ML17345A046

Issuance of Amendment No. 197 to Adopt Changes to the Emergency Plan (CAC No. MF9560; EPID L-2017-LLA-0184)

ML17345A046
Person / Time
Site:	Monticello
Issue date:	03/06/2018
From:	Robert Kuntz Plant Licensing Branch III
To:	Church C Northern States Power Company, Minnesota
Kuntz R, NRR/DORL/LPLIII
References
CAC MF9560, EPID L-2017-LLA-0184
Download: ML17345A046 (28)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 M:trch 6, 2018 Mr. Christopher Church Site Vice President Monticello Nuclear Generating Plant Northern States Power Company -

Minnesota (NSPM) 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT- ISSUANCE OF AMENDMENT NO. 197 TO ADOPT CHANGES TO THE EMERGENCY PLAN (CAC NO. MF9560; EPID L-2017-LLA-0184)

Dear Mr. Church:

The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 197 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant (Monticello). The amendment consists of changes to the Monticello emergency action level scheme in response to your application dated March 31, 2017, as supplemented by letter dated September 25, 2017.

The amendment revises the emergency action level scheme to one based on the Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 21, 2012. NEI 99-01, Revision 6, was endorsed by the NRC by letter dated March 28, 2013.

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

, nior Project Manager Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosures:

1. Amendment No. 197 to DPR-22

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 197 License No. DPR-22

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

A. The application for amendment submitted by Northern States Power Company (NSPM, the licensee), dated March 31, 2017, as supplemented by letter dated September 25, 2017, 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.

2. Accordingly, by Amendment No. 197, Renewed Facility Operating License No. DPR-22 is hereby amended to authorize revision to the Monticello Nuclear Generating Plant Site Emergency Plan as set forth in the licensee's application dated March 31, 2017, as supplemented by letter dated September 25, 2017, and evaluated in the NRC staff's safety evaluation enclosed with this amendment.

Enclosure 1

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION Brian E. Holian, Acting Director Office of Nuclear Reactor Regulation Date of Issuance: March 6, 2 O1 8

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 197 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By application dated March 31, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17095A107), as supplemented by letter dated September 25, 2017 (ADAMS Accession No. ML17269A076), Northern States Power Company (the licensee) requested changes to the Monticello Nuclear Generating Plant (Monticello)

Emergency Plan. The proposed changes would revise the emergency action level (EAL) scheme to one based on the Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ADAMS Accession No. ML12326A805). NEI 99-01, Revision 6, was endorsed by the U.S. Nuclear Regulatory Commission (NRC or the Commission) by letter dated March 28, 2013 (ADAMS Accession No. ML13091A209).

The supplemental letter dated September 25, 2017, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 6, 2017 (82 FR 26134).

2.0 REGULATORY EVALUATION

The applicable regulations and guidance for the emergency plans are provided in Sections 2.1 and 2.2 below.

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 reactors. 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.

Enclosure 2

Regulation 10 CFR 50.47(b) establishes the planning standards that the onsite and offsite emergency response plans must meet for NRC staff to make a finding 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)(4) of 10 CFR 50.47 requires that onsite and offsite emergency response plans meet the following standard:

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.

The regulation in 10 CFR 50.47(b)(4) requires the use of a standard emergency classification and action level scheme, assuring 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 its EAL scheme as necessary to address plant-specific design considerations or preferences.

The regulations in 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.B.1, states, in part:

The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant.

Section IV.B.2 of Appendix E to 10 CFR Part 50 states, in part:

A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change.

2.2 Guidance The EAL development guidance was initially established in Generic Letter 79-50, "Emergency Plans Submittal Dates," dated October 10, 1979 (ADAMS Accession No. ML031320278). This guidance was subsequently revised in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980 (ADAMS Accession No. ML040420012), which was originally endorsed by the NRC in Regulatory Guide (RG) 1.101, Revision 2, "Emergency Planning and Preparedness for Nuclear Power Reactors," dated October 31, 1981 (ADAMS Accession No. ML090440294 ), as an approach acceptable to the NRC for the development of an EAL scheme.

