ML13270A279

Issuance of Amendments Emergency Plan Changes

ML13270A279
Person / Time
Site:	Prairie Island
Issue date:	01/25/2014
From:	Scott Wall Plant Licensing Branch III
To:	Davison K Northern States Power Co
Wengert T
References
TAC MF0379, TAC MF0380
Download: ML13270A279 (13)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 25, 2014 Mr. Kevin Davison Site Vice President Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota 1717 Wakonade Drive East Welch, MN 55089-9642

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2-ISSUANCE OF AMENDMENTS RE: EMERGENCY PLAN CHANGES {TAC NOS.

MF0379 AND MF0380)

Dear Mr. Davison:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 210 to Renewed Facility Operating License No. DPR-42 and Amendment No. 198 to Renewed Facility Operating License No. DPR-60 for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, respectively. The amendments consist of changes to the facility operating licenses in response to your application dated December 13, 2012, as supplemented by letters dated June 21, 2013, and July 23, 2013.

The amendments revise the PINGP Emergency Plan by revising the emergency action level (EAL) initiating conditions for classification of liquid effluent releases and for the determination of fuel clad barrier loss. The first proposed change revises the action level for escalation to emergency classification Alert level due to releases from 200 times the Offsite Dose Calculation Manual (ODCM) alarm setpoint value to 60 times the ODCM value. The second proposed change revises the Fuel Clad Barrier Loss EAL to remove the indication from radiation monitor R-9 as an indicator of fuel clad barrier loss.

K. Davison A copy of the related safety evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Scott P. Wall, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosures:

1. Amendment No. 210 to DPR-42

2. Amendment No. 198 to DPR-60

3. Safety Evaluation cc: ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY- MINNESOTA DOCKET NO. 50-282 PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 210 License No. DPR-42

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Northern States Power Company, a Minnesota Corporation (NSPM, the licensee), dated December 13, 2012, as supplemented by letters dated June 21, 2013, and July 23, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 210, Renewed Facility Operating License No. DPR-42 is hereby amended to authorize revision to the Prairie Island Nuclear Generating Plant Emergency Plan as set forth in NSPM's application dated December 13, 2012, as supplemented by letters dated June 21, 2013, and July 23, 2013, and evaluated in the NRC staff's safety evaluation dated Jarruary zs, 2014. The license amendment is effective as of its date of issuance and shall be implemented within 90 days.

LEAR REGULATORY COMMISSION

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: January 25, 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY- MINNESOTA DOCKET NO. 50-306 PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 198 License No. DPR-60

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Northern States Power Company, a Minnesota Corporation (NSPM, the licensee), dated December 13, 2012, as supplemented by letters dated June 21, 2013, and July 23, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, by Amendment No. 198, Renewed Facility Operating License No. DPR-60 is hereby amended to authorize revision to the Prairie Island Nuclear Generating Plant Emergency Plan as set forth in NSPM's application dated December 13, 2012, as supplemented by letters dated June 21, 2013, and July 23, 2013, and evaluated in the NRC staff's safety evaluation dated January 25, 2014. The license amendment is effective as of its date of issuance and shall be implemented within 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION JwflJ ic J. Leeds, Director Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: January 25, 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 210 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-42 AND AMENDMENT NO. 198 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-60 NORTHERN STATES POWER COMPANY- MINNESOTA PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306

1.0 INTRODUCTION

By application dated December 13, 2012 (Reference 1), and as supplemented by letters dated June 21, 2013 (Reference 2), and July 23, 2013 (Reference 3), Northern States Power Company, a Minnesota corporation (NSPM, the licensee), doing business as Xcel Energy, proposed changes associated with the emergency action level (EAL} initiating conditions, RA 1.2, "VALl D reading on one or more of the following radiation monitors (Table R-1) that exceeds the reading shown for 15 minutes or longer" and Fission Product Barrier Fuel Clad Loss, "Other Indications," for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2.

EAL RA 1.2 includes a threshold that is beyond the capabilities of the stated instrument. The "Fuel Clad-Loss" criteria from the Fission Product Barrier Matrix includes a value that is inconsistent with the intent of this particular loss criteria. The proposed changes are intended to restore EAL RA 1.2 to be within the calibrated range of the instrument and to correct the inconsistency with the Fission Product Barrier Matrix.

The supplemental letters dated June 21, 2013, and July 23, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 4, 2013 (78 FR 14134).

