Text

Day Response to NRC Bulletin 2011-01: Mitigating Strategies
	ML111870102
Person / Time
Site:	Fermi
Issue date:	07/05/2011
From:	Plona J; DTE Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BL-11-001, NRC-11-0035
	Download: ML111870102 (17)
	v • d • e

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 10 CFR 50.54(f)

July 5, 2011 NRC-11-0035 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

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

2) NRC Bulletin 2011-01, "Mitigating Strategies,"

dated May 11, 2011

3) Detroit Edison's Letter to NRC, "Fermi 2 30-Day Response to NRC Bulletin 2011-01: Mitigating Strategies," NRC-11-0029, dated June 10, 2011

Subject:

Fermi 2 60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies The Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01 (Reference 2), to request each licensee to provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.54(hh)(2). Addressees were required to provide a written response to the NRC in accordance with 10 CFR 50.54(f).

In Bulletin 2011-01, the NRC requested each licensee to submit a written response within 30 days of the date of the Bulletin. The 30 day response for Fermi 2 was provided in Reference 3.

The attachment to this letter forwards the response requested within 60 days of the date of the Bulletin to provide information regarding mitigation strategies for 10 CFR 50.54(hh)(2). The enclosure includes information that addresses measures that are currently in place.

USNRC NRC-11-0035 Page 2 There are no new commitments included in this document.

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

Alan I. Hassoun, Manager - Nuclear Licensing at (734) 586-4287.

Sincerely,

Enclosure:

60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies 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

USNRC NRC-11-0035 Page 3 I, Joseph H. Plona, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Joseph H. Plona Site Vice President, Nuclear Generation On this 5 day of '--a 4- , 2011 before me personally appeared Joseph H. Plona, being first duly swdrn and says that he executed the foregoing as his free act and deed.

Notary Public W0cAMISSN EXPIRES Ju 14%,

MO1 A'TMNGo""POF

Enclosure to NRC-11-0035 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies

Enclosure to NRC-11-0035 Page 1 Detroit Edison's 60 Day Response to NRC Bulletin 2011-01: Mitigating Strategies:

On May 11, 2011, the NRC issued Bulletin 2011-01 "Mitigating Strategies." The Bulletin requested information to be provided within 60 days of the date of the Bulletin. Enclosed is Detroit Edison's response to the 60 day information request for Fermi 2.

The items described below represent current station practices. Individual items may be revised or adjusted in the future based on new or revised vendor recommendations or industry experience, in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0 "Commitment Management Guidelines."

The B.5.b procedures at Fermi 2 are known as "Extreme Damage Mitigation" (EDM) procedures. Fermi 2 utilizes procedures for all EDM strategies. The use of procedures instead of guidelines or work instructions requires the application of the controls contained in General Administrative Conduct Manual Chapter MGA02, "Procedures, Manuals and Orders." This conduct manual chapter establishes the responsibility for the preparation, review, approval and use of all site procedures.

NRC Request:

Within 60 days of the date of this bulletin, the NRC requests that licensees provide information regarding their mitigation strategies programs for 10 CFR 50.54(hh)(2).

In responding to the following questions, provide information that addresses measures that are currently in place, noting any additional planned actions with expected completion dates.

NRC Request 1:

1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.

Examples of the types of information to include when providing your response to Question (1) are:

a. Measures implemented to maintain the equipment, including periodicity.

b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Enclosure to NRC-11-0035 Page 2

Response

The maintenance activities listed below have been established to ensure that the procured B.5.b equipment can perform its intended function.

Equipment Maintenance Periodicity Basis EDM Fire Truck Inspected and tested by Annually Vendor recommendation Vendor using Dept. of Transportation Checklist and certified Emergency Vehicle Technicians EDM Fire Truck Inspected and tested by Annually Vendor recommendation Pump Vendor using Dept. of Transportation Checklist and certified Emergency Vehicle Technicians, National Fire Protection Association (NFPA) 24 EDM Storage Trailer Lubricate axle bearings Annually Good operating practice and move trailer to mix grease Fire hoses Check hose and Quarterly NFPA 1962 (2.5 inch, 4 inch, 5 couplings for damage inch) 100 feet of 6 inch Check hose and Quarterly NFPA 1962 suction hose (10 foot couplings for damage sections) for Fire Truck EDM Corrective Action As needed Generator/Inverter sets are Generator/Inverter Program as deficiencies based on tested monthly sets (2) are identified during test results testing or use EDM flanges, RHR Corrective Action As needed Flanges are inventoried and Hotwell Program as deficiencies based on quarterly are identified during inspection testing or use results Flashlights, plant Corrective Action As needed This equipment is tested radios, plant radio Program as deficiencies based on monthly charger, 800 MHz are identified during test results radios testing or use 2 Way Ball valve (4" Corrective Action As needed These valves are cycled Stortz with 2x 2.5" Program as deficiencies based on quarterly male outlets) are identified during test results testing or use

