ML17023A065

Pre-Submittal Call Regarding License Amendment Requests for Prairie Island Nuclear Generating Plant, Units 1 and 2 and Monticello Nuclear Generating Plant Emergency Action Level Scheme Changes

ML17023A065
Person / Time
Site:	Monticello, Point Beach, Prairie Island
Issue date:	01/24/2017
From:	Xcel Energy
To:	Office of Nuclear Reactor Regulation
Kuntz R, DORL/LPL3, 415-3733
References
Download: ML17023A065 (12)

Text

Pre-Submittal Call License Amendment Requests for Prairie Island and Monticello Emergency Action Level Scheme Changes January 24, 2017 1

Agenda Pre-Submittal Call Purpose Current Licensing Basis Proposed Change LAR Content and Precedent Regulatory Requirements, Guidance, & EP FAQs LAR Schedule Conclusions 2

Pre-Submittal Call Purpose Communicate EAL scheme change LAR plans for Prairie Island and Monticello Outline proposed LAR format and content Discuss:

Regulatory Criteria Regulatory Guidance Current NRC staff positions (EP FAQs) 3

Current EAL Licensing Basis Prairie Island and Monticello Current EALs:

NEI 99-01, Rev 4, for non-security EALs NEI 99-01, Rev 5, for security EALs 4

Proposed EAL Changes Scheme change for both sites to adopt the NRC endorsed NEI 99-01, Rev 6 EALs Separate submittals for the sites Differences will be noted and explained Only deviations are approved based on EP FAQ responses (also noted and explained in the applications) 5

LAR Content and Precedent Two LARs Cover Letter Enclosure - Content per NEI 06-02 Attachment 1 - Differences and Deviations Attachment 2 - NEI 99-01 Rev 6 Mark-up Copy Attachment 3 - NEI 99-01 Rev 6 Clean Copy Attachment 4 - Supporting Calculations Attachment 5 - Wall Board (Information Only)

Precedent for NEI 99-01, Rev 6 LARs 6

Regulatory Requirements 10 CFR 50.47(b)(4) 10 CFR 50, Appendix E,Section IV.B.1 10 CFR 50, Appendix E, Section IV.B.2 10 CFR 50.90, 50.91 and 50.92 7

Regulatory Guidance RG 1.219, Revision 1, Guidance On Making Changes to Emergency Plans for Nuclear Power Plants NUREG-0654, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors NRC letter to NEI, US Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, dated November, 2012 RIS 2003-18, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, and its supplements NEI 06-02, License Amendment Request (LAR) Guidelines 8

Current EP FAQs LAR incorporates EP FAQs:

2015-003, 2015-004, 2015-005, and 2015-006 (MNGP) 2015-008, 2015-014, and 2015-015 (MNGP &

PINGP)

LAR does not incorporate EP FAQ 2015-013 EP FAQ reviewed but no changes at either site 9

LAR Schedule Both Prairie Island and Monticello:

Plan to submit separate applications by the end of the first quarter/beginning of second quarter 2017 Request a one year review Propose a 180 day implementation period for both facilities 10

Conclusions Proposed EAL scheme changes:

Based on NRC endorsed NEI 99-01, Rev 6 Provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency Continue to minimize impact of radiological emergencies and provide protection of public health and safety Revised Emergency Plans continue to meet:

Planning standards of 10 CFR 50.47(b) 10 CFR 50, Appendix E,Section IV.B 11

Acronyms CFR Code of Federal Regulations EAL Emergency Action Level EP Emergency Preparedness FAQ Frequently Asked Questions LAR License Amendment Request NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NUREG NRC technical report designation RG Regulatory Guide RIS Regulatory Issue Summary 12