by the drills, exercises, and other training activities conducted since the previous biennial exercise provides evidence that Fermi 2 has regularly exercised its emergency response strategies and personnel in coordination with offsite authorities as required by regulations. Granting an exemption from the requirement of conducting the biennial exercise will not pose an undue risk to public health and safety and will ensure that focus is maintained on plant safety and security.

As required by 10 CFR 50.12, the requested exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security.

to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 Sequence of Events for Alert Declaration Sunday, June 6, 2010 - Monday, June 7, 2010 Sunday, June 6,2010 Time Event 0217 The National Weather Service issued a Tornado Warning for Monroe County. Control Room Supervisor entered AOP 20.000.01, "Acts of Nature."

0238 Loss of both 345kV offsite power lines, EDG #13 & 14 start to supply Division 2 power. Loss of thru two out of three 120kV offsite power lines. Main turbine tripped. Reactor scrammed. The main 0245 condenser was used as heat sink via turbine bypass lines. Shift Manager receives reports of trailers turned over and damage to turbine building and several outbuildings.

0253 Shift Manager became the Emergency Director (SM/ED) and declared an Unusual Event (HU 1),

"Natural AND Destructive Phenomena Affecting the Protected Area", EAL #9, "Assessment by the Control Room that a destructive event affecting the protected area has occurred' based on storm damage within the Protected Area.

0253 Message 1 - Initial Notification of the declaration of an Unusual Event (HUI) 0259 Initial Notification to off-site authorities complete.

0346 Message 2 - Follow-up Notification signed by SM/ED.

0348 Notification to off-site agencies complete.

0353 SM/ED activates ECOS to supplement on-shift personnel to assist in damage assessment.

0401 Shift Manager received a phone call reporting possible damage to the Auxiliary Building. The Superintendent, Operations left the control room to investigate.

0408 Superintendent, Operations reported to the SM/ED that there was a large hole in the Auxiliary Building East wall.

0415 TSC ED arrives at the TSC.

0417 The SM/ED declared an Alert (HA 1), "Natural AND Destructive Phenomena Affecting the Plant Vital Area", EAL #3, "Any occurrence that results in VISIBLE DAMAGE to the Reactor Building, Auxiliary Building, or RHR Complex" based on confirmed damage to the Auxiliary Building.

0417 Message 3 - Initial Notification of an Alert (HAl).

0418 Assembly and Accountability ordered.

0422 Initial Notification to off-site authorities complete.

0430 SM/ED activates ECOS for the Alert.

NRC-10-0061 Page 2 Sequence of Events for Alert Declaration Sunday, June 6, 2010 - Monday, June 7, 2010 0439 Assembly and Accountability completed. One ITC employee not accounted for. Hi Com announcements and search initiated.

0447 NRC Briefing with TSC ED.

0453 Message 4 - Follow-up Notification signed by SM/ED.

0457 Notification to off-site agencies complete.

0502 TSC functional.

0505 OSC has no power. OSC Coordinator moving staff to Alternate OSC.

0520 All personnel accounted for. Missing ITC employee found working on 345kV mat.

0536 OSC functional.

0550 Message 5 - Follow-up Notification signed by TSC ED.

0548 NRC Briefing with TSC NRC Communicator 0552 TSC ED attempted to contact the State Emergency Director.

0554 Notification to off-site agencies complete.

0554 EOF functional.

0557 State EOC operational 0604 4-hour report to NRC complete as required by 10CFR50.72.b.2.iv.B (RPS Actuation) and in accordance with MLS05004, "Fermi 2 Event Notification Worksheet" 0621 Message 6 - Follow-up Notification signed by EOF EO.

0623 Notification to State EOC complete 0636 State Emergency Director contacted TSC ED.

0640 Notification to ANI (American Nuclear Insurers) 0652 Message 7 - Follow-up Notification signed by EOF EO.

0652 Notification to State EOC complete 0703 NRC Briefing with TSC ED.

NRC-10-0061 Page 3 Sequence of Events for Alert Declaration Sunday, June 6,2010 - Monday, June 7,2010 0715 Message 8 - Follow-up Notification signed by EOF EO.

0718 Notification to State EOC complete 0733 Notification to INPO (Institute of Nuclear Power Operations) 0742 Message 9-Follow-up Notification signed by EOF EO.

0743 Notification to State EOC complete 0810 Message 10 - Follow-up Notification signed by EOF EO.

0812 Notification to State EOC complete 0830 Monroe County declared a State of Emergency.

0830 NRC Briefing with TSC ED.

0831 Message 11 - Follow-up Notification signed by EOF EO.

0833 Notification to State EOC complete 0841 NRC Briefing with EOF EO.

0853 EOF EO authorizes distribution of Press Release.

0855 Message 12 - Follow-up Notification signed by EOF EO.

0902 Notification to State EOC complete 0917 Message 13 - Follow-up Notification signed by EOF EO.

0918 Notification to State EOC complete 0940 Message 14 - Follow-up Notification signed by EOF EO.

0941 Notification to Regional Manager, DTE Corporate & Governmental Affairs, who immediately contacted local county, city, and township officials.

0942 Mid America employees on site with chain saws to clear a path of fallen trees to the cooling towers.

0943 Notification to State EOC complete 0951 Follow up Notification reporting frequency decreased to every hour (vice every half hour).

NRC-10-0061 Page 4 Sequence of Events for Alert Declaration Sunday, June 6, 2010 - Monday, June 7, 2010 1016 ITC employee received bums to his arms from a static discharge while working on 345kV mat.

1018 Shift Manager requests ambulance to be dispatched to site.

1037 Message 15 - Follow-up Notification signed by EOF EO.

1038 Notification to State EOC complete 1040 Injured ITC employee transported to Mercy Memorial Hospital via ambulance.

1042 NRC Briefing with TSC NRC Communicator concerning injured ITC employee 1049 Lansing Flight Services notified that N. and S. Cooling Tower lights inoperable due to loss of power and/or damage.

1050 NRC Briefing with EOF EO and TSC ED.

1107 Notification to ANI and INPO.

1111 TSC ED directs Outage Control Center (OCC) to start staffing per EP-402, Recovery Organization.

1134 Message 16 - Follow-up Notification signed by EOF EO.

1135 Notification to State EOC complete.

1203 Notification to ANI and INPO.

1228 Message 17 - Follow-up Notification signed by EOF EO.

1229 Notification to State EOC complete 1230 NRC Briefing with EOF EO.

1313 Message 18 - Follow-up Notification signed by EOF EO.

1318 Notification to State EOC complete.

1353 Notified NEIL, per GRRR 1-17, of wind damage to insured buildings (AB, TB, CWPH, Cooling Towers).

1406 Message 19 - Follow-up Notification signed by EOF EO.

1407 Notification to State EOC complete 1430 NRC Briefing with EOF EO.

NRC-10-0061 Page 5 Sequence of Events for Alert Declaration Sunday, June 6, 2010 - Monday, June 7, 2010 1440 Two representatives from the National Weather Service arrived on site to conduct an inspection.

