ML13281A826

License Amendment Request: Change to the MNGP Emergency Plan to Remove the Radwaste Operator as a 60 Minute Responder

ML13281A826
Person / Time
Site:	Monticello
Issue date:	10/04/2013
From:	Fili K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-1 3-089
Download: ML13281A826 (15)

Text

Monticello Nuclear Generating Plant XcelEnergy@

2807 W County Road 75 Monticello, MN 55362 October 4, 2013 L-MT-1 3-089 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Monticello Nuclear Generating Plant Docket 50-263 Renewed Facility Operating License No. DPR-22 License Amendment Request: Change to the MNGP Emergency Plan to Remove the Radwaste Operator as a 60 Minute Responder Pursuant to 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM),

doing business as Xcel Energy, Inc., proposes to revise the Monticello Nuclear Generating Plant (MNGP) Emergency Plan. Completion of an on-site staffing analysis of the Emergency Response Organization determined that the Radwaste Operator is not necessary to augment plant staff to perform repair and corrective actions within 60-minutes as prescribed within the Emergency Plan. Consequently, NSPM proposes to remove the Radwaste Operator position from being one of the responders credited within the Emergency Plan. provides a description of the proposed changes and includes the technical evaluation and associated no significant hazards determination and environmental evaluation. Enclosure 2 provides a marked-up copy of the existing Emergency Plan pages indicating the proposed changes.

The MNGP Plant Operations Review Committee has reviewed this application. In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Minnesota Official.

In accordance with 10 CFR 50.91(a)(1), the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission.

NSPM requests approval of this proposed license amendment request by October 30, 2014, with the amendment being implemented within 90 days of U. S. Nuclear Regulatory Commission (NRC) approval.

Document Control Desk L-MT-13-089 Page 2 of 2 This license amendment request has been evaluated and has no impact on the pending Extended Power Uprate and Maximum Extended Load Line Limit Analysis Plus (MELLLA+) license amendment requests currently under NRC review.

Should you have questions regarding this letter, please contact Mr. Richard Loeffler at (763) 295-1247.

Summary of Commitments This letter proposes no new commitments and does not revise any existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October _1, 2013.

Karen D. Fili Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (2) cc:

Administrator, Region III, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Minnesota Department of Commerce

ENCLOSURE 1 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST CHANGE TO THE MNGP EMERGENCY PLAN TO REMOVE THE RADWASTE OPERATOR AS A 60 MINUTE RESPONDER DESCRIPTION OF CHANGES (7 pages follow)

TABLE OF CONTENTS SECTION TITLE PAGE

1.0 DESCRIPTION

1

2.0 BACKGROUND

1 3.0 DETAILED DESCRIPTION 2

4.0 TECHNICAL EVALUATION

2 5.0 REGULATORY SAFETY ANALYSIS 4

5.1 Applicable Requlatory Requirements / Criteria 4

5.2 Precedent 5

5.3 No Siqnificant Hazards Consideration Determination 5

6.0 ENVIRONMENTAL EVALUATION 7

7.0 REFERENCES

7

L-MT-1 3-089 Page 1 of 7 CHANGE TO THE MNGP EMERGENCY PLAN TO REMOVE THE RADWASTE OPERATOR AS A 60 MINUTE RESPONDER

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM),

doing business as Xcel Energy, Inc., proposes to revise the Monticello Nuclear Generating Plant (MNGP) Emergency Plan. Completion of an on-site staffing analysis of the Emergency Response Organization (ERO) determined that the Radwaste Operator is not necessary to augment plant staff to perform repair and corrective actions within 60-minutes as prescribed within the Emergency Plan. Consequently, NSPM proposes to remove the Radwaste Operator position from being one of the responders credited within the Emergency Plan.

In accordance with10 CFR 50.54(q)(4), changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in 10 CFR 50.54(q)(1)(iv) may not be implemented without prior U. S. Nuclear Regulatory Commission (NRC) approval and are submitted as license amendment requests (LAR) in accordance with 10 CFR 50.90.

2.0 BACKGROUND

As part of the Emergency Preparedness rulemaking published in November 2011, 10 CFR 50, Appendix E, Section IV.A, "Organization," was amended to address concerns regarding assignment of tasks or responsibilities to on-shift ERO personnel that might potentially overburden them and prevent timely performance of emergency plan functions.