As industry and regulatory experience was gained with the implementation and use of EAL schemes, the industry issued revised EAL scheme development guidance to reflect lessons learned, numerous of which have been provided to the NRC for review and endorsement as generic (i.e., non-plant-specific) EAL development guidance. Most recently, the industry provided NEI 99-01, Revision 6, to the NRC, which the NRC staff endorsed by letter dated March 28, 2013, as acceptable generic (i.e., not plant-specific) EAL scheme development guidance.

Although the EAL development guidance contained in NEI 99-01, Revision 6, is generic and may not be entirely applicable for some light water reactor designs, it bounds the most typical accident/event scenarios for which emergency response is necessary in a format that allows for industry standardization and consistent regulatory oversight. Licensees may choose to develop plant-specific EAL schemes using NEI 99-01, Revision 6, with appropriate plant-specific alterations as applicable.

On October 8, 2003, the NRC issued Regulatory Issue Summary (RIS) 2003-18, "Use of NEI 99-01, 'Methodology for Development of Emergency Action Levels,' Revision 4, Dated January 2003" (ADAMS Accession No. ML032580518). The NRC subsequently issued Supplement 1 dated July 13, 2004, and Supplement 2 dated December 12, 2005 (ADAMS Accession Nos. ML041550395, and ML051450482, respectively). RIS 2003-18 and its supplements provide guidance for developing or changing a standard EAL scheme. In addition, this RIS and its supplements provide recommendations to assist licensees, consistent with Section IV.B.2 of Appendix E to 10 CFR Part 50, in determining whether to seek prior NRC approval when considering changes to its EAL scheme.

In summary, the NRC staff considers NEI 99-01, Revision 6, to be an acceptable method to develop plant-specific EALs that meet the requirements of Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), with the understanding that licensees may want to develop EALs that differ from the guidance document as allowed in RG 1.101.

2.3 NRC Staff Review In its application, the licensee proposes to revise the current Monticello EAL scheme to one based on NEI 99-01, Revision 6. In its application and supplemental letter, the licensee submitted the proposed EAL scheme, the technical basis containing an evaluation and rationale for each proposed EAL change, and a comparison matrix providing a line-by-line comparison of the proposed initiating conditions, mode applicability, and EAL wording for Monticello to that found in NEI 99-01, Revision 6. The comparison matrix also included a description of global changes applicable to the EAL scheme and a justification for any differences or deviations from NEI 99-01, Revision 6. The application states that the licensee used the terms "difference" and "deviation" as defined in RIS 2003-18, as supplemented, when comparing its proposed plant-specific EALs to the generic EALs in NEI 99-01, Revision 6.

The NRC staff verified that the proposed EAL scheme is consistent with the guidance provided in NEI 99-01, Revision 6, to assure that the proposed EAL scheme meets planning standard 10 CFR 50.47(b)(4) and the requirements of Section IV of Appendix E to 10 CFR Part 50. The NRC staff reviewed the proposed site-specific EAL scheme, technical basis, comparison matrix, and all additional information provided in the licensee's application and supplemental letter. The NRC staff found that both the current and proposed EALs have modifications from the NEI 99-01, Revision 6, guidance due to specific plant designs and licensee preference.

The NRC staff verified that the instrumentation and setpoints derived for this proposed EAL scheme are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme.

Although the EALs must be plant-specific, the NRC staff reviewed the proposed EALs for the following key characteristics of an effective EAL scheme to ensure consistency and regulatory stability:

• Consistency, including standardization of intent, if not in actual wording (i.e.,

the EALs would lead to similar decisions under similar circumstances at different plants);

• Human factors engineering and user-friendliness;

• Potential for emergency classification level upgrade only when there is an increasing threat to public health and safety;

• Ease of upgrading and downgrading the emergency classification level;

• Thoroughness in addressing and disposing of the issues regarding completeness and accuracy of Appendix 1 to NUREG-0654 (i.e., the EALs are unambiguous and are based on site-specific indicators);

• Technical completeness for each classification level;

• Logical progression in classification for multiple events; and

• The use of objective and observable values.

