ML13281A826

Monticello Nuclear Generating Plant - 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 D 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 PlantXcelEnergy@

2807 W County Road 75Monticello, MN 55362October 4, 2013 L-MT-1 3-08910 CFR 50.90U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555Monticello Nuclear Generating PlantDocket 50-263Renewed Facility Operating License No. DPR-22License Amendment Request:

Change to the MNGP Emergency Plan to Remove theRadwaste 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 NuclearGenerating Plant (MNGP) Emergency Plan. Completion of an on-site staffing analysisof the Emergency Response Organization determined that the Radwaste Operator isnot necessary to augment plant staff to perform repair and corrective actions within60-minutes as prescribed within the Emergency Plan. Consequently, NSPM proposesto remove the Radwaste Operator position from being one of the responders creditedwithin the Emergency Plan.Enclosure 1 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 Planpages indicating the proposed changes.The MNGP Plant Operations Review Committee has reviewed this application.

Inaccordance with 10 CFR 50.91, a copy of this application, with enclosures, is beingprovided 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 theCommission.

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

Document Control DeskL-MT-13-089 Page 2 of 2This license amendment request has been evaluated and has no impact on the pendingExtended 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 existingcommitments.

I declare under penalty of perjury that the foregoing is true and correct.Executed on October _1, 2013.Karen D. FiliSite Vice President Monticello Nuclear Generating PlantNorthern States Power Company -Minnesota Enclosures (2)cc: Administrator, Region III, USNRCProject Manager, Monticello, USNRCResident Inspector, Monticello, USNRCMinnesota Department of Commerce ENCLOSURE 1MONTICELLO NUCLEAR GENERATING PLANTLICENSE AMENDMENT REQUESTCHANGE TO THE MNGP EMERGENCY PLAN TO REMOVETHE RADWASTE OPERATOR AS A 60 MINUTE RESPONDER DESCRIPTION OF CHANGES(7 pages follow)

TABLE OF CONTENTSSECTION TITLE PAGE1.0 DESCRIPTION 12.0 BACKGROUND 13.0 DETAILED DESCRIPTION 24.0 TECHNICAL EVALUATION 25.0 REGULATORY SAFETY ANALYSIS 45.1 Applicable Requlatory Requirements

/ Criteria 45.2 Precedent 55.3 No Siqnificant Hazards Consideration Determination 56.0 ENVIRONMENTAL EVALUATION

77.0 REFERENCES

7 L-MT-1 3-089Enclosure 1Page 1 of 7CHANGE TO THE MNGP EMERGENCY PLAN TO REMOVETHE 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 NuclearGenerating Plant (MNGP) Emergency Plan. Completion of an on-site staffing analysisof the Emergency Response Organization (ERO) determined that the RadwasteOperator 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 theresponders credited within the Emergency Plan.In accordance with10 CFR 50.54(q)(4),

changes to a licensee's emergency plan thatreduce the effectiveness of the plan as defined in 10 CFR 50.54(q)(1)(iv) may not beimplemented without prior U. S. Nuclear Regulatory Commission (NRC) approval andare 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 addressconcerns 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 PowerPlants,"

Revision 0, dated November 2011 (Reference 1). ISG Section IV.C providesspecific detail on the criteria and acceptable methods for the conduct of the on-shiftstaffing

analysis, including endorsement of Nuclear Energy Institute (NEI) 10-05,Revision 0, "Assessment of On-Shift Emergency Response Organization Staffing andCapabilities" (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 untilrelieved 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 toperform the specified staff augmentation function (perform repair and corrective actionswithin 60-minutes),

considering the staffing in place. Consequently, NSPM proposes toremove the Radwaste Operator position as one of the 60-minute responders identified within the Emergency Plan.

