83_FR_21400 83 FR 21310 - Northern States Power Company: Monticello Nuclear Generating Plant

83 FR 21310 - Northern States Power Company: Monticello Nuclear Generating Plant

NUCLEAR REGULATORY COMMISSION

Federal Register Volume 83, Issue 90 (May 9, 2018)

Page Range21310-21316
FR Document2018-09801

The U.S. Nuclear Regulatory Commission (NRC) has issued an exemption for the Monticello Nuclear Generating Plant, Docket No. 50- 263, in response to an April 6, 2017, request from Northern States Power Company. Specifically, the exemption is from the regulation that requires where redundant trains of systems necessary to achieve and maintain hot shutdown conditions located within the same fire area outside of primary containment, one of the redundant trains remains free of fire damage by one of three methods of physical separation.

Federal Register, Volume 83 Issue 90 (Wednesday, May 9, 2018)
[Federal Register Volume 83, Number 90 (Wednesday, May 9, 2018)]
[Notices]
[Pages 21310-21316]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2018-09801]


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NUCLEAR REGULATORY COMMISSION

[Docket No. 50-263; NRC-2018-0090]


Northern States Power Company: Monticello Nuclear Generating 
Plant

AGENCY: Nuclear Regulatory Commission.

ACTION: Exemption; issuance.

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SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) has issued an 
exemption for the Monticello Nuclear Generating Plant, Docket No. 50-
263, in response to an April 6, 2017, request from Northern States 
Power Company. Specifically, the exemption is from the regulation that 
requires where redundant trains of systems necessary to achieve and 
maintain hot shutdown conditions located within the same fire area 
outside of primary containment, one of the redundant trains remains 
free of fire damage by one of three methods of physical separation.

DATES: The exemption was issued on May 1, 2018.

ADDRESSES: Please refer to Docket ID NRC-2018-0090 when contacting the 
NRC about the availability of information regarding this document. You 
may obtain publicly[dash]available information related to this document 
using any of the following methods:
     Federal Rulemaking Web Site: Go to http://www.regulations.gov and search for Docket ID NRC-2018-0090. Address 
questions about NRC dockets to Jennifer Borges; telephone: 301-287-
9127; email: [email protected]. For technical questions, contact 
the individual listed in the FOR FURTHER INFORMATION CONTACT section of 
this document.
     NRC's Agencywide Documents Access and Management System 
(ADAMS): You may obtain publicly-available documents online in the 
ADAMS Public Documents collection at http://www.nrc.gov/reading-rm/adams.html. To begin the search, select ``ADAMS Public Documents'' and 
then select ``Begin Web-based ADAMS Search.'' For problems with ADAMS, 
please contact the NRC's Public Document Room (PDR) reference staff at 
1-800-397-4209, 301-415-4737, or by email to [email protected]. The 
ADAMS accession number for each document referenced (if it is available 
in ADAMS) is provided the first time that it is mentioned in the 
attached exemption. In addition, for the convenience of the reader, the 
ADAMS accession numbers are provided in a table in the ``Availability 
of Documents'' section of the exemption.
     NRC's PDR: You may examine and purchase copies of public 
documents at the NRC's PDR, Room O1-F21, One White Flint North, 11555 
Rockville Pike, Rockville, Maryland 20852.

FOR FURTHER INFORMATION CONTACT: Robert F. Kuntz, Office or Nuclear 
Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 
20555-0001; telephone: 301-415-3733, email: [email protected].

SUPPLEMENTARY INFORMATION: The text of the exemption is attached.

    Dated at Rockville, Maryland, this 3rd day of May 2018.

    For the Nuclear Regulatory Commission.
Robert F. Kuntz,
Senior Project Manager, Plant Licensing Branch III, Division of 
Operating Reactor Licensing, Office of Nuclear Reactor Regulation.

Attachment--Exemption

NUCLEAR REGULATORY COMMISSION

Docket No. 50-263

Northern States Power Company

Monticello Nuclear Generating Plant

Exemption

I. Background

    Northern States Power Company, doing business as Xcel Energy 
(the licensee), is the holder of Renewed Facility Operating License 
Number 50-263, which authorizes operation of the Monticello Nuclear 
Generating Plant (Monticello). The license provides, among other 
things, that the facility is subject to all rules, regulations, and 
orders of the U.S. Nuclear Regulatory Commission (NRC or the 
Commission) now or hereafter in effect.
    The facility consists of a boiling water reactor located in 
Wright County, Minnesota.

