ML22131A265
| ML22131A265 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 05/11/2022 |
| From: | Robert Kuntz NRC/NRR/DORL/LPL3 |
| To: | Loeffler R Northern States Power Company, Minnesota |
| References | |
| Download: ML22131A265 (16) | |
Text
From:
Kuntz, Robert Sent:
Wednesday, May 11, 2022 6:07 AM To:
Loeffler, Richard A.
Cc:
Scott, Sara
Subject:
Request for Additional Information RE: Xcel Energy Amendment Request to Create a Common EPlan and EOF for Monticello and Prairie Island Attachments:
Xcel Fleet Plan FINAL Request for Additional Information.docx Mr. Loeffler:
By application dated November 15, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21320A226), Northern States Power Company (NSPM), a Minnesota corporation doing business as Xcel Energy (Xcel), submitted changes to the Monticello Nuclear Generating Plant (MNGP) and the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plans, which include the Corporate Offsite Emergency Plan, to the U.S.
Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, a new Xcel Energy Standard Emergency Plan (hereafter referred to as the Xcel SEP) that includes site-specific annexes is proposed. Additionally, Xcel proposes to replace the existing MNGP and PINGP near site Emergency Operations Facilities (EOFs), and their common backup EOF (BUEOF) with a consolidated EOF located in the Xcel headquarters.
The attached requests for additional information (RAI) is needed for the NRC staff to complete its review. During a clarification call April 27, 2020 a response date of June 10, 2020 was agreed upon. If Xcel Energy will require additional time contact me to discuss.
Robert Kuntz Senior Project Manager NRC/NRR/DORL/LPL3
Hearing Identifier:
NRR_DRMA Email Number:
1632 Mail Envelope Properties (SA9PR09MB4640F3949F7FBC1B539B134F99C89)
Subject:
Request for Additional Information RE: Xcel Energy Amendment Request to Create a Common EPlan and EOF for Monticello and Prairie Island Sent Date:
5/11/2022 6:07:01 AM Received Date:
5/11/2022 6:06:00 AM From:
Kuntz, Robert Created By:
Robert.Kuntz@nrc.gov Recipients:
"Scott, Sara" <sara.scott@xcelenergy.com>
Tracking Status: None "Loeffler, Richard A." <rick.a.loeffler@xcelenergy.com>
Tracking Status: None Post Office:
SA9PR09MB4640.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1319 5/11/2022 6:06:00 AM Xcel Fleet Plan FINAL Request for Additional Information.docx 68005 Options Priority:
Normal Return Notification:
No Reply Requested:
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Normal Expiration Date:
DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLANS NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 By application dated November 15, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21320A226), Northern States Power Company (NSPM), a Minnesota corporation doing business as Xcel Energy (Xcel), submitted changes to the Monticello Nuclear Generating Plant (MNGP) and the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plans, which include the Corporate Offsite Emergency Plan, to the U.S.
Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, a new Xcel Energy Standard Emergency Plan (hereafter referred to as the Xcel SEP) that includes site-specific annexes is proposed. Additionally, Xcel proposes to replace the existing MNGP and PINGP near-site Emergency Operations Facilities (EOFs), and their common backup EOF (BUEOF) with a consolidated EOF located in the Xcel headquarters.
The following requests for additional information (RAI) is needed for the NRC staff to complete its review.
RAI 1
Requirement:
Issue: Page 2 of the request dated November 15, 2021, states, Enclosures 1, 2, and 3 provide technical analyses evaluating the impact to the effectiveness of the plans by combining the MNGP Emergency Plan, the PINGP Emergency Plan, and the Corporate Offsite Emergency Plan, into a combined SEP with site-specific Annexes for the MNGP and PINGP, respectively. [emphasis added]
However, throughout the license amendment request (LAR), the justifications state, do not represent a material change from the current Corporate Offsite, MNGP, or PINGP Emergency Plan commitments.
Language standardized in the proposed Plan without change in process or intent.
There are no changes identified that Xcel determined would be a reduction in effectiveness requiring NRC approval.