The NRC staff verified that risk assessments were appropriately used to set the boundaries of the emergency classification levels and ensure that all EALs that trigger the declaration of an emergency classification are in the same range of relative risk. In addition, the NRC staff verified that the proposed EAL scheme is technically complete for each classification level and consistent with EAL schemes implemented at similarly designed plants.

To aid in understanding the nomenclature used in this safety evaluation the following conventions are used:

• The scheme's generic information is organized by Recognition Category, the first letter in an EAL, in the following order.

o A or R - Abnormal Radiation Levels / Radiological Effluent, o C - Cold Shutdown/ Refueling System Malfunction, o E - Independent Spent Fuel Storage Installation, o F - Fission Product Barrier, o H - Hazards and Other Conditions Affecting Plant Safety, and o S or M - System Malfunction.

• The second letter in an EAL signifies the emergency classification level:

o U = Notification of Unusual Event (UE),

o A= Alert, o S = Site Area Emergency (SAE), and o G = General Emergency (GE).

• The number in an EAL denotes the sequential subcategory designation from the plant-specific EAL scheme.

An EAL set refers to EALs within an EAL Recognition Category that includes an escalation path for one or more classification levels. Not all EAL Recognition Categories require an EAL set.

This safety evaluation uses the numbering system from the proposed plant-specific EAL scheme; however, the numbering system from the generic EAL scheme development guidance contained in NEI 99-01, Revision 6, is annotated in [brackets] to aid in cross-referencing the site-specific EAL numbering convention with that of the guidance.

3.0 TECHNICAL EVALUATION

3.1 Recognition Category 'R' - Abnormal Radiation Levels/Radiological Effluent 3.1.1 Monticello EAL Set RU1/RA1/RS1/RG1 [AU1/AA1/AS1/AG1]

The intent of this EAL set is to ensure that an emergency classification is declared upon plant-specific indications of a release of radioactivity (gaseous and/or liquid). In recognition of the lower possible radioactivity concentrations, the assessment of liquid releases is limited to the UE and Alert classification levels. The set provides for accident assessments using pre-calculated values based on assumed conditions, real-time parameters, and field monitoring results.

The NRC staff verified that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• RU1 - This EAL addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

• RA 1 - This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1 percent of the U.S. Environmental Protection Agency (EPA) early phase protective action guides (PAGs) (ADAMS Accession No. ML17044A073).

• RS1 - This initiating condition addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 1O percent of the early phase EPA PAGs.

• RG1 - This initiating condition addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the early phase EPA PAGs.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.1.2 Monticello EAL Set RU2/RA2/RS2/RG2 [AU2/AA2/AS2/AG2]

The intent of this EAL set is to ensure that an emergency classification is declared upon plant-specific indications of potential or actual damage to an irradiated fuel assembly or multiple assemblies. It addresses a lowering of water level over irradiated fuel or fuel uncovery (i.e.,

level below the top of the fuel) and a spectrum of fuel handling accidents that results in mechanical damage to irradiated fuel (e.g., a dropped fuel assembly). Some of these EAL conditions rely on the spent fuel pool level instrument required by NRC Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ADAMS Accession No. ML12056A044).

The NRC staff has verified that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• RU2 - This EAL addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels.

• RA2 - This EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool.

• RS2 - This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to imminent fuel damage.

