Text

Issuance of Amendment No. 209 Ten-Year Inspection of the Diesel Generator Fuel Oil Storage Tank
	ML22318A215
Person / Time
Site:	Monticello
Issue date:	12/27/2022
From:	Robert Kuntz; NRC/NRR/DORL/LPL3
To:	Domingos C; Northern States Power Company, Minnesota
References
	EPID L-2021-LLA-0231
	Download: ML22318A215 (1)
	v • d • e

December 27, 2022 Mr. Christopher P. Domingos Site Vice President Northern States Power Company - Minnesota Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - ISSUANCE OF AMENDMENT NO. 209 RE: 10-YEAR INSPECTION OF THE DIESEL GENERATOR FUEL OIL STORAGE TANK (EPID L-2021-LLA-0231)

Dear Mr. Domingos:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 209 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant. The amendment consists of changes to the technical specifications (TSs) in response to your application dated December 13, 2021, as supplemented by letter dated August 8, 2022.

The amendment revises TSs 3.8.2, AC [alternating current] Sources - Shutdown, and 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, to allow the common fuel oil storage tank to be out of service for up to 14 days to complete an inspection required every 10 years under the License Renewal Aging Management, Fuel Oil Chemistry, and Buried Piping and Tanks Inspection programs.

C. Domingos A copy of the safety evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Robert F. Kuntz, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosure:

1. Amendment No. 209 to DPR-22

2. Safety Evaluation cc: Listserv

NORTHERN STATES POWER COMPANY DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 209 Renewed License No. DPR-22

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

A. The application for amendment by Northern States Power Company (NSPM) dated December 13, 2021, as supplemented by letter dated August 8, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.2 of Renewed Facility Operating License No. DPR-22 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 209, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented prior to beginning the inspection of the fuel oil storage tank.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Scott Scott P. Wall P.Date:Wall 2022.12.27 14:46:34 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: December 27, 2022

ATTACHMENT TO LICENSE AMENDMENT NO. 209 MONTICELLO NUCLEAR GENERATING PLANT RENEWED FACILITY OPERATING LICENSE NO. DPR-22 DOCKET NO. 50-263 Renewed Facility Operating License Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT Page 3 Page 3 Technical Specifications Replace the following page of the Appendix A, Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3.8.2-3 3.8.2-3 3.8.3-1 3.8.3-1 3.8.3-2 3.8.3-2 3.8.3-3 3.8.3-3

2. Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensees filings dated August 16, 1974 (those portions dealing with handling of reactor fuel);

3. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

4. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and

5. Pursuant to the Act and 10 CFR Parts 30 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission, now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

1. Maximum Power Level NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 2004 megawatts (thermal).

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 209, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. Physical Protection NSPM shall implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Amendment No. 209

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------------------------------NOTE-----------------------------

1. The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.7, SR 3.8.1.9, and SR 3.8.1.11.

2. SR 3.8.1.5 is not applicable during the fuel oil storage tank inspection during the 2023 Refueling Outage. This note expires upon completion of that inspection.

The following SRs are applicable for AC sources In accordance required to be OPERABLE: with applicable SRs SR 3.8.1.1 SR 3.8.1.5 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.3 SR 3.8.1.9 SR 3.8.1.4 SR 3.8.1.11 Monticello 3.8.2-3 Amendment No. 209

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystems shall be within limits for each required emergency diesel generator (EDG).

APPLICABILITY: When associated EDG is required to be OPERABLE.

ACTIONS

NOTE-----------------------------------------------------------

1. Separate Condition entry is allowed for each EDG.

2. a. During the 2023 Refueling Outage the fuel oil storage tank (FOST) may be made inoperable and drained, to support cleaning, inspection, testing, and associated repair activities without entering Conditions A or G, provided Notes 2.b through 2.d are satisfied.

If the FOST is not restored within 14 days, or Notes 2.b through 2.d are not satisfied, enter Condition G.

b. Verify once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the Alternate Fuel Oil Supply System (AFOSS) contains at least a 7-day supply of fuel oil.

c. While in standby, verify once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the required EDG day/base tanks, in combination, provides an 8-hour supply of fuel oil.

d. The compensatory measures specified within Attachment 1 to letter L-MT-21-072 are applicable to performance of the FOST inspection evolution.

e. SR 3.8.1.5 and SR 3.8.3.1 are not required to be met during the FOST inspection evolution.

f. Note 2 expires upon completion of the FOST inspection evolution during the 2023 Refueling Outage.

CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel oil level < 7-day A.1 Restore fuel oil level to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months supply and > 6-day within limits.

supply in storage tank.

Monticello 3.8.3-1 Amendment No. 209

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more EDGs with B.1 Restore lube oil inventory to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months lube oil inventory within limits.

< 7-day supply and

> 6-day supply.

C. Stored fuel oil total C.1 Restore fuel oil total 7 days particulates not within particulates to within limit.

limit.

D. New fuel oil properties D.1 Restore stored fuel oil 30 days not within limits. properties to within limits.

E. One or more EDGs with E.1 Restore starting air receiver 7 days starting air receiver pressure to 165 psig.

pressure in one starting air subsystem

< 165 psig.

F. One or more EDGs with F.1 Restore starting air receiver 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months starting air receiver pressure in one starting air pressure in both starting subsystem to 165 psig.

air subsystems

< 165 psig and 125 psig.

G. Required Action and G.1 Declare associated EDG Immediately associated Completion inoperable.

Time of Condition A, B, C, D, E, or F not met.

OR One or more EDGs with diesel fuel oil, lube oil, or starting air subsystem(s) not within limits for reasons other than Condition A, B, C, D, E, or F.