II. Request/Action

    In its letter dated April 6, 2017 (Agencywide Documents Access 
and Management System (ADAMS) Accession No. ML17096A599), as 
supplemented by its letter dated November 20, 2017 (ADAMS Accession 
No. ML17324B361), the licensee requested an exemption from Title 10 
of the Code of Federal Regulations (10 CFR), Part 50, Appendix R, 
Section III.G.2, which requires that where redundant trains of 
systems necessary to achieve and maintain hot shutdown conditions 
are located within the same fire area outside of primary 
containment, that one of the redundant trains remains free of fire 
damage by either a 3-hour rated barrier; or 20 feet horizontal 
separation, no intervening combustibles, and detection and 
suppression system; or a 1-hour barrier, and detection and 
suppression systems. The licensee requested NRC approval for 
Monticello to use a method to maintain a hot shutdown train free of 
fire damage that is not one of the acceptable methods listed in 10 
CFR part 50, Appendix R, Section III.G.2. The licensee's exemption 
request is intended to justify why the proposed alternative, the use 
of a shorting switch, is acceptable in accordance with the 
requirements of 10 CFR 50.12, Specific Exemptions.
    The regulatory framework that applies to Monticello is contained 
in 10 CFR 50.48(b)(1) which requires that plants licensed before 
January 1, 1979, to meet Sections III.G, J, and O, of Appendix R to 
10 CFR part 50. Monticello began commercial operations in 1971. 
Section III.G.2 of 10 CFR part 50, Appendix R, requires, that, 
``where cables or equipment, including associated non-safety 
circuits that could prevent operation or cause maloperation due to 
hot shorts, open circuits, or shorts to ground, of redundant trains 
of systems necessary to achieve and maintain hot shutdown conditions 
are located within the same fire area outside of primary 
containment, one of the following means of ensuring that one of the 
redundant trains is free of fire damage shall be provided: a. 
Separation of cables and equipment and associated non-safety 
circuits of redundant trains by a fire barrier having a 3-hour 
rating. Structural steel forming a part of or supporting such fire 
barriers shall be protected to provide fire resistance equivalent to 
that of the barrier; b. Separation of cables and equipment and 
associated non-safety circuits of redundant trains by a horizontal 
distance of more than 20 feet with no intervening combustible or 
fire hazards. In addition, fire detectors and an automatic fire 
suppression system shall be installed in the fire area; or c. 
Enclosure of cable and equipment and associated non-safety circuits 
of one redundant train in a fire barrier having a 1-hour fire 
rating. In addition, fire detectors and an automatic fire 
suppression system shall be installed in the fire area.''
    In its April 29, 2014, triennial fire protection inspection 
report 05000263/2014008, (ADAMS Accession No. ML14119A216), the NRC 
staff identified two pairs of Drywell Spray (DWS) motor-operated 
valve (MOV) control cables that are not

[[Page 21311]]

protected in accordance with an acceptable option provided in 10 CFR 
part 50, Appendix R, Section III.G.2. In 2012, the licensee 
installed a modification, called a shorting switch, to mitigate the 
lack of protection. The shorting switch modification had been 
approved for use at some plants that had adopted a risk-informed 
(RI), performance-based (PB) fire protection program (FPP) under 10 
CFR 50.48(c)(4). Although Monticello had at one time expressed 
intent to adopt a 10 CFR 50.48(c)(4) FPP (ADAMS Accession No. 
ML053460342), Monticello later withdrew its letter of intent (ADAMS 
Accession No. ML102000433).
    The requirements at 10 CFR part 50, Appendix R, Section III.G.2, 
require that hot shorts and open circuits be considered, and the 
licensee's analysis showed that the shorting switch modification 
could fail to meet its design purpose if certain hot shorts and open 
circuits were to occur due to fire damage. Therefore, on April 6, 
2017, the licensee submitted an RI request for an exemption from the 
requirements of 10 CFR part 50, Appendix R, Section III.G.2, to 
address postulated spurious actuations of the DWS MOVs that could 
occur in the event that an open circuit caused the shorting switch 
to fail to perform its function.