2.0 REGULATORY EVALUATION

This safety evaluation addresses the impact of the proposed EAL changes to PINGP, Units 1 and 2. The regulatory requirements and guidance on which the NRC staff based its acceptance are as follows:

Enclosure 3

2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, "Emergency plans," sets forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1 )(i) state, in part, that:

... no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Section 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (4) of this section requires that a licensee's emergency response plan contain: "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."

Section 50.47(b)(4) of 10 CFR specifies a standard emergency classification and action level scheme, and as such, the NRC staff will ensure that implementation methods are relatively consistent throughout the industry for a given reactor and containment design while simultaneously providing an opportunity for a licensee to modify their EAL scheme as necessary to address plant-specific design considerations or preferences.

Section 50.54(q)(4) states, in part, that:

[C]hanges to a licensee's emergency plan that reduce the effectiveness of the plan ... may not be implemented without prior approval by the NRC. ... [A licensee's request for approval] must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in appendix E to [1 0 CFR part 50 and] the planning standards of § 50.47(b).

The Staff's review standards likewise are similar. Specifically, The NRC may approve a proposed emergency plan change that the licensee determined to be a reduction in effectiveness if the NRC can find that the emergency plan, as modified, continues to meet the requirements of Appendix E, and for nuclear power reactor licensees, the planning standards of§ 50.47(b),

and continues to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Final Rule, Enhancements to Emergency Preparedness Regulations, 76 Fed. Reg. 72,560, 72,577 (Nov. 23, 2011 ).

2.2 Guidance Revision 4 to Regulatory Guide 1.101, issued in July 2003, (Reference 4) endorses the guidance contained in the Nuclear Energy Institute (NEI) document NEI 99-01 "Methodology for Development of Emergency Action Levels," Revision 4, January 2003 (Reference 5), as an acceptable alternative method to that described in the following guidance for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4):

• Appendix 1 to NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Reference 6).

Regulatory Issue Summary (RIS) 2003-18, with Supplements 1 & 2, "Use of NEI 99-01, Methodology for Development of Emergency Action Levels," (Reference 7), provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, this RIS provides recommendations to assist licensees, consistent with Section IV.B to Appendix E of Part 50, in determining whether to seek prior NRC approval of deviations from the guidance.

3.0 TECHNICAL EVALUATION

3.1 Background The current NRC-approved emergency classification scheme for PINGP, Units 1 and 2, is based on NEI 99-01 (Revision 4) and was approved by letter dated November 18, 2005 (Reference 8).

The proposed changes would: (1) revise a setpoint for an Alert condition, such that indications are approximately 90 percent of the range of the instrumentation relied upon to make the declarations, and (2) remove the use of Reactor Coolant System (RCS) letdown radiation monitor R-9 as one criterion for determining the loss of the fuel clad barrier. The other criteria for loss of the fuel clad barrier continue to be applicable and valid.

As required by 10 CFR 50.54(q)(4), the licensee identified the reason for the changes as (1) to provide an indication of an EAL entry condition that is readily available for the operating staff and, (2) prevent an incorrect declaration of an EAL based on an overly conservative indication.

3.2 Evaluation 3.2.1 Requirements in Appendix E to 10 C.F.R. part 50 As required by 10 CFR 50.54(q)(4), the licensee provided its basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in Appendix E to 10 CFR Part 50. The proposed changes will provide for escalation of an event at the appropriate level for a liquid release and will continue to provide viable indications to determine the loss of the fuel clad fission product barrier. Therefore, PINGP will continue to meet the requirements of Appendix E to 10 CFR 50.

The fundamental basis of RA 1.2 is not a radiation dose or dose rate, but rather the potential or actual decrease in the level of safety of the plant implied by the uncontrolled release. EAL RA 1.2 is entered for a reading on the Waste Effluent [Radiation] Monitor, R-18, based on a liquid radioactive release of a level 200 times the Offsite Dose Calculation Manual (ODCM) alarm setpoint value. The approved emergency classification value is greater than the indicating range of the radiation monitor used for this purpose, resulting in either no emergency classification being made due to the inability to determine if the setpoint has been reached or an unnecessary declaration of an emergency classification due to the listed instrument exceeding its indicating range. The NRC staff finds that changing the classification based on 60 times the ODCM limit instead of 200 times for the liquid effluent monitor is within the range of the installed equipment and maintains a clear delineation between the Notice of Unusual Event and Alert classifications. This change will allow the licensee to use a more reliable indication that an EAL classification level criterion has been reached and will result in more accurate EAL declarations.