Enclosure to NRC-11-0035 Page 3 Equipment Maintenance Periodicity Basis Monitor Nozzles (4 Corrective Action As needed Monitor nozzles are tested Blitzfire Oscillating, Program as deficiencies based on monthly 1 on truck, 1 on are identified during test results trailer, 2 on RB5) testing or use Task Force Tips Corrective Action As needed In line flow indicators are (TFT) Fire Fighting Program as deficiencies based on tested monthly Equipment; Show- are identified during test results Flo 2.5" In line Flow testing or use Indicator Hand Pump Corrective Action As needed The hand pump is tested Program as deficiencies based on annually are identified during test results testing or use 1 Ton Chainfall, Replacement Annually Conduct Manual MMA07, 10' Nylon Straps "Hoisting, Rigging and Load Handling" Nitrogen Regulators Corrective Action As needed A functional check is Program as deficiencies based on performed every 2 years are identified during test results testing or use Power Independent Corrective Action As needed A functional check is Level Gauge (200" Program as deficiencies based on performed every 2 years WC Differential are identified during test results Pressure Gage) testing or use Fire Fighting Turnout Cleaning and inspection 2 year NFPA 1851 gear in RHR by vendor Complex Note:

Maintenance and Testing Guidance is contained in the following Fermi 2 procedures:

1. Fire Protection Procedure 28.508.06, "Weekly Inspection of EDM Equipment"

2. Fire Protection Procedure 28.508.07, "EDM Equipment Inspection"

3. Fire Protection Procedure 28.508.08, "EDM Fire Hose Hydrostatic Test and Inspection"

Enclosure to NRC-11-0035 Page 4 NRC Request 2:

2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.

Examples of the types of information to include when providing your response to Question (2) are:

a. A description of any testing accomplished to ensure the strategies were initially feasible.

b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement

c. A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Response

The following table is a description of testing accomplished to ensure the strategies' initial feasibility.

Strategy Description Fuel Pool External Makeup Time validation for EDM Fire Truck to move to location, setup, and EDM Fire Truck pump flow test Fuel Pool Spray EDM pump flow test was performed including spray pattern validation with Blitzfire oscillating monitors The following table describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Equipment Test Description Periodicity Basis EDM Fire Truck Tested by driving truck Weekly In accordance with for about 15 minutes Frenchtown Fire Dept.

each week recommendations Vendor truck inspection Annually

Enclosure to NRC-11-0035 Page 5 Equipment Test Description Periodicity Basis EDM Fire Truck Run in recirculation Weekly In accordance with Pump mode (tank to tank) Frenchtown Fire Dept.

April through October. recommendations Cycle truck valves Weekly manually, verify tire inflation (visual)

Run once per month Monthly with external flow during April through October, verify operation of emergency pump shutdown Vendor testing for pump Annually National Fire Protection certification Association (NFPA) 24 EDM Storage Trailer Lubricate axle bearings Annually Good operating practice and move trailer to mix grease 2.5, 4, 5 inch Fire Condition inspection Quarterly NFPA 1962 hoses Hydrostatic test of fire Hydro every hoses 3 years 100 feet of 6 inch Condition inspection Quarterly NFPA 1962 suction hose (10 foot sections) for Fire Truck Hydrant Connectors Rotate to verify Quarterly Good operating practice operation EDM Run Generator and Monthly Good operating practice Generator/Inverter Inverter, plug in cable, sets (2) verify voltage Flashlights, plant Turn on flashlights, Quarterly Good operating practice radios, plant radio transmit on plant radio charger, 800 MHz and 800Mhz radio, lights radios on charger 2 Way Ball valve (4" Cycle valve to verify Quarterly Good operating practice Stortz with 2x 2.5" operation male outlets)