Monticello 3.8.3-2 Amendment No. 209

Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify the fuel oil storage tank contains a 7-day In accordance with supply of fuel. the Surveillance Frequency Control Program SR 3.8.3.2 Verify, for each EDG, lube oil inventory is a 7-day In accordance with supply. the Surveillance Frequency Control Program SR 3.8.3.3 Verify fuel oil properties of new and stored fuel oil In accordance are tested in accordance with, and maintained within with the Diesel the limits of, the Diesel Fuel Oil Testing Program. Fuel Oil Testing Program SR 3.8.3.4 Verify each EDG air start receiver pressure is In accordance with 165 psig. the Surveillance Frequency Control Program SR 3.8.3.5 Check for and remove accumulated water from the In accordance with fuel oil storage tank. the Surveillance Frequency Control Program Monticello 3.8.3-3 Amendment No. 209

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 209 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 December 13, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21348A718), as supplemented by letter dated August 8, 2022 (ML22220A272), Northern States Power Company (the licensee) requested a change to the technical specifications (TSs) for Monticello Nuclear Generating Plant (Monticello).

The proposed amendment would revise TSs 3.8.2, AC [alternating current] Sources -

Shutdown, and 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air, to allow the common fuel oil storage tank (FOST) to be out of service for up to 14 days to complete the inspection of the FOST required every 10 years under the License Renewal Aging Management, Fuel Oil Chemistry, and Buried Piping and Tanks Inspection programs.

The supplemental letter dated August 8, 2022, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on February 22, 2022 (87 FR 9647).

2.0 REGULATORY EVALUATION

2.1 System Description Monticellos Updated Safety Analysis Report (USAR) section 8.4.1, Safeguard Emergency Diesel Generator (EDG) Systems (ML21070A109), describes each EDG (11 or 12) having local fuel tanks (day tank and base tank) fed from a common FOST. This common FOST contains a fuel oil capacity sufficient to operate one EDG for 7 days. Each EDG has a separate fuel supply in a day tank (T-45 A or B). A small fuel tank, known as the base tank, is mounted on the same base as the engine, generator, and controls. The day tanks are supplied from the common FOST, which contains sufficient fuel capacity for one weeks operation of one unit at full power.

Enclosure 2

During normal operation, fuel is transferred from the FOST, located underground, to the local day tanks using diesel oil transfer pumps. The EDG 11 transfer pumps (P-160 A & C) are in the Diesel Oil Pump House (below grade). The EDG 12 transfer pumps (P-160 B & D) are in the Diesel Generator Building T-45B Day Tank Room (above grade). Each division has a dedicated suction connection to the FOST to provide an independent supply of fuel oil to each EDG day tank. However, these existing transfer pumps cannot be used when the FOST is unavailable and drained during the FOST inspection evolution.

The normal fuel storage system consists, in part, of:

One main FOST (T-44), which contains sufficient capacity (i.e., 60,000 gallons) to provide for approximately 7 days of operation at rated load.

A 10,000-gallon Diesel Oil Receiving Tank (T-83) (located underground) is used to isolate replacement fuel oil until it can be sampled and verified to meet specifications prior to transfer to the FOST.

One day tank (and base tank) per EDG containing 1,500 gallons per tank, each located in isolated, separate rooms within the Seismic Class 1 Diesel Generator Building. The day tank and base tank combination has at least an 8-hour fuel supply for the engine at full load.

The EDG day tanks are normally kept continuously full by an operating transfer pump in each division, with the redundant pump available to place in service to support maintenance. Excess fuel oil recirculates back to the FOST by gravity flow from an overflow connection near the top of each day tank.

As indicated above, the diesel oil receiving tank (T-83) is used to isolate new fuel oil until it can be sampled and verified to meet specifications prior to transfer to the FOST. This tank will not be used to support the inspection evolution.

2.2 Proposed Changes The main FOST (T-44) is required to be inspected every 10 years under the License Renewal Aging Management, Fuel Oil Chemistry, and Buried Piping and Tanks Inspection programs, to manage aging effects regarding the potential for loss of material due to general corrosion, pitting corrosion, crevice corrosion, galvanic corrosion, and microbiological influenced corrosion.

This requires that the FOST be drained, inspected, cleaned, and repaired (as necessary) during each 10-year inspection performed with the plant shutdown during a refueling outage (RFO).

The TS changes are proposed to allow the common FOST to be out-of-service for up to 14 days for the purpose of performing tank inspection.

The proposed TS 3.8.3 changes insert appropriate required actions applicable during the FOST inspection evolution, implementation of initial conditions, and specification of TS requirements and compensatory measures in a proposed note to the specifications ACTIONS table, during the period the FOST is out-of-service (OOS). Surveillance Requirement (SR) 3.8.3.1 requires verification that the FOST supply supports 7-day operation. The proposed inserted required actions would make this SR inapplicable since FOST would not be available.

The proposed TS 3.8.2 changes add a note in SR 3.8.2.1 making SR 3.8.1.5 not applicable during the FOST inspection during the 2023 RFO. The proposed change would expire upon completion of the 2023 inspection.

2.3 Applicable Regulations The regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications. This regulation requires that the TSs include items in five specific categories. These categories include:

(1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls.

The regulation at 10 CFR 50.36(c)(2) states, in part, that the LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The NRC staffs technical evaluation also considers whether the safety and security measures, as proposed in the license amendment request (LAR), provide a level of protection commensurate with the protection measures required in 10 CFR 73.55, 10 CFR 73.58, and appendix C to part 73,Section II.B.3.c (v).

The regulation at 10 CFR 73.55(e)(7)(i)(B) requires the isolation zone to be monitored with intrusion detection equipment designed to satisfy the requirements of section 73.55(i) and be capable of detecting both attempted and actual penetration of the protected area (PA) perimeter barrier before completed penetration of the PA perimeter barrier.

