NRC-12-0022, Detroit Edison'S Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)

Detroit Edison'S Answer to March 12, 2012 Commission Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)

ML12094A050
Person / Time
Site:	Fermi
Issue date:	04/02/2012
From:	Plona J Detroit Edison, Co, DTE Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, NRC-12-0022
Download: ML12094A050 (4)

Text

Joseph H. Plona Site Vice President 6400 N.Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 10 CFR 2.202 April 02, 2012 NRC-12-0022 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

References:

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

2) NRC Letter EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

Subject:

Detroit Edison's Answer to March 12, 2012 Commission Order Modifying License With Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (Order Number EA-12-049)

On March 12, 2012, the Nuclear Regulatory Commission ("NRC") issued an immediately effective order in the captioned matter entitled "Order Modifying License with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately)" ("Order")to, inter alia, Detroit Edison. The Order states that, as a result of the NRC's evaluation of the lessons learned from the accident at Fukushima Dai-ichi in March 2011, the NRC has decided to direct nuclear power plant licensees and construction permit holders to take certain actions.

Specifically with respect to this Order, the NRC is requiring additional defense-in-depth measures at licensed nuclear power reactors to address uncertainties associated with protection from beyond-design-basis external events. Licensees are specifically directed by the Order to develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling in the event

USNRC NRC-12-0022 Page 2 of a beyond-design-basis external event. Specific requirements are outlined in to the Order.

The Order requires submission of an overall integrated plan including a description of how compliance with the requirements described in Attachment 2 will be achieved to the NRC for review by February 28, 2013. In addition, the Order requires submission of an initial status report-60 days following issuance of the final interim staff guidance and at six month intervals following submittal of an overall integrated plan on February 28, 2013. The Order states that the NRC intends to issue the interim staff guidance containing specific details on implementation of the requirements of this Order in August 2012. Finally, the Order requires full implementation of its requirements no later than two refueling cycles after submittal of the overall integrated plan, or December 31, 2016, whichever comes first.

Pursuant to 10 C.F.R. § 2.202 and the terms specified in the Order, Detroit Edison hereby submits its answer to the Order. Detroit Edison consents to the Order and does not request a hearing. Based on information currently available, Detroit Edison has not identified any circumstances of the type described in Sections IV.B.1 and IV.B.2 of the Order requiring relief at this time. In addition, Detroit Edison has not identified any impediments to compliance with the Order within two refueling cycles after submittal of the integrated plan, or December 31, 2016, whichever is earlier. Detroit Edison will provide further responses as required by Section IV.C. in accordance with the specified deadlines. However, due the unavailability of implementing guidance until August 2012, the ultimate scope of required work is uncertain. The potential impact on Detroit Edison's ability to comply with the specific compliance deadline dates depends on the availability of this guidance. Detroit Edison's future responses may include schedule relief requests as warranted by subsequent NRC requirements or implementing guidance or the results of engineering analyses not yet performed. Any such request would be submitted in accordance with the relaxation provision in Section IV of the Order.

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

Kirk R. Snyder, Manager, Industry Interface at (734) 586-5020.

Sincerely,

USNRC NRC-12-0022 Page 3 cc: Director, Office of Nuclear Reactor Regulation 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-12-0022 Page 4 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.

Josep H. Plona Site Vice President, Nuclear Generation M COUNTY OF MNO My Commission Expires April 4 2013 On this ___day of April o2,O/IA, 2012 before me personally appeared Joseph H. Plona, being first duly sworn and says that he executed the foregoing as his free act and deed.