NRC-15-0003, DTE Electric Company - Fermi, Unit 2 - Fourth 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 - Fermi, Unit 2 - Fourth 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)

ML15056A067
Person / Time
Site:	Fermi
Issue date:	02/23/2015
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NRC-15-0003
Download: ML15056A067 (7)

Text

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Die Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kamiskasvidteenergy.com 10 CFR 2.202 February 23, 2015 NRC-15-0003 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 Reliable Spent Fuel Pool Instrumentation,"

dated March 12, 2012 (ADAMS Accession No. ML12054A682)

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

Revision 0, dated August 29, 2012 (ADAMS Accession No. ML1221A339)

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, 2012 (ADAMS Accession No. ML12240A307)

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 (ADAMS Accession No. ML12296A040)

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 (ADAMS Accession No. ML13063A285)

USNRC NRC-15-0003 Page 2

Subject:

DTE Electric Company Fourth 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 spent fuel pool instrumentation. Reference 6 provided the DTE overall integrated plan.

Reference 2 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 4 provides direction regarding the content of the status reports. The purpose of this letter is to provide the fourth 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.

Kevin Burke, Manager, Industry Interface at (734) 586-5148.

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

Executed on Februar 2 2914 If 7, Wayne A. Colonnello Director -Nuclear Support For Vito A. Kaminskas Enclosure cc: Director, Office of Nuclear Reactor Regulation NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission Regulated Energy Division (kindschl@michigan.gov)

Enclosure to NRC-15-0003 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Company's Fourth 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-15-0003 Page 1 DTE Electric Company's Fourth 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 6), documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI), in response to Reference 2. This enclosure 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 The SFP LI has been installed and procedures associated with placing the instrument in service have been completed.

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 (Rfe c 5)

Submit Overall Integrated Plan Feb 2013 (Reference 6)

Submit Response to Request for Aug 2013 Complete Additional Information (RAI) (Reference 7)

Submit 6 Month Updates:

Update 1 Aug 2013 (Reference 8)

Update 2 Feb 2014 Complete (Reference 9)

Update 3 Aug 2014 Complete (Reference 10)

Enclosure to NRC-15-0003 Page 2 Target Activity Milestone Completion Status Date Update 4 Feb 2015 Complete Update 5 Aug 2015 Not Started Modifications:

Design Engineering Jul 2014 Complete Implementation Nov 2015 Complete Procedures:

Create Procedures Nov 2015 Complete Training:

Develop Training Plan Oct 2015 Complete Training Complete Nov 2015 In progress SFP LI Implementation Nov 2015 In progress Submit Completion Report Jan 2016 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 6).

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 Interim Staff Evaluation Reference 7 provided a response to NRC Requests for Additional Infonnation (RAI) regarding the Overall Integrated Plan (Reference 6). In Reference 11, the NRC provided an Interim Staff Evaluation (ISE) of the Overall Integrated Plan and the DTE responses to the RAIs (Reference 7). In Reference 12, the NRC announced that the review of Overall Integrated Plans would be conducted through an audit process. The audit is scheduled for the week of June 22, 2015.

Enclosure to NRC-15-0003 Page 3 7 References

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

2. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ADAMS Accession No. ML12054A682)

3. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML1221A339)

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, 2012 (ADAMS Accession No. ML1.2240A307)

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 (ADAMS Accession No. ML12296A040)

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 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 (ADAMS Accession No. ML13063A285)

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 (ADAMS Accession No. ML13231A233)

8. DTE Electric Company letter, NRC-13-0043, "DTE Electric Company First Six-Month 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 August 26, 2013 (ADAMS Accession No. ML13239A118)

9. DTE Electric Company letter, NRC-14-0001, "DTE Electric Company Second Six-Month 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 February 27, 2014 (ADAMS Accession No. ML14059A277)

10. DTE Electric Company letter, NRC-14-0059, "DTE Electric Company Third Six-Month 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 August 28, 2014 (ADAMS Accession No. ML14241A288)

Enclosure to NRC-15-0003 Page 4

11. NRC letter, "Fermi 2 -Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0771)," dated November 21, 2013(ADAMS Accession No. ML13309B129)

12. NRC letter, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051," dated March 26, 2014 (ADAMS Accession No. ML14083A620)