Monitor Nozzles (4 Verify flow, range of Monthly Good operating practice Blitzfire Oscillating, motion during operation, 1 on truck, 1 on Verify shutoff operation trailer, 2 on RB5)

Enclosure to NRC-11-0035 Page 6 Equipment Test Description Periodicity Basis TFT Fire Fighting Verify flow during EDM Monthly Good operating practice Equipment; Show- truck flow testing Flo 2.5" In line Flow Indicator Turn on to verify Quarterly operation (AOV) remote Cycle the 3 way to Quarterly Good operating practice operation rig verify operation (3 way valve)

Hand Pump Perform fuel transfer Annual Good operating practice 1 Ton Chainfall, Replacement Annually Conduct Manual MMA07, 10' Nylon Straps "Hoisting, Rigging and Load Handling" Nitrogen Regulators Functional check 2 years Good operating practice Power Independent Functional check 2 years Good operating practice Level Gauge (200" WC Differential Pressure Gage)

Fire Fighting Turnout Cleaning and inspection 2 year NFPA 1851 gear in RHR by vendor Complex Adjustable wrenches, Operate to verify Quarterly Good operating practice socket set, pipe operation wrenches, bolt cutter Electrical: Stripper, Cycle to verify operation Quarterly Good operating practice crimper, cutter, pliers Multimeter Turn on to verify Quarterly Good operating practice operation Notes:

Maintenance and Testing Guidance is contained in the following Fermi 2 procedures:

1. Fire Protection Procedure 28.508.06, "Weekly Inspection of EDM Equipment"

2. Fire Protection Procedure 28.508.07, "EDM Equipment Inspection"

3. Fire Protection Procedure 28.508.08, "EDM Fire Hose Hydrostatic Test and Inspection"

The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending.

When an issue is identified, a condition report is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance level of the condition.

Enclosure to NRC-11-0035 Page 7 NRC Request 3:

3. Describe in detail the controls for assuring that the equipment is available when needed.

Examples of the types of information to include when providing your response to Question (3) are:

a. A description of any inventory requirements established for the equipment.

b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Response

In addition to the controls described in responses 1 and 2, procured non permanently installed EDM equipment is inventoried in accordance with station processes or procedures. This inventory assures that the items are stored in the proper quantities and location. (See Table below)

Inventory deficiencies are entered into the Corrective Action Program. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.

Quantity of items, locations and accessibility for all equipment is specified by procedures.

Equipment is stored on the EDM truck or in containers with tamper seals. Pressures and calibrations are specified in the response to question 2, equipment testing.

Equ t Inventory Special Storage Frequency Controls EDM Fire Truck Weekly Heated storage EDM Fire Truck Pump Weekly Heated storage EDM Storage Trailer Quarterly None 2.5 inch Fire hoses, 50 foot Quarterly Heated storage 4 inch Fire Hose, 50 foot Quarterly Heated storage 5 inch Fire Hose, 100 foot Quarterly Heated storage 6 inch suction hose (10 foot sections) for EDM Fire Truck Quarterly Heated storage EDM Generator/Inverter sets (2) Quarterly Heated storage EDM Flanges, RHR and Hotwell, with, gasket Quarterly None Plant radios Quarterly None Plant radio charger Quarterly None 800 MHz radios Quarterly None

Enclosure to NRC-11-0035 Page 8 Equ t Inventory Special Storage Frequency Controls 2 Way Ball valve ( 4" Stortz with 2x 2.5" male outlets) Quarterly None Monitor Nozzles (Blitzfire Oscillating) Quarterly None TFT Fire Fighting Equipment; Show-Flo 2.5" In line Flow Quarterly None Indicator Power Independent Level Gauge Quarterly None Hand Pump Quarterly None 1 Ton Chainfall Quarterly None 10' Nylon Straps Quarterly None Nitrogen Regulators Quarterly None Power Independent Level Gauge (200" WC Differential None Pressure Gage) Quarterly Fire Brigade Equipment, Firefighting turnout gear (RHR Quarterly None Complexony Complex only) Quarterly None Fire Brigade Equipment, Self Contained Breathing Apparatus Quarterly None (SCBA) (RHR Complex only)

