NRC-15-0070, DTE Electric Company'S Second Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number

DTE Electric Company'S Second Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-

ML15162A729
Person / Time
Site:	Fermi
Issue date:	06/11/2015
From:	Kaminskas V DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NRC-15-0070
Download: ML15162A729 (9)

Text

Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172

.' 7 Email: kaminskasv@dteenergy.com DTE Energy*

June 11 , 2015 10 CFR 50.54(£)

NRC-15-0070 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-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013 (Accession No. ML13130A067)

3) NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events," Revision 0, dated November 14, 2013 (Accession No. ML13304B836)

4) NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 7, 2013 (Accession No. ML13316A853)

5) DTE Electric Company letter, NRC-14-0043, "DTE Electric's Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014 (Accession No. ML14182A203)

6) DTE Electric Company letter, NRC-14-0075, "DTE Electric Company's First Six Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109)," dated December 18, 2014 (Accession No. ML14352Al 74)

USNRC NRC-15-0070 Page 2

Subject:

DTE Electric Company's Second Six-Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109)

On June 6, 2013, the U.S. Nuclear Regulatory Commission (NRC) issued an order (Reference 2) to DTE Electric Company (DTE). Reference 2 was immediately effective and directed DTE to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are provided in of Reference 2.

Reference 2 required submission of a Phase 1 Overall Integrated Plan pursuant to Section IV, Condition D.1. Reference 3 endorses industry guidance document NEI 13-02, Revision 0 (Reference 4) with clarifications and exceptions identified in Reference

3. Reference 5 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. References 3 and 4 provide direction regarding the content of the status reports. The first six-month status report was provided in Reference 6. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition D.3, of Reference 2, that delineates progress made in implementing the requirements of Reference 2. The Enclosure provides an update of milestone accomplishments since the submittal of Reference 6.

This letter contains no new regulatory commitments.

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

Christopher Robinson, Licensing Manager at (734) 586-5076.

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

Executed on June 11, 2015 Vito A. Kaminskas Site Vice President

USNRC NRC-15-0070 Page 3

Enclosure:

DTE Electric Companys Second Six-Month Status Report for the Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions 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-15-0070 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Electric Companys Second Six-Month Status Report for the Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

Enclosure to NRC-15-0070 Page 1 DTE Electric Companys Second Six-Month Status Report for the Implementation of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

1. Introduction DTE Electric Company (DTE) developed an Overall Integrated Plan (OIP) (Reference 8.1),

documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 8.2. This enclosure provides an update of milestone accomplishments since submittal of the Phase 1 OIP.

2. Milestone Accomplishments

• First Six-Month Status Report submitted (Reference 8.3)

• Design Change Package issued for Cycle 17/Refueling Outage 17 (RF17)

3. Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. Target completion dates provided in this section include updates from the OIP. This section provides the activity status of each item, and the expected completion date. The dates are planning dates and subject to change as design and implementation details are developed.

Milestone Target Activity Comments Completion Status Date Phase 1 HCVS Milestone Table Submit Overall Integrated Plan Jun 2014 Complete Reference 8.1 Submit 6 Month Updates:

Update 1 Dec 2014 Complete Reference 8.3 Update 2 Jun 2015 Complete Update 3 Dec 2015 On target Update 4 Jun 2016 On target Update 5 Dec 2016 On target Modifications:

Hold preliminary/conceptual design meeting Jun 2014 Complete Design Change Package issued for Cycle Mar 2015 Complete 17/RF17 Design Change implementation Cycle 17 Aug 2015 In progress Design Change implementation RF17 Nov 2015 On target Design Change Package issued for RF18 Mar 2016 In progress

Enclosure to NRC-15-0070 Page 2 Milestone Target Activity Comments Completion Status Date Design Change implementation RF18 Apr 2017 On target Walk Through Demonstration/Functional Jun 2017 On target Test Procedure Changes Operations Procedure Changes Developed Dec 2016 On target Site Specific Maintenance Procedure Dec 2016 On target Developed Procedure Changes Active Apr 2017 On target Training:

Training Complete Feb 2017 On target Completion HCVS Implementation Apr 2017 On target Submit Completion Report Jun 2017 On target

4. Changes to Compliance Method No changes in the compliance method for Fermi 2 have been made since the submittal of the Phase 1 OIP.