1500 Message 20 - Follow-up Notification signed by EOF EO. Nuclear Information requested to only be notified if significant changes occur.

1501 Notification to State EOC complete 1505 Management conferred with NRC and decided to cancel FERMEX '10 due to resources needed for recovery.

1520 Notification to INPO 1553 Message 21 - Follow-up Notification signed by EOF EO.

1557 Notification to State EOC complete 1610 EOF EO gave permission for Monroe County EMD to view pictures of Fermi storm damage. They are to get any hardcopies from Nuclear Information.

1634 Brownstown #3 line is energized.

1642 Message 22 - Follow-up Notification signed by EOF EO.

1645 Notification to State EOC complete 1729 345kV Switchyard Buses 301 & 302 are energized.

1742 Message 23 - Follow-up Notification signed by EOF EO.

1742 Notification to State EOC complete 1748 NRC requests a formal briefing every two hours 1828 Message 24 - Follow-up Notification signed by EOF EO.

1830 NRC Briefing with EOF EO.

1831 Notification to State EOC complete 1923 Message 25 - Follow-up Notification signed by EOF EO.

1924 Notification to State EOC complete 1951 OCC being manned in preparation of taking over recovery once termination is declared.I!

NRC-10-0061 Page 6 Sequence of Events for Alert Declaration Sunday, June 6, 2010 - Monday, June 7, 2010 2020 Message 26 - Follow-up Notification signed by EOF EO.

2022 Notification to State EOC complete 2030 NRC Briefing with EOF EO.

2110 Informed that injured ITC employee had burns to his hands, hip, and stomach. He has been released from Mercy Memorial Hospital.

2215 The National Weather Service Survey Team confirmed an EF-1 tornado had impacted Fermi site' It touched down at the Southwest portion of Detroit Beach and tracked 6.5 miles to the Northeast portion of Estrai Beach. The path was 500 yards wide with estimated wind speeds of 90 mph.

2116 Off site power restored to 4160v ESF bus 65E. EDG 13 is shutdown.

2121 Message 27 - Follow-up Notification signed by EOF EO.

2122 Notification to State EOC complete 2222 Message 28 - Follow-up Notification signed by EOF EO.

2224 Notification to State EOC complete 2315 Message 29 - Follow-up Notification signed by EOF EO.

2318 Notification to State EOC complete NRC-10-0061 Page 7 Sequence of Events for Alert Declaration Sunday, June 6, 2010 - Monday, June 7, 2010 Monday, June 7,2010 Time Event 0012 Message 30 - Follow-up Notification signed by EOF EO.

0013 Notification to State EOC complete 0030 NRC Briefing with EOF EO.

0031 Wayne County EMD terminated from the event. Only the Wayne County Liaison (DTE ERO member) is present at that facility.

0040 Off site power restored to 4160v ESF bus 65F. EDG 14 is shutdown.

0110 Message 31 - Follow-up Notification signed by EOF EO.

0112 Notification to State EOC complete 0150 NRC Briefing with TSC ED.

0208 Message 32 - Follow-up Notification signed by EOF EO.

0209 Notification to State EOC complete 0220 The EOF EO and TSC ED conferred and terminated the Alert per EP-103, Step 7.8.

0233 State EOC terminated from the event.

0234 NRC Brief with EOF EO and TSC ED concerning termination.

0235 Message 33 - Initial Notification of event termination. Notification to State EOC complete 0236 ERDS de-activated. IPCS reset to display "NO EMERG."

to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 Drills and Training activities since the 2008 biennial Exercise Fermi 2 has regularly exercised its emergency response strategies and personnel in coordination with offsite authorities and will not pose undue risk to public health and safety. The following is a list of drills, exercises, and other training activities that have occurred since the last evaluated exercise that was performed on May 20, 2008:

Drills:

13 drills were conducted since the last biennial evaluated exercise and were performed on the following dates:

8/6/2008; 9/24/2008; 10/20/2008; 10/22/2008; 3/4/2009; 5/11/2009; 5/19/2009; 7/14/2009; 8/18/2009; 8/25/2009; 9/17/2009; 9/23/2009; 10/13/2009; 12/18/2009; 3/3/2010; 5/12/2010, 5/26/2010 and 06/09/2010.

Training:

Requalification training, which included a table top drill, was conducted during the following weeks during 2009 and 2010:

2/16/2009; 5/4/2009; 7/20/2009; 10/5/2009; 12/14/2009; 1/ 12/2010; 1/ 19/2010; 1/26/2010; 2/2/2010; and 2/9/2010.

47 evaluated simulator sessions for Licensed Operators were conducted since the last biennial evaluated exercise and were performed on the following dates:

6/24/2008; 7/1/2008; 7/15/2008; 7/22/2008; 7/28/2008; 9/25/2008; 10/2/2008; 10/13/2008; 3/10/2009;5/7/2009; 6/2/2009; 6/3/2009; 6/9/2009; 6/11/2009; 6/16/2009; 6/17/2009; 6/23/2009; 6/24/2009; 6/30/2009; 7/1/2009; 7/6/2009; 7/7/2009; 8/11/2009; 9/1/2009; 9/2/2009; 9/8/2009; 9/9/2009; 9/14/2009; 9/16/2009; 10/3/2009; 11/10/2009; 11/17/2009; 11/23/2009; 12/1/2009; 12/8/2009; 1/19/2010; 1/26/2010; 2/2/2010; 2/9/2010; 2/16/2010; 2/23/2010; 3/30/2010; 4/6/2010; 4/13/2010; 4/20/2010; 4/27/2010, and 5/4/2010.

13 table top exercises for Non-Licensed Operators were conducted since the last biennial evaluated exercise and were performed on the following dates:

7/3/2008; 7/9/2008; 10/28/2008; 11/4/2008; 11/11/2008; 11/18/2008; 11/26/2008; 5/21/2009; 6/3/2009; 6/10/2009; 6/17/2009; 6/24/2009, and 7/1/2009.

to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 ACTUAL EVENT OBJECTIVE CRITIQUE

SUMMARY

A.