In conjunction with the new rule, the NRC issued, Interim Staff Guidance (ISG)

NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," Revision 0, dated November 2011 (Reference 1). ISG Section IV.C provides specific detail on the criteria and acceptable methods for the conduct of the on-shift staffing analysis, including endorsement of Nuclear Energy Institute (NEI) 10-05, Revision 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" (Reference 2).

An On-Shift Staffing Analysis (OSA) was conducted in 2012, as required by 10 CFR 50, Appendix E, to ensure on-shift staffing was adequate to perform critical functions until relieved by the augmented ERO in accordance with the ISG and the NEI guidance.

Results of the OSA indicated that the Radwaste Operator position was not necessary to perform the specified staff augmentation function (perform repair and corrective actions within 60-minutes), considering the staffing in place. Consequently, NSPM proposes to remove the Radwaste Operator position as one of the 60-minute responders identified within the Emergency Plan.

L-MT-1 3-089 Page 2 of 7 3.0 DETAILED DESCRIPTION Emergency Plan Table 1, "Minimum Shift Staffing and Capability for Additions for Nuclear Power Plant Emergencies," is proposed to be revised to remove the Radwaste Operator position from being credited for Repair & Corrective Actions under the Major Task Category as indicated below:

Capability for Additions Major Functional Area Major Tasks Position Title or On 30 60 Expertise Shift Min Min Plant System Engineering, Repair and Corrective Actions Repair & Corrective Mech Maint 1*

1 Actions Radwate -OpW 4

Elec Maint 1*

1 1

I&C 1

Also, Emergency Plan Section 5.3.1.1, "Plant Operations and Operational Assessment,"

first paragraph is proposed to be revised to remove the position of the Radwaste Operator as indicated below:

The duty Operations crew retains the responsibility for plant operation throughout an emergency situation. When in SAMGs [Severe Accident Management Guidelines] the duty operations staff implements the actions as directed by the SAMGs. Non-duty Operations personnel in the TSC and OSC will augment the duty Operations staff. Included in this augmentation is thee addition of one Operato-r, qualified in radioactive waste system; operations, in approximately 60 m~inutes.

A mark-up of the proposed changes to the Emergency Plan for Sections 5.3.1.1 and Table 1 is provided in Enclosure 2.

4.0 TECHNICAL EVALUATION

10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect emergency plans which meet the planning standards in Section 50.47(b) and the requirements in Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR 50. In accordance with 10 CFR 50.47(b)(2), a licensee must provide"... adequate staffing to

L-MT-1 3-089 Page 3 of 7 provide initial facility accident response in key functional areas [that] is maintained at all times," and ensure that "timely augmentation of response capabilities is available... "

NUREG-0654 / FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Table B-1 (Reference 3) specifies the minimum staffing requirements for the ERO. The functional area of "Repair and Corrective Actions," is fulfilled on-shift by a total of two personnel that also "may be provided by shift personnel assigned other functions." It further identifies that the "position title or expertise" for the "repair and corrective actions" task could be augmented by Mechanical Maintenance/Radwaste Operator, Electrical Maintenance or the Instrumentation and Control (I&C) Technician within 30 minutes or 60 minutes. The guidance provided within NUREG-0654 /

FEMA-REP-1, was incorporated into the MNGP Emergency Plan and indicated that the Radwaste Operator could be utilized as one of the available personnel to perform the

repair and corrective action" functions.

10 CFR 50 Appendix E directed that a detailed study be performed by December 24, 2012, to ensure on-shift staffing was adequate to perform critical functions, e.g., event mitigation, radiation protection response, firefighting, chemistry and Emergency Plan functions, until relieved by the augmented ERO. Staffing analyses performed pursuant to 10 CFR 50, Appendix E, Section IV.A.9, should consider the postulated design basis accidents (DBAs) (i.e., condition IV events) analyzed in the licensee's USAR.

Furthermore, the NRC staff guidance recommends additional scenarios, such as, the plant security Design Basis Threat (DBT), aircraft threat, and Control Room Fire scenarios, also be considered. The NRC, in the ISG NSIR / DPR-ISG-01 guidance, endorsed NEI 10-05 as an acceptable means of performing the required OSA.