L-MT-1 3-089Enclosure 1Page 2 of 73.0 DETAILED DESCRIPTION Emergency Plan Table 1, "Minimum Shift Staffing and Capability for Additions forNuclear Power Plant Emergencies,"

is proposed to be revised to remove the RadwasteOperator position from being credited for Repair & Corrective Actions under the MajorTask Category as indicated below:Capability forAdditions Major Functional Area Major Tasks Position Title or On 30 60Expertise Shift Min MinPlant System Engineering, Repair andCorrective ActionsRepair & Corrective Mech Maint 1* -- 1Actions Radwate -OpW --4Elec Maint 1* 1 1I&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 RadwasteOperator 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 theSAMGs. Non-duty Operations personnel in the TSC and OSC will augment theduty 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 andTable 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 planningstandards in Section 50.47(b) and the requirements in Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"

to 10 CFR 50. Inaccordance with 10 CFR 50.47(b)(2),

a licensee must provide"

... adequate staffing to L-MT-1 3-089Enclosure 1Page 3 of 7provide initial facility accident response in key functional areas [that] is maintained at alltimes," 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 theERO. The functional area of "Repair and Corrective Actions,"

is fulfilled on-shift by atotal of two personnel that also "may be provided by shift personnel assigned otherfunctions."

It further identifies that the "position title or expertise" for the "repair andcorrective 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 theRadwaste Operator could be utilized as one of the available personnel to perform therepair 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., eventmitigation, radiation protection

response, firefighting, chemistry and Emergency Planfunctions, until relieved by the augmented ERO. Staffing analyses performed pursuantto 10 CFR 50, Appendix E, Section IV.A.9, should consider the postulated design basisaccidents (DBAs) (i.e., condition IV events) analyzed in the licensee's USAR.Furthermore, the NRC staff guidance recommends additional scenarios, such as, theplant security Design Basis Threat (DBT), aircraft threat, and Control Room Firescenarios, 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 guidanceprovided 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 RadwasteOperator, while currently reflected in the Emergency Plan, was determined through therecent OSA to be unnecessary to perform the functions discussed above, for any of thespecific DBAs described in the USAR or for the specific event/threat scenarios definedin NSIR / DPR-ISG-01.

To summarize, there was no accident/event/scenario where aRadwaste Operator should be used for performance of any repair or corrective actionfunctions within the first 60 minutes of an event. Therefore, the results of the OSAindicate that the Radwaste Operator function is not necessary to meet the current staffERO augmentation requirements for 60-minute responders in accordance with the morerecent staff requirements specified in NSIR / DPR-ISG-01 and the guidance ofNEI 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 Enclosure 1Page 4 of 7Since the OSA demonstrated that the on-shift staffing was adequate to perform criticalfunctions until relieved by the augmented ERO, it is appropriate to remove theRadwaste Operator position from the shift ERO augmentation function currently specified in the Emergency plan. Therefore, Emergency Plan Table 1, "Minimum ShiftStaffing and Capability for Additions for Nuclear Power Plant Emergencies,"

and Section5.3.1.1, "Plant Operations and Operational Assessment",

are proposed to be revised toreflect the removal of this position.

This proposed change is acceptable because theMNGP Emergency Plan will continue to meet the requirements of 10 CFR 50 AppendixE and the planning standards of 10 CFR 50.47(b).

5.0 REGULATORY SAFETY ANALYSIS5.1 Applicable Requlatory Requirements

/ Criteriaa. 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 theplanning 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 forthemergency 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 mustmeet the following standards:

(1) Primary responsibilities for emergency response by the nuclearfacility licensee and by State and local organizations within theEmergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have beenspecifically established, and each principal response organization has staff to respond and to augment its initial response on acontinuous basis.(2) On-shift facility licensee responsibilities for emergency responseare unambiguously

defined, adequate staffing to provide initialfacility accident response in key functional areas is maintained atall times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities andoffsite support and response activities are specified.

L-MT-13-089 Enclosure 1Page 5 of 7NSPM has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria.