Jumper Wire 12 AWG Quarterly N 2 Conductor 400 feet with plug on each end of wire Wire Terminations (Alligator Clips, harnesses, jumpers) Quarterly None Electrical tools (Wire stripper, crimper, cutter, Multimeter, per procedure) Quarterly Quary None Extension Cords Quarterly None Fall arrest harness Quarterly None Fire Hose Straps Quarterly None Fire Hose Rollers Quarterly None Fire Hose Spanner Wrenches Quarterly None Coupling Hydrant Connector 4-1/2" NST to 4" Storz Quarterly None Coupling P161 (4" NST Female to Stortz) Quarterly None Coupling P161 (aluminum 4" NPT to 4"NST double male) Quarterly None Hydrant Connector 4-1/2" Female NST to 4" Storz Quarterly None Hydrant Connector 4-1/2" Female NST to 5" Storz Quarterly None Pneumatic Jumpers (>30' with 3/4" couplings) Quarterly None Nylon Rope 100' length Quarterly None "Jerry" Cans (5 gallon, empty) Quarterly None Gasoline Safety Can (5 Gallon) (empty) Quarterly None Funnel Quarterly None Socket Wrenches Q y (3/4 inch set and breaker bar) Quary Air Operated Valve (AOV) remote operation rig (3 way valve, 6' supply, 300' instrument hose, 3' Vent hose) Quarterly None Quarte Ladders Quarterly None Floating strainers Quarterly None Instrument Hoses/Fittings, 0.25 inch Quarterly None Tool Haligan Bar to open doors Quarterly None

Enclosure to NRC-11-0035 Page 9 Inventory Special Storage Equipment Frequency Controls Flashlights Quarterly None Tygon Hose Quarterly None Adjustable Wrenches Quarterly None Valve Wrenches Quarterly None Pipe Wrenches Quarterly None Door wedges Quarterly None Screwdrivers Quarterly None Bolt Cutters Quarterly None Note:

Inventory Guidance is contained in the following Fermi 2 procedures:

1. Fire Protection Procedure 28.508.07, "EDM Equipment Inspection"

Enclosure to NRC-11-0035 Page 10 NRC Request 4:

4. Describe in detail how configuration and guidance management is assured so that strategies remain feasible.

Examples of the types of information to include when providing your response to Question (4) are:

a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.

b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.

c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.

d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Response

a. Plant configuration control is maintained utilizing Conduct Manual MES20, "Implementation of Modifications." A Procedure/Program Revision Notice (PPRN) is issued upon initial issuance and revisions to engineering documents that may impact plant procedures and programs. Engineering documents include Engineering Design Packages (EDPs), Technical Service Requests (TSRs), Equivalent Replacement Evaluations (EREs) , Installation-Replacement Installation Documents (I-RIDs), As-Built TSRs, and Design Calculations (DCs). A PPRN is issued to major site organizations including Operations, Fire Protection, Nuclear Security and Nuclear Training. The PPRN is reviewed for impact to programs, procedures, and training. Fermi 2 EDM strategies are contained in plant procedures. Any plant configuration changes will be reviewed for their effect on feasibility of the mitigating strategies.

b. Initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews. Subsequent procedure changes are validated to ensure that the guidelines remain viable.

Enclosure to NRC-11-0035 Page 11 A timed response of Fermi 2 procedure 29.EDM.03, "Spent Fuel Pool Makeup - External Strategy," was performed to ensure that the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time limit would be met. EDM pump flow test was performed including spray pattern validation with Blitzfire oscillating monitors.

c. The PPRN process described above ensures plant configuration changes will be reviewed for their effect on feasibility of the mitigating strategies procedures. Fermi 2 Conduct Manual MGA02, "Procedures, Manuals and Orders," controls how revisions to Fermi 2 procedures are performed. Technical reviews and commitment reviews are performed as part of the Document Change Request (DCR) process. Procedures listed as references to the procedure being revised are also reviewed to determine if they require revision as a result of the original procedure change. These measures ensure that the Fermi 2 EDM procedures remain up-to-date and consistent with the plant configuration.

d. Training in support of the mitigative strategies includes Non-Licensed Operators, Licensed Operators and Fire Brigade members. Non-licensed and Licensed operators are position qualified. All qualified individuals receive initial and continuing training for B.5.b. The continuing training elements are on a two year training frequency covered during requalification training.

The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.

Station Personnel Training Periodicity Evaluation Licensed Operator Initial training and continuing 2 year Informal evaluation Training training Non-Licensed Initial training and continuing 2 year Informal evaluation Operator Training training ERO - Key decision One time training of Emergency None Informal evaluation makers Officers, Emergency Directors in the TSC, and OSC Coordinators in 2008 Fire Brigade Large accelerant fed fires is Quarterly Fire Annual practice included in Fire Brigade training Brigade training, sessions.

