ML060040437

Monticello, Revision to Emergency Plan Emergency Action Levels

ML060040437
Person / Time
Site:	Monticello
Issue date:	01/05/2006
From:	Tam P S Plant Licensing Branch III-2
To:	Conway J T Nuclear Management Co
References
TAC MC5017
Download: ML060040437 (7)

Text

January 5, 2006Mr. John T. ConwaySite Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT, UNIT NO. 1 - REVISION TOEMERGENCY PLAN EMERGENCY ACTION LEVELS (TAC NO. MC5017)

Dear Mr. Conway:

By letter dated October 22, 2004, as supplemented by letters dated December 22, 2004, June 24, November 22, and December 20, 2005, Nuclear Management Company, Inc. (NMC),

requested changes to the Emergency Action Levels (EALs) for Monticello Nuclear Generating Plant (MNGP). The proposed changes revise the MNGP EALs using the guidance provided in Nuclear Energy Institute document NEI 99-01, Revision 4, "Methodology for Development ofEmergency Action Levels," which was endorsed by the Nuclear Regulatory Commission (NRC)in Regulatory Guide 1.101, Revision 4, "Emergency Planning and Preparedness for Nuclear Power Reactors."The NRC staff has completed its review of the proposed EAL scheme change and supportingdocumentation, and has concluded that the proposed revision meets the standards set forth in10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, and therefore, isacceptable. Details of the review are delineated in the enclosed safety evaluation.Sincerely,/RA/Peter S. Tam, Senior Project ManagerPlant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-263

Enclosure:

Safety Evaluation cc w/encl: See next page January 5, 2006Mr. John T. ConwaySite Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT, UNIT NO. 1 - REVISION TOEMERGENCY PLAN EMERGENCY ACTION LEVELS (TAC NO. MC5017)

Dear Mr. Conway:

By letter dated October 22, 2004, as supplemented by letters dated December 22, 2004, June 24, November 22, and December 20, 2005, Nuclear Management Company, Inc. (NMC),

requested changes to the Emergency Action Levels (EALs) for Monticello Nuclear Generating Plant (MNGP). The proposed changes revise the MNGP EALs using the guidance provided in Nuclear Energy Institute document NEI 99-01, Revision 4, "Methodology for Development ofEmergency Action Levels," which was endorsed by the Nuclear Regulatory Commission (NRC)in Regulatory Guide 1.101, Revision 4, "Emergency Planning and Preparedness for Nuclear Power Reactors."The NRC staff has completed its review of the proposed EAL scheme change and supportingdocumentation, and has concluded that the proposed revision meets the standards set forth in10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, and therefore, isacceptable. Details of the review are delineated in the enclosed safety evaluation.Sincerely,/RA/Peter S. Tam, Senior Project ManagerPlant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-263

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:PUBLICLPLIII-1 R/FTKobetzKWilliamsDBarssPTamTHarrisBBurgess, RIII OGCACRSDORL DPRADAMS Accession Number: ML060040437*Safety evaluation transmitted by memo of this date.

OFFICENRR/LPL3-1/PMNRR/LPL3-1/LANSIR/LRIS/BC*NRR/LPL3-1/BC (A)NAMEPTamTHarrisEWeissTKobetz DATE1/5/061/5/061/5/061/5/06OFFICIAL RECORD COPY SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO PROPOSED UPGRADED EMERGENCY ACTIONS LEVELS (EALs)MONTICELLO NUCLEAR GENERATING PLANT (MNGP)NUCLEAR MANAGEMENT COMPANY, LLCDOCKET NO. 50-26

31.0 INTRODUCTION

By letter dated October 22, 2004, (Agencywide Document Access and Management System(ADAMS) Accession No. ML053420669) and as supplemented by letters dated December 22, 2004 (ADAMS Accession No. ML043650186); June 24, 2005 (ADAMS Accession No.