The proposed Emergency Plan changescontinue to assure that regulatory requirements and emergency planningstandards 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 PowerCompany -Minnesota (NSPM), doing business as Xcel Energy, Inc., requestsan amendment to facility Renewed Operating License DPR-22, for the Monticello Nuclear Generating Plant (MNGP) to revise the Emergency Plan. Completion ofan on-site staffing analysis of the Emergency Response Organization determined the Radwaste Operator is no longer necessary as a 60-minute responder andNSPM proposes to remove the function from the Emergency Plan.NSPM has evaluated the proposed amendment in accordance with10 CFR 50.91 against the standards in 10 CFR 50.92 and has determined thatthe operation of the MNGP in accordance with the proposed amendment presents no significant hazards.

NSPM's evaluation against each of the criteriain 10 CFR 50.92 follows.1. Does the proposed change involve a significant increase in theprobability or consequences of an accident previously evaluated?

Response:

No.The proposed change to the Emergency Plan does not impact the functionof plant structures,

systems, or components (SSCs). The proposedchange does not affect accident initiators or precursors, nor does it alterdesign assumptions.

The proposed change does not alter or prevent theability of the Emergency Response Organization to perform their intendedfunctions to mitigate the consequences of an accident or event. Thisproposed change only removes a no longer credited position from theEmergency Plan.Therefore, the proposed change does not involve a significant increase inthe probability or consequences of an accident previously evaluated.

L-MT-13-089 Enclosure 1Page 6 of 72. 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 changedoes 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 plantoperation, or new operator actions.

The proposed change does notintroduce failure modes that could result in a new accident, and thechange does not alter assumptions made in the safety analysis.

Thisproposed change only removes a no longer credited position from theEmergency Plan. The proposed change therefore does not alter orprevent the ability of the Emergency Response Organization to performtheir intended functions to mitigate the consequences of an accident orevent.Therefore, the proposed change does not create the possibility of a new ordifferent kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in amargin of safety?Response:

No.Margin of safety is associated with confidence in the ability of the fissionproduct barriers (i.e., fuel cladding, reactor coolant system pressureboundary, and containment structure) to limit the level of radiation dose tothe public. The proposed change is associated with the Emergency Planstaffing and does not impact operation of the plant or its response totransients or accidents.

The change does not affect the Technical Specifications.

The proposed change does not involve a change in themethod of plant operation, and no accident analyses will be affected bythe proposed change. Safety analysis acceptance criteria are not affectedby this proposed change. The revised Emergency Plan will continue toprovide the necessary response staff with the proposed change.Therefore, the proposed change does not involve a significant reduction ina margin of safety.Based on the above, the NSPM has determined that operation of the facility inaccordance with the proposed change does not involve a significant hazardsconsideration as defined in 10 CFR 50.92(c),

in that it does not: (1) involve asignificant increase in the probability or consequences of an accident previously L-MT-1 3-089Enclosure 1Page 7 of 7evaluated; or (2) create the possibility of a new or different kind of accident fromany accident previously evaluated; or (3) involve a significant reduction in amargin 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 hazardsconsideration, or (ii) authorize a significant change in the types or a significant increasein 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, theproposed amendment meets the eligibility criterion for a categorical exclusion set forthin 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 preparedin connection with the proposed amendment.

7.0 REFERENCES

1. NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for NuclearPower Plants,"

Revision 0, November 2011.2. NEI 10-05, Revision 0, "Assessment of On-Shift Emergency ResponseOrganization Staffing and Capabilities,"

dated June 2011.3. NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation ofRadiological Emergency Response Plans and Preparedness in Support ofNuclear Power Plants,"

Revision 1, U.S. Nuclear Regulatory Commission andFederal Emergency Management Agency, Washington, DC, November 1980.

ENCLOSURE 2MONTICELLO NUCLEAR GENERATING PLANTLICENSE AMENDMENT REQUESTCHANGE TO THE MNGP EMERGENCY PLAN TO REMOVETHE RADWASTE OPERATOR AS A 60 MINUTE RESPONDER MARKED-UP EMERGENCY PLAN PAGES(3 pages follow)

MONTICELLO NUCLEAR GENERATING PLANT E-PLANTITLE: EMERGENCY PLAN Revision 40I Page 21 of 116The EOF Security Group is staffed by personnel from the SiteSecurity Group. The EOF Security Coordinator reports to theEOF Coordinator.

