ML102020164

License Amendment Request for Approval of the Northern States Power Company - Minnesota Cyber Security Plan

ML102020164
Person / Time
Site:	Monticello, Prairie Island
Issue date:	07/20/2010
From:	Salamon G Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
L-XE-10-007, TAC ME2702, TAC ME2773, TAC ME2774
Download: ML102020164 (24)

Text

/@ Xcel EnergyB 414 Nicollet Mall - MP4 Minneapolis, MN 55401 July 20, 2010 L-XE-10-007 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Monticello Nuclear Generating Plant Units 1 and 2 Docket 50-263 Dockets 50-282 and 50-306 Renewed License No. DPR-22 License Nos. DPR-42 and DPR-60 License Amendment Request (LAR) for Approval of the Northern States Power Company - Minnesota (NSPM) Cvber Securitv Plan (TAC Nos. ME2702, ME2773, and ME2774)

References:

1. Letter from Northern States Power Company, a Minnesota corporation (NSPM) to the Nuclear Regulatory Commission (NRC),

"Request for Approval of the Northern States Power Company -

Minnesota (NSPM) Cyber Security Plan," dated November 23, 2009.

2. Letter from NSPM to the NRC, "Supplement to License Amendment Request (LAR) for Approval of the Northern States Power Company

- Minnesota (NSPM) Cyber Security Plan," dated January 14, 2010, Accession Number MLI 00150644.

3. Letter from the NRC to NSPM, "Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, Units 1 And 2 - License Amendment Request for Approval of the Cyber Security Plan (TAC Nos. ME2702, ME2773, and ME2774)", dated May 21,2010, Accession Number MLI 01 170879.

In accordance with the provisions of 10 CFR Sections 50.4 and 50.90, and 10 CFR 73.54, NSPM, doing business as Xcel Energy, submits a request for amendments to the Facility Operating Licenses (FOL) for Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP), and Monticello Nuclear Generating Plant (MNGP). These proposed amendments request NRC approval of the NSPM Cyber Security Plan, provide a proposed Implementation Schedule, and add a sentence to the existing PINGP and MNGP FOL Physical Protection license conditions to require NSPM to fully implement and maintain in effect all provisions of the Commission approved Cyber Security Plan.

Pursuant to the provisions of Reference 3, the proposed Cyber Security Plan is consistent with NEI 08-09, Revision 6 and by this letter NSPM requests withdrawal of the license amendment request submitted in Reference 1 as supplemented by Reference 2.

Document Control Desk Page 2 provides an evaluation of the proposed changes. provides the proposed NSPM Cyber Security Plan Implementation Schedule with implementation milestones and basis for the milestone completion dates.

Note that the implementation milestone completion dates will be managed through NSPM's commitment management program. provides a copy of the proposed NSPM Cyber Security Plan which is a standalone document that will be incorporated by reference into the NSPM Physical Security Plans upon approval.

NSPM requests an implementation period of 90 days following NRC approval of the license amendments to make the proposed operating license changes. The proposed date when implementation of the cyber security plan will be complete and will enter the maintenance phase is provided as a License Condition in each plant's FOL.

In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR by transmitting a copy of this letter and enclosures to the designated State Official.

Please contact Mr. Dale Vincent, P.E., at 651-388-1 121 for any question regarding this submittal.

Summary of Commitments New commitments are provided in Enclosure 4. This letter contains no revisions to existing commitments.

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

Executed on July 20, 2010.