III. Discussion

    Pursuant to 10 CFR 50.12, the Commission may, upon application 
by any interested person or upon its own initiative, grant 
exemptions from the regulations when: (1) the exemptions are 
authorized by law, will not present an undue risk to public health 
or safety, and are consistent with the common defense and security; 
and (2) when special circumstances are present. The licensee 
requested an exemption from 10 CFR part 50, Appendix R, Section 
III.G.2, claiming that the special circumstances of 10 CFR 
50.12(a)(2)(ii), which states that, ``Application of the regulation 
in the particular circumstances would not serve the underlying 
purposed of the rule or is not necessary to achieve the underlying 
purpose of the rule,'' apply.
    The underlying purpose of 10 CFR part 50, Appendix R, Section 
III.G.2, is to provide reasonable assurance of fire protection of 
safe shutdown capability by providing a means to ensure that one of 
the redundant trains of systems necessary to achieve and maintain 
hot shutdown conditions is free of fire damage. The licensee's 
position is that the safety benefit, when measured using accepted 
probabilistic risk assessment (PRA) techniques, is ``virtually'' the 
same as if the plant had used one of the three separation options 
described in 10 CFR part 50, Appendix R, Section III.G.2.a, b, or c.
    The NRC staff's evaluation of the licensee's exemption request 
is provided below.

3.1 Deterministic Technical Evaluation

    The fire scenario, as described in the licensee's exemption 
request, is that there will be spurious operation of two normally 
closed DWS MOVs due to a fire. The cables are routed from the 
control room and may be subject to a fire in three other rooms. Two 
of the rooms are in Fire Area IX, the rooms (called fire zones) are 
Fire Zone 13C--Turbine Building East--Engineered Safeguards Feature 
Motor Control Center Area, and Fire Zone 19C--Turbine Building 
East--Pipe and Cable Tray Penetration Area. The third room is in 
Fire Area XII, Fire Zone 19B, Turbine Building East and Engineered 
Safeguards Features Motor Control Center Cable Tunnel. It is within 
these three rooms that the separation required by 10 CFR part 50, 
Appendix R, Section III.G.2, is not provided.
    The scenario postulates that a fire in one of these areas could 
damage the control cables to the two DWS MOVs and cause the normally 
closed valves to spuriously open. If these valves were to open while 
the same division's residual heat removal (RHR) pump were operating, 
the scenario postulates that the RHR pumps would be damaged and safe 
shutdown capability would be impaired.

3.1.1 Explanation of Postulated Scenario and Shorting Switch 
Modification

    The NRC staff evaluated the licensee's analysis of how the 
protection provided by the shorting switch compares to the 10 CFR 
part 50, Appendix R, Section III.G.2 requirement that one train be 
free of fire damage by comparing the installed shorting switch 
configuration to the configuration required by the regulation. This 
section includes a discussion of how the installed shorting switch 
works to prevent a spurious opening of the DWS MOVs.
    To reduce the likelihood of a spurious actuation, the licensee 
installed a shorting switch on one of the valves in series. There 
are two trains of DWS. A shorting switch is installed on MOV MO-2020 
(Division I), and installed on MOV MO-2021 (Division II). The other 
valves in series, MOVs MO-2022 (Division I) and MO-2023 (Division 
II), are not equipped with a shorting switch, and therefore may be 
subject to an energized cable fault that could cause a spurious 
opening of those valves. Figure 1 of the licensee's exemption 
request includes a one-line diagram of the system.
    When the control room switch is in the closed position, the 
shorting switch creates an electrical circuit that provides a low 
impedance path bypassing the valve's ``open'' coil. If an energized 
cable fault or hot short were to occur that would energize the 
``open'' coil, this low impedance path would divert enough current 
away from the ``open'' coil through the shorting switch electrical 
circuit to prevent the ``open'' coil from actuating. When the 
control room switch is set to the open position, this low impedance 
path is removed from the circuit and the valve can be opened 
normally. The shorting switch only functions to prevent spurious 
actuation of the valve in the event of an energized cable fault. A 
simplified shorting switch circuit is shown in Figure 2 of the 
licensee's exemption request.
    The fire scenario of concern would involve three fire-induced 
failures. First, an energized cable fault or hot short would need to 
occur on control circuitry for the DWS MOV that does not have a 
shorting switch installed, for example MO-2022. Second, the fire 
would need to cause a cable to become severed, also called an open 
circuit, on one of the conductors for the shorting switch protected 
valves, such as MO-2020. Third, the fire would have to cause that 
same severed cable to MO-2020 to be exposed to an energized cable 
fault or hot short. Essentially the severed cable would remove the 
shorting switch from the circuit, thereby, defeating the design 
capability of the shorting switch. Similarly, the pair of valves 
MO[dash]2021 and MO-2023 would be vulnerable to the same potential 
failure mode. Note that both valves in a pair, MO-2020 and MO-2022 
or MO-2021 and MO-2023, would need to be impacted to remove the 
shorting switch from the circuit. A hot short from one cable in the 
first pair and one cable in the second pair would not create a 
condition where the RHR pumps could be damaged.