Drill/Exercise Implementation 6/6/2010 ERO Green Team on call Date B.

Overall Actual Event Performance Overall Fermex 2010 Objectives Met SAT D

UNSAT Yes D

No Al Demonstrate the ability to establish and maintain priorities for the emergency response effort.

Satisfactory A2 Provide effective periodic briefings throughout the emergency.

Satisfactory A3 Develop an effective mitigation and response strategy.

Satisfactory B

Onsite Emergency Organzation - Planning Stan ard B 1 Demonstrate the activation of the Emergency Response Organization.

Satisfactory B2 Demonstrate the ability to staff the (Emergency Response Facility) in a timely Unsatisfactory manner.

(Documented in CARD 10-24665) m iergency Response Support andl Resources C3 Demonstrate the ability to activate the State and County Liaisons.

Satisfactory

1) miergenc% Classification System - Planning Standard DI Demonstrate the ability to accurately classify simulated plant conditions in a Satisfactory timely manner.

..E Notification Methods and Procedures - P.lanning Standard El Demonstrate timely and accurate initial notifications of plant events.

Satisfactory E2 Demonstrate the ability to provide informative and timely follow-up Satisfactory notifications to offsite authorities.

E3 Demonstrate the ability to perform prompt, information notifications to the Satisfactory NRC.

F mergenc*y Communication System - Plannin Standard F1 Demonstrate effective inter-and intra-facility communications.

Satisfactory F2 Demonstrate effective log keeping.

Satisfactory NRC-10-0061 Page 2 ACTUAL EVENT OBJECTIVE CRITIQUE

SUMMARY

GI Demonstrate effective rumor control.

Not observed G2 Demonstrate the ability to conduct effective news media briefings.

Not observed G3 Demonstrate proper response to technical questions from the media.

Not observed G4 Demonstrate adequate security controls for the facility.

Not observed I1 Enmrgeuncy Facilities and Equipieh-PnigStadard HI Demonstrate effective turnover(s) of responsibilities between emergency Satisfactory response facilities.

H2 Demonstrate timely and effective status board updates.

Satisfactory H3 Demonstrate the ability to inspect, inventory, and use of E-kits.

Satisfactory H4 Demonstrate adequate preparation and use of damage control teams.

Satisfactory H5 Demonstrate the ability to obtain current and forecast meteorological data.

Satisfactory q

Accident Assessmnent - P'lanmw fin iar I1 Demonstrate accurate and timely dose assessment operations.

Satisfactory 12 Demonstrate effective operations of the IPCS/SPDS system.

Satisfactory 13 Demonstrate timely activation and dispatch on-site and off-site RETs.

Not observed 15 Demonstrate effective plume tracking operations.

Not observed 16 Demonstrate the performance and evaluation of portable air samples.

Not observed J

ProtectiN e Response -Planning Standard J 1 Recognize when to activate the on-site alarm system Satisfactory J2 Formulate on-site protective actions.

Satisfactory J4 Formulate timely and accurate offsite protective action recommendations.

Not observed J6 Demonstrate the ability to establish and implement appropriate radiological Satisfactory controls.

K adilgcl Fxposu re Conrols *- Plannhin Slawlard K2 Demonstrate the ability to apply the emergency exposure guidelines of Not observed EP-201-03.

K3 Demonstrate the ability to program emergency dose extensions into electronic Not observed dosimetry devices.

NRC-10-0061 Page 3 ACTUAL EVENT OBJECTIVE CRITIQUE

SUMMARY

NI Job Briefs Satisfactory N2 Self Checking Satisfactory N3 Verification Techniques Satisfactory N4 Effective Communication Satisfactory N5 Questioning Attitude Satisfactory N6 Procedure Use and Adherence Satisfactory to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 Evaluated Exercise - Actual Event Objective Review A review of the objectives that had been generated for the 2010 Fermi Evaluated Exercise was conducted based on actions that were demonstrated during the actual event.

ctive aluated E.Actl Een iberK Evaluation ASSIGNMVENT AND RESPONSIBILITY ard: Primary responsibilities for emergency response by the nuclear facility i......

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sibilities of thle vario...... pporting organizations have been specifically established.,and ch prilm soraiainha iiforýsondand to agi o1 u's ha s..n.i its initialresponse on a co u&&b*is.

Demonstrate the ability to establish and maintain priorities for the emergency response effort.

Standard: The Facility Manager (FM) shall review procedural guidance to assist in the development of response strategies and priorities. The FM shall collaborate with ERO members throughout the event to help determine appropriate response strategies and priorities. Players shall determine, through the course of the event, an appropriate repair, monitoring, and operational plan.

Communications between the engineering staff, Operations personnel, RP personnel, and the appropriate decision-makers will be critical to this task's Complete successful completion. Prioritizing tasks, identifying and obtaining needed resources (equipment and personnel), and evaluating probable scenarios will lead to the development of appropriate strategies. The goal is to achieve a safe and stable operating condition. Constant assessment of response activities is critical to ensure appropriate efforts are maintained. The FM shall review field team data as it becomes available to refine strategies and priorities throughout the emergency. The FM shall solicit input from response personnel in order to gauge response efforts and adiust existing strategies and priorities.

A2 Provide effective periodic briefings throughout the emergency.

Standard: The FM shall provide for facility briefings. The FMs should refer to the applicable facility's briefing guide. Facility briefings shall be clear and Complete understandable, avoiding acronyms and technical jargon. Each briefing should address the resource needs, current response efforts and priorities. The FM should also solicit input from personnel in the facility.

A3 Develop an effective mitigation and response strategy.

Standard: The ERO should identify necessary resources for support to the response efforts for the event. Field teams should be established and Complete dispatched to acquire information for the FM to determine further response measures and response. Plant information and procedures should be made available and reviewed to assist in these efforts.

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B1 Demonstrate activation of the Emergency Response Organization.

Standard: Once the initial declaration of emergency is made the SM must activate the Emergency Call Out System in accordance with EP-290. The SM may select from one of the existing messages or record one of their own.

Activation of the back-up method is accomplished in accordance with EP-Complete 292. The SM must also make the appropriate announcements using the site paging system. Implementation of the Building Coordinator "network" in accordance with FBP-36 and the Owner Controlled Area Notification System may also be necessary depending on the emergency.

B2 Demonstrate the ability to staff the (Emergency Response Facility) in a timely manner.

Standard: The Technical Support Center shall achieve minimum staffing in accordance with EP-301-01. The Operational Support Center shall achieve minimum staffing in accordance with EP-302-01. The Emergency Operation Facility shall achieve minimum staffing in accordance with EP-303-01.