• RG2 - This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel and addresses NRC Order EA-12-051.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.1.3 Monticello EAL RA3 [AA3]

The intent of this EAL is to ensure that an emergency classification is declared when elevated radiation levels in certain plant rooms and areas preclude or impede personnel from performing actions necessary to maintain normal plant operation or to perform a normal plant cooldown and shutdown. This includes equipment in the control room and the central alarm station. The Alert classification level is primarily intended to ensure that the plant emergency response organization (ERO) is activated to support the control room in removing the impediment to normal access, as well as assisting in quantifying potential damage to the fuel. Indications of increasing radiation levels in the plant are bounded by Recognition Category 'F,' as well as RS1 and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.2 Recognition Category 'C' - Cold Shutdown/Refueling System Malfunction 3.2.1 Monticello EAL Set CU1/CA1/CS1/CG1 [CU1/CA1/CS1/CG1]

The intent of this EAL set is to ensure an emergency classification is declared upon a loss of reactor pressure vessel (RPV) inventory.

The NRC staff verified that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• CU 1 - This EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV level concurrent with indications of coolant leakage.

• CA 1 - This EAL addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).

• CS1 - This EAL addresses a significant and prolonged loss of RPV inventory control and makeup capability leading to imminent fuel damage.

• CG1 - This EAL addresses the inability to restore and maintain RPV level above the top of active fuel with containment challenged.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.2.2 Monticello EAL Set CU2/CA2 [CU2/CA2]

The intent of this EAL set is to ensure that an emergency classification is declared upon a loss of available alternating current (ac) power to emergency power electrical buses during cold shutdown, refueling, or defueled conditions.

The NRC staff verified that the progression from a UE to an Alert classification level is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are bounded by EALs RS1 and RG1.

• CU2 - This EAL describes a significant degradation of offsite and onsite ac power sources such that any additional single failure would result in a loss of all ac power to safety systems.

• CA2 - This EAL addresses a total loss of ac power that compromises the performance of all safety systems requiring electric power, including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal, and the ultimate heat sink.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.2.3 Monticello EAL Set CU3/CA3 [CU3/CA3]

The intent of this EAL set is to ensure that an emergency classification is declared based on the inability to maintain control of decay heat removal during cold shutdown and refueling.

The NRC staff verified that the progression from a UE to an Alert classification level is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are bounded by EALs RS1 and RG1.

• CU3 - This EAL addresses an unplanned increase in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level.

• CA3 - This EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.2.4 Monticello EAL CU4 [CU4]

The intent of this EAL is to ensure that an emergency classification is declared upon a loss of vital direct current (de) power that compromises the ability to monitor and control operable safety systems when the plant is in the cold shutdown or refueling mode. This EAL is primarily intended to ensure that key ERO members and offsite response organizations (OROs) are aware of the event, resources necessary to respond to the event are mobilized, and any necessary compensatory measures are promptly implemented. The Alert, SAE, and GE classification levels for a protracted loss of vital de power are bounded by EALs CA 1, CA3, CS 1, CG1, RA1, RS1, and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The

NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.2.5 Monticello EAL CU5 [CU5]

The intent of this EAL is to highlight the importance of emergency communications by ensuring that an emergency classification is declared if normal communication methods for onsite and offsite personnel, or with OROs, including the NRC, are lost. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the loss of communications capabilities, the resources necessary to restore communications are mobilized, and compensatory measures are promptly implemented. Considering that a loss of emergency communications capability would not involve an actual or potential substantial degradation to the level of safety of the plant, no escalation path is necessary for this EAL.

The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.2.6 Monticello EAL CA6 [CA6]

The intent of this EAL is to ensure that an emergency classification is declared when hazardous events lead to potential damage to safety systems during cold shutdown or refueling. The hazardous events of interest include an earthquake, flooding, high winds, tornado strike, explosion, fire, low river water level, or any other similar hazard applicable for the site. This EAL is primarily intended to ensure that the plant ERO is activated to support the control room in understanding the event impacts and restoring affected safety system equipment to service.

Indications of hazard-induced damage to components containing radioactive materials are bounded by EALs CS1, CG1, RS1, and RG1.