3.2 Risk-Informed Technical Evaluation

    The licensee's exemption request includes a risk assessment of 
the proposed plant change. The use of risk information in a 10 CFR 
part 50, Appendix R, exemption request is in accordance with 
Regulatory Position 1.8 of Regulatory Guide (RG) 1.189, ``Fire 
Protection for Nuclear Power Plants,'' Revision 2, dated October 
2009 (ADAMS Accession No. ML092580550), which says that RI/PB 
methodologies may be used to evaluate the acceptability of FPP 
changes; however, for this approach, the licensee should use 
methodologies and acceptance criteria that the NRC has reviewed and 
approved. RG 1.174, ``An Approach for Using Probabilistic Risk 
Assessment in Risk-Informed Decisions on Plant-Specific Changes to 
the Licensing Basis,'' Revision 2, (ADAMS Accession No. 
ML100910006), includes guidance for RI changes to a plant's current 
licensing bases.
    Accordingly, the NRC staff reviewed the licensee's exemption 
request using the review methodology and criteria contained in RG 
1.174, Revision 2, which includes the following elements:
     Defining the proposed change,
     Performing an engineering analysis, including an 
evaluation that the proposed change is consistent with the defense-
in-depth (DID) philosophy and the principle that sufficient safety 
margins are maintained,
     Assessing the technical adequacy of the PRA analysis, 
the methods used to determine the risk impact of the proposed 
change, and the results of the risk impact assessment,
     Defining the implementation and monitoring program to 
ensure that no unexpected adverse safety degradation occurs due to 
the proposed change, and
     Confirming that an integrated approach was used to 
evaluate the proposed change.

3.2.1 Proposed Change to the Appendix R Program

    Pursuant to 10 CFR 50.12, the licensee requested an exemption 
from 10 CFR part 50, Appendix R, Section III.G.2 requirements with 
respect to the protection of the control circuitry for the DWS MOVs. 
In lieu of meeting the protection requirements of Section III.G.2, 
the licensee has installed a shorting switch modification on the 
control circuitry for one MOV in each division of the DWS system to 
reduce the risk impact of a fire-induced multiple spurious operation 
(MSO) that fails both MOVs. A detailed

[[Page 21312]]

description of the modification is provided in Enclosure 1, Section 
3.1, of the licensee's exemption request.

3.2.2 Engineering Analysis

    Regulatory Position 2.1 of RG 1.174, Revision 2, indicates that, 
for RI changes to the plant licensing basis, the licensee should 
evaluate the proposed change to determine whether it is consistent 
with the DID philosophy and the principle that sufficient safety 
margins are maintained.

Fire Protection DID

    Regulatory Position 2.1.1 of RG 1.174, Revision 2, provides 
guidance on maintaining the philosophy of nuclear safety DID and 
identifies several elements to consider in this evaluation. DID 
involves prevention, protection, and mitigation. With respect to 
nuclear power plant FPPs, the regulations in 10 CFR part 50, 
Appendix R, Section II.A state that the FPP shall extend the concept 
of DID to fire protection in fire areas important to safety with the 
following objectives:
     to prevent fires from starting;
     to detect rapidly, control, and extinguish promptly 
those fires that do occur; and
     to provide protection for structures, systems and 
components important to safety so that a fire that is not promptly 
extinguished by the fire suppression activities will not prevent the 
safe shutdown of the plant.
    An engineering analysis that evaluates the impact of a proposed 
change to an Appendix R FPP on the balance among these FPP DID 
elements is deemed by the NRC staff to satisfy the RG 1.174 
guidance. Enclosure 1, Section 3.2, of the exemption request 
provides the licensee's evaluation of the FPP DID elements. Fire 
protection DID elements consist of administrative controls such as 
plant procedures to limit combustible materials or control hot work 
activities, plant design features, fire protection inspections, 
installed fire detection and suppression systems, and passive fire 
protection features such as fire barriers.
    The licensee's position is that the use of a shorting switch 
meets the underlying purpose of the rule by providing equivalent 
protection to one of the separation methods of 10 CFR part 50, 
Appendix R, Section III.G.2. The licensee chose to install the 
shorting switch in lieu of possibly separating the cables for the 
valves in series (MO-2021 from MO-2023, and MO-2020 from MO-2022) 
into separate areas. The following sections discuss the fire 
protection DID elements of preventing fires, suppressing fires that 
do occur, and protecting safe shutdown.