The regulation at 10 CFR 73.55(e)(9), Vital areas, states that: (i) Vital equipment must be located only within vital areas, which must be located within a [PA] so that access to vital equipment requires passage through at least two physical barriers, except as otherwise approved by the Commission and identified in the security plans. (ii) The licensee shall protect all vital area access portals and vital area emergency exits with intrusion detection equipment and locking devices that allow rapid egress during an emergency and satisfy the vital area entry control requirements of this section. (iii) Unoccupied vital areas must be locked and alarmed.

(iv) More than one vital area may be located within a single [PA].

The regulation at 10 CFR 73.55(f)(1), Target sets, requires that [t]he licensee shall document and maintain the process used to develop and identify target sets, to include site-specific analyses and methodologies used to determine and group the target set equipment or elements.

The regulation at 10 CFR 73.55(o), Compensatory measures, states in part that (1) The licensee shall identify criteria and measures to compensate for degraded or inoperable equipment, systems, and component; (2) Compensatory measures must provide a level of protection that is equivalent to the protection that was provided by the degraded or inoperable, equipment, system, or components; (3) Compensatory measures must be implemented within specific time frames necessary to meet the requirements stated in paragraph (b) of this section and described in the security plans.

The regulation at 10 CFR 73.58(a) requires [e]ach operating nuclear power reactor licensee with a license issued under part 50 or 52 of this chapter shall comply with the requirements of

this section. 10 CFR 73.58(b) requires [t]he licensee to assess and manage the potential adverse effects on safety and security, including the site emergency plan, before implementing changes to plant configurations, facilities conditions, or security. 10 CFR 73.58(c) requires

[t]he scope of changes to be assessed and managed must include planned and emergent activities (such as, but not limited to, physical modifications, procedural changes, changes to operator actions or security assignments, maintenance activities, system reconfiguration, access modification or restrictions, and changes to the security plan and its implementation).

10 CFR 73.58(d) [w]here potential conflicts are identified, the licensee shall communicate them to appropriate licensee personnel and take compensatory and/or mitigative actions to maintain safety and security under applicable Commission regulations, requirements, and license conditions.

Appendix C to part 73, section II.B.3.c (v), requires licensees to develop, implement, and maintain a written protective strategy to be documented in procedures that describes in detail the physical protection measures, security systems and deployment of the armed response team relative to site specific conditions, to include but not be limited to, facility layout, and the location of target set equipment and elements. The protective strategy should support the general goals, operational concepts, and performance objectives identified in the licensees safeguards contingency plan.

As stated in section 4.1 of the LAR, the Monticello design was reviewed for construction under the General Design Criteria (GDC) for Nuclear Power Plant Construction, issued for comment by the Atomic Energy Commission (AEC) in July 1967, and is committed to meet the intent of the General Design Criteria (GDC), published in the Federal Register on May 21, 1971, as appendix A to 10 CFR part 50.

GDC Criterion 17, Electric power systems, states, in part:

An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled, and containment integrity and other vital functions are maintained in the event of postulated accidents. The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

2.4 Applicable Guidance Chapter 18, Human Factors Engineering, of NUREG-0800 Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: [light-water reactor]

Edition (ML16125A114), contains the guidance used by NRC staff to conduct regulatory reviews of license amendments that address human factors topics. It directs NRC staff to applicable review criteria such as those included in NUREG-1764, Guidance for the Review of Changes to Human Actions, Revision 1, (ML072640413). NUREG-1764 describes how to assess changes to manual operator actions. It provides a risk-informed process to determine the level of NRC review necessary and provides the acceptance criteria for each level of review.

NUREG-1764 states that a Level I review is used for human actions (HAs) in the high-risk

category, which require the most stringent review. A Level I review includes most of the review elements from NUREG-0711, Human Factors Engineering Program Review Model, Revision 3 (ML12324A013).

NUREG-1764 also states that the NRC conducts a Level II review for HAs in the medium risk category. While the guidance addresses topical areas similar to those in the Level I review, the extent of the staff's review is notably less for Level II. The evaluation processes for this level are less prescriptive and afford greater latitude to both the licensee and the NRC reviewers for collecting and analyzing information. The Level II evaluation process addresses general deterministic review criteria, analysis, human-system interface design, procedures, training, and HA verification.

NUREG-1764 further states that HAs in the low-risk category receive a Level III review by the NRC, which is generally limited to verifying-that the HA is in fact in Level Ill. Typically, no detailed HFE review is necessary. Licensees may choose to use the Level II guidance to address HFE considerations for HAs that fall into Level Ill.

Regulatory Guide (RG) 5.44, Perimeter Intrusion Alarm Systems, Revision 3, dated October 1997 (ML003739217), describes methods acceptable to the NRC staff that licensees can use to provide detection of penetration or attempted penetration of the PA or the isolation zone adjacent to the PA barrier to ensure that adequate response by the security organization can be initiated.

RG 5.74, Managing the Safety/Security Interface, Revision 1, dated April 2015, (ML14323A549), describes a method that the NRC staff considers acceptable for nuclear power plant licensees to assess and manage changes to safety and security activities to prevent or mitigate potential adverse effects that could negatively impact either plant safety or security at power reactors.

RG 5.76, Physical Protection Programs at Nuclear Power Reactors, Revision 1, dated November 2020 and RG 5.54, Standard Format and Content of Safeguards Contingency Plans for Nuclear Power Plants, Revision 1, dated June 2009, (both nonpublic safeguards information (SGI)), provides guidance on meeting the requirements related to the layers of defense and defense-in-depth (DID). RG 5.76 also describes interlocking/overlapping fields-of-fire.

3.0 TECHNICAL EVALUATION

3.1 Technical Specification Changes Evaluation The EDGs are provided with a common FOST having a fuel oil capacity sufficient to operate one EDG for 7 days while that EDG is supplying full load (2500 KW). As noted in the LAR, fully draining the FOST every 10 years for the performance of inspections and any necessary cleaning, repair, and testing activities is required to meet license renewal committed inspection activities. Performance of the FOST inspection is planned during the 2023 RFO and could take up to 14 days while the reactor is shutdown and the reactor cavity is fully flooded up for refueling.