Gabor Salamon Director, Nuclear Licensing and Emergency Preparedness Northern States Power Company - Minnesota Enclosures (4) cc: Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC Project Manager, MNGP, USNRC Resident Inspector, MNGP, USNRC State of Minnesota

ENCLOSURE 1 Evaluation of the Proposed Change Request for Approval of the Northern States Power Company Minnesota (NSPM)

Cyber Security Plan

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION i 3. TECHNICAL EVALUATION I 4. REGULATORY ANALYSIS 4.1 Applicable Regulatory Requirementslcriteria 4.2 Significant Hazards Consideration 4.3 Conclusion

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS Attachment 1 - Prairie Island Nuclear Generating Plant marked-up Facility Operating License (FOL) pages Attachment 2 - Monticello Nuclear Generating Plant marked-up FOL pages Attachment 3 - Prairie Island Nuclear Generating Plant FOL pages in final typed format Attachment 4 - Monticello Nuclear Generating Plant FOL pages in final typed format Page 1 of 6

Enclosure 1 NSPM Cyber Security Plan 1 1.

SUMMARY

DESCRIPTION The proposed license amendment request (LAR) includes the proposed Northern States Power Company, a Minnesota corporation (NSPM), Cyber Security Plan (Plan),

a proposed Implementation Schedule, and a proposed sentence to be added to the existing Prairie Island Nuclear Generating Plant, Units 1 and 2 (PINGP), and the Monticello Nuclear Generating Plant (MNGP) Facility Operating Licenses (FOL)

Physical Protection license conditions.

I

2. DETAILED DESCRIPTION The proposed LAR includes three parts: the proposed Plan, a proposed Implementation Schedule, and a proposed sentence to be added to the existing FOL Physical Protection license condition to require NSPM to fully implement and maintain in effect all provisions of the Commission approved cyber security plan as required by 10 CFR 73.54. A Federal Register notice issued the final rule that amended 10 CFR Part 73.

The regulations in 10 CFR 73.54, "Protection of digital computer and communication systems and networks," establish the requirements for a cyber security program. This regulation specifically requires each licensee currently licensed to operate a nuclear power plant under Part 50 of this chapter to submit a cyber security plan that satisfies the requirements of the Rule. Each submittal must include a proposed implementation schedule and implementation of the licensee's cyber security program must be consistent with the approved schedule. The background for this application is addressed by the NRC Notice of Availability published on March 27, 2009, 74 FR 13926 (Reference 1).

3. TECHNICAL EVALUATION Federal Register notice 74 FR 13926 issued the final rule that amended 10 CFR Part

73. Cyber security requirements are codified as new 10 CFR 73.54 and are designed to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks up to and including the design basis threat established by 10 CFR 73.1(a)(l)(v). These requirements are substantial improvements upon the requirements imposed by EA-02-026 (Reference 2).

NRC issued Regulatory Guide 5.71, "Cyber Security Programs for Nuclear Facilities",

January 2010, which provides an approach the NRC staff deems acceptable for complying with the Commission's regulations for protecting digital computers, communications systems, and networks. The Nuclear Energy Institute (NEI) issued NEI 08-09, "Cyber Security Plan for Nuclear Power Reactors ", (Reference 3) for use by licensees in development of their own cyber security plans.

Page 2 of 6

Enclosure 1 NSPM Cyber Security Plan This LAR includes the proposed Plan (Enclosure 3 of the cover letter) that conforms to the template provided in NEI 08-09 (Reference 3) with one deviation discussed below.

In addition the LAR includes the proposed change to the existing PINGP and MNGP FOL license conditions for "Physical Protection" (Attachments 1 through 4). Finally, the LAR contains the proposed lmplementation Schedule (Enclosure 2 of the cover letter) as required by 10 CFR 73.54. As shown in Enclosure 4 of the cover letter, the proposed lmplementation Schedule implementation milestone completion dates will be managed through NSPM's commitment management program.

I The proposed NSPM Cyber Security Plan deviates from NEI 08-09, Revision 6, in that I the definition of "Cyber Attack" is included in the Plan which supersedes the definition I provided in Appendix B of NEI 08-09, Revision 6. The proposed definition of Cyber Attack complies with the guidance in Reference 4.

