NRC-13-0043, DTE Electric Company First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

DTE Electric Company First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13239A118
Person / Time
Site:	Fermi
Issue date:	08/26/2013
From:	Conner J DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-13-0043, EA-12-051
Download: ML13239A118 (2)

Text

J. Todd Conier Site Vice President DTE Energy Company 6400 N.Dixie highway, Newport, MI 48166 Tel: 734.586.4849 Fax: 734.586,5295 Email: connerj@dteenergy.com DTE Enrgy, 10 CFR 2.202 August 26, 2013 NRC-13-0043 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

References:

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

2) NRC Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

3) NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation,"

Revision 0, dated August 29, 2012

4) NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'," Revision 1, dated August 24, 2012

5) DTE Electric Company letter, NRC-12-0063, "Detroit Edison's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated October 19, 2012

6) DTE Electric Company letter, NRC-13-0006, "DTE Electric Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013

USNRC NRC-13-0043 Page 2

7) DTE Electric Company letter, NRC-13-0042, "Response to Request for Additional Information (RAI) Regarding the Overall Integrated Plan in Response to Order EA-12-051 'Reliable Spent Fuel Pool Instrumentation'," dated August 19, 2013

Subject:

DTE Electric Company First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 2) to DTE Electric Company (DTE). Reference 2 was immediately effective and directed DTE to install reliable spent fuel pool water level indication. Specific requirements are provided in Attachment 2 of Reference 2.

Reference 2 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 3) and an overall integrated plan pursuant to Section IV, Condition C. Reference 3 endorses industry guidance document NEI 12-02, Revision 1 (Reference 4) with clarifications and exceptions identified in Reference 3.

Reference 5 provided the DTE initial status report regarding mitigation strategies.

Reference 6 provided the DTE overall integrated plan. Reference 7 provided DTE responses to RAIs associated with Reference 6.

Reference 2 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 4 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 2, that delineates progress made in implementing the requirements of Reference 2. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

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

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

Sincerely, A0 5. P oa JMZ C.Cram

USNRC NRC-13-0043 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Mr. Robert J. Fretz, Jr., NRR/JLD/PMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Supervisor, Electric Operators, Michigan Public Service Commission

USNRC NRC-13-0043 Page 4 I, Kent C. Scott, 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.

Direct lear Production Nuclear ration On this 26th day of August, 2013 before me personally appeared Kent C. Scott, being first duly sworn and says that he executed the foregoing as his free act and deed.

'/

Notary Public SHARON S.MARSHALL NOTARY PUBLIC, STATE OF MI COUNTY OF MONROE MY COMMISSION EXPIRES Jun 14, 2019 ACTING INCOUNTY OF

Enclosure to NRC-13-0043 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Company's First Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation

Enclosure to NRC-13-0043 Page 1 DTE Electric Company's First Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation 1 Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (Reference 1 in Section 8),

documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI),

in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments None 3 Milestone Schedule Status The following provides a milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date. The dates are planning dates subject to change as design and implementation details are developed.

Target Activity Milestone Completion Status Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit Response to Request for Aug 2013 Complete*

Additional Information (RAI)

Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started Modifications:

Design Engineering Apr 2014 In-progress

Enclosure to NRC-13-0043 Page 2 Target Activity Milestone Completion Status Date Implementation Nov 2015 Not Started Procedures:

Create Procedures Nov 2015 Not Started Training:

Develop Training Plan Oct 2015 Not Started Training Complete Nov 2015 Not Started SFP LI Implementation Nov 2015 Not Started Submit Completion Report Jan 2016 Not Started

• See Open Items, Item 6 below, for follow-up RAI response schedule.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation DTE expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation Reference 3 provided a response to NRC Requests for Additional Information (RAI) regarding the Overall Integrated Plan (Reference 1). As stated in Reference 3, some of the requested information will be submitted with upcoming six month status updates reports, as shown below:

RAI Response Open Item Follow-up Response Schedule RAI-1b August 2014 RAI-3c August 2014 RAI-4c August 2014 RAI-6b August 2014 RAI-7a August 2014

Enclosure to NRC-13-0043 Page 3 RAI Response Open Item Follow-up Response Schedule RAI-8a February 2015 RAI-8b February 2015 RAI-8c February 2015 RAI-8d February 2015 RAI-10a February 2015 RAI-1Ob February 2015 RAI-11 February 2015 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure:

1. "DTE Electric's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," NRC-13-0006, dated February 28, 2013.

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

3. "Response to Request for Additional Information (RAI) Regarding the Overall Integrated Plan in Response to Order EA-12-051 'Reliable Spent Fuel Pool Instrumentation'," NRC-13-0042, dated August 19, 2013