Annual off site Annual unannounced Fire Brigade Fire Brigade Drill for training each shift Security Hostile Threat Drill held None Hostile Threat Drill 12/9/2009. Included Incident Critique Command Post activation, large accelerant fed fire, mass casualties.

Enclosure to NRC-11-0035 Page 12 NRC Request 5:

5. Describe in detail how you assure availability of off-site support.

Examples of the types of information to include when providing your response to Question (5) are:

a. A listing of off-site organizations you rely on for emergency response.

b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.

c. A listing of any training or site familiarization provided to off-site responders. This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Response

The following table describes the off-site support available in support of the mitigating strategies, methods of ensuring continuity of agreements, and off-site training and familiarization provided.

Off-site Organization Implementing Validation Training/Familiarization Document and Refresher /Periodicity Periodicity Frenchtown Fire Dept. Letter of Open ended Annual training conducted Agreement agreement for hospital and ambulance personnel Mercy Memorial Letter of Open ended Annual training conducted Hospital Agreement agreement for hospital and ambulance personnel Oakwood Southshore Letter of Open ended Annual training conducted Medical Center Agreement agreement for hospital and ambulance personnel

Enclosure to NRC-11-0035 Page 13 Off-site Organization Implementing Validation Training/Familiarization Document and Refresher /Periodicity Periodicity Monroe Community Letter of Open ended Annual training conducted Ambulance Agreement agreement for hospital and ambulance personnel Institute for Nuclear Letter of Open ended None Power Operations Agreement agreement (INPO) Nuclear Power Plant Emergency Response Voluntary Assistance Agreement Mutual Assistance Letter of Open ended None Agreement Between - Agreement agreement Detroit Edison, Entergy Nuclear Palisades LLC, Indiana Michigan Power US Department of Letter of Open ended None Energy ( Chicago Agreement agreement Operations Office)

Northwestern Ohio and Annually, One time Table Top Drill Michigan Mutual Aid Membership continuous (9/23/09)

District (NOMMAD) since 2008 BP Oil Toledo, Ohio Members of None None US Coast Guard Toledo NOMMAD Required Ohio General Electric GE SIL 324, Rev 6 None None Company BWR Required Emergency Support Program Note:

The letters of agreement and memberships identified above were re-validated in 2011 and are reviewed annually. Detroit Edison Letters of Agreement are open-ended agreements and as such, do not require renewal. There have been no lapsed Letters of Agreement or memberships from 2008.

Text

Joseph H. Plona Site Vice President 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 10 CFR 50.54(f)

July 5, 2011 NRC-11-0035 U. S. Nuclear Regulatory Commission Attention: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

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

2) NRC Bulletin 2011-01, "Mitigating Strategies,"

dated May 11, 2011

3) Detroit Edison's Letter to NRC, "Fermi 2 30-Day Response to NRC Bulletin 2011-01: Mitigating Strategies," NRC-11-0029, dated June 10, 2011

Subject:

Fermi 2 60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies The Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01 (Reference 2), to request each licensee to provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.54(hh)(2). Addressees were required to provide a written response to the NRC in accordance with 10 CFR 50.54(f).

In Bulletin 2011-01, the NRC requested each licensee to submit a written response within 30 days of the date of the Bulletin. The 30 day response for Fermi 2 was provided in Reference 3.

The attachment to this letter forwards the response requested within 60 days of the date of the Bulletin to provide information regarding mitigation strategies for 10 CFR 50.54(hh)(2). The enclosure includes information that addresses measures that are currently in place.

USNRC NRC-11-0035 Page 2 There are no new commitments included in this document.

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

Alan I. Hassoun, Manager - Nuclear Licensing at (734) 586-4287.

Sincerely,

Enclosure:

60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies 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

USNRC NRC-11-0035 Page 3 I, Joseph H. Plona, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Joseph H. Plona Site Vice President, Nuclear Generation On this 5 day of '--a 4- , 2011 before me personally appeared Joseph H. Plona, being first duly swdrn and says that he executed the foregoing as his free act and deed.