During the inspection process, the FOST (T-44 being inspected) and diesel oil receiving tank (T-83) will be unavailable along with their FOST transfer pumps. The licensee estimated that the required draining, inspecting, and refilling of the FOST will take approximately 10 days. The

requested 14-day Completion Time includes some margin should the evolution take longer than expected and provides time to complete any necessary repairs if required.

A temporary alternate fuel oil supply system (AFOSS) will be installed and used to support the EDG fuel inventory needs. This AFOSS supply is used to maintain the operability of the required EDG during the inspection evolution. The AFOSS, referred to as hybrid fuel oil system in the application, uses the following:

1. The existing safety-related EDG day and base tank combination located within the Diesel Generator Building; and

2. Double-walled temporary fuel oil storage tanks (typically rated at 18,000 gallons each) installed onsite, referred to as FRAC tanks, and associated fuel oil transfer equipment that will substitute for the FOST as the EDG day tank supply source.

The LAR states that the EDG day and base tanks in combination provide an 8-hour safety-related, seismically qualified supply of fuel oil. The AFOSS provides the requisite 7-day supply of fuel oil to the required EDG day tank during the FOST inspection evolution. The LAR states these tanks will be verified once per 24-hours to contain the required amount of fuel oil. If the FRAC tanks were themselves to be impacted, there are other sources of diesel fuel oil available onsite and within the Twin Cities metro area, as described in section 3.6 (note 5) of the LAR.

TS 3.8.2 requires one qualified offsite circuit and one EDG to be operable and capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem in Modes 4 and 5. To avoid inoperability due to SRs, a note would be added in SR 3.8.2.1 making SR 3.8.1.5 not applicable during the FOST inspection, and which would expire upon completion of that inspection. The NRC staff finds that this note is acceptable since the change does not impact availability or function of the EDGs and allows the planned inspection and cleaning to be performed without entering this LCO.

The LAR also proposes incorporation of a note 2 (Items a through f) into ACTIONS in TS 3.8.3 to allow the main FOST to be inoperable for up to 14 days. The note requires that if the FOST is not restored within 14 days, or if notes 2.b through 2.d are not satisfied, the licensee must enter TS 3.8.3 Condition G and immediately declare the associated EDG inoperable. To avoid inoperability due to TS 3.8.3 surveillance requirements, note 2.e is added, making SR 3.8.3.1 FOST inventory verification not applicable during the FOST inspection, and which would expire upon completion of that inspection (Note 2.f).

The new TS 3.8.3 Note 2 specifies the appropriate TS required actions and compensatory measures applicable during the FOST inspection evolution. This note 2 includes the following required actions to be taken during the FOST cleaning activity:

a. During the 2023 Refueling Outage [RFO] the FOST may be made inoperable and drained, to support cleaning, inspection, testing, and associated repair activities without entering Conditions A or G, provided Notes 2.b through 2.d are satisfied. If the FOST is not restored within 14 days, or if Notes 2.b through 2.d are not satisfied, enter Condition G.

b. Verify once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the AFOSS contains at least a 7-day supply of fuel oil.

c. While in standby, verify once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months that the required EDG day/base tanks, in combination, provides an 8-hour supply of fuel oil.

d. The compensatory measures specified within Attachment 1 to letter L-MT-21-072 are applicable to performance of the FOST inspection evolution.

e. SR 3.8.1.5 and SR 3.8.3.1 are not required to be met during the FOST inspection evolution.

f. Note 2 expires upon completion of the FOST inspection evolution during the 2023 Refueling Outage.

As indicated in the newly added note 2.d, compensatory measures specified within to the LAR are applicable to performance of the FOST inspection evolution. These proposed compensatory measures are discussed in section 3.7 and Attachment 1 of the LAR.

To support the removal of the FOST from service, a temporary AFOSS will be installed onsite and verified to supply the requisite 7-day supply of fuel oil to the required EDG day tanks during the FOST inspection evolution. The alternate diesel fuel oil supply system, which the LAR stated will be established prior to beginning the FOST drain down, consists of the existing required EDG day and base tanks located in the diesel generator building, re-supplied as required by alternate fuel oil source.

The compensatory measures specified within attachment 1 to the LAR are applicable to performance of the FOST inspection evolution. Attachment 1 contains a table with the following TS compensatory measures:

1. Prior to removing the FOST from service verify the AFOSS is staged and can contain and provide a 7-day supply of fuel oil to the required EDG.

2. Prior to removing the FOST from service verify the required EDG day and base tank, in combination, provide an 8-hour supply of fuel oil to the required EDG.

3. Procedures will be instituted to transfer fuel oil between the FOST and the AFOSS and from the AFOSS to the required EDG day tank.

4. Elective maintenance and testing that affects OPERABILITY of the required EDG will not be permitted.

5. Two of three power sources (i.e., the 1R, 2R, or 1AR transformers) are protected during the inspection evolution.

6. Evaluate weather forecast prior to beginning the FOST inspection evolution and periodically thereafter.

The LAR states that once the FOST is returned to service and declared operable, the TS conditions specified in note 2 to the ACTIONS table for TS 3.8.3 and note within SR 3.8.2.1 are no longer applicable and the AFOSS demobilized.

The proposed TS change has no effect on the design of the EDG, and the proposed actions will ensure that the EDG function is maintained during the inspection evolution. The NRC staff finds that the compensatory measures in Attachment 1 of the LAR adequately describe reasonable

actions during the required draining, inspecting/cleaning, and refilling of the FOST. The NRC staff finds the compensatory actions to be appropriate as they will be implemented to minimize the likelihood of needing the EDGs and retain the ability of FOST function being available.