Request: Provide the regulatory basis for performing the review of the LAR, with the exception of the consolidation of the near-site EOFs into the proposed consolidated EOF. Additionally, what specific changes require NRC prior approval under 10 CFR 50.54(q)(4)?
RAI 2
Issue: Table B-1, Minimum On-Shift and Augmented Staffing, (hereafter referred to as Table B-1) of the proposed Xcel SEP indicates that a second communicator was added that would be either a Reactor Operator (RO) or Senior Reactor Operator (SRO). The NRC staff could not determine if the RO or SRO provided in Table B-1 would be a dedicated communicator that is in addition to the licensed on-shift operators required by technical specifications and/or regulations. Because Table B-1 does not show the RO or SRO communicator as a position that is performed by an individual performing concurrent actions, it appears that this would be a dedicated communicator that is in addition to on-shift licensed operator staffing.
Request: Provide clarification as to whether the RO or SRO performing a communication function would be in addition to the on-shift licensed operators as required by technical specifications and/or regulation. Note: if a RO or SRO is required by technical specifications or regulations to operate the plant, it does not appear reasonable that that individual be concurrently assigned the ERO communications task because both of those functions could require immediate actions and could not reasonably be performed concurrently.
RAI 3
Issue: The proposed Xcel SEP would replace the chemistry technician performing dose assessment with one of the on-shift radiation protection (RP) technicians. Enclosure 2, Xcel Energy Standard Emergency Plan Monticello Annex - Technical Analysis, and Enclosure 3, Xcel Energy Standard Emergency Plan Prairie Island Annex - Technical Analysis, of the application states that that one of the two on-shift RP technicians performs on-site surveys and that the second on-shift RP technician will perform the protective action function. It was not clear to the NRC staff how two on-shift RP technicians could perform these tasks concurrently with performing the dose assessment function.
Request: Explain how replacing the chemistry technician performing dose assessment with one of the on-shift RP technicians will not impact the capability to perform the required RP functions until relieved at 60 minutes.
RAI 4
Issue: Section B.3 of the proposed Xcel SEP states, The Xcel Energy Minimum Staff Table B-1 includes on-shift and augmented positions as identified in NUREG-0654, Revision 2, Table B-1 as well as those positions required in the TSC [Technical Support Center], OSC [Operations Support Center] and EOF for facility activation.
However, Figures B-1, TSC Organization, B-2, OSC organization, and B-3, EOF Organization, show minimum staffing for the respective facility activation that is not consistent with the Xcel Table B-1.
Request: Provide justification as to how these facilities can be considered staffed for activiation with the level of staffing below the Xcel Table B-1 minimum staffing.
RAI 5
Issue: The proposed Xcel SEP would eliminate the following positions from the MNGP Emergency Plan:
Table-1: MNGP Positions with responsibilities transferred to other individuals Monitoring Section Leader TSC Assistant EOF Coordinator / Agency Liaison EOF Assistant RP Support Supervisor EOF As justification for the above changes, Xcel stated that the responsibilities have been transferred to other individuals and there is no corresponding position in NUREG-0654, Revision 2, Table B-1. Because Xcel is proposing to change the MNGP and PINGP Emergency Plans, the NRC staff needs sufficient objective evidence to independently conclude that the proposed Xcel SEP and site-specific annexes will continue to meet the requirements of 10 CFR 50.47(b)(2) and the applicable sections of Appendix E to 10 CFR Part 50.
Request: Provide objective evidence that demonstrates the proposed Xcel SEP and site-specific annexes would continue to be effective with the removal of the ERO positions identified in Table-1 of this document. This objective evidence could include a detailed task analysis and/or a demonstration through a drill that the plan would be effective as proposed.