4. REGULATORY ANALYSIS

4. I Applicable Regulatory Requirements I Criteria This LAR is submitted pursuant to 10 CFR 73.54 which requires licensees currently licensed to operate a nuclear power plant under 10 CFR Part 50 to submit a Cyber Security Plan as specified in Sections 50.4 and 50.90.

4.2 Significant Hazards Consideration This license amendment request proposes changes to the Prairie Island Nuclear Generating Plant (PINGP), Units Iand 2, and Monticello Nuclear Generating Plant (MNGP) Facility Operating Licenses (FOLs) required by 10 CFR 73.54 (the Rule) and includes three parts. The first part is the submittal of the Cyber Security Plan (Plan) for NRC review and approval. The Plan conforms to the template provided in NEI 08-09, Revision 6, (except for the addition of the definition of "Cyber Attack") and provides a description of how the requirements of the Rule will be implemented at PINGP and MNGP. The Plan establishes the licensing basis for the Northern States Power Company, a Minnesota corporation (NSPM), Cyber Security Program for PINGP and MNGP. The Plan establishes how to achieve high assurance that nuclear power plant digital computer and communication systems and networks associated with the following are adequately protected against cyber attacks up to and including the design basis threat:

Safety-related and important-to-safetyfunctions, Security functions, Emergency preparedness functions including offsite communications, and Support systems and equipment which if compromised, would adversely impact safety, security, or emergency preparedness functions.

Page 3 of 6

Enclosure I NSPM Cyber Security Plan The second part of the proposed changes is a proposed Implementation Schedule.

The third part adds a sentence to the existing PlNGP and MNGP FOL license conditions for Physical Protection. Both of these changes are administrative.

NSPM has evaluated the proposed amendments using the criteria in 10 CFR 50.92 and has determined that the proposed amendments do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

I Response: No The proposed amendments incorporate new requirements in the Facility Operating Licenses (FOLs) to implement and maintain a Cyber Security Plan (Plan) as part of the facilities' overall program for physical protection, Inclusion of the Plan in the FOLs itself does not involve any modifications to the safety-related structures, systems or components (SSCs). Rather, the Plan describes how the requirements of 10 CFR 73.54 are to be implemented to identify, evaluate, and mitigate cyber attacks up to and including the design basis cyber attack threat, thereby achieving high assurance that the facilities' digital computer and communications systems and networks are protected from cyber attacks. The Plan and any plant modifications will not alter previously evaluated Updated Safety Analysis Report (USAR) design basis accident analysis assumptions, add any accident initiators, or affect the function of the plant safety-related SSCs as to how they are operated, maintained, modified, tested, or inspected. Therefore, the proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendments provide assurance that safety-related SSCs are protected from cyber attacks. Implementation of 10 CFR 73.54 and the inclusion of a Plan in the FOLs do not result in the need of any new or different USAR design basis accident analysis. It does not introduce new equipment that could create a new or different kind of accident, and no new equipment failure modes are created. As a result, no new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of these proposed amendments.

Therefore, the proposed amendments do not create a possibility for an accident of a new or different type than those previously evaluated.

Page 4 of 6

Enclosure 1 NSPM Cyber Security Plan

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The margin of safety is associated with the confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant pressure boundary, and containment structure) to limit the level of radiation to the public. The proposed amendments would not alter the way any safety-related SSC functions and would not alter the way the plants are operated. These amendments provide assurance that safety-related SSCs are protected from cyber attacks. The proposed amendments would not introduce any new uncertainties or change any existing uncertainties associated with any safety limit. The proposed amendments would have no impact on the structural integrity of the fuel cladding, reactor coolant pressure boundary, or containment structure. Based on the above considerations, the proposed amendments would not degrade the confidence in the ability of the fission product barriers to limit the level of radiation to the public. Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.