COMMENT: The Technical Support Center was activated within 45 minutes of the ECOS call-out, the Operational Support Center (OSC) was activated within 79 minutes and the Emergency Operations Facility was activated within 97 minutes of the ECOS call-out. The arriving Emergency Response Organization members reported to, and activated, their emergency response facilities. Assembly and accountability was performed and Complete completed at 0439. The RERP Plan, B. 1.2, states, "It is the goal of Detroit Edison to augment Control Room staff by the Emergency Response Organization (Table B-I) in two groups of key personnel. The first group of key personnel should be in their Emergency Response Facility within 30 minutes of an Alert being declared. However, there may be some conditions where up to 60 minutes may be required The second group of key personnel should be in place within 60 minutes of being declared" As evidenced by the road conditions as a result of the tornado (i.e. trees uprooted wires down, some impassable roads, etc.) and testimony of personnel reporting to site during the event, conditions warranted their caution to drive slowly, take alternate routes, etc. The weather conditions, and the aftermath of the storm, resulted in a delayed response and augmentation.

C3 NRC-10-0061 Page 3 Evaluated Exercise - Actual Event Objective Review EMErRGENCY REPNESPOTADRESOUTRCES Standard: Arrangement'freretjhi and effectively us I'nlasistace resources have been made, airrangements to accommociate Siatc'and loal staff at thelicl.ensee s, near-site Emiergenlcy Operations, ae ee

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iations capable of agmentngy the planned re's-ponsv have Demonstrate the ability to activate the State and County Liaisons.

Standard: The Liaisons are notified of an event at the Alert declaration of Complete emergency and are to be stationed in the respective EOCs upon their activation.

EMEIRGENCNY c'LASSIFICAkTION`SYSTEM SIdard A stndaremergeney i'.ýification and etloll eelscllý ebase,,, )I'\\hi iciue s~tm nel~ietpmaicesiinuebtil nuLIle'1a "icfaility 1licensee, arnd Stlte ailnd loccaV response plans call for rel anceoiiiiiOrmation provided b y licensee for dcte rntoi i of nmi.n.imu initial offsite res ps...asures Demonstrate the ability to accurately classify simulated plant conditions in a timely manner.

Standard: Players shall monitor plant conditions using all available resources. They should follow the progression of events which approach conditions requiring classification(s). Players shall utilize EP-101 to evaluate potential classifications. Minimal time (< 15 minutes) shall be taken once Complete indications are available to recognize, evaluate, and classify an emergency.

Once a classification is declared further monitoring and evaluation must be performed so that all possible changes in classification are identified. Players shall also take appropriate actions identified in the individual event procedures, EP-102 through EP-105. This is a risk significant activity.

NOTIFICATIO. I I E-THOD.S AND PROCEDURF S%.~

StandIard: P~rocedutres hi~v!).:bLn establlsishd fo--r niotificatiin, h\\ytile licenscee of State aind local Demonstrate timely and accurate initial notifications of plant events.

Standard: All initial no tions shall be completed, approved, and communicated to off-site authorities within 15 minutes of any declared emergency. Players shall complete EP-290001 with the required information in a timely and legible manner. The initial PAR is communicated on the same form as the initial notification of a General Emergency. Any changes to Complete an existing PAR shall be communicated as an initial notification using EP-290001 as quickly as possible but not to exceed 15 minutes. A change in PAR based on dose calculations requires completion of both EP-290001 and EP-290002. All lines on the form(s) must be completed correctly, with the exception of minor variations of met data. This is a risk significant activity.

NRC-10-0061 Page 4 Evaluated Exercise - Actual Event Objective Review E2 Demonstrate the ability to provide informative and timely follow-up notifications to offsite authorities.

Standard: Follow-up messages are normally completed following an initial message. During fast breaking scenarios this may not be possible. Follow-up messages are provided as conditions change or every 30 minutes, whichever Complete is sooner. The players shall use EP-290002 for each follow-up message.

Follow-up messages shall be completed to the maximum extent possible.

Dose calculations must be written onto EP-290002. Canada is not provided follow-up messages by the ERO.

E3 Demonstrate the ability to perform prompt, informative notifications to the NRC.

Standard: The NRC shall be notified immediately following off-site authoritie Coinlete notifications will be on the applicable form communicated AND the communicator's log. The ERO should maintain an open line to the NRC at all times.

F.EMERGENCY COMMUNICATION SYSTEM Standard: Prov isions. exist for the prompt coimmunkac'tiotis amioiiIng pincipal response orgaiaol t

emier cy persoinsel andto the public.

F1 Demonstrate effective inter-and intra-facility communications.

Standard: Players shall effectively utilize available telecommunications equipi should include the use of "this is a drill" at the beginning and end of each transmission. Written communications shall be legible. Communications Complete between facilities is crucial in assuring facility specific tasks can be accomplished quickly and accurately. Radios are operated in accordance with FCC rules and regulations. All communications involving the transfer of data must use proper three-way communications.

F2 Demonstrate effective log keeping.

Standard: ERO personnel should keep a chronological log for their position.

It must identify pertinent events and communications made with other Complete personnel. It shall be completed in a timely and effective manner. The log should be written in such a way as to recreate the events and actions taken.

NRC-10-0061 Page 5 Evaluated Exercise - Actual Event Objective Review FOR1~4ATION CG. PUBLIC, EDUCATION ANU. INFO-ITO San~d rhat lnforiationis imae avaýillable to the piublic ola periodic basis on Aio\\wtIhe III be: notif"ied an httheir initial acti6ons.-hmuId be iini emer~gency,~ the prin~cipal points ofcotntac't'ith thet nlews media for di~ssemnaition of iniformratoie during an enmergency are established in adý ance, anid procedures forb.oordinated disseminffitoti ol'f itnfoation to' the nublic are ~~lse:~

G1 Demonstrate effective rumor control.

Standard: Upon activation of the JIC, a rumor control group shall be in place to answer questions from the general public. The phone numbers for rumor control shall be given during the first media briefing and may be given during Not observed subsequent media briefings. When questions are asked the rumor control group shall give answers that are accurate and timely. The rumor control personnel shall be aware of the events taking place, weather conditions, road conditions, evacuation routes, shelter areas, etc.

G2 Demonstrate the ability to conduct effective news media briefings.

Standard: Upon activation of the JIC, the Joint Information Team (JIT) shallg approximately every 60 minutes, but can be held earlier if conditions change Not observed dramatically at the plant, or if there is a change in classification or protective action recommendations, or any other actions occur that are deemed important enough to call for a media briefing.

