ML20210Q285
| ML20210Q285 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/18/1997 |
| From: | Hill W NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9708290082 | |
| Download: ML20210Q285 (5) | |
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Northem States Power Company I
Monticello Nuclear Generating Plant 2007 West Hwy 76 Monticeho, Minnesota 55362 9637 August 18,1997 US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR 22 Request for Exemption from State and Local Participation in MNGP Emergency Plan Exercise of November 18,1997 Ref.: Letter from J.D. Franklin, Minnesota Department of Public Safety, to Michelle Burkett, FEMA Region V, dated August 12,1997 (copy attached)
By letter dated August 12,1997, the Minnesota Division of Emergency Management requested a hardship exemption from FEMA for participation in Monticello's biennial exercise scheduled for November 18,1997. NSP is required to conduct a full participation exercise at MNGP in accordance with 10 CFR 50 Appendix E, Section IV.F.2.c. In light of the state's situation, NSP is reouesting a specific exemption from the full participation requirements of Section IV.F.2.c of Appendix E to 10 CFR 50 for the November 18,1997 exercise in accordance with Section 50.12 of 10 CFR 50. Section 50.12 part (a)(2)(iii) contains a provision for a special circumstance exemption from a regulation where compliance would result in undue hardship. The state's argument for relief due to the hardship created by compliance is provided in the above attached letter.
This one-time exemption does not present an undue risk to the hecith and safety of the public and is consistent with the common defense and secunty. The performance of outside agencies in previous exercises has been excellent, and no degradation in performance is expected. Recent actual disasters have improved the performance of these outside agencies. Barring any unforeseen circumstances, NSP expects full participation of state and local agencies in the next regularly scheduled biennial exercise for June 22,1999, in addition, all other training requirements of Section F of Appendix E to 10 CFR 50 will continue to be met, if this exemption request is approved, NSP will submit a letter with the new objectives and timeline for the upcoming 1997 exercise. This letter will account for the revised offsite participation. Given the compressed time period available to plan the exercise, NSP requests that the staff expedite its review.
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9708290002 970818 PDR ADOCK 05000263 F
o Please contact Joel Beres, Licensing Engineer, at (612) 295-1436 if yao require.-f/,tional information.
llEmh William J. Hill Plant Manager Monticello Nuclear Generating Plant c:
Regional Administrator-lil, NRC NRR Project Manager, NRC Sr, Resident inspector, NRC State of Minnesota, Attn: Kris Sanda FEMA Region V J. Silberg, Esq.
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ma STATE OF MINNESOTA DEPARTMENT OF PUBLIC 8AFETY j
August 12,1997 l
Michelle Burkett, Dlroctor FEMARegion V 175 W. Jackson,4* Ploor Chicago,IL 60604 l
Dear Ms. Bwkett:
l As proylded for in 44 CPR 3$0.9( c ), I am writing tids letter to request relief &om participating in the Monticano Nuclear Puwer rivit exercise, currently scheduled for November 1s,1997 This exemption request is on behalf of the state ofMinnesota, Shaburne and Wright County It
!s based on the hardships faced by both the state and the countles following a year of msjor dimten. The situation faced by both state and local govemments la as foUows:
The Minnesota Division or 1 Emergency Management (DEM) and other state agencies are in various phases of sew 0 aldential Declarations ofMajor Disoters within the last two
- years, Sherburne and Wright County are stul conducting damage aimsments for their third e
Presidentis! Declaration in the lut eight months, The scope of our most recent disuters were well documented and of catastrophic proportions. Following on the heels ofmcord cold and orippling snowfkll, we experlunced the worst floods in the history of the state. Thousands of state, local and federal emwgency respondws were activated, tens of thousands of people were evacusted, and damage estlmstes are expected to exceed 1 billion dollan. Finy-nins counties wwe declared a major disarter and hundreds of families are st01 displaced.
AN EQUAL OPPORTUNITY EMPLOYER b
et/14/97 WON 078 s4 111 01: 330 fast N3p An.13.1997 8:01M!
Mll DIV 0F EMIRG WGt No.0963 P. 3/4 mu. Man, pne.2 Summer gave no respite to thosejurisdictions already burdsned by winter and spring disasters.
The month of July started with a string of seven stonns which brought high speed straight line winds, tornadoes and rnore flooding to centrs! Minnesota.
DEM continues to have 42% of staff assigned to these disastus. In addition, many othat state agendes have numerous staff corteentrating on recovery issues (many of whom are part of the REP program),
Oft 3clats in Sherburne and Wright County are stillin the midst of clean-up, restoration, recovery and human services activities. These people are the staff responsible for coordinating REP response in the upcoming exercise. Their priority is, appropriately, dealing with the aftermath of the July windstorms and tornadoes. Heavily damaged schools will probably not open in time for the fall semester.
l As you can see from the summary above, partidpotion in the November exerelse would place an unusual hardship on state and local offelte response organizations, it is in the best interest of everyone involved to rwtuost this relief. Because we have a good record of exerdse perfonnance, FEMA should not be concerned regarding the protection of health and safety of the pubtle. The State has not had a defidency since 1991 and neither county has ever had a deBelency, Currently, the state has one open ARCA from the 1996 Prairio Island exercise (for reception center vehicle monitoring) and Sheiburne County ba 3 open ARCAs from the 1995 Monticello exercise (all resulting from an exercise issue of simulation versus actual radio transmissions).
During these various disasters this past year, Minnesota received numerous accolades from FEMA and other federal and volunteer agencies (br the effective and edicient way in which we responded. This is directly attributable to REP. The State and both counties drew upon the planning and exercise experiences from the last 15 years in REP and feel that the actual use of plans and procedures was fa'more valuable than an exordse ever could have oesn.
I am proposing that the ex.emption be effbetive until the next scheduled exercise for each offelte response organization. The next scheduled exercise for the State is July 21 and 22,1998 with the Prairie Island plant. This will be a full participation, full scale ingestion pathway exercise. The next scheduled Monticello exardse is June 22,1999. The State, Sherburne and Wright County all will fbily participate in that exercise.
Kds Eide, of my staff, has discussed this issue with Megs Hepler, Exarcise Director at FEMA Headquarters and FEMA V staff. Both have expressed tholt understanding and support for this proposal. The owner and operator of the plant, Northern States Power Company, is also requesting that the Nuclear Regulatory Commlssion approve exemption from their license requirement for participation of olisite response organizations,
08/10/97 MON 07188 FAI 018 ast' fees Nsr Cood Au 13.1997 B:02AM 101 Dl? 0F IERG ET No.0963 P. 4/4 I*
v.a u.s.dmi,pe 3 An inittel mguest for an ahernative approach of receiving exercleo credit for an actual responn was submitted to you on June 10,1p97. We received our denial for tMs request on August 11, 1997. Doe to the lengthy deley in receiving a respones, we are now on a very tight timeline. I would approdatsifFEMA would grant tNs exetaption by August 15,1997 in order to meet our exwdse objective submittal date of August it*,
Thank you for your consideration of this very important decision.
neere b
anos D. Franklin tate Director cc:
Mike Offerdahl.NSP Gary Petwson. Sherbume County GenellReese, Wright Cotmty Woodie Cunia,RAC Chair