Based on the above considerations, Northern States Power Company, a Minnesota corporation (NSPM), concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusion In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION The proposed amendment establishes the licensing basis for a Cyber Security Program for PlNGP and MNGP and will be a part of the Physical Security Plans. This proposed amendment will not involve any significant construction impacts. Pursuant to 10 CFR 51.22(~)(12)no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

Page 5 of 6

Enclosure 1 NSPM Cyber Security Plan I 6. REFERENCES

1. Federal Register Notice, Final Rule 10 CFR Part 73, Power Reactor Security Requirements, published on March 27, 2009, 74 FR 13926.

2. EA-02-026, Order Modifying Licenses, Safeguards and Security Plan Requirements, issued February 25, 2002.

3. NEI 08-09, "Cyber Security Plan for Nuclear Power Reactors", Revision 6, April 2010.

I I 4. Letter from Christopher Earls (NEI) to Richard Correia (NRC), "NEI 08-09, Revision 6, 'Cyber Security Plan for Nuclear Power Reactors,' April 2010",

dated June 2,201 0, Accession Number MLI 01550061.

Page 6 of 6

ENCLOSURE I,ATTACHMENT 1 Prairie Island Nuclear Generating Plant Facility Operating License Pages (Markup)

Unit I, page 4 Unit 1, page 5 Unit 2, page 4 Unit 2, page 5 4 pages follow

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire I protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29,1980, July 28, 1981, October 27,1989, and October 6, 1995, subject to the following provision:

NSPM may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 188, are hereby incorporated into this license. NSPM shall I operate the facility in accordance with the Additional Conditions.

(6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance 2 . Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures Unit 1 Amendment No. 4-88

(c) Actions to minimize release, to include consideration of:

I.Water spray scrubbing

2. Dose to onsite responders 0 This license is effective as of the date of issuance and shall expire at midnight August 9,2013, FOR THE ATOMIC ENERGY COMMISSION Original Signed by Roger S Boyd A. Giarnbusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B Additional Conditions Date of Issuance: April 5, 1974 Unit 1 Amendment No, 44%

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire I

protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units Iand 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29,1980, July 28, 1981, October 27,1989, and October 6, 1995, subject to the following provision:

NSPM may make changes to the approved Fire Protection Program I without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 177, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

(6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance 2 . Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures Unit 2 Amendment No. 47-7

(c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

2. D This license is effective as of the date of issuance and shall expire at midnight October 29, 2014.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: October 29, 1974 Unit 2 Amendment No. 442

, qnw

-v I

ENCLOSURE 1, ATTACHMENT 2 Monticello Nuclear Generating Plant Facility Operating License Pages (Markup) 2 pages follow

2 Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensee's filings dated August 16, 1974 (those portions dealing with handling of reactor fuel) and August 17, 1977 (those portions dealing with fuel assembly storage capacity);

3 Pursuant to the Act and 10 CFR Parts 30,40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; 4 Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and

5. Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 1775 megawatts (thermal).

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment N o . , are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. Phvsical Protection NSPM shall implement and maintain in effect all provisions of the Commission

-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p)(2). The combined set of plans, which contain Safeguards Renewed License No. DPR-22 Amendment No. 4-tlw- -

Information protected under 10 CFR 73.21, are entitled: "Monticello Nuclear Generating Plant Physical Security, Training and Qualification, and Safeguards Contingency Plan," with revisions submitted through May 12, 2006.

4. Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report for the facility and as approved in the SER dated August 29, 1979, and supplements dated February 12, 1981 and October 2, 1985, subject to the following provision:

NSPM may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

5. Emergency Pre~arednessPlan NSPM shall follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix El including amendments and changes made pursuant to the authority of 10 CFR 50.54(q). The licensee shall meet the requirements of 10 CFR 50.54(s), 50.54(t), and 50.54(u).

TMI Action Plan NSPM has satisfactorily met all TMI-2 Lessons Learned Category " A requirements applicable to the facility. NSPM shall make a timely submittal in response to the letter dated October 31, 1980 regarding post-TMI requirements from Darrell G. Eisenhut, Director, Division of Licensing, Office of Nuclear Reactor Regulation to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits (NUREG-0737).