G3 Demonstrate proper response to technical questions from the media.

Standard: When "technical" questions are asked by the media, the JIC staff shall arrange to have one or more of the three Technical Advisors (depending on the types of questions being asked) meet with the media to answer their Not observed questions. The Technical Advisor(s) shall answer the questions in a brief and accurate manner, yet in "non-technical" terms, so as to be understood by the media and general public. The Media Relations Administrator, or designee, shall be in the vicinity to assist the Technical Advisors.

G4 Demonstrate adequate security controls for the facility.

Standard: Fermi 2 Nuclear Security shall provide three (3) security personnel to the JIC, who will station themselves at strategic, predetermined locations. They are to maintain order, distribute access badges to all Not observed personnel (whether a member of the JIC or a member of the PRESS), control access and movement of personnel throughout the JIC, and, if required, control and coordinate the movement of media personnel from the JIC to the Onsite News Center, located in the NTC Auditorium.

NRC-10-0061 Page 6 Evaluated Exercise - Actual Event Objective Review

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EMERGENCY FACILITIES AND EQ1.IPM..T Standard: Adequate emergency facilities and equicmet to sup ort the ýrnergency response are

~provided and maintained.

H1 Demonstrate effective turnover(s) of responsibilities between emergency response facilities.

Standard: Upon activation facility personnel begin to make their facility functional using the associated facility procedures. Once functional the "oncoming" facility manager will accept responsibility for various tasks. It will depend on availability of personnel as to the tasks the facility can accept.

These tasks may include dose assessment calculations, emergency notifications, NRC notifications, Emergency Director duties (i.e.,

classifications, command and control), and the development of mitigation and repair strategy. Detailed, focused, timely, and accurate communications between the facility managers are critical to a successful transfer. A controlled and informed approach by each facility manager in addition to active participation by ERO personnel is needed to facilitate an effective turnover.

Complete H2 Demonstrate timely and effective status board updates.

Standard: ERO Personnel should update status boards at a minimum of every 10 minutes. They should also be updated as conditions change. Data that is not pertinent to the particular event should be marked "n/a" or Complete equivalent. Generally "blanks" on the board are not acceptable. All "broken" equipment should be identified. All facility personnel are expected to monitor the status boards for accuracy.

H3 Demonstrate the ability to inspect, inventory, and use of E-kits.

Standard: Equipment is inspected prior to use. Physical condition is checked, Complete equipment or damage. Inventories are performed in accordance with 67.000.405.

H4 Demonstrate adequate preparation and use of damage control teams.

Standard: OSC personnel should respond to requests from the Control Room and/or the TSC as necessary to form repair teams. Teams are dispatched upon Emergency Director approval. Teams are formed and briefed in accordance with EP-204-01. The goal for dispatch of a team is within approximately 15 minutes of request. Upon return the team will be debriefed discussing what actions were taken, damage control equipment status (inventory, etc.), and other pertinent information regarding the event.

H5 Demonstrate the ability to obtain current and forecast meteorological data.

Standard: IPCS is used to acquire current met data. Forecast data is acquired Complete from the Fermi Internet sources or via the National Weather Service using the phone number in the RERP Emergency Telephone Directory.

NRC-10-0061 Page 7 Evaluated Exercise - Actual Event Objective Review 11 Demonstrate accurate and timely dose assessment operations.

Standard: The ERO shall monitor radiation and meteorological data using available instrumentation. Careful scrutiny of all available information sources must occur. It is critical to correctly identify when a radioactive release actually begins. Players must recognize and validate any effluent monitor alarms as needed. Review of SP1NG data (including magnitude of activity), ventilation system operation(s), core damage estimates (CHRRMs) are critical in the calculation of dose to the public. Comparison of Actual and Potential dose calculations must be performed and reported to facility decision-makers in a timely manner. As conditions change or new information becomes available, timely analysis of potential impacts on the current response efforts must occur. Timely communication of all related information pertaining to a radioactive release must occur to ensure proper actions and assessments are made. This is a risk significant activity.

Complete 12 Demonstrate effective operations of the IPCS/SPDS system.

Standard: The ERO shall utilize the IPCS system to acquire information during the event. The ERO should be able to access available instrumentation Complete using the IPCS system for accident, dose and met data assessments. The ERO should be able use IPCS to identify most safety-related equipment that are out of service.

13 Demonstrate timely activation and dispatch on-site and off-site RETs.

Standard: On and Off-Site RETs are formed at the Alert declaration or earlier if needed. Each team prepares in accordance with EP-220. A brief is Not observed performed for each team. Radiological conditions, safety hazards, expected tasks, travel routes, met conditions are discussed. Teams are dispatched as needed to determine or verify radiological conditions outside of the plant.

15 Demonstrate effective plume tracking operations.

Standard: Plume tracking is performed in accordance with EP-220, Tab 2.

Plume tracking is required to be performed when a radiological release is Not observed likely, suspected or in progress. Good ALARA techniques must be demonstrated in order to keep personnel exposure low. All survey results must be reported quickly and accurately.

16 Demonstrate the performance and evaluation of portable air samples.

Standard: Portable air samples are performed in accordance with EP-220, Tab 4. Care must be exercised to prevent cross-contamination of samples.

Personnel must perform good ALARA techniques to keep their exposure low.

Not observed Survey data must be communicated quickly and accurately. Samples should be transported as soon as possible for counting by plant personnel for use in dose assessment operations as needed (nuclide data analysis).

NRC-10-0061 Page 8 Evaluated Exercise - Actual Event Objective Review eJl iy EPZ appropriate to the locale has [:ecii d\\

Recognize when to activate the on-site alarm system.

Standard: During a declared emergency the on-site alarm system will be activated by the Shift Manager to inform personnel of any on-site protective actions.

Complete J2 Formulate on-site protective actions.

Standard: Players shall review plant and weather conditions, radiological conditions, and/or dose assessment results, as needed using all available methods. Careful review of this information is critical in determining the Complete correct on-site protective action(s). Players shall determine the appropriate on-site protective actions for the scenario indications. Players shall review EP-530 to determine appropriate on-site protective actions.

J3 Demonstrate the ability to perform Assembly and Accountability in a timely manner.

Standard: Assembly and Accountability is required at an Alert (or higher) declaration. It is ordered by the Emergency Director and the Protected Area must be completed within 30 minutes of the order. It is complete when the Emergency Director is informed by Security that all personnel in the Protected Area are accounted for or when given a list of those personnel who are presumed missing.