As described in NUREG 0654/FEMA REP 1, Revision 1, and the endorsed guidance in NEI 99 01, Revision 6, an Alert class exists when "Events are in process or have occurred

which involve an actual or potential substantial degradation of the level of safety of the plant.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels." The endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event. However, there may be cases where a hazardous event only causes damage to a single safety system component or a single safety system train. Additionally, an Alert classification should not be made if the damage from the hazardous event is limited to a safety system component or a safety system train that was inoperable or out of service prior to the event occurring.

The licensee is proposing that an Alert classification will be made when a hazardous event results in indications of degraded performance to one train of a safety system with either indications of degraded performance on a second safety system train or visible damage to a second safety system train, such that the operability or reliability of the second safety system train is a concern. Although different from the endorsed guidance in NEI 99-01, Revision 6, this change is acceptable, considering that the endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.4 7(b )( 4) and Section IV. B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.3 Recognition Category 'E' - Independent Spent Fuel Storage Installation 3.3.1 Monticello EAL EU1 [E-HU1]

This EAL applies to an event that results in damage to the confinement boundary of a storage cask containing spent fuel, regardless of the cause. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the cask damage, resources necessary to respond to the event are mobilized, and protective measures, if warranted, are promptly implemented.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.4 7(b )( 4 ). The NRC staff also verified

that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.4 Recognition Category 'F' - Fission Product Barrier Matrix 3.4.1 Monticello EAL Set FA1/FS1/FG1 [FA1/FS1/FG1]

The intent of this EAL set is to ensure that an emergency classification is declared upon a loss or potential loss of one or more fission product barriers.

This EAL set uses plant condition based thresholds as triggers within a particular logic configuration needed to reflect a loss or potential loss of a fission product barrier. Non-passive, large light water reactors in the United States have three fission product barriers: fuel cladding, the RCS, and primary containment. Licensees are to develop thresholds that provide EAL decisionmakers input into making an event declaration based upon degradation of one or more of these fission product barriers.

There are numerous triggers used as logic inputs to decide on the appropriate classification based upon the number of loss and/or potential loss indicators that are triggered for each barrier. By design, these indicators are redundant with other similar indicators in Recognition Categories 'R' and 'S-.'

The NRC staff verified that the logic used to determine the appropriate emergency classification is consistent with the generic EAL scheme development guidance in NEI 99-01, Revision 6.

The progression from an Alert to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• FA 1 - Any loss or any potential loss of either the fuel clad or RCS barrier.

• FS1 - Loss or potential loss of any two barriers.

• FG1 - Loss of any two barriers and loss or potential loss of the third barrier.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.4 7(b )( 4 ). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.5 Recognition Category 'H' - Hazards and Other Conditions Affecting Plant Safety 3.5.1 Monticello EAL Set HU1/HA1/HS1/HG1 [HU1/HA1/HS1/HG1]

The intent of this EAL set is to ensure that an emergency classification is declared based upon a security-related event.

The NRC staff verified that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• HU1 - This EAL addresses events that pose a threat to plant personnel or safety system equipment.

• HA 1 - This EAL addresses the occurrence of a hostile action within the Owner Controlled Area or notification of an aircraft attack threat.

• HS1 - This EAL addresses the occurrence of a hostile action within the Protected Area.

• HG1 - This EAL addresses an event in which a hostile force has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a hostile action leading to a loss of physical control that results in actual or imminent damage to spent fuel.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.4 7(b )( 4 ). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.5.2 Monticello EAL HU2 [HU2]

The intent of this EAL is to ensure that an emergency classification is declared based upon a seismic event that results in accelerations at the plant site greater than specified for an operating basis earthquake. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the earthquake magnitude at the plant site and that post-event damage

assessments are promptly implemented. This EAL is considered part of an EAL set containing EALs CA6 and SA9, depending on the operating mode applicable at the time of the event.