3.2.2 Planning Standards of 10 CFR 50.47(b).

As required by 10 CFR 50.54(q)(4}, the licensee provided its basis for concluding that the licensee's emergency plan, as revised, will continue to meet the planning standards of 10 CFR 50.57(b). The proposed change maintains the standard emergency classification and action level scheme and improves the facility parameters used for its basis.

The second change requests the removal of the RCS letdown radiation monitor R-9 indication of 10 rem per hour (R/hr) or greater from the Fission Product Barrier, Fuel Clad LOSS Column.

Other indications of loss of fuel clad integrity equate to an RCS activity for Dose Equivalent Iodine of 300 IJCi/gm. This RCS activity level would be equivalent to approximately 734 R/hr, as indicated by the RCS letdown monitor. The existing setpoint of 10 R/hr or greater represents the maximum scale of radiation monitor R-9. Therefore, an Alert declaration would be made, using this indication based on approximately one percent of the basis for all other indications of loss of the fuel clad barrier, resulting in an unnecessary declaration of an emergency classification. The NRC staff considers the classification of a loss of the fuel clad barrier based on approximately one percent of other criteria to be overly restrictive. The NRC staff also finds that the four remaining indications of the Fuel Clad Barrier Loss along with Emergency Director Judgment continue to provide specific and redundant indication of the loss of the cladding as a fuel barrier. In an actual loss of fuel cladding event, all of the listed indications would provide information of the loss. It takes only one of the indications to trigger an alert classification, so the deletion of the R-9 radiation monitor does not affect the licensee's ability to properly classify the event. The proposed change maintains the standard emergency classification and action level scheme and improves the facility parameters used for its basis.

3.2.3 Reasonable Assurance These changes constitute an improvement in the standard emergency classification and action level scheme and improve the facility parameters used for its basis. As such, the NRC staff finds that the revised PINGP emergency plan continues to provide reasonable assurance that adequate protective can and will be taken to protect plant personnel and the public in the unlikely event of an accident.

3.3 Conclusion The NRC staff performed a technical and regulatory review of the proposed changes to EALs RA1.2 and Fuel Clad Barrier Loss. The NRC staff concludes that: (1) changing the classification for EAL RA 1.2 to 60 times the ODCM limit and (2) removing the RCS letdown radiation monitor indication from the Fission Product Barrier, Fuel Clad LOSS Column is acceptable.

Therefore, the NRC staff has determined, based on the considerations discussed in the Evaluation section above, that the proposed change: (1) continues to meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards in 10 CFR 50.47(b); and (2) continues to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to use of a facility component located within the restricted area, as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (78 FR 14134). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

7.0 REFERENCES

1. Letter from NSPM to the U.S. Nuclear Regulatory Commission dated December 13, 2012, "License Amendment Request (LAR) to Revise Emergency Plan (EP) Emergency Action Levels (EALs): RA 1.2 and Fuel Clad Barrier Loss Criteria." (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12349A362).

2. Letter from NSPM to the U.S. Nuclear Regulatory Commission dated June 21, 2013, "Supplement to License Amendment Request (LAR) to Revise Emergency Plan (EP)

Emergency Action Levels (EALs): RA 1.2 and Fuel Clad Barrier Loss Criteria" (ADAMS Accession No. ML13172A404).

3. Letter from NSPM to the U.S. Nuclear Regulatory Commission dated July 23, 2013, "Supplement to License Amendment Request (LAR) to Revise Emergency Plan (EP)

Emergency Action Levels (EALs): RA1.2 and Fuel Clad Barrier Loss Criteria" (ADAMS Accession No. ML13205A309).

4. Regulatory Guide 1.101, Revision 4, "Emergency Planning and Preparedness for Nuclear Power Reactors." (ADAMS Accession No. ML032020276).

5. NEI 99-01, "Methodology for Development of Emergency Action Levels" Revision 4, January 2003. (ADAMS Accession No. ML041470143).

6. NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

(ADAMS Accession No. ML040420012).

7. Regulatory Issue Summary 2003-18, with Supplements 1 & 2, "Use of NEI 99-01, Methodology for Development of Emergency Action Levels." (ADAMS Accession Nos. ML032580518, ML041550395, and ML051450482).

8. Chawla, Mahesh L., U.S. Nuclear Regulatory Commission, Letter to Thomas J.

Palmisano, Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC dated November 18, 2005, "Prairie Island Nuclear Generating Plant, Units 1 and 2-Changes to Emergency Action Levels (TAC Nos. MC4930 and MC4931)."

(ADAMS Accession No. ML053080024).

Principal Contributors: D. Johnson M. Wasem Date: January 25, 2014

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