Notary Public W0cAMISSN EXPIRES Ju 14%,

MO1 A'TMNGo""POF

Enclosure to NRC-11-0035 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 60-Day Response to NRC Bulletin 2011-01: Mitigating Strategies

Enclosure to NRC-11-0035 Page 1 Detroit Edison's 60 Day Response to NRC Bulletin 2011-01: Mitigating Strategies:

On May 11, 2011, the NRC issued Bulletin 2011-01 "Mitigating Strategies." The Bulletin requested information to be provided within 60 days of the date of the Bulletin. Enclosed is Detroit Edison's response to the 60 day information request for Fermi 2.

The items described below represent current station practices. Individual items may be revised or adjusted in the future based on new or revised vendor recommendations or industry experience, in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04, Revision 0 "Commitment Management Guidelines."

The B.5.b procedures at Fermi 2 are known as "Extreme Damage Mitigation" (EDM) procedures. Fermi 2 utilizes procedures for all EDM strategies. The use of procedures instead of guidelines or work instructions requires the application of the controls contained in General Administrative Conduct Manual Chapter MGA02, "Procedures, Manuals and Orders." This conduct manual chapter establishes the responsibility for the preparation, review, approval and use of all site procedures.

NRC Request:

Within 60 days of the date of this bulletin, the NRC requests that licensees provide information regarding their mitigation strategies programs for 10 CFR 50.54(hh)(2).

In responding to the following questions, provide information that addresses measures that are currently in place, noting any additional planned actions with expected completion dates.

NRC Request 1:

1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.

Examples of the types of information to include when providing your response to Question (1) are:

a. Measures implemented to maintain the equipment, including periodicity.

b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Enclosure to NRC-11-0035 Page 2

Response

The maintenance activities listed below have been established to ensure that the procured B.5.b equipment can perform its intended function.

Equipment Maintenance Periodicity Basis EDM Fire Truck Inspected and tested by Annually Vendor recommendation Vendor using Dept. of Transportation Checklist and certified Emergency Vehicle Technicians EDM Fire Truck Inspected and tested by Annually Vendor recommendation Pump Vendor using Dept. of Transportation Checklist and certified Emergency Vehicle Technicians, National Fire Protection Association (NFPA) 24 EDM Storage Trailer Lubricate axle bearings Annually Good operating practice and move trailer to mix grease Fire hoses Check hose and Quarterly NFPA 1962 (2.5 inch, 4 inch, 5 couplings for damage inch) 100 feet of 6 inch Check hose and Quarterly NFPA 1962 suction hose (10 foot couplings for damage sections) for Fire Truck EDM Corrective Action As needed Generator/Inverter sets are Generator/Inverter Program as deficiencies based on tested monthly sets (2) are identified during test results testing or use EDM flanges, RHR Corrective Action As needed Flanges are inventoried and Hotwell Program as deficiencies based on quarterly are identified during inspection testing or use results Flashlights, plant Corrective Action As needed This equipment is tested radios, plant radio Program as deficiencies based on monthly charger, 800 MHz are identified during test results radios testing or use 2 Way Ball valve (4" Corrective Action As needed These valves are cycled Stortz with 2x 2.5" Program as deficiencies based on quarterly male outlets) are identified during test results testing or use

Enclosure to NRC-11-0035 Page 3 Equipment Maintenance Periodicity Basis Monitor Nozzles (4 Corrective Action As needed Monitor nozzles are tested Blitzfire Oscillating, Program as deficiencies based on monthly 1 on truck, 1 on are identified during test results trailer, 2 on RB5) testing or use Task Force Tips Corrective Action As needed In line flow indicators are (TFT) Fire Fighting Program as deficiencies based on tested monthly Equipment; Show- are identified during test results Flo 2.5" In line Flow testing or use Indicator Hand Pump Corrective Action As needed The hand pump is tested Program as deficiencies based on annually are identified during test results testing or use 1 Ton Chainfall, Replacement Annually Conduct Manual MMA07, 10' Nylon Straps "Hoisting, Rigging and Load Handling" Nitrogen Regulators Corrective Action As needed A functional check is Program as deficiencies based on performed every 2 years are identified during test results testing or use Power Independent Corrective Action As needed A functional check is Level Gauge (200" Program as deficiencies based on performed every 2 years WC Differential are identified during test results Pressure Gage) testing or use Fire Fighting Turnout Cleaning and inspection 2 year NFPA 1851 gear in RHR by vendor Complex Note:

Maintenance and Testing Guidance is contained in the following Fermi 2 procedures:

1. Fire Protection Procedure 28.508.06, "Weekly Inspection of EDM Equipment"

2. Fire Protection Procedure 28.508.07, "EDM Equipment Inspection"

3. Fire Protection Procedure 28.508.08, "EDM Fire Hose Hydrostatic Test and Inspection"

Enclosure to NRC-11-0035 Page 4 NRC Request 2:

2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.