RAI 6
Issue: The proposed Xcel SEP and site-specific annexes would eliminate the following positions from the MNGP and PINGP Emergency Plans:
Table-2: Positions removed from MNGP or PINGP Emergency Plans Safety Parameter Display System (SPDS) Operator MNGP TSC Trending MNGP TSC Support Group Leader MNGP TSC Support Group MNGP TSC Radiation Protection (RP) Status Board MNGP EOF SPDS Operator MNGP EOF Trending MNGP EOF Support Staff MNGP EOF Assembly Point Coordinator PINGP TSC Radiological Emergency Coordinator Assistant PINGP TSC Operations Group Leader Assistant PINGP TSC TSC Coordinator Assistant PINGP TSC Work Management Leader PINGP TSC Logistics Support Leader PINGP TSC Emergency Response Computer System Operator PINGP TSC Status Board Keeper PINGP TSC Record Log Keeper PINGP TSC Ops Advisor (refers to use of on-shift and personnel and the TSC Operations Coordinator)
PINGP OSC Status Board Keeper PINGP OSC RP Support Supervisor Assistant -State Liaison (assigned responsibilities to Radiological Assessment Coordinator)
PINGP EOF RP Support Supervisor Assistant - Field Monitoring and Dose Assessment PINGP EOF Rad Status Board Keeper PINGP EOF EOF Coordinator Assistant PINGP EOF Administrative Support Lead PINGP EOF Administrative Support Staff PINGP EOF Status Board Keeper PINGP EOF Trending Team Leader PINGP EOF Emergency Response Computer System Operator PINGP EOF Event Status Board Keeper PINGP EOF Narrative Log Keeper PINGP EOF The typical justification provided for the above changes is that the positions do not perform any emergency preparedness functions and will continue to be provided in accordance with implementing procedures. It was not clear to the NRC staff why emergency preparedness functions would be retained in implementing procedures for positions that do not perform any emergency preparedness functions. Xcel further stated that the responsibilities have been transferred to other individuals and there is no corresponding position in NUREG-0654, Revision 2, Table B-1. Because Xcel is proposing to change the MNGP and PINGP Emergency Plans, the NRC staff needs sufficient objective evidence to independently conclude that the proposed Xcel SEP and site-specific annexes will continue to meet the requirements of 10 CFR 50.47(b)(2) and the applicable sections of Appendix E to 10 CFR Part 50.
Request: Due to the number of support or administrative positions being removed, provide objective evidence that demonstrates the proposed Xcel SEP would continue to be effective with the removal of the ERO positions identified in Table-2 of this document. This objective evidence could include a detailed task analysis and/or a demonstration through a drill that the plan would be effective as proposed.
RAI 7
Issue: Section E.3 of Attachment 1, Enclosure 1, Standard Emergency Plan, states: The content of the follow-up messages is detailed in implementing procedures.
However, the proposed Xcel SEP and site-specific annex removed significant details contained in currently approved emergency plans for the respective sites.
Request: Describe where the level of detail removed from the approved emergency plans for the respective sites, and necessary to implement the proposed Xcel SEP and site-specific annexes, will be specifically addressed (e.g., emergency plan implementing procedures) and the process to be used to ensure the continued effective implementation of the Xcel SEP and site-specific annexes.
RAI 8
Issue: Page 1 of the November 15, 2021, request refers to an EOF as the Emergency Offsite Facility. The Xcel SEP identifies the EOF as an Emergency Operations Facility.
Request: Provide clarification that the EOF referred to in the LAR should actually refer to an Emergency Operations Facility and not an Emergency Offsite Facility.
RAI 9
Requirement:
Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site. Minimum provisions at this location should include the following items: conference area with whiteboards, separate areas suitable for briefing and debriefing response personnel, telephones, site ERO telephone contact lists, computers with internet access, access to a copier and office supplies, and radiation monitoring capability.
Issue: Sections H.3 and H.3.a of the site-specific annexes do not provide a description of the minimum provisions at the near-site locations.
Request: Pease provide a list of minimum provisions at the near-site locations for MNGP and PINGP site-specific annexes.
Requirement:
Issue: Section H, Emergency Facilities and Equipment, of the PINGP site-specific annex states in part, The PINGP TSC has the following capabilities:
- Sufficient working space for ERO and NRC personnel.
