ML073120503

Request for Additional Information Related to Proposed Revision to the Radiological Emergency Response Preparedness Plan

ML073120503
Person / Time
Site:	Fermi
Issue date:	01/07/2008
From:	Adrian Muniz NRC/NRR/ADRO/DORL/LPLIII-1
To:	Jennifer Davis Detroit Edison
muniz A, ADRO/DORL/415-4044
References
TAC MD5611
Download: ML073120503 (5)

Text

January 7, 2008

Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO PROPOSED REVISION TO THE RADIOLOGICAL EMERGENCY RESPONSE PREPAREDNESS PLAN (TAC NO. MD5611)

Dear Mr. Davis:

By letter to the Nuclear Regulatory Commission (NRC) dated May 14, 2007, Detroit Edison Company submitted a request to revise the Radiological Emergency Response Preparedness Plan, for Fermi 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on January 7, 2008, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC

=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4093.

Sincerely,

/RA/ Adrian Muniz, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-341

Enclosure:

Request for Additional Information

cc w/encl: See next page Mr. Jack M. Davis Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

SUBJECT:

FERMI 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO PROPOSED REVISION TO THE RADIOLOGICAL EMERGENCY RESPONSE PREPAREDNESS PLAN (TAC NO. MD5611)

Dear Mr. Davis:

By letter to the Nuclear Regulatory Commission (NRC) dated May 14, 2007, Detroit Edison Company submitted a request to revise the Radiological Emergency Response Preparedness Plan, for Fermi 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on January 7, 2008, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC

=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4093.

Sincerely, /RA/ Adrian Muniz, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-341

Enclosure:

Request for Additional Information cc w/encl: See next page

DISTRIBUTION:

PUBLIC LPL3-1 R/F RidsNrrDorlLpl3-1 RidsNRRPMAMuniz RidsNrrLATHarris RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr K. Williams, NSIR ADAMS Accession Number: ML073120503 OFFICE LPL3-1/PM LPL3-1/LA NSIR/DPR/DDEP/LIB/BC LPL3-1/(A)BC NAME AMuniz THarris KWilliams CMunson DATE 01/7/08 01/7/08 01/7/08 01/7/08 OFFICIAL RECORD COPY Fermi 2 cc:

David G. Pettinari Legal Department 688 WCB Detroit Edison Company 2000 2nd Avenue Detroit, MI 48226-1279

Michigan Department of Environmental Quality Waste and Hazardous Materials Division Radiological Protection and Medical Waste Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741

U.S. Nuclear Regulatory Commission Resident Inspector's Office 6450 N Dixie Highway Newport, MI 48166

Mr. M. V. Yudasz, Jr., Director Monroe County Emergency Management Division 965 South Raisinville Road Monroe, MI 48161

Ronald W. Gaston Manager, Nuclear Licensing Detroit Edison Company Fermi 2 - 200 TAC 6400 North Dixie Highway Newport, MI 48166

Supervisor - Electric Operators Michigan Public Service Commission P.O. Box 30221 Lansing, MI 48909

Wayne County Emergency Management Division 10250 Middlebelt Road Detroit, MI 48242

Mr. Joseph H. Plona Vice President - Nuclear Generation Detroit Edison Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, MI 48166

ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION FERMI 2 DOCKET NO. 50-341

In reviewing the Detroit Edison Company

=s (DeCo) submittal dated May 14, 2007 (Agencywide Documents Access and Management System Accession No. ML071430159), related to the proposed revision of the Fermi 2 (Fermi) Radiological Emergency Response Preparedness (RERP) Plan, the Nuclear Regulatory Commission (NRC) staff has determined that the following information is needed in order to complete its review:

1. Proposal 1 would eliminate the requirement for the Station Nuclear Engineer (previously the Reactor Engineer) from reporting to the site within 30 minutes. Part of the justification for this proposed change states that "Since the original approval of the RERP plan, training has greatly improved the Shift Technical Advisor's [STA] knowledge and capabilities. The STA's expertise allows for the Stat ion Nuclear E ngineer/Reactor Engineer requirement to be eliminated from the ERO [Emergency Response Organization] staffing." What are the training and qualification requirements for the Station Nuclear Engineer/Reactor Engineer position and how do these requirements compare to those for the STA position?

2. Proposal 1 states in part that "The STA can adequately respond to any accident to assure reactor safety until relieved by the Engineering Staff in the TSC [Technical Support Center]". By eliminating the 30-minute reporting requirement for the Station Nuclear Engineer, TSC Engineering Staff may not be available for up to 60 minutes following an Alert or higher declaration. What tasks are performed by the STA position during an emergency in addition to those previously performed by the Station Nuclear Engineer/Reactor Engineer? What was the basis for determining that the STA would be able to effectively perform these tasks for any accident until relieved by TSC Engineering Staff?

3. Proposal 3 states that one of two Support Engineers would be eliminated as a 60-minute responder. However, in the Fermi submittal identified as NRC-07-0009, Enclosure 1, Table 2, two Support Engineers are shown as of Revision 3A of the Fermi RERP and only one Support Engineer is shown as of Revision 32, indicating that this change was made in a previous revision to the emergency plan. Additional information is requested to clarify when this change occurred and the basis for the change at the time it was originally made.

4. Proposal 3 would provide for one Nuclear Safety Advisor (or Technical Engineer) and one Support Engineer to be available in the TSC within 60 minutes. Describe in more detail how typical technical support functions, such as electrical and mechanical engineering support, are addressed by TSC staffing under the current Fermi RERP.

How would these same technical support functions be addressed under Proposal 3?

5. Proposal 4 w ould eliminate the Emergency Operations Facility (E OF) Coordinator position, which is not an augmented ERO position. However, in the discussion of Proposal 4 it states that the EOF Coordinator position was eliminated in March 1988.

Additional information is requested to clarify the basis for the change at the time it was originally made and why NRC approval is being requested or is necessary now.

6. Proposal 4 states that "[T]he EOF Coordinator was identified as the person who directed activities in the EOF" and that this function is actually performed by the Emergency Officer. The Fermi RERP, Table B-2, Revision 3A, indicates that the EOF Coordinator performed other functions as well, including notifying government emergency response agencies and recommending protective measures to off-site emergency response organizations based on dose assessment. Additional information is requested to clarify how the other tasks that were performed by the EOF Coordinator have been addressed.