Examples of the types of information to include when providing your response to Question (2) are:

a. A description of any testing accomplished to ensure the strategies were initially feasible.

b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement

c. A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

Response

The following table is a description of testing accomplished to ensure the strategies' initial feasibility.

Strategy Description Fuel Pool External Makeup Time validation for EDM Fire Truck to move to location, setup, and EDM Fire Truck pump flow test Fuel Pool Spray EDM pump flow test was performed including spray pattern validation with Blitzfire oscillating monitors The following table describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Equipment Test Description Periodicity Basis EDM Fire Truck Tested by driving truck Weekly In accordance with for about 15 minutes Frenchtown Fire Dept.

each week recommendations Vendor truck inspection Annually

Enclosure to NRC-11-0035 Page 5 Equipment Test Description Periodicity Basis EDM Fire Truck Run in recirculation Weekly In accordance with Pump mode (tank to tank) Frenchtown Fire Dept.

April through October. recommendations Cycle truck valves Weekly manually, verify tire inflation (visual)

Run once per month Monthly with external flow during April through October, verify operation of emergency pump shutdown Vendor testing for pump Annually National Fire Protection certification Association (NFPA) 24 EDM Storage Trailer Lubricate axle bearings Annually Good operating practice and move trailer to mix grease 2.5, 4, 5 inch Fire Condition inspection Quarterly NFPA 1962 hoses Hydrostatic test of fire Hydro every hoses 3 years 100 feet of 6 inch Condition inspection Quarterly NFPA 1962 suction hose (10 foot sections) for Fire Truck Hydrant Connectors Rotate to verify Quarterly Good operating practice operation EDM Run Generator and Monthly Good operating practice Generator/Inverter Inverter, plug in cable, sets (2) verify voltage Flashlights, plant Turn on flashlights, Quarterly Good operating practice radios, plant radio transmit on plant radio charger, 800 MHz and 800Mhz radio, lights radios on charger 2 Way Ball valve (4" Cycle valve to verify Quarterly Good operating practice Stortz with 2x 2.5" operation male outlets)

Monitor Nozzles (4 Verify flow, range of Monthly Good operating practice Blitzfire Oscillating, motion during operation, 1 on truck, 1 on Verify shutoff operation trailer, 2 on RB5)

Enclosure to NRC-11-0035 Page 6 Equipment Test Description Periodicity Basis TFT Fire Fighting Verify flow during EDM Monthly Good operating practice Equipment; Show- truck flow testing Flo 2.5" In line Flow Indicator Turn on to verify Quarterly operation (AOV) remote Cycle the 3 way to Quarterly Good operating practice operation rig verify operation (3 way valve)

Hand Pump Perform fuel transfer Annual Good operating practice 1 Ton Chainfall, Replacement Annually Conduct Manual MMA07, 10' Nylon Straps "Hoisting, Rigging and Load Handling" Nitrogen Regulators Functional check 2 years Good operating practice Power Independent Functional check 2 years Good operating practice Level Gauge (200" WC Differential Pressure Gage)

Fire Fighting Turnout Cleaning and inspection 2 year NFPA 1851 gear in RHR by vendor Complex Adjustable wrenches, Operate to verify Quarterly Good operating practice socket set, pipe operation wrenches, bolt cutter Electrical: Stripper, Cycle to verify operation Quarterly Good operating practice crimper, cutter, pliers Multimeter Turn on to verify Quarterly Good operating practice operation Notes:

Maintenance and Testing Guidance is contained in the following Fermi 2 procedures:

1. Fire Protection Procedure 28.508.06, "Weekly Inspection of EDM Equipment"

2. Fire Protection Procedure 28.508.07, "EDM Equipment Inspection"

3. Fire Protection Procedure 28.508.08, "EDM Fire Hose Hydrostatic Test and Inspection"

The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending.

When an issue is identified, a condition report is initiated, a management review team determines level of review required, and corrective actions are determined and implemented in accordance with the significance level of the condition.