ML19114A290
| ML19114A290 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/24/2019 |
| From: | Church C Northern States Power Company, Minnesota, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-MT-19-021 | |
| Download: ML19114A290 (7) | |
Text
fl Xcel Energy RESP ON S I BL E B V NATURE 4/24/2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 2807 West County Road 75 Monticello, MN 55362 L-MT-19-021 10 CFR 50.54(q)(5) 1 0CFR 72.44(f)
Changes to the Monticello Nuclear Generating Plant (MNGP) Emergency Plan Pursuant to 10 CFR 50.54(q)(5) and 10 CFR 72.44 (f), Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, submits a summary of changes to the MNGP Emergency Plan as Enclosure 1. The new revision to the Emergency Plan is provided in Enclosure 2. The Emergency Plan changes have been reviewed and do not result in a reduction in the effectiveness of the Emergency Plan.
Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.
hristopher R. Church Site Vice President, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure (2) cc:
Emergency Response Coordinator, Region Ill, USNRC (with Enclosures)
Resident Inspector, MNGP, USNRC (with Enclosure 1)
Administrator, Region Ill, USNRC (w/o Enclosures)
Chief, Operations Branch, Division of Reactor Safety, Region Ill, USNRC (with Enclosure 1)
Director, Division of Spent Fuel Management, Office of Nuclear Material Safety and Safeguards (with Enclosure 1)
ENCLOSURE 1
SUMMARY
OF CHANGES
Change (#) 1 *. *.-
==
Description:==
Revise MNGP Emergency Plan and MNGP Alert and Notification Design Report to eliminate the use of backup route alerting as a secondary method of notifying the public in the event of a siren failure and replace it with the use of the Integrated Public Alert Warning System *
(IPAWS) as.the backup method as approved by DHS/FEMA Region Vin letter to the MN Division Homeland Security and Emergency Management dated June 25th, 2018.
Doc ID or (Procedure Number)/ Revision Number:
E-Plan revision 53, section 7.7 Document
Title:
Emergency Plan PCR Number: 602000008037 Editorial Basis (applies to E-Plan changes only)
NA Licensing/Basis Affected The State must submit changes to the approved Alert and Notification System (ANS) design and testing and maintenance procedures approved in the final ANS design report to FEMA for review pursuant to 44 CFR 350.14, "Amendments to State Plans." The NRC relies on FEMA to review and approve the ANS design and changes to it. Change 1 aligns the MNGP Emergency Plan with the current MNGP ANS Design Report which was reviewed and approved by FEMA in accordance with the above noted requirement.
Regulatory Compliance Basis NPP licensees are required by 10 CFR Part 50, Appendix E, Section IV.D.3, to demonstrate that the ANS capability exists. Alerting and notifying the public is a function assigned to the State and local governments and evaluated by FEMA. Change 1 to the Emergency Plan aligns with the change to the MNGP ANS Design Report replacing backup alert route alerting with the Integrated Public Alert and Warning System (IPAWS). The change was reviewed and approved by DHS/FEMA Region V in a letter dated June 25, 2018 to the State of MN, Preparedness Branch, Division Homeland Security and Emergency Management.
Emergency Plan Effectiveness Basis Integrated Public Alert and Warning System (IPAWS) is an upgraded communication system that is replacing the vehicle routing alert system and emergency planning zone maps which the counties used to alert personnel when the siren system, parts of the siren system or individual sirens are out of service.
Integrated Public Alert and Warning System (IPAWS) is made up of the Emergency Alert System (EAS) and Wireless Emergency Alert (WEA) System and was previously part of the MNGP ANS Design Report as an alternate backup alerting method. This change credits
!PAWS as the primary backup method.
!PAWS is available to United States federal, state, local, territorial, and tribal government officials. !PAWS improves alert and warning capabilities by allowing the delivery of an emergency message from a single portal to multiple communication pathways. These pathways include: EAS, WEA, National Weather Service Dissemination Systems including NOAA weather radio, Unique Systems ( emergency telephone networks, sirens, or digital road signs), and future systems.
Homeland Security Emergency Management and the Minnesota Duty Officer are responsible for initiating Public Information Messages through the Wireless Emergency Alert (WEA) System which activates mobile/cellular devices located in Sherburne and Wright Counties. This is considered a backup form of alert and notification to the public in the unlikely event siren(s) are inoperable. EAS and WEA are activated at the same time in the Protective Action Decision Process. The State does not wait for a siren failure in order to activate WEA. !PAWS has been tested and is maintained by the state of Minnesota.
The use of !PAWS as the backup alerting and warning method is an improved method over route alerting that allows delivery of an emergency message from a single portal to multiple communications pathways. In addition, it frees up resources that might otherwise be involved in completing route alerts to support other emergency response activities. The change was approved DHS/FEMA Region V. It does not result in a reduction of effectiveness of the MNGP Emergency Plan.