J4 Formulate timely and accurate offsite protective action recommendations.

Standard: Players shall monitor plant conditions, radiological and meteorological conditions, including weather forecasts, dose assessment results, and RET survey data as the event progresses in order to identify possible PARs. Players shall review EP-545 to determine the appropriate PAR. Once the initial PAR is formulated it shall be communicated along with the initial notification to off-site authorities of the General Emergency.

Not observed Minimal time (<1 5 minutes) shall be taken once indications are available to recognize, evaluate, and communicate the PAR. Players should consider the impact of the increase traffic patterns as a potential hindrance and should report this condition to off-site authorities. Constant review of this information in addition to the information described in Enclosure A of EP-545 is essential in the evaluation of PAR adequacy. If a change in PAR is anticipated, minimal time (<15 minutes) shall be taken to recognize, evaluate, and communicate the new PAR. This is a risk significant activity.

NRC-10-0061 Page 9 Evaluated Exercise - Actual Event Objective Review J6 Demonstrate the ability to establish and implement appropriate radiological controls.

Standard: The ERO shall determine radiological conditions inside and outside of the plant as soon as practical. This is normally done by reviewing installed instrumentation to determine these conditions. Access controls are then developed and communicated to the ERO through regular briefings.

Normal radiological practices should be used whenever possible. As response teams are dispatched, further data is gathered and becomes available. These controls may become too stringent as to provide an effective and timely response by ERO personnel. Radiological controls can be modified based on this new data. In these cases the requirements of EP-201-03 may be

nrinlpmPnthq Complete y to apply the emergency exposure guidelines of EP-201-03.

Standard: Two separate guidelines can be used. One for saving property and one for life-saving situations. The Emergency Director or RPA may approve extensions up to the Federal Exposure limit whereas the Emergency Director is the only person who may authorize extensions beyond the Federal Exposure Guidelines. EP-201-03 details the requirements for these extensions and the limits involved.

Not observed K3 Demonstrate the ability to program emergency dose extensions into electronic dosimetry devices.

Standard: Whenever possible electronic dosimetry is the preferred method Not observed for tracking individual dose during response. Dose extensions can be programmed into electronic dosimetry by using the RERP Work Instruction "Administration of Electronic Dosimetry for Emergency Response Teams" 1

t4 NRC-10-0061 Page 10 Evaluated Exercise - Actual Event Objective Review NHUMA PERFORMANCE NI Job Briefs Standard: Job Briefs and its supporting tools help the supervisor and worker to recognize and address the risk of human error to safety and reliability. The Complete supporting tools include the following elements, Task Preview, Pre-Job Briefs, Turnover, Job Status Update, and Post Job Reviews.

N2 Self Checking Standard: Self Checking is a human performance tool that helps the performer focus attention on the appropriate component or task at hand. The tools used to Self Check are Flagging and STAR (Stop Think Act Review).

N3 Verification Techniques Standard: Verification techniques include Peer Check, Concurrent Verification, and Independent Verification. Verification techniques help to Complete prevent errors by a person, confirms equipment conditions and configuration, and to confirm the condition of a component before, during, and after an action.

N4 Effective Communication Standard: When communicating operational information important to safety and emergency response, effective communications are critical to ensure a Complete positive outcome. Effective communications consists of three-way communication and use of the phonetic alphabet.

N5 Questioning Attitude Standard: A questioning attitude fosters situation awareness, encouraging thought about safety before action is taken. Ask "Does this make sense?

Use in-field decision making by employing READE.

Recognize the degraded condition or uncertain situation that threatens safety.

Express the situation in terms of consequence, if left alone, related to plant safety and reliability or personal safety.

Appraise the situation, with a questioning attitude, to identify Complete conditions that could threaten safety.

Decide what to do to resolve the situation safely. Compare appraisal to critical parameters, safety limits, or abort criteria. Consider what absolutely has to go right.

Evaluate the effectiveness of the action(s) in achieving the desired results.

Another valuable method is Take Two which will improve a person's situation awareness particularly when first arriving at a job site.

NRC-10-0061 Page 11 Evaluated Exercise - Actual Event Objective Review N

!HUMN PERFRAC N6 Procedure Use and Adherence Standard: Procedure adherence means understanding the procedure's intent and purpose and following its direction. Procedure quality is paramount to safety and reliability. The completeness, accuracy, and internal consistency of the instructions, and its usability (easy to understand and follow) all impact Complete the user. Experience has shown that procedures do not always contain sufficient information. With this in mind, users follow procedures while mindful of the impact their actions could have on plant equipment before taking the actions.

NRC-10-0061 Page 12 Evaluated Exercise - Actual Event Objective Review Objectives Not Observed The following objectives were not observed:

a. Objective G: Public Education and information - Planning Standard GI: Demonstrate effective rumor control.

G2: Demonstrate the ability to conduct effective news media briefings.

G3: Demonstrate proper response to technical questions from the media.

G4: Demonstrate adequate security controls for the facility.

The objectives were not utilized because the intent is to exercise the Joint Information Center (JIC). The JIC was exercised during drills conducted in 2008, 2009, and 2010.

However, since a JIC is not activated at an Alert declaration, the intent of this objective to keep the public informed during the event was met by the following actions that occurred during the actual event:

The Unusual Event declaration and the first follow-up notification were both communicated to Nuclear Information by the MCR at 0359. There was no answer. The Shift Communicator left a voicemail explaining the current emergency status. Within minutes, the Shift Communicator tried again, reached Nuclear Information and relayed the information concerning the Unusual Event. At 0421, Nuclear Information was contacted for the Alert declaration.

Immediately upon notification of the Unusual Event, Nuclear Information relayed the information to Media Relations in the DTE Energy Headquarters in Detroit, MI. They conferred and put together a communication plan. Nuclear Information would handle questions concerning Fermi 2 and Media Relations would handle questions concerning Monroe County issues. They recognized that the Emergency Officer would have to approve any Press Releases prior to distribution.

At 0530, contacted the NRC Region III Public Affairs Office relaying information, what our communication plan consisted of, and coordinated with the NRC Communication Plan.

At 0725, the first Press Release was approved by the EOF EO for distribution.

At approximately 0830 and throughout the event, the following media outlets were in communication with Nuclear Information:

TV - Channels 2, 4, 7 (all Detroit), CBS News (New York), Weather Channel Atlanta)

Radio - WWJ, WJR (all Detroit)

Print - Monroe Evening News Misc - Dow Jones, Bloomberg News, AP (Associated Press)

NRC-10-0061 Page 13 Evaluated Exercise - Actual Event Objective Review

b. Under Objective I: Accident Assessment - Planning Standard, the following support objectives were not observed 13: Demonstrate timely activation and dispatch on-site and off-site RETs.