The determination of the required ERO personnel, based upon the prior guidance provided in NUREG-0654 / FEMA-REP-1, was incorporated into the MNGP Emergency Plan and indicated that the Radwaste Operator could be utilized as one of the available personnel to perform the "repair and corrective action" functions. The Radwaste Operator, while currently reflected in the Emergency Plan, was determined through the recent OSA to be unnecessary to perform the functions discussed above, for any of the specific DBAs described in the USAR or for the specific event/threat scenarios defined in NSIR / DPR-ISG-01. To summarize, there was no accident/event/scenario where a Radwaste Operator should be used for performance of any repair or corrective action functions within the first 60 minutes of an event. Therefore, the results of the OSA indicate that the Radwaste Operator function is not necessary to meet the current staff ERO augmentation requirements for 60-minute responders in accordance with the more recent staff requirements specified in NSIR / DPR-ISG-01 and the guidance of NEI 10-05. Repair and corrective actions, where determined necessary, are performed by other personnel credited in the OSA as prescribed by the current requirements/

guidance (i.e., ISG NSIR / DPR-ISG-01 and NEI 10-05).

L-MT-13-089 Page 4 of 7 Since the OSA demonstrated that the on-shift staffing was adequate to perform critical functions until relieved by the augmented ERO, it is appropriate to remove the Radwaste Operator position from the shift ERO augmentation function currently specified in the Emergency plan. Therefore, Emergency Plan Table 1, "Minimum Shift Staffing and Capability for Additions for Nuclear Power Plant Emergencies," and Section 5.3.1.1, "Plant Operations and Operational Assessment", are proposed to be revised to reflect the removal of this position. This proposed change is acceptable because the MNGP Emergency Plan will continue to meet the requirements of 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b).

5.0 REGULATORY SAFETY ANALYSIS 5.1 Applicable Requlatory Requirements / Criteria

a. Title 10 Code of Federal Regulations 50.54(q):

10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect emergency plans which meet the planning standards in Section 50.47(b) and the requirements in Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"

to 10 CFR Part 50. Section 50.47 of 10 CFR, "Emergency plans," sets forth emergency plan requirements for nuclear power plant facilities.

b. Title 10 Code of Federal Regulations 50.47(b):

(b) The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:

(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

L-MT-13-089 Page 5 of 7 NSPM has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria. The proposed Emergency Plan changes continue to assure that regulatory requirements and emergency planning standards associated with emergency response are met.

5.2 Precedent NSPM is not aware of any direct precedent.

5.3 No Significant Hazards Consideration Determination In accordance with the requirements of 10 CFR 50.90, Northern States Power Company - Minnesota (NSPM), doing business as Xcel Energy, Inc., requests an amendment to facility Renewed Operating License DPR-22, for the Monticello Nuclear Generating Plant (MNGP) to revise the Emergency Plan. Completion of an on-site staffing analysis of the Emergency Response Organization determined the Radwaste Operator is no longer necessary as a 60-minute responder and NSPM proposes to remove the function from the Emergency Plan.

NSPM has evaluated the proposed amendment in accordance with 10 CFR 50.91 against the standards in 10 CFR 50.92 and has determined that the operation of the MNGP in accordance with the proposed amendment presents no significant hazards. NSPM's evaluation against each of the criteria in 10 CFR 50.92 follows.

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the Emergency Plan does not impact the function of plant structures, systems, or components (SSCs). The proposed change does not affect accident initiators or precursors, nor does it alter design assumptions. The proposed change does not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event. This proposed change only removes a no longer credited position from the Emergency Plan.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

L-MT-13-089 Page 6 of 7

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not impact the accident analysis. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. This proposed change only removes a no longer credited position from the Emergency Plan. The proposed change therefore does not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with the Emergency Plan staffing and does not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed change does not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed change. Safety analysis acceptance criteria are not affected by this proposed change. The revised Emergency Plan will continue to provide the necessary response staff with the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, the NSPM has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it does not: (1) involve a significant increase in the probability or consequences of an accident previously

L-MT-1 3-089 Page 7 of 7 evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

6.0 ENVIRONMENTAL EVALUATION The NSPM has determined that the proposed change would not revise a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, or (ii) authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) result in a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, NSPM concludes that pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," Revision 0, November 2011.

2.

NEI 10-05, Revision 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," dated June 2011.

3.

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, Washington, DC, November 1980.

ENCLOSURE 2 MONTICELLO NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST CHANGE TO THE MNGP EMERGENCY PLAN TO REMOVE THE RADWASTE OPERATOR AS A 60 MINUTE RESPONDER MARKED-UP EMERGENCY PLAN PAGES (3 pages follow)

MONTICELLO NUCLEAR GENERATING PLANT E-PLAN TITLE:

EMERGENCY PLAN Revision 40 I Page 21 of 116 The EOF Security Group is staffed by personnel from the Site Security Group. The EOF Security Coordinator reports to the EOF Coordinator. Responsibilities of EOF Security include EOF access, dosimetry issuance to EOF personnel and Fitness-for-duty assessment (if required during off-hours activations).