Fire Protection DID Element 1--Preventing Fires

    The licensee indicated that each of the three rooms has 
administratively controlled restrictions on combustibles. The 
licensee described that of the three zones, only Fire Area IX, Fire 
Zone 13C, has significant fixed ignition sources, which are motor 
control centers. The NRC staff finds that this exemption does not 
degrade the preventing fires DID element, because the proposed 
change does not introduce additional combustibles or ignition 
sources at such a level that necessitates additional controls be put 
in place to prevent fires from starting.

Fire Protection DID Element 2--Detecting and Extinguishing Fires

    The licensee indicated that all three of the rooms addressed in 
this exemption are equipped with full area ionization smoke 
detection systems. Only Fire Area IX, Fire Zone 13C, has significant 
fixed ignition sources and it is equipped with an automatic water 
based suppression system which the licensee indicates is based on 
the significance of the fire hazards contained within that room. The 
smoke detection system annunciates to the control room which results 
in response of the fire brigade.
    Each of the three rooms included in this exemption has fire hose 
stations and fire extinguishers in the rooms or in adjacent rooms. 
Fire Area IX, Fire Zone 13C, and Fire Area XII, Fire Zone 19B, are 
900 square feet, are considered large rooms, and have extinguishers 
and hose stations within the rooms. Fire Area IX, Fire Zone 19C, 
does not have a fire hose station or extinguisher in the room. 
Because Fire Area IX, Fire Zone 19C, has a small floor area of 204 
square feet, the NRC staff concludes that it is reasonable that 
extinguishers and fire hoses could be brought from adjoining areas. 
The NRC staff also concludes that this exemption does not degrade 
the detecting and extinguishing fires DID element, because the 
installation of the switches (1) does not impact the ability of the 
installed detection and suppression systems to detect and extinguish 
a fire, and (2) does not impact the fire brigades ability to 
manually extinguish a fire using the installed extinguishers and 
fire hose stations.

Fire Protection DID Element 3--Safe Shutdown

    The NRC staff determined that the safe shutdown element of fire 
protection DID is impacted by this exemption request. The licensee 
proposes to install an engineered feature called a shorting switch, 
in lieu of the protection required by 10 CFR part 50, Appendix R, 
Section III.G.2. Compliance with the regulation by use of a barrier, 
or separation with fire detection and suppression, protects against 
possible failure modes, but the shorting switch modification results 
in a possible failure mode involving hot shorts and open circuits. 
10 CFR part 50, Appendix R, Section III.G.2, specifically states 
that a plant licensed before January 1, 1979, must address these 
failure modes (i.e., ``maloperation due to hot shorts [and] open 
circuits'').
    Although the licensee has chosen to use a RI analysis to compare 
compliance with the regulation and the proposed alternative using a 
shorting switch, the following deterministic features are in place, 
in addition to the fire prevention, fire detection, and fire 
suppression that are discussed above.
    A fire would have to occur in one of the three subject areas and 
damage the cables to two of the MOVs. One MOV cable would have to be 
subjected to an energized fault or hot short, and the second MOV 
cable would have to be subjected to both a hot short and a severed 
cable also called an open circuit. For the combination of cable 
faults to damage the RHR pumps, the pumps would have to be running 
at the time of the cable faults. Although possible in an actual 
plant event, the licensee did not assume in its evaluation that 
plant operators would turn off the pumps before they became damaged. 
The NRC staff considers this assumption to be conservative because 
the licensee indicated that operators would initiate a controlled 
shutdown to preclude equipment failures.
    Additionally, the NRC staff determined that hot shorts would 
have to be of sufficient duration to open the MOVs enough to result 
in a flow that would cause RHR pump failure due to runout and that 
typically, hot shorts are of a very short duration.
    These aspects of the scenario, the likelihood of cable faults, 
the assumption that the RHR pumps are operating, and the possible 
operator actions and timing related to mitigating the potentially 
damaging configuration were not explicitly credited in the analysis. 
The NRC staff has determined that the DID discussion regarding 
prevention, protection, and mitigation satisfies the RG 1.174 
guidance for a DID analysis because it discussed multiple means to 
accomplish safety functions in accordance with the guidance provided 
in Regulatory Position 2.1.1 of RG 1.174.