However, item #418 of Enclosure 3, Attachment 3, Prairie Island Nuclear Generating Plant Emergency Plan Justification Matrix, states, Working space for about twenty-five people.
Additionally, the site-specific details in the Xcel SEP and site-specific annexes do not address some of the functional criteria in NUREG-0696 (e.g., function, size, structure, habitability, instrumentation, data system equipment and power supplies, etc.) for the TSCs.
Request: Provide justification for not addressing the functional criteria for the TSC in the Xcel SEP and site-specific annexes.
RAI 11
Requirement:
No specific habitability criteria are established for the OSC. If the OSC habitability is not comparable to that of the control room, the licensees emergency plan shall include procedures for evacuation of OSC personnel in the event of a large radioactive release.
Issue: Item #462 of Enclosure 2, Attachment 3, Monticello Nuclear Plant Change Justification Matrix, states in part, The Plan eliminates specification of an onsite Back-up OSC.
There is no information related to a back-up OSC in the current PINGP Emergency Plan, nor the PINGP Annex.
Request: Provide justification for not addressing the functional criteria for the OSC in the Xcel SEP and site-specific annexes.
Requirement:
Issue: Section H.3 of Enclosure 1, Attachment 1, Standard Emergency Plan, does not address some of the functional criteria in NUREG-0696 (e.g., function, size, structure, habitability, instrumentation, data system equipment and power supplies, etc.) for the proposed consolidated EOF.
Request: Provide justification for not addressing the functional criteria for the EOF in the Xcel SEP.
Requirement:
Issue: The Section 3.1.7 of Enclosure 4, Consolidation of Emergency Operations Facility,
- states, Instrumentation used to continuously monitor vital plant parameters in the MCR [main control room] is described in the site USARs [Updated Safety Analysis Reports].
Essential plant data monitoring capability is available in the emergency facilities through facility computer and display systems.
However, this does not address some of the functional criteria in NUREG-0696 (i.e., total EOF data system shall be designed to achieve an operational unavailability goal of 0.01 during all plant operating conditions above cold shutdown) for the proposed consolidated EOF.
Request: Does the EOF data system meet the operational unavailability goal as describe in NUREG-0696?
RAI 14
Requirement:
Working space for the personnel assigned to the EOF as specified in the licensees emergency plan, including State and local agency personnel.
Issue: Item H.3 of Enclosure 1, Attachment 1, Standard Emergency Plan, provides no discussion of State and local agency personnel.
Additionally, there is no discussion of State and local agency personnel responding to the proposed Consolidated EOF in Enclosure 4, Consolidation of Emergency Operations Facilities.
Request: Have the States or local agencies requested or considered any changes to its coordination with Xcel for emergency response actions by staffing appropriate State or local agency responders at the proposed consolidated EOF?
RAI 15
Requirement:
Issue: Item #590 of Enclosure 2, Attachment 3, Monticello Nuclear Plant Change Justification Matrix, states in part, The Standard Plan maintain the commitment to provide the capability without the detailed description of the specific methodology used.
However, the proposed Xcel SEP and site-specific annexes removed significant details contained in currently approved emergency plans for the respective sites.
Request: Provide justification for not addressing the evaluation criteria in the Xcel SEP and site-specific annexes with respect to the post-accident sampling capability.
RAI 16
Issue: Item I.10 of Enclosure 1, Attachment 1, Standard Emergency Plan, states in part, Xcel Energy personnel coordinate environmental radiological monitoring and assessment efforts with state assessors as appropriate for the site.
However, the LAR proposed consolidation of the responsibilities and coordination of the local EOFs into the backup EOF.
Request: Have the States or local agencies requested or considered any changes to the coordination of the environmental radiological monitoring and assessment efforts at the proposed consolidated EOF?
RAI 17
Issue: Item I.10 of Enclosure 1, Attachment 1, Standard Emergency Plan, states in part, Xcel Energy personnel coordinate environmental radiological monitoring and assessment efforts with state assessors as appropriate for the site.