7. Repairs to the Recirculation System P i ~ i n g The repairs to the recirculation system piping are approved and the unit is hereby authorized to return to power operation, subject to the following condition:

Prior to the startup of Cycle 11, NSPM shall submit by August 1, 1983 for the Commission's review and approval, a program for inspection and/or modification of the recirculation system piping.

Renewed License No. DPR-22 Amendment No.

ENCLOSURE 1, ATTACHMENT 3 Prairie Island Nuclear Generating Plant Facility Operating License Pages (Retyped)

Unit 1, page 4 Unit 1, page 5 Unit 2, page 4 Unit 2, page 5 4 pages follow

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved NSPM cyber security plan by December 1,2014.

1 (4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29,1980, July 28, 1981, October 27,1989, and October 6, 1995, subject to the following provision:

NSPM may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

I (5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 188, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

(6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance 2 . Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures Unit 1 Amendment No.

(c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

2. D. This license is effective as of the date of issuance and shall expire at midnight August 9,2013.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by Roger S Boyd A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: April 5, 1974 Unit I Amendment No.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved NSPM cyber security plan by December 1,2014. I (4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29,1980, July 28, 1981, October 27,1989, and October 6, 1995, subject to the following provision:

NSPM may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 177, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

(6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance 2 . Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures Unit 2 Amendment No.

(c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders

2. D. This license is effective as of the date of issuance and shall expire at midnight October 29, 2014.

FOR THE ATOMIC ENERGY COMMISSION Original Signed by A. Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

1. Appendix A - Technical Specifications

2. Appendix B - Additional Conditions Date of Issuance: October 29, 1974 Unit 2 Amendment No.

ENCLOSURE 1, ATTACHMENT 4 Monticello Nuclear Generating Plant Facility Operating License Pages (Retyped) 2 pages follow

Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensee's filings dated August 16, 1974 (those portions dealing with handling of reactor fuel) and August 17, 1977 (those portions dealing with fuel assembly storage capacity);

3 Pursuant to the Act and 10 CFR Parts 30,40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; 4 Pursuant to the Act and 10 CFR Parts 30,40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and 5 Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 1775 megawatts (thermal).

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment N o . , are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

Phvsical Protection NSPM shall implement and maintain in effect all provisions of the Commission

-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(~)(2).The combined set of plans, which contain Safeguards Renewed License No. DPR-22 Amendment No. -

Information protected under 10 CFR 73.21, are entitled: "Monticello Nuclear Generating Plant Physical Security, Training and Qualification, and Safeguards Contingency Plan," with revisions submitted through May 12, 2006.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved NSPM cyber security plan by December I , 2014.

Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report for the facility and as approved in the SER dated August 29, 1979, and supplements dated February 12,1981 and October 2, 1985, subject to the following provision:

NSPM may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

5. Emergency Preparedness Plan NSPM shall follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, including amendments and changes made pursuant to the authority of 10 CFR 50.54(q). The licensee shall meet the requirements of 10 CFR 50.54(s), 50.54(t), and 50.54(u).

6. TMI Action Plan NSPM has satisfactorily met all TMI-2 Lessons Learned Category " A requirements applicable to the facility. NSPM shall make a timely submittal in response to the letter dated October 31, 1980 regarding post-TMI requirements from Darrell G. Eisenhut, Director, Division of Licensing, Office of Nuclear Reactor Regulation to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits (NUREG-0737).

7. Repairs to the Recirculation System Piping The repairs to the recirculation system piping are approved and the unit is hereby authorized to return to power operation, subject to the following condition:

Prior to the startup of Cycle 11, NSPM shall submit by August 1, 1983 for the Commission's review and approval, a program for inspection and/or modification of the recirculation system piping.

Renewed License No. DPR-22 Amendment No. -