ML17037D117

License Amendment Requests for Change in Emergency Plan Staff Augmentation Response Times Pre-Submittal Meeting for Prairie Island Nuclear Generating Plant Monticello Nuclear Generating Plant: February 7, 2017

ML17037D117
Person / Time
Site:	Monticello, Prairie Island
Issue date:	02/07/2017
From:	Xcel Energy
To:	Division of Operating Reactor Licensing
Kuntz R, 415-3373
References
Download: ML17037D117 (14)

Text

License Amendment Requests for Change in Emergency Plan Staff Augmentation Response Times Pre-Submittal Meeting for:

Prairie Island Nuclear Generating Plant Monticello Nuclear Generating Plant February 7, 2017 1

Participants Brian Carberry - PINGP EP Manager Lucas Anderson - MNGP EP Manager Marty Murphy - NSPM Director of Nuclear Licensing John Fields - Projects Licensing Engineer Monica Ray - EP Consultant 2

Agenda Pre-Submittal Meeting Purpose Emergency Plan Licensing Basis Proposed Emergency Plan Changes LAR Format LAR Schedule Conclusions Questions?

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Pre-Submittal Meeting Purpose Outline proposed Emergency Plan changes Discuss LAR Development / Content Review application of Industry Operating Experience for similar Licensing Amendment Requests 4

Emergency Plan Licensing Basis PINGP - E-Plan Status Last NRC Approved Plan - Revision 2, approved 12/27/1982 Current Emergency Plan is Revision 52 MNGP - E-Plan Status Last NRC Approved Plan - Revision 2, approved 1/20/1983 Current Emergency Plan is Revision 47 The LAR includes an analysis of NUREG-0654 Table B-1 functions as implemented in the Emergency Plan between the last approved and current revisions.

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Proposed Emergency Plan Changes Proposes an increase in augmentation staff response times from 30 and 60 minutes to 60 and 90 minutes Define facility activation criteria for TSC, OSC and EOF Removal of RP support coming from opposite site in a specified time frame Removal of Electrical Maintenance Responder and Radwaste Operator (PINGP only)

Removal of post-accident in-plant surveys by licensed operators (PINGP only) 6

Reason for Proposed Changes Increases in ERO augmented positions since 1982/1983 requires commensurate increase in the number of individuals required to meet Emergency Plan requirements PINGP E-Plan staffing levels Rev. 2 plan consisted of 52 augmented responders Current plan increases augmented responders by 200%

MNGP E-Plan staffing levels Rev. 2 plan consisted of 87 augmented responders Current plan increases augmented responders by 66%

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LAR Format LAR follows NEI 06-02, License Amendment Request (LAR) Guidelines Enclosures/Attachments include:

Technical Justification based on improvements in plant systems, procedures, dose assessment and training Functional analysis of Table B-1 Major Tasks Marked Up Copy of Affected Plan pages Clean Copy of Affected Plan pages Table B-1 Comparative Chart Letters of Offsite Response Organization Concurrence 8

Regulatory Guidance RG 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants NSIR/DPR-ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities 9

Industry Operating Experience Proposed changes to MNGP and PINGP E-Plans similar to changes approved by NRC for other licensees:

Susquehanna Fermi River Bend Watts Bar Point Beach Duane Arnold Energy Center (accepted for review only) 10

LAR Schedule Submittal of both LARs by 3/31/2017 Request approval by 4/30/2018 Propose a 180 day implementation period 11

Conclusions Proposed staffing continues to minimize impact of radiological emergencies and provide protection of public health and safety Supported by Technical Justification and Functional Analysis Revised Emergency Plan continues to meet

§50.54(q)(2), §50 Appendix E, and the planning standards of §50.47(b) 12

Questions?

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Acronyms E-Plan - Emergency Plan EOF - Emergency Operations Facility EP - Emergency Planning/Preparedness ERO - Emergency Response Organization LAR - License Amendment Request MNGP - Monticello Nuclear Generating Plant NEI - Nuclear Energy Institute NRC - Nuclear Regulatory Commission NSIR - Office of Nuclear Safety and Incident Response OSC - Operational Support Center PINGP - Prairie Island Nuclear Generating Plant RG - Regulatory Guide RIS - Regulatory Information Summary RP - Radiation Protection TSC - Technical Support Center 14