Indications of earthquake-induced damage to components containing radioactive materials are bounded by Recognition Category 'F,' as well as EALs RA1, RS1, or RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.3 Monticello EAL HU3 [HU3]

The intent of this EAL is to ensure that an emergency classification is declared based upon the effects that natural or technological hazard events may have on the facility, which are considered to be precursors to a more significant event or condition or have potential impacts that warrant emergency notification to local, State, and Federal authorities. Specific hazards addressed include:

• Tornado strike within the protected area,

• Internal room or area flooding requiring electrical isolation of a safety system component,

• Movement in the protected area impeded by an offsite event (e.g., toxic gas release),

• An external event that prohibits the plant staff from accessing the site via personal vehicles, and

• High or low river water level affecting the protected area.

This EAL is primarily intended to ensure that key ERO members and OROs are aware of the hazardous event affecting the plant site, and post-event damage assessments are promptly implemented. In addition, other site-specific events that may impact the effective implementation of the site emergency plan are considered.

This EAL is considered part of an EAL set containing EALs CA6 and SA9, depending on the operating mode applicable at the time of the event. Indications of hazard-induced damage to components containing radioactive materials are bounded by Recognition Category 'F,' as well as EALs RA1, RS1, or RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development

guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.4 Monticello EAL HU4 [HU4]

The intent of this EAL is to ensure that an emergency classification is declared based upon the effect that a fire may have on the facility, which would be indicative of a potential degradation of the level of safety of the plant. This EAL is primarily intended to ensure that key ERO members and OROs are aware of the fire, and post-event damage assessments are promptly implemented. This EAL is considered part of an EAL set containing EALs CA6 and SA9, depending on the operating mode applicable at the time of the event. Indications of a protracted fire involving radioactive materials are bounded by Recognition Category 'F,' as well as EALs RS1 and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.5 Monticello EAL HAS [HAS]

The intent of this EAL is to ensure that an emergency classification is declared based upon the effect that toxic, corrosive, asphyxiating, or flammable gases may have on the facility, which precludes or impedes access to equipment necessary to maintain normal plant operation or is required for a normal plant cooldown and shutdown. This EAL is primarily intended to ensure that the plant ERO is activated to support the control room in removing the impediment to normal access to the affected area or room. Indications of a protracted loss of access to equipment necessary for normal plant operations, cooldown, or shutdown are bounded by Recognition Category 'F,' as well as EALs RS1 and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.5.6 Monticello EAL Set HA6/HS6 [HA6/HS6]

The intent of this EAL set is to ensure that an emergency classification is declared based upon a control room evacuation with the transfer of control to remove the alternate shutdown panel.

The NRC staff verified that the progression from an Alert to an SAE classification level is appropriate and consistent with EAL scheme development guidance. The GE classification level for this specific accident progression is bounded by Recognition Category 'F,' as well as EAL RG1.

• HA6 - This EAL addresses an evacuation of the control room that results in transfer of plant control to the alternate shutdown panel.

• HS6 - This EAL addresses an evacuation of the control room that results in transfer of plant control to the alternate shutdown panel, and the control of a key safety function cannot be reestablished in a timely manner.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.5.7 Monticello EAL Set HU7/HA7/HS7/HG7 [HU7/HA7/HS7/HG7]

The intent of this EAL set is to provide decision makers with an escalating emergency classification to consider when, in their judgment, entry into the site's emergency plan and mobilization of the licensee's ERO and ORO is warranted.

The NRC staff verified that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• HU7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency classification because conditions exist that are believed by the Emergency Director to fall under the emergency classification level description for a UE.

• HA7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency classification because conditions exist that are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

• HS7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency classification because conditions exist that are believed by the Emergency Director to fall under the emergency classification level description for a SAE.

• HG7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency classification because conditions exist that are believed by the Emergency Director to fall under the emergency classification level descri"ption for a GE.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6 Recognition Category 'S' - System Malfunction 3.6.1 Monticello EAL Set SU1/SA1/SS1/SG1 [SU1/SA1/SS1/SG1]

The intent of this EAL set is to ensure that an emergency classification is declared based upon a loss of available ac power sources to the emergency busses.