Safety Margins

    In Enclosure 1, Section 3.4.3, of the exemption request, the 
licensee provided its assessment of how sufficient safety margins 
are maintained. The licensee explained that the design and 
installation of the shorting switches was completed using applicable 
codes and standards and that the Monticello safety analyses were not 
impacted by the installation of the switches or the exemption 
request. In its letter dated November 20, 2017, in response to the 
NRC's October 18, 2017, request for additional information (RAI) 
(ADAMS Accession No. ML17293A091), the licensee indicated that 
sufficient safety margins are demonstrated by the design, operation, 
and performance monitoring of the shorting switches. The licensee 
indicated that the RHR system currently meets all applicable codes 
and standards (with the exception of the stated 10 CFR part 50, 
Appendix R, Section III.G.2 noncompliance), and also stated that 
granting the exemption will not affect Monticello's ability to 
demonstrate consistency with all applicable codes and standards.
    In its November 20, 2017, letter, the licensee also summarized 
some of the PRA bases for ensuring sufficient safety margins. The 
summarized bases included maintaining a FPP that meets regulatory 
requirements, using a fire PRA (FPRA) that was developed in 
accordance with NUREG/CR-6850, ``Fire PRA Methodology for Nuclear 
Power Facilities,'' having had formal industry peer reviews of 
internal events PRAs (IEPRAs) and FPRAs, and using verified and 
validated fire models.
    The NRC staff concludes that the licensee's safety margins 
assessment is acceptable because it demonstrated that codes and 
standards or their alternatives approved by the NRC are met, and 
that the safety analysis acceptance criteria described in the 
licensing basis are met.

[[Page 21313]]

3.2.3 PRA

    The licensee performed a risk impact assessment for installation 
of the shorting switches rather than physically separating the 
control circuitry for the DWS MOVs in accordance with the 10 CFR 
part 50, Appendix R, separation requirements. For the assessment, 
the risk was evaluated by estimating the change in risk between an 
Appendix R-compliant configuration and the as-installed and as-
operated configuration of the shorting switches. The risk assessment 
was provided in Enclosure 1, Section 3.3, of the licensee's 
exemption request.