TS 3.8.2 requires one offsite power source and one EDG during Mode 5 and provides remedial actions for their inoperability. Compliance with 10 CFR 50.36(c)(2)(i) for TS 3.8.2 (TS LCO itself and its remedial actions) is maintained since this LAR does not impact TS 3.8.2 except for the minor change of not requiring one of its SRs during the FOST inspection.

The proposed note 2 to TS 3.8.3 allows monitoring of AFOSS and EDG day tanks to ensure availability of the required EDG. If, during RFO 23, that note is not followed, then required action 3.8.3.G.1 would be entered, requiring the operable Division 1 EDG to be declared inoperable. If EDG is declared inoperable, the licensee must take immediate actions to restore its operability under TS 3.8.2. Restoration depends on the exact condition causing its operability. The NRC staff finds that compliance with 10 CFR 50.36(c)(2)(i) concerning TS 3.8.3 is maintained due to monitoring of fuel oil in AFOSS, including EDG day tank, and because of the required, remedial action invoked by 3.8.3.G.1. Declaring the required EDG inoperable, if necessary, and its restoration to operability is governed by TS 3.8.2. Those requirements are not altered by this LAR.

During the FOST inspection, initial conditions and compensatory measures to ensure the availability of the operable EDG and adequate fuel for its operation are included, as discussed above. Further, the AFOSS will provide sufficient capacity for the operation of one EDG for 7 days of operation at rated load. Therefore, the EDG will be available and capable to perform its safety function. As such, the NRC staff finds that the proposed change does not affect compliance with GDC 17 based on availability of onsite electric power system to permit functioning of structures, systems, and components important to safety.

3.1.1 Defense-In-Depth (DID)

Regarding DID, Monticello has alternate power sources, including the non-safety diesel generator 13 (DG13), as indicated in LAR, section 3.6. Further, the required EDG and two offsite power sources, will be protected as noted in initial conditions 4 and 5, which is one more offsite source than as specified for Mode 5 by TS 3.8.2.

The NRC staff notes that the DID considerations proposed in the amendment request for FOST inspection ensures that alternate power sources are available if needed.

3.2 Evaluation of HFE (Human Factors Engineering) 3.2.1 HFE Estimate of the Warranted HFE Review Level Because the LAR was not a risk-informed submittal, NRC staff considered the guidance in section 2.4 of NUREG-1764, Screening Process for Non-Risk-Informed Change Requests.

Since the AFOSS was not modeled in the NRCs standardized plant analysis of risk (SPAR),

NRC staff used the generic method, discussed in section 2.4.3.2 of NUREG-1764, to develop an initial estimate of the HFE review-level warranted for the review of the LAR.

The NRC staff determined that the human action being considered in the LAR was associated with the actions involving the risk-important systems listed in group 2 of Table A.2, Generic PWR [pressurized-water reactor] Human Actions That Are Risk Important. in Appendix A of

NUREG-1764. Subsequently, to determine whether the proposed change to human actions warranted an initially estimated assignment of a Level-II or a Level-III review, the NRC staff considered the following information from the LAR.

The LAR states that the FOST is removed from service for this inspection evolution and the required EDG day tank will be described in procedures or temporary modification documents utilized during the FOST inspection evolution. Further, the inspection evolution will require the following analogous operator monitoring/actions for the installed AFOSS. Note that these procedures/temporary modification documents are Compensatory Measures as described in section 3.7 and attachment 1 of the LAR.

Monitoring fuel level (volume) in the AFOSS storage tanks (colloquially referred to as FRAC tanks) instead of the FOST. Monitoring the FOST is done once per shift while an EDG is in standby and approximately hourly while an EDG is in service. As this is passive monitoring, and is essentially the same action that currently exists, no timing analysis was performed.

Monitoring fuel level in the required EDG Day Tank instead of verifying continuous flow from the FOST. This is done once per shift while an EDG is in standby and approximately hourly while an EDG is in service. As this is passive monitoring, and is essentially the same action that currently exists, no timing analysis was performed.

Receiving new fuel oil directly to the AFOSS storage tanks rather than receiving fuel oil to the Diesel Oil Receiving Tank (T-83) and then transferring it to the FOST.

Combining these two existing activities into a single action simplifies the process requiring less time than the process currently employed, hence no timing analysis was performed.

Transferring fuel oil from the FRAC tanks to maintain the required EDG Day Tank supply manually instead of the normal continuous flow from the FOST. This will be accomplished by routing a discharge hose from a portable fuel oil transfer pump which takes suction on the FRAC tanks to transfer fuel oil to the required EOG Day Tank.

A timing analysis involving a simulated walk through of the evolution using the current planned temporary modification documents for the AFOSS was performed which resulted in the following timeline:

o In parallel, one operator reports to the AFOSS where the portable fuel oil transfer pump is located, while a minimum of one operator along with a security officer and a radiation protection technician report to the 11 EDG Room access door - approximately 5 minutes total.

o The EDG access door is opened and the pre-staged hose is routed to the EDG Day Tank designated fill point - approximately 20 minutes.

o The portable fuel oil transfer pump is started and filling commences -

approximately 5 minutes.

o Therefore, approximately 30 minutes will be needed to commence filling the required EDG Day Tank.

Additionally, as described in the LAR, once commenced, a complete refilling of an empty EDG day tank (a 1,500 gallon tank) is estimated to take approximately 30 minutes. Therefore, based on the above considerations, the time duration to refill the required EDG day tank is well within the minimum 8-hour supply of fuel oil available for the EDG.

This evolution involves full draining the FOST every 10 years for the performance of these inspections and any necessary cleaning, repair and testing activities required will take place.

Performance of the FOST inspection will occur during the RFO when the reactor is shut down and the reactor cavity is flooded up for refueling. An AFOSS will be installed during this time.