15: Demonstrate effective plume tracking operations.

16: Demonstrate the performance and evaluation of portable air samples.

During the actual event there was no radiological release. As a result, the above objectives were not exercised. However, the EOF dose assessors did initiate the dose assessment program using potential scenarios that could occur during the actual event conditions. Additionally, this objective was evaluated during drills conducted during 2008, 2009, and 2010.

c. Under Objective J: Protective Response - Planning Standard, the following support objectives were not observed J4: Formulate timely and accurate offsite protective action recommendations.

During the actual event there was no radiological release. As a result, the above objectives were not exercised during the actual event. However, these enabling objectives were evaluated during drills conducted during 2008, 2009, and 2010.

d. Objective K: Radiological Exposure Controls - Planning Standard K2: Demonstrate the ability to apply the emergency exposure guidelines of EP-201-03.

K3: Demonstrate the ability to program emergency dose extensions into electronic dosimetry devices.

During the actual event there was no radiological release. As a result, the above objectives were not exercised during the actual event. However, these enabling objectives were evaluated during drills conducted during 2008, 2009, and 2010.

NRC-10-0061 Page 14 Evaluated Exercise - Actual Event Objective Review Challenged Objective B2 Demonstrate the ability to staff the (Emergency Response Facility) in a timely manner.

Standard: The Technical Support Center shall achieve minimum staffing in accordance with EP-301-01. The Operational Support Center shall achieve minimum staffing in accordance with EP-302-01. The Emergency Operation Facility shall achieve minimum staffing in accordance with EP-303-01.

The EOF was activated within 97 minutes. The TSC was activated within 45 minutes. The OSC was activated within 79 minutes. This does not meet the standards set forth in the procedures.

ECOS was activated for the Unusual Event on June 6, 2010 at 0353. During an Unusual Event, ECOS contacted Operational Support Center (OSC) staff, Technical Support Center (TSC) minimum staff, RERP Advisors, NRC Resident Inspectors, Senior Management, and Nuclear Information personnel. While these people were in route to the site, the SM/ED declared an Alert at 0417.

ECOS was activated for the Alert on June 6, 2010 at 0430. The 13 minute delay between Alert declaration and ECOS activation in addition to road and weather conditions contributed in part to not meeting the Emergency Response Facility activation time requirements, per EP-302-01 and EP-301-01, for functionality. It was also noted that the loss of power led to difficulty in contacting ERO members via telephone. The delayed response of augmented personnel did not impact the control room's ability to operate the plant and ensure plant safety.

There were instances of ERO Green Team (the duty team) members not responding to ECOS, or to their emergency response facility, and/or arriving late. CARDs 10-24626 and 10-24665 were written to address these issues.

RERP Plan, B. 1.2, states, "It is the goal of Detroit Edison to augment Control Room staff by the Emergency Response Organization (Table B-I) in two groups of key personnel. The first group of key personnel should be in their Emergency Response Facility within 30 minutes of an Alert being declared However, there may be some conditions where up to 60 minutes may be required The second group of key personnel should be in place within 60 minutes of being declared" As evidenced by the road conditions left by the tornado (i.e. trees uprooted, wires down, some roads impassable, etc.) and testimony of personnel reporting to site during the event, conditions warranted their caution to drive slowly, take alternate routes, etc. The weather conditions, and the aftermath of the storm, resulted in a delayed response and augmentation.

to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 DRILL/EXERCISE COMPONENT CHECKLIST l"-I Drill Date:

Start Time:

F-Exercise Date:

Start Time:

Drill Setting: Actual Event - Alert - 06/06/10 A. Communications

1. State of Michigan

2. Wayne County

3. Monroe County

4. Offsite Field Teams

5. TSC

6. OSC

7. EOF

8. Alternate Facility E Alternate OSC

-- Alternate TSC F] Alternate EOF

9. JIC

10. Back-up Communications used D

D D

D D

El El El Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No El El NRC-10-0061 Page 2 DRILL/EXERCISE COMPONENT CHECKLIST B. Fire

1. Offsite assistance used

2. Onsite Fire Brigade response C. Medical

1. Onsite medical emergency

2. Offsite medical emergency

3. Involves a simulated contaminated individual(s)

4. First aid/rescue teams

5. Ambulance support

6. Hospital support Z

Mercy Memorial Hospital F-1 Oakwood Southshore Medical Center E-Yes Z No I-- Yes Z*No Z Yes F-1 No Z Yes F-1 No M] Yes ZNo Z Yes F-1 No Z Yes IF No Z Yes F-1 No NRC-10-0061 Page 3 DRILL/EXERCISE COMPONENT CHECKLIST D. Radiological/Health Physics Monitoring

1. Involves an offsite radioactive release

2. Plume tracking

3. Dose rate measurements

4. Contamination surveys

5. Emergency TLD collection (simulated)

6. Collection and analysis of air sample

7. Collection and analysis of environmental samples F--

Vegetation

['

Surface Water R

Snow F--

Soil F-1 Drinking Water

8. Radiological Exposure Controls FD El F-1 El Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No E. Miscellaneous Components

1. Shift staffing and augmentation

a. Activated ECOS

2. Notification of onsite and offsite responders

3. Accident detection and assessment El El NRC-10-0061 Page 4 DRILL/EXERCISE COMPONENT CHECKLIST

a. Classifications

[

Yes DNo

b. IPCS/SPDS Use

] Yes

]No

4. Radioactive release detection and assessment (dose assessment)

Z Yes DNo

a. Automatic method

-Yes Z*No

b. Manual method

[

Yes

]No

c. Forecast meteorology used

[

Yes

-No

d. Grab sample/nuclide data analysis

- Yes Z*No

5. Protective Response Z

Yes R No

a. Assembly and Accountability Z

Yes R No

b. PARS, including PAR changes E-Yes Z No

c. Facility Access Control/Security Z

Yes R No

6. Weather conditions (describe):

EFI Tornado on site

7. Security Force Response E-Yes Z No Describe threat:

8. Severe Accident Management Yes Z No

9. JIC Operations NRC-10-0061 Page 5 DRILL/EXERCISE COMPONENT CHECKLIST

a. Rumor Control F-- Yes

[No

b. Media Interface Yes

]No

c. Corporate Headquarters Support

[--

Yes

]No

10. Hazwoper Response

" Yes ZNo

11. OPA Response Yes

[No

12. Ingestion Exposure Pathway Drill El Yes

]No F. Six Year Components

1. Use of back-up power Yes

[No I--

TSC I-EOF

2. Recovery Organization

[

Yes DNo

3. Off-hours, between 1800 to 0400 Yes

-] No

4. Unannounced drill ZYes

-No

5. Limited site evacuation to offsite assembly areas Yes ZNo

6. Personnel Monitoring Team(s)

Yes SNo

7. KI distribution (on site only)

E-Yes

[Z No to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 Drill and Exercise Opportunities for the Actual Event Classifications and Notifications I