Technical Adequacy of the PRA

    The licensee used Revision 4.0 of the Monticello FPRA model to 
perform the risk impact assessment. For the development of the FPRA, 
the licensee modified its IEPRA model to capture the effects of 
fire. Therefore, the NRC staff evaluated both the IEPRA and FPRA 
quality information provided by the licensee in the exemption 
request to determine whether the plant-specific PRA used in the risk 
impact assessment includes sufficient scope, level of detail, and 
technical adequacy for this assessment.
    Consistent with the information provided in NRC Regulatory Issue 
Summary 2007[dash]06, ``Regulatory Guide 1.200 Implementation,'' 
March 22, 2007 (ADAMS Accession No. ML070650428), the NRC staff uses 
RG 1.200, ``An Approach for Determining the Technical Adequacy of 
Probabilistic Risk Assessment Results for Risk-Informed 
Activities,'' Revision 2 (ADAMS Accession No. ML090410014).
    The licensee stated that a full-scope peer review was performed 
in April 2013, for the IEPRA model (Revision 3.2). The peer review 
was performed using Nuclear Energy Institute (NEI) 05-04, Revision 
2, ``Process for Performing Internal Events PRA Peer Reviews Using 
the ASME/ANS [American Society of Mechanical Engineers/American 
Nuclear Society] PRA Standard'' (ADAMS Accession No. ML083430462), 
as clarified by RG 1.200, Revision 2. The PRA standard provides 
supporting requirements for the PRA against capability categories 
(CC) CC-I, CC-II, or CC-Ill. The peer review resulted in 
identification of PRA standard supporting requirements that did not 
meet CC-II, or that were met and had related findings (Reference: 
Evaluation of Risk Significance of Permanent Integrated Leak Rate 
Testing Extension--ML16047A273). In Enclosure 2 of the exemption 
request, the licensee provided the peer review finding-level facts 
and observations (F&Os) against the PRA standard supporting 
requirements and the licensee's resolution to each of the F&Os. The 
licensee stated that all of the finding-level F&Os have been 
resolved and that none were determined to affect the exemption 
request.
    The licensee stated that a full-scope peer review of the FPRA 
model (Revision 1a) was performed in March 2015, using NEI 07-12, 
Revision 1, ``Fire Probabilistic Risk Assessment (FPRA) Peer Review 
Process Guidelines,'' June 2010 (ADAMS Accession No. ML102230070), 
and RG 1.200, Revision 2. The peer review resulted in identification 
of PRA standard supporting requirements that did not meet CC-II, or 
CC-III for one supporting requirement (Reference: Monticello ILRT 
license amendment--ML16047A273). In Enclosure 3 of the exemption 
request, the licensee provided the peer review finding-level F&Os 
against the PRA standard supporting requirements and its resolution 
to each of the F&Os. The licensee stated that all of the finding-
level F&Os have been resolved and that none were determined to 
affect the exemption request.
    The licensee stated that a focused-scope peer review of Revision 
4.0 of the FPRA model was performed in December 2016, of a subset of 
high-level requirements impacted by the use of enhanced fire 
modeling methods that were implemented subsequent to the March 2015, 
peer review. The licensee provided the two peer review finding-level 
F&Os from this focused-scope peer review in Enclosure 4 of the 
exemption request. The licensee stated that the two finding-level 
F&Os have been resolved and that neither was determined to affect 
the exemption request. The licensee also stated that the PRA used in 
the risk impact assessment represents the current as-installed and 
as-operated configuration of Monticello.
    The NRC staff reviewed the exemption request to determine the 
technical adequacy of the Monticello IEPRA and FPRA models used for 
this exemption request. The licensee stated that it evaluated its 
PRA against Revision 2 of RG 1.200 and the ASME/ANS PRA standard. 
The licensee stated that it had resolved all peer review and 
focused-scope peer review finding-level F&Os and concluded that they 
had no impact on the exemption request. Based on the information 
provided by the licensee, the NRC staff found that the licensee's 
PRA represents the current as-installed and as-operated plant, and 
the margin between the reported risk values and the guidance 
recommended values is acceptable.
    The NRC staff concludes that the IEPRA is adequate and can be 
used to support the FPRA because the licensee demonstrated that the 
resolution of the F&Os did not affect the technical adequacy of the 
licensee's PRA analysis submitted to support the licensee's risk 
evaluation of the proposed exemption request.
    The NRC staff concludes that the IEPRA is adequate and can be 
used to support the FPRA because the licensee demonstrated that the 
resolution of the F&Os support the technical adequacy of the 
licensee's PRA analysis submitted for the licensee's risk evaluation 
of the proposed exemption request.
    The NRC staff also concludes that the FPRA is of sufficient 
technical adequacy and that its quantitative results can be used to 
demonstrate that the change in risk due to the lack of physical 
separation between the DWS division meets the acceptance guidelines 
in RG 1.174 because the licensee demonstrated that the resolution of 
the relevant F&Os supports the determination that the quantitative 
results are adequate and have no significant impact on the FPRA. For 
several F&Os, the NRC staff determined that the resolutions could 
impact the delta risk results reported in the exemption request, but 
that their resolution is unlikely to change the delta risk results 
reported by the licensee in the exemption request enough to increase 
the delta core damage frequency (CDF) and the delta large early 
release frequency (LERF) by an amount necessary to exceed the RG 
1.174 risk guidelines for very small changes.
    Based on the above, NRC staff concludes that the FPRA model is 
of sufficient technical adequacy to support the risk impact 
assessment of the proposed change.