5.3 Emergency Response Organization Augmentation The Emergency Response Organization augmentation goals are outlined in Table 1.

The augmentation of each functional area and the methods used to accomplish ERO augmentation are described in this section.

5.3.1 ERO Augmentation Description and Goals 5.3.1.1 Plant Operations and Operational Assessment The duty Operations crew retains the responsibility for plant operation throughout an emergency situation. When in SAMGs the duty operations staff implements the actions as directed by the SAMGs. Non-duty Operations personnel in the TSC and OSC will augment the duty Operations staff.

augment ftion is the addition of one Opcrator, qaiidi r-adlio-active waste system eperatienc, within apRomately 60 The responsibilities of the non-duty Operations personnel include operational assessment, under the direction of the Emergency Director in the TSC, and support of emergency repair and corrective action efforts in the OSC including Fire Brigade support.

When a transition point (Primary Containment flooding is required) in the EOPs is reached, the duty Shift Manager and Operations Group Leader will make a joint decision to transition from the EOPs to the Severe Accident Management Guidelines (SAMGs). At this point, the Operations Group Leader would inform the TSC that they have relieved the duty Shift Manager as the Decision Maker. The Decision Maker is designated to assess and select the strategies to be implemented. When using the SAMGs, the Operations Group Leader will act as the Decision Maker and direct control room response as specified in the SAMGs. The Assistant Operations Group Leader is a member of the Accident Management Team (AMT).

M/arb

MONTICELLO NUCLEAR GENERATING PLANT E-PLAN TITLE:

EMERGENCY PLAN Revision 40 I Page 29 of 116 5.5.11 City of St. Paul Water Department The Water Department can shut off water intakes, if necessary.

A complete description of response capabilities, organizational resources, activation plans, designations of emergency operations centers and letters of agreement for the organizations mentioned above are available in the Minnesota Emerqency Operations Plan.

Table 1 MINIMUM SHIFT STAFFING AND CAPABILITY FOR ADDITIONS FOR NUCLEAR POWER PLANT EMERGENCIES Capability for Additions Postion Title or On 30 60 Major Functional Area Major Tasks Expertise Shift min min Plant Operations and Shift Manager 1

Assessment of Control Room Supv 1

Operational Aspects SRO 1

Nuclear Lead 1

PE&RO (RO)

Nuclear PE&RO 2

Nuclear Asst. PEO 3

Emergency Direction Emergency Director 1*

and Control (Shift Manager until relieved)

Notification/

Notify licensee, Shift Emerg 1

Communication Local, State, and Communicator Federal personnel &

agencies Maintain Emergency 1

2 Communications Communicators Radiological Accident Emergency Emergency 1

Assessment and Operations Facility Manager Support of Operational Coordinate EOF prior EOF Coord 1

Accident Assessment to arrival of Emergency Manager Off-Site Dose Radiological 1

Assessment Emergency Coord M/arb

MONTICELLO NUCLEAR GENERATING PLANT E-PLAN TITLE:

EMERGENCY PLAN Revision 40 I Page 30 of 116 Table 1 MINIMUM SHIFT STAFFING AND CAPABILITY FOR ADDITIONS FOR NUCLEAR POWER PLANT EMERGENCIES (CONT'D)

Capability for Additions Postion Title or On 30 60 Major Functional Area Major Tasks Expertise Shift min min Off-Site Surveys Radiation Protection 1

1 On-Site (out-of-plant) 1 1

In-Plant Surveys 2

1 Chemistry/Radio-Chemistry 1

1 Chemistry Plant System Technical Support Technical Advisors 1*

Engineering, Repair and Core/Thermal Hyd.

1" Corrective actions Electrical 1

Mechanical 1

Repair & Corrective Mech Maint 1*

1 Actions Radwaste OpQe Elec Maint 1V 1

1 I&C 1

Protective Actions Radiation Protection Radiation Protection 2*

1 1

(In-Plant)

a.

Access Control

b.

HP Coverage for response actions

c.

Personnel monitoring

d. Dosimetry Fire Fighting Fire Brigade per Local 4 AWI-08.01.01 Support Rescue Operations and 2*

Local First Aid Support Site Access Control and

Security, Security Force All per Personnel Accountability Communications, Security Plan Personnel Accountability 13 9

• May be provided by shift personnel assigned other functions.

M/arb