ML051820559); November 22, 2005 (ADAMS Accession No. 053320282); and December 20, 2005 (ADAMS Accession number ML053560091) Nuclear Management Company, Inc. (the licensee, NMC), requested changes to the EALs for the MNGP. The proposed changes revise the MNGP EALs using the guidance provided in Nuclear Energy Institute (NEI) document, NEI 99-01, Revision 4, "Methodology for Development of Emergency Action Levels," which was endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide (RG) 1.101,Revision 4, "Emergency Planning and Preparedness for Nuclear Power Reactors."

2.0 REGULATORY EVALUATION

The applicable regulations and guidance that the NRC staff used to review the licensee'sproposed EAL revision are discussed in the following sections.2.1 RegulationsPart 50 of Title 10 of the Code of Federal Regulations, Section 50.47 (10 CFR 50.47),"Emergency plans," states that no operating license for a nuclear power reactor will be issuedunless a finding is made by the NRC that the state of onsite and offsite emergencypreparedness provides reasonable assurance that adequate protective measures can and willbe taken in the event of a radiological emergency. This regulation also establishes requirements that must be met by the onsite and offsite emergency response plans for the NRC staff to make a positive finding that there is reasonable assurance that adequateprotective measures can and will be taken in the event of a radiological emergency. Paragraph50.47(b)(4) of 10 CFR stipulates that emergency plans include a standard emergency classification and action level scheme.ENCLOSURE Appendix E,Section IV.B, "Emergency Planning and Preparedness for Production andUtilization Facilities," of 10 CFR 50 provides that emergency plans are to include EALs, whichare to be used as criteria for determining the need for notification and participation of local and State agencies and which are to be used for determining when and what type of protective measures should be considered, both onsite and offsite, to protect public health and safety.

EALs are to be based on in-plant conditions and instrumentation, and onsite and offsite monitoring.Section IV.B of Appendix E provides that initial EALs shall be discussed and agreed on by the applicant and State and local authorities, be approved by the NRC, andreviewed annually thereafter with State and local authorities. In addition,Section IV.B states that an EAL revision must be approved by the NRC before implementation if: (1) the licensee ischanging from one EAL scheme to another EAL scheme (e.g., a change from an EAL scheme based on NUREG-0654 (see below for title) to a scheme based upon NUMARC/NESP-007 (seebelow for title) or NEI-99-01); (2) the licensee is proposing an alternate method for complying with the regulations; or (3) the EAL revision decreases the effectiveness of the emergency plan.2.2 GuidanceAs stated in Section 1.0, for developing EALs required by 10 CFR Part 50, Appendix E, SectionIV.B and 10 CFR Paragraph 50.47(b)(4), NRC RG 1.101, Revision 4, endorses the guidanceprovided in NEI 99-01, Revision 4, as acceptable alternative methods to those described in the following documents:*Appendix 1 to NUREG-0654/Federal Emergency Management Agency-REP-1, "Criteriafor Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (November 1980), and*Nuclear Utilities Management Council document NESP-007, "Methodology forDevelopment of Emergency Action Levels" (Revision 2, January 1992).NRC's Regulatory Issue Summary (RIS) 2003-18, "Use of NEI 99-01, Methodology forDevelopment of Emergency Action Levels," dated October 8, 2003, and as supplemented on July 13, 2004, and December 12, 2005, provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, this RIS provided recommendations to assist licensees, consistent with Part 50, Appendix E,Section IV.B, in determining whether to seek prior NRC approval of deviations from the new guidance.

3.0 TECHNICAL EVALUATION

3.1 ScopeThe

licensee's proposed revision updates the existing MNGP EALs, based on NUREG-0654, to implement the NEI 99-01, Revision 4, EALs.The NRC staff's evaluation of the proposed revisions to initiating conditions (ICs) and EALthreshold values is based on the licensee's letters referenced in Section 1 above. ICs, entitled "Defueled Station Malfunctions," and listed under Category D in NEI 99-01 (Revision 4), are not applicable since Monticello has a current operating license, and therefore, were not consideredduring this technical evaluation.