The LAR states that operating procedures for the AFOSS will be developed and training will be provided to the operators as determined by the system approach to training (SAT) process for the fuel oil transfer activities during the FOST inspection.

3.2.2 Qualitative Assessment of Human Action Safety-Significance In accordance with section 2.3.5.1 of NUREG-1764, Factors Used in the Qualitative Assessments, the NRC staff determined that the LAR warranted a qualitative assessment of personnel functions and tasks, and design support for task performance. In conducting this assessment, the staff considered the following factors:

Change in Tasks: Has the requested change significantly modified the way in which personnel perform their tasks?

Change in Performance Context: Has the requested change created, in some way, a new context for task performance?

Change in Procedures: Has the requested change significantly changed the procedures that personnel use to perform the task?

Change in Training: Has the requested change significantly modified the training, or is the task not addressed in training?

Task and Performance Context Considerations Regarding task and performance considerations, the NRC staff determined that the use of the AFOSS does not constitute a change of the task because the tasks are essentially the same but are being performed with the AFOSS instead of the FOST. There is a manual action to route a discharge hose from a portable fuel oil transfer pump which takes suction from the AFOSS to transfer the fuel oil to the day tanks. A timing analysis involving a simulated walk through of the evolution using the current planned temporary modification documents for the AFOSS was performed as follows:

In parallel, one operator reports to the AFOSS where the portable fuel oil transfer pump is located, while a minimum of one operator along with a security officer and a radiation protection technician report to the 11 EDG Room access door - approximately 5 minutes total.

The EDG access door is opened and the pre-staged hose is routed to the EDG Day Tank designated fill point - approximately 20 minutes.

The portable fuel oil transfer pump is started and filling commences -

approximately 5 minutes.

Therefore, approximately 30 minutes will be needed to commence filling the required EDG Day Tank.

Procedure and Training Considerations The NRC considered the significance of any changes to procedures or training associated with this TS change, and whether these procedures would serve to ensure that operators were aware of the change. The LAR states that procedures will be in place and training will be provided to the operators as determined by the SAT training process for the fuel oil resupply activities to the required EDGs day tank during the FOST inspection.

3.2.3 NRC Staff HFE Review Level Determination The NRC staff reviewed the proposed changes and considered the actions involved with the FOST inspection activities. The proposed change will occur during the refueling of one of the reactors supported by this system. The staff reviewed Table A.1, Generic BWR [boiling-water reactor] Human Actions That Are Risk Important, in Appendix A of NUREG-1764 and verified that no actions from that table are included in the LAR, which would have indicated that the planned human actions are potentially important to risk.

The NRC staff concludes that, while draining a common FOST is a potentially risk-important human action, this evolution is occurring during refueling when the reactor vessel cavity is flooded and while the AFOSS will be supplying fuel oil to the remaining in-service EDG. Further, DID will be maintained because offsite power sources will be available and, therefore, the risk significance remains low. In addition, any actions that are new or impacted by this temporary modification will be proceduralized and operators will receive training per the SAT process, as stated in the LAR.

The NRC staff considered available relevant risk information in the LAR. The LAR provided an evaluation of the associated risk, stating that during the FOST inspection evolution, the required EDG will continue to rely on its safety-related 8-hour day tank located withing the Seismic, Category 1, diesel generator building to provide fuel oil for operation, and the EDG will be periodically resupplied from the AFOSS during the time the FOST is out of service.

Based on the review of Table A.2, in NUREG-1764 and range in which the integrated conditional core damage probability fall according to NUREG-1764, a Level III review, the least stringent, human factors review was determined to be appropriate. Therefore, the NRC staff applied the criteria for a Level III review.

3.2.4 NRC Staff HFE Conclusion The LAR, as supplemented, described the operator actions associated with the proposed changes to the TS to support the 10-year inspection of the EDG FOST. The NRC staff reviewed the list of proposed scheduled activities and verified that these actions are in the low-risk category by assessing them against the applicable tables in NUREG-1764.

The NRC staff confirmed that operator actions planned as part of this amendment do not provide any significant increase in risk to the facility and existing operator actions contained in the current licensing basis continue to provide a reasonable means of DID during the outage period. Therefore, the NRC staff finds that the HFE factors related to the requested change to TSs 3.8.3 and 3.8.2 acceptable.

3.3 Technical Specification Evaluation Conclusion Based on the discussion above, including the initial conditions, the compensatory measure referred to in the revised note 2 of TS 3.8.3, and DID considerations, the NRC staff finds the proposed amendment to be acceptable because controls are in place to retain ability for the EDGs to perform their design functions during inspection, maintenance, and associated repair activities of the main FOST. While the EDG fuel tank is unavailable, the EDG will remain available with adequate fuel supply retained onsite consistent TS volumetric requirements.

Additionally, the proposed change does not affect the continued compliance with GDC 17.

Therefore, the NRC staff finds TS changes acceptable for the proposed amendment to extend the expiration on a one-time basis for the main FOST to be inoperable for up to 14 days for the purpose of performing required inspection, cleaning, and any necessary repair activities.

Further, NRC staff reviewed the actions included in the proposed changes to the TS applying the guidance in NUREG-1764 by conducting a Level III review that focused on ensuring that DID was not degraded. The staff confirmed that the operator actions described in the amendment are low-risk. The NRC staff found that the DID actions are maintained and, therefore, the staff concluded that there is no significant degradation in safety as a result of approving this amendment with regards to HFE. Ultimately, the NRC staff finds that the proposed changes are consistent with the elements in NUREG-1764 and therefore as discussed in Section 3.1 of this safety evaluation, the NRC staff finds that the proposed TS changes meet the criteria in 10 CFR 50.36(c)(2) and GDC 17. Therefore, the proposed changes are acceptable. Further, as discussed in Section 3.2 of this SE, the NRC staff finds that the HFE factors related to the proposed TS changes are acceptable.