Responsibilities of EOF Security includeEOF access, dosimetry issuance to EOF personnel andFitness-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 EROaugmentation are described in this section.5.3.1 ERO Augmentation Description and Goals5.3.1.1 Plant Operations and Operational Assessment The duty Operations crew retains the responsibility for plantoperation throughout an emergency situation.

When in SAMGsthe duty operations staff implements the actions as directed bythe SAMGs. Non-duty Operations personnel in the TSC andOSC will augment the duty Operations staff.augment ftion is the addition of one Opcrator, qaiidir-adlio-active waste system eperatienc, within apRomately 60The responsibilities of the non-duty Operations personnel include operational assessment, under the direction of theEmergency Director in the TSC, and support of emergency repair and corrective action efforts in the OSC including FireBrigade support.When a transition point (Primary Containment flooding isrequired) in the EOPs is reached, the duty Shift Manager andOperations 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 wouldinform the TSC that they have relieved the duty Shift Manageras the Decision Maker. The Decision Maker is designated toassess and select the strategies to be implemented.

Whenusing the SAMGs, the Operations Group Leader will act as theDecision Maker and direct control room response as specified in the SAMGs. The Assistant Operations Group Leader is amember of the Accident Management Team (AMT).M/arb MONTICELLO NUCLEAR GENERATING PLANT E-PLANTITLE: EMERGENCY PLAN Revision 40I Page 29 of 1165.5.11 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 theorganizations mentioned above are available in the Minnesota Emerqency Operations Plan.Table 1MINIMUM SHIFT STAFFING AND CAPABILITY FOR ADDITIONS FOR NUCLEAR POWERPLANT EMERGENCIES Capability forAdditions Postion Title or On 30 60Major Functional Area Major Tasks Expertise Shift min minPlant 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 untilrelieved)

Notification/

Notify licensee, Shift Emerg 1 ... ...Communication Local, State, and Communicator Federal personnel

&agenciesMaintain Emergency

--- 1 2Communications Communicators Radiological Accident Emergency Emergency

---.. .1Assessment and Operations Facility ManagerSupport of Operational Coordinate EOF prior EOF Coord --- 1 ---Accident Assessment to arrival ofEmergency ManagerOff-Site Dose Radiological

--- 1Assessment Emergency CoordM/arb MONTICELLO NUCLEAR GENERATING PLANT E-PLANTITLE: EMERGENCY PLAN Revision 40I Page 30 of 116Table 1MINIMUM SHIFT STAFFING AND CAPABILITY FOR ADDITIONS FOR NUCLEAR POWERPLANT EMERGENCIES (CONT'D)Capability forAdditions Postion Title or On 30 60Major Functional Area Major Tasks Expertise Shift min minOff-Site Surveys Radiation Protection 1 1On-Site (out-of-plant) 1 1In-Plant Surveys 2 --- 1Chemistry/Radio-Chemistry 1 1Chemistry Plant System Technical Support Technical Advisors 1*Engineering, Repair and Core/Thermal Hyd. --- 1" ---Corrective actions Electrical

--- --- 1Mechanical

--- --- 1Repair & Corrective Mech Maint 1* --- 1Actions Radwaste OpQe ---Elec Maint 1V 1 1I&C --- 1Protective Actions Radiation Protection Radiation Protection 2* 1 1(In-Plant)

a. Access Controlb. HP Coverage forresponse actionsc. Personnel monitoring

d. Dosimetry Fire Fighting Fire Brigade per Local4 AWI-08.01.01 SupportRescue Operations and 2* LocalFirst Aid SupportSite Access Control and Security, Security Force All perPersonnel Accountability Communications, Security PlanPersonnel Accountability 13 9* May be provided by shift personnel assigned other functions.

M/arb