Proposed deviations or differences from the guidance in NEI 99-01 (Revision 4), other than minor differences, such as station-specific terminology, system and component names, orformatting, were identified in the justification matrix provided in Enclosure 4 to the licensee's letter dated November 22, 2005, which provided a specific evaluation for each.By its letter of December 20, 2005, the licensee provided a complete, revised version of theEAL Bases document, including EAL Matrix, ICs, and associated EAL threshold values. This EAL Bases document reflects the changes made to EAL Matrix, ICs, EAL threshold values, and Bases provided by the licensee's letter dated October 22, 2004, as supplemented by lettersdated December 22, 2004, June 24, and November 22, 2005.3.2 Approval by State and Local AuthoritiesAs stated in Section 2.1,Section IV.B of Appendix E to 10 CFR Part 50 states that initial EALsshall be discussed and agreed on by the applicant and State and local authorities, be approved by the NRC, and reviewed annually thereafter with State and local authorities.In its letter dated October 22, 2004, the licensee stated that the proposed EALs had beendiscussed and agreed to by the applicable State and local government officials. Enclosure 3 to the licensee's letter dated October 22, 2004, contained documentation of these discussionswith the following offsite agencies:*Division of Homeland Security and Emergency Management*Sherburne County Emergency Management

• Wright County Emergency Management3.3 List of CommitmentsThe licensees letter dated June 24, 2005, contains no new commitments, and withdraws thecommitment made in its letter dated October 22, 2004, to provide the NRC a supplementalsubmittal for the MNGP security EALs. In its June 24, 2005, letter, the licensee states:"This letter contains no new commitments; it revises the commitment made inReference 1. NMC will not provide a supplement to reflect updated security EALs forMNGP. Instead, NMC will evaluate revised security EALs at MNGP in accordance withthe distribution guidance using 10 CFR 50.54(q) and will provide an additional submittalonly if the final guidance requires it."3.4 EvaluationBased on the review of the information provided in the licensee's letters referenced above, theNRC staff finds that the proposed changes to ICs, EAL threshold values, and EAL Bases areconsistent with the guidance in NEI 99-01, Revision 4, or provide an acceptable alternative. Hence, the proposed changes to the MNGP EALs and EAL Bases as reflected in the licensee's letter dated December 20, 2005, are acceptable.Changes to the MNGP security EALs based on the guidance provided in Attachment 1 toNRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events," dated July 18, 2005, were not evaluated as part of this review. As indicated in Section 3.3 above, the licensee intends to implement changes to its security EALs under 10 CFR 50.54(q), which is acceptable under the guidance provided in Bulletin 2005-02.

4.0 CONCLUSION

SThe NRC staff has performed a review of the proposed changes to the MNGP EALs and EAL Bases, as submitted by letters referenced above, using the guidance in NEI 99-01, Revision 4. The NRC staff finds that the proposed MNGP EAL revision and EAL Bases,provided in the licensee's letter dated December 20, 2005, is consistent with the guidance inNEI 99-01, Revision 4, or provides an acceptable alternative as discussed in Section 3.0 above.The NRC staff also finds that the proposed MNGP EAL revision meet the requirements of 10 CFR Paragraph 50.47(b) and Appendix E to 10 CFR Part 50, Section IV.B and is, therefore, acceptable.Principal Contributor: Kevin Williams Date: January 5, 2006 Monticello Nuclear Generating Plant cc:

Jonathan Rogoff, EsquireVice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016U.S. Nuclear Regulatory CommissionResident Inspector's Office 2807 W. County Road 75 Monticello, MN 55362Manager, Regulatory AffairsMonticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637Robert Nelson, PresidentMinnesota Environmental Control Citizens Association (MECCA) 1051 South McKnight Road St. Paul, MN 55119CommissionerMinnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-4194Regional Administrator, Region IIIU.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville RoadLisle, IL 60532-4351CommissionerMinnesota Department of Health 717 Delaware Street, S. E.

Minneapolis, MN 55440Douglas M. Gruber, Auditor/TreasurerWright County Government Center 10 NW Second Street Buffalo, MN 55313CommissionerMinnesota Department of Commerce 85 7th Place East, Suite 500 St. Paul, MN 55101-2198Manager - Environmental Protection DivisionMinnesota Attorney General's Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127Michael B. SellmanPresident and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016Nuclear Asset ManagerXcel Energy, Inc.

414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401November 2005