3.4 Physical Security Evaluation The LAR, as supplemented, did not propose changes to the site security plan. The Monticello Security Plan includes the Physical Security Plan, Training and Qualification Plan, the Safeguards Contingency Plan (hereafter, Security Plan), and the Cyber Security Plan (CSP).

There was limited security information provided in this submittal as described below.

The LAR states, in part:

To support the removal of the FOST from service, a temporary, alternate fuel oil storage system (AFOSS) will be installed onsite to supply the requisite 7-day supply of fuel oil to the required emergency diesel generator (EDG) day tank during the FOST inspection evolution.

The transfer equipment AFOSS will be a hybrid fuel oil system consisting of two parts: first, the existing safety-related required EDG day and base tanks combination located within the Diesel Generator Building; and second, the double-walled temporary fuel oil storage tanks installed onsite, colloquially referred to as FRAC tanks and associated fuel oil, that will substitute for the FOST as the EDG day tank supply source. The FRAC tanks will be located outside the Protected Area (PA) with the hoses and the fuel transfer system located inside the PA. Hoses from the FRAC tanks to the pumping equipment penetrating the PA fencing area will have security compensatory measures implemented as determined by the Security Plan.

When refilling the required EDG day tank, a hose from the fuel oil AFOSS transfer pump will be routed through a door of the Diesel Generator Building and into the required EDG day tank room. An elbow on the vent line from the day tank return to the FOST will be removed and used as the fill connection to the required EDG day tank. Appropriate fire protection and security measures will be implemented during the time the hose is run through the door of the Diesel Generator Building.

For this review, the NRC staffs evaluation of the LAR considered the planned temporary plant changes and the extent that these changes may impact the site security plans and protective strategy and their implementation. The NRC staffs review evaluated the physical security barriers that were proposed to be breached with temporary equipment and compensatory security measures. The staffs review also evaluated how the temporary change may affect other physical security aspects such as target sets, vital areas, interlocking/overlapping fields-of-fire, safety/security interface, and operator actions.

To complete the NRC staffs evaluation, additional information was requested of the licensee. A request for additional information (RAI) was submitted to the licensee via e-mail dated June 24, 2022, (ML22175A160). The licensees response to the staffs RAI was provided by letter dated August 8, 2022. The attachment to the licensee response contains SRI and is withheld from public disclosure in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding.

3.4.1 System Description (Safety/Security Interface)

The NRC staffs RAI included RAI-3, which requested a description of how safety/security interface is being addressed for the temporary plant change in accordance with 10 CFR 73.58, Safety/security interface requirements for nuclear power reactors.

The licensee stated in the enclosure to the letter dated August 8, 2022, that safety/security interface is addressed by the nuclear industry Standard Design Process. The response stated, in part, that development and implementation of the AFOSS temporary modification is controlled by this process. The licensee performed a Design Attribute Review to determine potentially impacted engineering disciplines/programs and stakeholders from other departments/areas, including site Security and Emergency Preparedness. The response stated that their Design Attribute Review resulted in an impact review performed by Security, who evaluated the physical changes to the plant for their effects on the site Security Plan. The response noted that security related input to support this temporary modification development, as well as the need for compensatory measures, was provided. The licensee concluded that there were no impacts

of the proposed amendment to the site Emergency Plan.

Accordingly, the NRC staff finds this response regarding safety/security interface to be acceptable because the licensees Design Attribute Review evaluated the physical changes to the plant for their effects on the site Security Plan and found that there would be no impact on the safety/security interface. Therefore, the NRC staff finds that 10 CFR 73.58(a-d) will continue to be met.

3.4.2 Security Compensatory Measures (Unattended Openings (UAO), PA Fence Line Penetration, Diesel Generator Building Access)

The NRC staffs RAI included RAI-2, item 1, which requested a description of how Monticello will continue to be protected against the design basis threat (DBT) with the security compensatory measures in place for the duration of the temporary configuration change to the plant.

The licensee response stated that, first, compensatory measures will be implemented during several phases of the temporary configuration change. For the first phase, the compensatory measures will be implemented during the time that excavation is conducted to entrench/install the fuel transfer hoses under the PA boundary. The response mentions that these specific compensatory measures will no longer be needed once the fuel transfer hoses are established under the PA boundary because the size of these hoses does not result in an UAO. The response also stated that these compensatory measures will also be established during the removal of the fuel transfer hoses. Furthermore, the response stated that compensatory measures will be in accordance with section 21.1 of the site Security Plan.

The response states that the compensatory measures will be implemented whenever the Diesel Generator Building door is opened to transfer fuel oil into the required EDG day tank. The licensee states that compensatory measures will be implemented during this phase are in accordance with section 21.2 of the Security Plan.

The NRC staffs RAI included RAI-2, item 2, which requested a description of how the hoses will penetrate the PA fence line (e.g., through open gates, penetration(s) through the fence line fabric) and requested the licensee to describe the security compensatory measures that will be implemented within site procedures in accordance with 10 CFR 73.55(o). The NRC staff also requested a description of how the intrusion detection system (IDS) and assessment system at the PA barrier will continue to provide its intended functions for the duration of the temporary plant configuration in accordance with 10 CFR 73.55(e)(7)(i)(B).

The response stated, in part, that the transfer hoses will be entrenched underneath the PA boundary. These hoses, once established, do not result in UAO pathways, therefore compensatory measures are no longer required. The installation of the fuel transfer hoses will not impact the IDS and assessment capabilities, which will be validated through approved testing procedures, as described in RG 5.44. The compensatory measures will be implemented as mentioned in the response to RAI-2 item 1.

The NRC staffs RAI included RAI-2, item 5, requested a description of the security compensatory measures for the diesel generating building that will be implemented per site procedures to protect against unauthorized access and control.