The NRC staff reviewed the licensee's evaluation and justification for plant-specific changes associated with this EAL set and verified that the progression from a UE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• SU1 - This EAL addresses a prolonged loss of offsite ac power for 15 minutes or longer.

• SA 1 - This EAL describes a significant degradation of offsite and onsite ac power sources such that any additional single failure would result in a loss of all ac power to safety systems.

• SS1 - This EAL addresses a loss of all ac power that compromises the performance of all safety systems requiring electric power, including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal, and the ultimate heat sink.

• SG1 - This EAL addresses a prolonged loss of all ac power sources to ac emergency buses.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.2 Monticello EAL Set SU2/SA2 [SU2/SA2]

The intent of this EAL set is to ensure that an emergency classification is declared based upon the effect that a loss of available indicators in the control room has on the facility.

The NRC staff verified that the progression from a UE to an Alert classification level is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are bounded by Recognition Category 'F,' as well as EALs RS1 and RG1.

• SU2 - This EAL addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain safety system parameters from within the control room.

• SA2 - This EAL addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain safety system parameters from within the control room.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.3 Monticello EAL SU3 [SU3]

The intent of this EAL is to ensure that an emergency classification is declared when RCS activity is greater than technical specification allowable limits. This EAL is primarily intended to ensure that key ERO members are aware of the elevated reactor coolant activity and support the control room in implementation of appropriate response measures. Escalation of the emergency classification is bounded by Recognition Category 'F,' as well as EALs RA1, RS1, and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b){4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.6.4 Monticello EAL SU4 [SU4]

The intent of this EAL is to ensure that an emergency classification is declared when the plant has indications of RCS leakage. By design, the indications for this EAL are redundant to corresponding indicators for a loss or potential loss of fission product barriers, as well as radiation monitoring, to ensure reactor and/or fission product barrier events are recognized.

This EAL is primarily intended to ensure that key ERO members are aware of the RCS leakage and support the control room in implementation of appropriate response measures. Escalation

of the emergency classification is bounded by Recognition Category 'F,' as well as EALs RA1, RS1, and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.6.5 Monticello EAL Set SU5/SA5/SS5 [SU5/SA5/SS5]

The intent of this EAL set is to ensure that an emergency classification is declared based upon the effect that a failure of the reactor protection system (RPS) may have on the plant.

The NRC staff verified that the progression from a UE to an SAE classification level is appropriate and consistent with EAL scheme development guidance. The GE classification level for this event is bounded by Recognition Category 'F,' as well as EAL RG1.

• SU5 - This EAL addresses an event where the RPS fails to automatically shut down the reactor when required, yet the reactor is successfully shut down by taking manual action(s) at the reactor control consoles.

• SA5 - This EAL addresses an event where the RPS fails to automatically shut down the reactor when required and operator actions taken at the reactor control consoles to manually shut down the reactor are unsuccessful.

• SS5 - This EAL addresses an event where the RPS fails to automatically shut down the reactor when required, all operator actions to manually shut down the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core, the RCS, or both.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each

classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.6 Monticello EAL SU6 [SU6]

The intent of this EAL is to highlight the importance of emergency communications by ensuring that an emergency classification is declared if normal communication methods for onsite and offsite personnel, or with OROs, including the NRC, are lost. It is primarily intended to ensure that key ERO members and OROs are aware of the loss of communications capabilities, the resources necessary to restore communications are mobilized, and compensatory measures are promptly implemented. Considering that a loss of emergency communications capability would not involve an actual or potential substantial degradation to the level of safety of the plant, no escalation path is necessary for this EAL.

The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance. The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.6. 7 Monticello EAL Set SS8/SG8 [SS8/SG8]

The intent of this EAL set is to ensure that an emergency classification is declared when a loss of all vital de power occurs, as this condition compromises the ability of the licensee to monitor and control the removal of decay heat.

The NRC staff verified that the progression from an SAE to a GE classification level is appropriate and consistent with EAL scheme development guidance.

• SS8 - This EAL addresses a loss of all vital de power which compromises the ability to monitor and control safety systems.