/A y

y 2

0346 0348 49 y

y 3

0417 (Alert) 0421 0422 34 y

y 4

0453 0457 35 y

y 5

0550 0554 57 y

y 6

0621 0623 29 y

y 7

0652 0652 29 y

y 8

0715 0718 26 y

y 9

0742 0743 25 y

y 10 0810 0812

.29 y

y 11 0831 0833 21 y

y 12 0855 0902 29 y

y 13 0917 0918 16 y

y 14 0940 0943 25 y

y 15 1037 1038 55 y

y 16 1134 1135 57 y

y 17 1228 1229 54 y

y 18 1313 1318 49 y

y 19 1406 1407 49 y

y NRC-10-0061 Page 2 Drill and Exercise Opportunities for the Actual Event Classifications and Notifications ZU 1I I1WI Y

y 21 1553 1557 56 y

y 22 1642 1645 48 y

y 23 1742 1742 57 y

y 24 1828 1831 49 y

y 25 1923 1924 53 y

y 26 2020 2022 58 y

y 27 2121 2122 60 y

y 28 2222 2224 62 y

y 29 2315 2318 54 y

y 30 0012 0013 55 y

y 31 0110 0112 59 y

y 32 0208 0209 57 y

y 33 020 Term 025 025 2

y 33 0220 (Term) 0235 0235 26 Y

Y to NRC-10-0061 Fermi 2 Exemption Request from the Biennial Emergency Preparedness Exercise Requirement in 10 CFR 50, Appendix E, Section IV.F.2.b NRC-10-0061 Page 1 Corrective Actions as a Result of the Actual Event A review of the Condition Assessment Resolution Document (CARD) database was performed to identify the CARDs written related to the event and associated damage. Additional CARDs may be written as further damage assessment and plant restoration continues.

CARD Title 10-24610 Building and equipment damage to NEIL insured structures 10-24611 Recorder T47R803A has no power and thus is INOP 10-24612 Aux bldg 5 th Floor stairwell wall exterior siding damaged due to damaging winds Turbine Bldg roof is damaged and the roof vents are open following high wind 10-24613 condition 10-24614 Fire Protection Riser pressure gauge damaged 10-24616 FO 10-02 Storm damage: Cooling tower materials & support building 10-24617 ARP 4D121 "345kV Bkr Pos CF Open" incorrectly states that CF breaker will trip on the generator under frequency signal 10-24618 FO 10-02 Storm Damage: N Cooling Tower 10-24619 FO 10-02 Storm Damage: S Cooling Tower 10-24620 ITC Personnel receives an electrical shock 10-24621 T46R9800B would not reset following loss of power 10-24622 Integrated Plant Computer System (IPCS) Server to external users (InfoServer) not responding 10-24624 HWC Tank Facility Walk-down 10-24625 Nitrogen Tank, 12-packs loose 10-24626 Request Evaluation of ECOS Timeliness of Callout 6/6/10 10-24627 Missed TRM Surveillance Requirements TRSR 3.4.5.1 10-24628 Guard House Gate 02 (GHG02) out of Alignment 10-24630 BOP Battery Charger 2C-1 Trouble Alarm 10-24631 BOP Battery Charger 2C 1-2 Trouble Alarm 10-24632 Minor EDG14 lube oil leaks 10-24633 On-Site Storage Facility Roof Penthouse Damage 10-24634 Blown output fuse for BOP Battery Charger 2C-1 10-24635 Debris on top of Low Pressure Turbine Hoods 10-24636 Request for Temporary Power on Auxiliary Bldg Roof 10-24637 Request for temporary power on Turbine Bldg Roof 10-24640 Covering of Main Generator Brushgear and RITA/Romon Skid 10-24644 Protected Area (PA) fence outrigger is bent causing barbed wire to sag 10-24646 Material Left in a Potentially Unsafe Condition 10-24648 3DMonicore Does Not Receive Scram Data from Rod Worth Minimizer Turbine valve fast closure scram due to loss of 345kV during tornado with 10-24656 subsequent Alert 10-24658 N6200F622, East OG Recombiner Outlet Isolation Valve Minor Oil Leak NRC-10-0061 Page 2 Corrective Actions as a Result of the Actual Event CARD Title 10-24660 Damage Assessment of REMP Sampling Equipment 10-24665 RERP Event: Untimely facility activation for Alert event of 06/06/10 10-24666 Loose insulation and debris on Auxiliary Building roof 10-24668 South TBHVAC Fan 10-24679 Potential Damage to RB5 East Wall Degrading trend in time taken to initiate Level 1 CARDs to Document Reactor 10-24680 Scrams 10-24685 Pressure gauge indicator needle is broken; fire hose station #RB-1, elv. 736' 10-24691 Safety concern not taken seriously.

10-24698 FO 10-02 Lessons Learned - Aux Building Blowout Panels 10-24703 FO 10-02 Storm Damage-Cooling Tower aircraft warning light guide cables 10-24710 RB SP1NG possible overheating from temporary weather covering 10-24717 Reactor Building Roof leaking rain water on to RB5 10-24718 Degraded Seals on OSB Windows Forced Outage 10-02, Emergent Issue, Below the Hook Lifting Device 10-24719 Inspection and Certification 10-24742 Green team members did not all show at TSC for the Alert on 6/6/20 10 10-24744 TSC staffing for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage issues 10-24745 Suggestions for improvement for TSC based on Alert on 6/6/2010 RERP Event: Failure to enter time of receipt of Alert indication in Control Rm.

10-24751 log 10-24752 ERO Phone Notification Enhancement 10-24756 Tornado damage to screen rack 10-24758 Evaluate potential airborne radiation dose to TB roof workers 10-24762 June 2010 ALERT Lesson Learned - Rechargeable Wireless Headsets 10-24765 Oxygen Pressure Gauge PI-57A 10-24831 RERP: State Liaisons during Long-Term Events