As mentioned in response to RAI-2, item 1, compensatory measures for the Diesel Generator

Building will be implemented whenever the diesel generator building door is opened to transfer fuel oil into the required EDG day tank. The response stated that, during this second phase, compensatory measures will be implemented in accordance with section 21.2 of the site Security Plan.

The Monticello Security Plan and site implementing procedures (nonpublic SGI) provide site security personnel with detailed instruction for the implementation of the site protective strategy to protect against the DBT, to include, but not limited to, compensatory measures.

Accordingly, the staff finds these responses to RAI-2, item 1, RAI-2 item 2, and RAI-2 item 5, to be acceptable since compensatory measures and IDS assessment capabilities will be available and implemented during the various phases of the temporary configuration change to continue to defend against the DBT. The excavation and installation of hoses under the PA barrier as described above will not create a UAO, and the compensatory measures described in section 21.1 of the Security Plan will be implemented to provide a level of protection to meet the requirements of 10 CFR 73.55(e)(7)(i)(B). Additionally, the compensatory measures to be taken when the diesel generator building door is open will be implemented in accordance with section 21.2 of the site Security Plan and will provide a level of protection to meet 10 CFR 73.55(o) because Section 21.2 of the licensee Security Plan describes the methods by which the licensee will meet these requirements. Further, although the installation of the fuel transfer hoses will not impact the IDS and assessment capabilities, the licensee will validate IDS assessment capabilities through approved testing procedures as described in RG 5.44 and in accordance with 10 CFR 73.55(n)(8), and site procedures.

3.4.3 Inspection and Testing The NRC staffs RAI included RAI-2, item 3, which requested a description of how changes to the IDS will be inspected and tested during implementation of any changes. The NRC staff requested that the licensee confirm whether the testing of IDS will conform to RG 5.44, Section 3, Recommended Testing Procedures, Testing Option I or II.

The response stated that there will be no changes to the IDS during this evolution and no alternative testing is needed or required. The response provided figures 1 and 2 (nonpublic SRI) to illustrate how the hoses will be installed.

Accordingly, the NRC staff finds this response to be acceptable since the licensee will not make any changes to IDS within the affected PA boundary that would need testing. Therefore, recommended testing options within RG 5.44 would not apply.

3.4.4 Location of FRAC and Fuel Oil Transfer Systems The NRC staffs RAI included RAI-2, item 4, which requested a detailed description of where the FRAC and fuel oil transfer systems will be located and whether these locations will interfere with the site protective strategy.

The licensees response stated that the FRAC tanks will be located to the west of the plant in a position between the sites credited early warning system and the PA boundary and IDS. The response stated that this location does not result in degradation of protective strategy effectiveness, for example, fields-of-fire. The response also provided figures 1 and 2 of the site with the location of the subject equipment.

Accordingly, the NRC staff finds this response to be acceptable because the licensee confirmed that the proposed location of the FRAC and fuel oil transfer systems does not interfere with the DID of the site protective strategy. As such, the staff finds the license amendment will not affect the licensees compliance with the requirements of appendix C to part 73, section II.B.3.c (v).

3.4.5 Target Sets, Vital Areas and Equipment, and Protective Strategy Implementation The NRC staffs RAI included RAI-1 which requested clarification on what effect, if any, the removal of the FOST and the installation of temporary equipment will have on (1) target sets, (2) vital areas and equipment, and (3) implementation of the sites protective strategy.

The response stated, in part, that the removal of the FOST and installation of temporary equipment does not: (1) create any new target sets or change any target sets described within the sites Target Set Analysis; (2) create any new vital areas or change any vital areas that are described within the Security Plan; and (3) affect implementation of the sites protective strategy. Compensatory measures will be implemented in accordance with the Security Plan during the applicable phases of the temporary configuration change.

Accordingly, the NRC staff finds the response, to be acceptable since the licensee provides adequate information describing how the temporary plant change evolution does not create or change any target sets, vital areas and equipment, and does not impact the implementation of the sites protective strategy. Therefore, the temporary plant change does not affect the licensees compliance with 10 CFR 73.55(f)(1) with regard to target sets, and 10 CFR 73.55(e)(9) with regard to vital areas.

3.4.6 Physical Security Evaluation Conclusion In consideration of the above, the NRC staff concludes that the proposed temporary changes to Monticello will not impact the site security plans or protective strategy and will not impact their implementation. Therefore, as discussed above in this SE, the proposed changes will allow the licensee to continue to meet the applicable requirements in 10 CFR 73.55 and 10 CFR 73.58.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Minnesota State official was notified of the proposed issuance of the amendment on November 21, 2022. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR part 20 or changes SRs.

The NRC 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 on February 22, 2022 (87 FR 9647) and there has been no public comment on such finding. 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 Commissions 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: Gordon Curran, NRR Molly Keefe-Forsyth, NRR Judy Petrucelli, NSIR Date of Issuance: December 27, 2022

ML22318A215 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/SCPB/BC NRR/DSS/STSB/BC NAME RKuntz SRohrer BWittick VCusumano DATE 11/10/22 11/15/22 9/19/2022 11/30/22 OFFICE NRR/DEX/EEEB/BC NRR/DIRS/IRAB/BC NSIR/DPCP/RSB OGC NLO NAME WMorton PMckenna ABowers MWright DATE 11/7/2022 8/23/2022 9/12/2022 12/21/2022 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME NSalgado SWall for RKuntz DATE 12/27/2022 12/27/2022

v t e Letter Sequence Approval
EPID:L-2021-LLA-0231, License Amendment Request: Revise MNGP Technical Specifications to Support a Ten-Year Inspection of the Diesel Generator Fuel Oil Storage Tank (Approved, Closed)
Initiation Request Acceptance Administration Questions 24 June 2022 Answers 8 August 2022 Results Approval Other:
MONTHYEAR2022-12-27 [Table View]

ML22318A215