• SGB - This EAL addresses a concurrent and prolonged loss of all ac and vital de power for 15 minutes or longer.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each classification level, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.

3.6.8 Monticello EAL SA9 [SA9]

The intent of this EAL is to ensure that an emergency classification is declared when a hazardous event leads to potential damage to safety systems needed for the current operating mode. The hazardous events of interest include an earthquake, flooding, high winds, tornado strike, explosion, fire, low river water level, or any other similar hazard applicable for Monticello.

This EAL is primarily intended to ensure that the plant ERO is activated to support the control room in understanding the event impacts and restoring affected safety system equipment to service. Indications of hazard-induced damage to components containing radioactive materials are bounded by Recognition Category 'F,' as well as EALs RS1 and RG1.

As described in NU REG 0654/FEMA REP 1, Revision 1, and the endorsed guidance in NEI 99 01, Revision 6, an Alert class exists when "Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels." The endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event. However, there may be cases where a hazardous event only causes damage to a single safety system component or a single safety system train. Additionally, an Alert classification should not be made if the damage from the hazardous event is limited to a safety system component or a safety system train that was inoperable or out of service prior to the event occurring.

For SA9, the licensee is proposing that an Alert classification will be made when a hazardous event results in indications of degraded performance to one train of a safety system with either indications of degraded performance on a second safety system train or visible damage to a second safety system train, such that the operability or reliability of the second safety system train is a concern. Although different from the endorsed guidance in NEI 99-01, Revision 6, this change is acceptable, considering that the endorsed guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred as a result of a hazardous event.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL

scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the plant-specific implementation strategies provided, and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete, addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.

Based on the above, the NRC staff concludes that the plant-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.

3.7 Review Summary The NRC staff has reviewed the technical bases for the proposed EAL scheme, the changes from NEI 99-01, Revision 6, and the licensee's evaluation of the proposed changes. The licensee chose to modify its proposed EAL scheme from the generic EAL scheme development guidance provided in NEI 99-01, Revision 6, in order to adopt a format that is better aligned with how it currently implements its EALs, as well as with plant-specific writer's guides and preferences. The NRC staff verified that these modifications do not alter the intent of any specific EAL within a set, recognition category, or within the entire EAL scheme described in NEI 99-01, Revision 6. Thus, the proposed changes meet the requirements in Section IV.B of Appendix E to 10 CFR Part 50 and the planning standard of 10 CFR 50.47(b)(4).

The NRC staff determined that the proposed EAL scheme uses objective and observable values, is worded in a manner that addresses human factors engineering and user-friendliness concerns, follows logical progressions for escalating events, and allows for event downgrading and upgrading based upon the potential risk to the public health and safety. Risk assessments were appropriately used to set the boundaries of the emergency classification levels and ensure that all EALs that trigger an emergency classification are in the same range of relative risk. In addition, the NRC staff determined that the proposed EAL scheme is technically complete and consistent with EAL schemes implemented at similarly designed plants.

The NRC staff verified that the instrumentation and setpoints derived for this proposed EAL scheme are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme.

Based on its review, the NRC staff finds that the licensee's proposed EAL scheme is acceptable and provides reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Specifically, the staff concludes that the licensee's site-specific EAL basis document provided by Attachment 3 of the letter dated September 25, 2017, is acceptable for implementation.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Minnesota State official was notified of the proposed issuance of the amendment on December 14, 2017. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes an inspection or surveillance requirement. The staff has determined that the amendment involves 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 amendment involves no significant hazards consideration and there has been no public comment on such finding (82 FR 26134). Accordingly, the amendment meets 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 amendment.

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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Michael Wasem, NSIR Date: March 6, 2018

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT- ISSUANCE OF AMENDMENT NO. 197 TO ADOPT CHANGES TO THE EMERGENCY PLAN (CAC NO. MF9560; EPID L-2017-LLA-0184) DATED MARCH 6, 2018 DISTRIBUTION:

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