However, this level of detail does not provide enough information for the NRC staff to evaluate if the evaluation criteria has been met for the Xcel SEP and site-specific annexes.
Request: Provide justification for not addressing the applicable evaluation criteria in the Xcel SEP and site-specific annexes.
RAI 18
Issue: Item J.1 of Enclosure 1, Attachment 1, Standard Emergency Plan, states in part, The implementing procedures describe.
The implementing procedures also describe provisions made.
However, this level of detail does not provide enough information for the NRC staff to evaluate if the evaluation criteria has been met for the Xcel SEP and site-specific annexes.
Request: Provide justification for not addressing the applicable evaluation criteria in the Xcel SEP and site-specific annexes.
RAI 19
Issue: Item J.3 of Enclosure 1, Attachment 1, Standard Emergency Plan, states in part, Requirements for radiological monitoring of personnel evacuated from the site are contained in Section L and address appropriate actions for any known or suspected overexposures or contamination. Details on the decontamination of evacuees are in Radiological Protection Procedures.
However, Section L is for Medical and Public Health Support, and doesnt specifically address radiological monitoring of personnel, including visitors that may be evacuated from the facility.
Request: Provide justification for not addressing the applicable evaluation criteria in the Xcel SEP and site-specific annexes.
RAI 20
Issue: Item J.5 of Enclosure 1, Attachment 1, Standard Emergency Plan, states in part, A range of protective actions applicable to site personnel include:
Additionally, Item #362 to 413 of Enclosure 2, Attachment 3, Monticello Nuclear Plant Change Justification Matrix, provides a majority of the justifications for removing the details for personal radiological protection for individuals arriving or remaining onsite during the incident as:
The Plan standardizes the language between the three existing Plans without change in practice or intent.
Similar changes are provided in Enclosure 3, Attachment 3, Prairie Island Nuclear Generating Plant Emergency Plan Justification Matrix.
However, this level of detail does not provide enough information for the NRC staff to evaluate if the evaluation criteria has been met for the Xcel SEP and site-specific annexes.
Request: Provide justification for not addressing the applicable evaluation criteria in the Xcel SEP and site-specific annexes.
RAI 21
Requirement:
Prior to the initial operation of a co-located or consolidated EOF and in at least one drill or exercise per exercise cycle thereafter, the EOF staff will demonstrate the ability to perform the additional co-located or consolidated EOF functions set forth in Subsection 4.1. [emphasis added]
Issue: Enclosure 4, Consolidation of Emergency Operations Facilities, Section 3.1.3, Staffing and training, states in part:
The ERO staff for the proposed EOF is described in Section B.1.a of the proposed Xcel SEP (Attachment 1 to Enclosure 1), and the training program is described in its Section O.
However, the proposed Xcel SEP or site-specific annexes does not discuss the frequency of conducting this drill or exercise (e.g. per exercise cycle).
Request: Clarify the frequency for conducting a periodic drill involving simultaneous events at multiple sites to periodically test and verify functional capability of the proposed consolidated EOF to support simultaneous events at multiple sites requiring EOF activation.
Requirement:
Issue: Section N, Exercises and Drills, of the Xcel SEP does not address whether these periodic drill or exercises will be used on a continuing basis to specifically evaluate the adequacy of the minimum staffing levels to ensure that they continue to retain the necessary key skills to perform required major functions prior to full augmentation.
Request: Describe how Xcel plans to specifically evaluate the adequacy of the minimum staffing levels to perform required functions until full augmentation, with the proposed ERO staffing changes, to ensure continued effective implementation of the respective emergency plans for each site.
Requirement:
Issue: Item P.3 of Enclosure 1, Attachment 1, Standard Emergency Plan, states in part, with other response organizations as shown in Figure P.1.
However, there is no Figure P.1 in the proposed Xcel SEP.
Request: Clarify if this information is correct and if so, include the referenced figure as appropriate, in the Xcel SEP and site-specific annexes.