Change(#) 2
==
Description:==
Changes resulting from the annual review and update of the Emergency Plan. The changes include the following:
- a.
Update to the normal site organization.
- b.
Update to titles and reporting structure of individuals who staff the site Emergency Response Organization.
C.
Clarifications to the operation and instrumentation descriptions for the plant Safety Parameter Display System (SPDS) description and meteorological monitoring system.
Doc ID or (Procedure Number)/ Revision Number:
E-Plan revision 53, sections 5.1, 5.2, 7.3.1.1, 7.3.1.2.2, and Table 9.
Document
Title:
Emergency Plan PCR Number: 602000008037 Editorial Basis (applies to E-Plan changes only)
See description section for discussion of editorial type changes.
Licensing/Basis Affected Section 8.2.2 of the MNGP E-plan identifies the following:
The Monticello Emergency Plan SHALL be reviewed and certified to be current on an annual basis in accordance with the Off-site Nuclear Emergency Plan. Other reviews of the Emergency Plan and Implementing Procedures will be performed as required by Technical Specifications. Annual revisions to the Emergency Plan are conducted in accordance with Surveillance Procedure 1406 and may be based on the following:
8.2.2.1 Lessons learned during drills and exercises and industry lessons learned.
8.2.2.2 Changes in the normal plant or Emergency Response Organization structures.
8.2.2.3 Modifications to plant systems, components or instrumentation.
8.2.2.4 Changes in the functions or responsibilities of supporting agencies and organizations.
8.2.2.5 Lessons learned from real emergency plan activations.
8.2.2.6 Changes in State or Federal regulations.
Regulatory Compliance Basis The changes are clarifications, administrative, and/or editorial in nature and update the Emergency Plan to align with:
- a.
Changes to the normal site organizations.
- b.
Changes to titles and reporting structure of individuals who staff the site Emergency Response Organization.
- c.
Clarifications and updates to the sfstem description and operational details of the plant SPDS and meteorological monitoring system.
Following is assessment of each change:
- a. Corporate Directive CD 1.2 (NSPM Organization and Responsibilities) describes the NSPM organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying Quality Assurance Plan (QAP) implementation at the Xcel Energy nuclear plants. The organizational structure includes headquarter functions and onsite functions at each site. The directive assigns specific responsibilities and duties, and defines the organizational interfaces involved in conducting activities and duties within the scope of the NSPM Quality Assurance Topical Report (QATR). The changes in Section 5.1 (Normal Site Organization) of the Emergency Plan aligns the plan with the NSPM organization and responsibilities identified in the current revision (#11) of CD 1.2.
- b. The changes in Section 5.2 (Emergency Organization and Responsibilities) of the Emergency Plan aligns the plan with the NSPM organization and responsibilities identified in the current revision (#11) of CD 1.2. The station Emergency Response Organization (ERO) and its staffing and response capabilities are unaffected by the changes to the normal plant organization. ERO members continue to be assigned to the ERO based on the same training, qualification, and functional area of
- expertise/background as occurred prior to implementation of the Maintain the Plant Organization reflected in the current NSPM Organization. Those assigned to the ERO continue to maintain the same authority and control for directing emergency response activities. Although the normal non-emergency reporting structure of some staff resources may have changed from reporting to the site to reporting to the fleet, all staff (site and fleet) continue to be available for ERO staffing purposes as needed to meet the
station E-Plan staffing requirements. The changes in Section 5.2 of E-Plan are of an administrative nature to align the plan with current station organizational structure.
- c.
Changes in Section 7.3.1.1 Safety Parameter Display System (SPDS), 7.3.1.2.2 Meteorological Monitoring System and Table 9 (On-site Meteorological Monitoring Instrumentation) are based on review of these sections of the Emergency Plan by the engineering and IT staff responsible for the maintenance and oversight of these systems. Review noted that some of the system description details and operational features were not well aligned with the same system descriptions and operational details noted in the technical basis documents for that equipment. The changes in these sections provide clarifications and minor corrections that better align the Emergency Plan equipment descriptions with that of the equipment technical basis documents for those systems. The changes are transparent to the end user of the equipment for emergency assessment and response purposes and do not change or impact the capabilities of ERO to carry out their emergency response activities associated with use of the equipment. The changes in these sections of the E-Plan are considered to be of an administrative nature to better align the plan descriptions with the current technical basis documents describing the equipment.
Emergency Plan Effectiveness Basis The changes are administrative, clarifications and/or editorial in nature and made in accordance with section 8.2.2 of the Emergency Plan, which requires that the plan be reviewed and updated on an annual basis. The changes align the E-plan with the programs (QAP and technical basis documents) that provide the regulatory basis and governance for the items being changed. The changes do not impact implementation of the requirements of the Emergency Plan. The changes do not result in a reduction of effectiveness of the Emergency Plan.
ENCLOSURE 2 NEW REVISION OF EMERGENCY PLAN