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 U.S. Nuclear Regulatory Commission (NRC) Interim Staff Evaluation (ISE)

The following table provides a summary of the open items documented in the Phase 1 OIP and the status of each item.

Overall Integrated Plan Phase 1 Open Item Status

1. Confirm thermal environment for actions using In progress Gothic

2. Confirm radiological environment In progress

3. Confirm suppression pool heat capacity In progress

4. Define tornado missile protection for Reactor In progress Building 5th floor (RB5) components

Enclosure to NRC-15-0070 Page 3 The following table provides a summary of the open items documented in the NRC ISE (Reference 8.4) of the Phase 1 OIP and the status of each item.

NRC Phase 1 ISE Open Item Status

1. Make available for NRC staff audit documentation Work in progress to resolve this confirming that all load stripping will be open item.

accomplished within one hour and fifteen minutes of event initiation and will occur at locations not impacted by a radiological event.

2. Make available for NRC staff audit an evaluation of Work in progress to resolve this Section 3.2.1 temperature and radiological conditions open item.

to ensure that operating personnel can safely access and operate controls and support equipment.

3. Make available for NRC staff audit, analyses Work in progress to resolve this demonstrating that HCVS has the capacity to vent the open item.

steam/energy equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.

4. Make available for NRC staff audit the descriptions Work in progress to resolve this of local conditions (temperature, radiation and open item.

humidity) anticipated during extended loss of alternating current (AC) power (ELAP) and sever accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.

5. Make available for NRC staff audit documentation of Work in progress to resolve this the HCVS nitrogen pneumatic system design open item.

including sizing and location.

6. Make available for NRC staff audit the final sizing Work in progress to resolve this evaluation for HCVS batteries/battery charger open item.

including incorporation into FLEX diesel generator (DG) loading calculation.

Enclosure to NRC-15-0070 Page 4 NRC Phase 1 ISE Open Item Status

7. Make available for NRC staff audit documentation Work in progress to resolve this that demonstrates adequate communication between open item.

the remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.

8. Provide a description of the final design of HCVS to Work in progress to resolve this address hydrogen detonation and deflagration. open item.

9. Provide a description of the strategies for hydrogen Work in progress to resolve this control that minimizes the potential for hydrogen gas open item.

migration and ingress into the reactor building or other buildings.

10. Make available for NRC staff review design details Work in progress to resolve this to ensure the potential for cross flow between HCVS open item.

and Standby Gas Treatment System (SGTS) is minimized.

11. Provide a justification for deviating from the Work in progress to resolve this instrumentation seismic qualification guidance open item.

specified in Nuclear Energy Institute (NEI) 13.02, endorsed, in part, by JLD-ISG-2013-02 as an acceptable means for implementing applicable requirements of Order EA-13-109.

12. Make available for NRC staff audit description of all Work in progress to resolve this instrumentation and controls (existing and planned) open item.

necessary to implement this order including qualification methods.

13. Make available for NRC staff audit documentation of Work in progress to resolve this an evaluation verifying the existing containment open item.

isolation valves, relied upon for the HCVS, will open under the maximum expected differential pressure during beyond design basis external events (BDBEE) and severe accident wetwell venting.

7. Interim Staff Evaluation Impacts There are no potential impacts to the ISE identified at this time.

Enclosure to NRC-15-0070 Page 5

8. References The following references support the updates to the Phase 1 OIP described in this enclosure:

8.1 DTE Electric Company letter, NRC-14-0043, DTE Electrics Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2014 (Accession No. ML14182A203) 8.2 NRC Order Number EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, dated June 6, 2013 (Accession No. ML13130A067) 8.3 DTE Electric Company letter, NRC-14-0075, DTE Electric Companys First Six Month Status Report in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions (Order Number EA-13-109), dated December 18, 2014 (Accession No. ML14352A174) 8.4 NRC Letter, Fermi, Unit 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents)

(TAC No. MF4362), dated April 1, 2015 (Accession No. ML15077A574)