NRC-15-0014, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)

ML15056A399
Person / Time
Site:	Fermi
Issue date:	02/23/2015
From:	Kaminskas V DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NRC-15-0014
Download: ML15056A399 (8)

Text

Vito A. Kam,-inskas Site vie sdn DT~E EnryCopn Te5 734661 Fax '734,56472 DTE Ersergy February 23, 2015 10 CFR 2.202 NRC-15-0014 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-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ADAMS Accession No. ML12054A735)

3) NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174)

4) NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)

5) DTE Electric Company letter, NRC-12-0061, "Detroit Edison's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 19, 2012 (ADAMS Accession No. ML12296A041)

6) DTE Electric Company letter, NRC-13-0009, "DTE Electric's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013 (ADAMS Accession No. ML1306A262)

USNRC NRC-15-0014 Page 2

Subject:

DTE Electric Company's Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses 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" or "Commission")

issued an order (Reference 2) to DTE Electric Company (DTE). Reference 2 was immediately effective and directed DTE to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-bases external event. 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 12-06, Revision 0 (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 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-rnonth status report pursuant to Section IV, Condition C.2, of Reference 2, that delineates progress made in implementing the requirements of Reference 2. Enclosure 1 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 I. Burke, Manager, Industry Interface at (734) 586-5148.

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

Executed on Febru ry -x2015 W neA. C 1 nello Director - Nuclear Support For Vito A. Kaminskas

USNRC NRC-15-0014 Page 3 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-15-0014 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-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Enclosure to NRC-15-0014 Page 1 DTE Electric Company's Fourth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (OIP) (Reference 6),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the last six-month update, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2. Milestone Accomplishments Design engineering for the FLEX modifications and the storage buildings has been completed.

FLEX procedures have been created. Development of response strategies with the Regional Response Centers (RRC) has been completed.

3. Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. Target completion dates provided in this section include updates from previous six-month updates. 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 (Reference 5)

Submit Overall Integrated Plan Feb 2013 Complete6)

(Reference Submit 6 Month Updates:

Update 1 Aug 2013 Complete 7)

(Reference Update 2 Feb 2014 Complete (Reference 8)

Update 3 Aug 2014 Complete (Reference 9)

Enclosure to NRC-15-0014 Page 2 Target Activity Milestone Completion Status Date Update 4 Feb 2015 Complete Update 5 Aug 2015 Not Started FLEX Strategy Evaluation Walk through or Demonstrations Aug 2016 Not Started Perform Staffing Analysis Apr 2015 In-progress Modifications:

Design Engineering Dec 2014 Complete Implementation Nov 2015 In-progress Storage Storage Design Engineering Dec 2014 Complete Storage Implementation Nov 2015 In-progress FLEX Equipment Procure On-Site Equipment Aug 2015 In-progress Develop Strategies with RRC Feb 2015 Complete Procure Staging Location Apr 2015 In-progress Procedures:

Create Procedures Dec 2014 Complete Training:

Develop Training Plan Jul 2015 In-progress Training Complete Nov 2015 In-progress FLEX Implementation Nov 2015 In-progress Submit Completion Report Jan 2016 Not Started

4. Changes to Compliance Method No changes in the compliance method for Fermi 2 have been made since the update provided in the last six-month update (Reference 9).

Enclosure to NRC-15-0014 Page 3

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 Interim Staff Evaluation The following table provides a summary of the open items documented in the Interim Staff Evaluation (ISE) (Reference 10) and the status of each item.

ISE Open Item Status 3.1.1.1.A. Each section of the Integrated Plan describing As reported in Reference 8, the storage protection from hazards makes reference to OIP has been revised to refer to Section 11 rather than to the specific protection the specific requirements of NEI requirements described in NEI 12-06 for the applicable 12-06 hazard; that is Section 6.2.3.1 for floods, Section 7.3.1 for wind, etc.

3.2.2.A Until the issue of relying on blow-away panels As reported in Reference 8, means to prevent [over] pressurization of the RB-5 is provided to vent RB-5 have been added to there is no reasonable assurance that the plan will the Fermi 2 strategy and the OIP conform with NEI 12-06, Table C-3. has been revised accordingly.

3.2.3.B Revision 3 to the BWROG EPG SAG is a As reported in Reference 8, the Generic Concern because the BWROG has not addressed NRC generic concerns with the the potential for the revised venting strategy to increase revised venting strategy contained the likelihood of detrimental effects on containment in Revision 3 to the BWROG EPG response for events in which the venting strategy is SAG have been resolved. This invoked. [Note: For Fermi, containment venting is a venting strategy is being backup plan to torus feed and bleed discussed above.] incorporated into the Fermi 2 Emergency Operating Procedures.

At Fermi 2, use of containment venting is a back-up to the primary strategy.

7. References

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

2. NRC Order Number 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 (ADAMS Accession No. ML12054A735)

Enclosure to NRC-15-0014 Page 4

3. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12229A174)

4. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012 (ADAMS Accession No. ML12242A378)

5. DTE Electric Company letter, NRC-12-0061, "Detroit Edison's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 19, 2012 (ADAMS Accession No. ML12296A041)

6. DTE Electric Company letter, NRC-13-0009, "DTE Electric's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013 (ADAMS Accession No. ML1306A262)

7. DTE Electric Company letter, NRC-13-0044, "DTE Electric Company's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013 (ADAMS Accession No. ML13239A121)

8. DTE Electric Company letter, NRC-14-0002, "DTE Electric Company's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2014 (ADAMS Accession No. ML14059A350)

9. DTE Electric Company letter, NRC-14-0060, "DTE Electric Company's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 28, 2014 (ADAMS Accession No. ML14241A298)

10. NRC Letter, "Fermi, Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC No. MF0770), dated November 25, 2013 (ADAMS Accession No. ML13220A133)