Risk Impact Assessment

    The licensee stated that the evaluation of the risk for the 
proposed change was done using Revision 4.0 of the Monticello FPRA 
model to estimate the change in risk between an Appendix R-compliant 
configuration and the as-installed and as-operated configuration of 
the shorting switches.
    In Enclosure 1, Section 3.3.3, of the exemption request, the 
licensee described how it developed the risk of the as-installed and 
as-operated configuration of the plant with shorting switches 
installed. For this plant configuration, the licensee modified the 
FPRA model to include new basic events to fail the DWS MOVs due to 
fire-induced MSOs (referred to as the ``variant model''). The model 
modification included identifying the cables that could cause a DWS 
MOV MSO, identifying the plant locations (fire zones) where these 
cables are located in the plant, and linking these cables to 
specific fire scenarios modeled in the FPRA. The exemption request 
also described the revised fault tree logic that incorporated the 
new basic events.
    Each of the two DWS trains includes two-normally-closed in-
series MOVs that could fail open due to a fire-induced MSO and 
result in core damage. Each in-series pair of DWS MOVs were added 
together in the fault tree and assigned a hot short probability. The 
MOVs without a shorting switch have a hot short probability of 0.39, 
which is taken from Volume 2 of NUREG/CR-7150, ``Joint Assessment of 
Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE)'' 
(ADAMS Accession No. ML14141A129). The MOVs with a shorting switch 
are assumed to have a failure probability of 1.0E-03, which is the 
assumed failure probability of the shorting switch. In enclosure 1, 
section 3.3.5 of the exemption request, the licensee justified its 
use of the 1.0E-03 failure probability by explaining that it was 
found acceptable by the NRC staff in the safety evaluations related 
to National Fire Protection Association 805 license amendment 
requests by other licensees (see ADAMS Accession Nos. ML15212A796 
and ML16223A481). The licensee stated that the control circuitry 
configuration for the shorting switch application at these plants is 
substantially similar to that for the Monticello DWS MOVs.
    The NRC staff finds that the use of a hot short probability of 
0.39 is acceptable because it is the most bounding of the MOV hot 
short probabilities for grounded and ungrounded alternate current 
control circuits as described in Table 8-1 of NUREG/CR-7150, Volume 
2. The NRC staff also finds that the licensee's use of the 1.0E-3 
failure probability for the shorting switches is acceptable because 
the conditions that would

[[Page 21314]]

have to occur to fail a shorting switch are considered extremely 
unlikely.
    The exemption request further explained that the flow diversion 
created by the failure of just one train of DWS MOVs (i.e., spurious 
opening of both in-series MOVs) was assumed to result in damage of 
the RHR pumps because activation of the Drywell Sprays would result 
in lowering the drywell pressure. This in turn could result in the 
potential loss of containment accident pressure, which leads to a 
loss of net positive suction head and which, in turn, would fail the 
RHR pumps. All RHR pumps are potentially damaged because the RHR 
removal cross[dash]tie valves are normally kept open. The failure of 
the RHR pumps and loss of net positive suction head result in 
failure of all associated functions modeled in the PRA (except DWS), 
specifically:
     Shutdown cooling,
     Low pressure coolant injection (LPCI),
     Torus cooling (which fails high pressure coolant 
injection and reactor coolant isolation cooling when suction is from 
the torus),
     Core spray,
     Alternate injection with condensate service water, the 
fire protection system, or RHR service water, and
     Primary containment.
    Because of the failure of RHR pumps, the torus sprays would also 
fail, which is not modeled in the PRA.
    In Enclosure 1, Section 3.3.2, of the exemption request, the 
licensee described how it developed the risk of the Appendix R-
compliant configuration. For this plant configuration, the licensee 
revised the FPRA model to assume the DWS MOVs do not fail due to a 
fire-induced MSO (referred to as the ``compliant model''). The 
licensee explained that its assumption is conservative because it 
assumes a failure probability of zero for the DWS MOVs due to a 
fire[dash]induced MSO. The NRC staff concludes that this assumption 
is conservative because, although unlikely, there is a greater-than-
zero probability of a large enough fire that could defeat the 
Appendix R protection requirements and produce a MSO that would fail 
the MOVs.
    In Enclosure 1, Section 3.3.4, of the exemption request, the 
license explained that it calculated the change in risk for the 
proposed change by subtracting the calculated risk (CDF) and LERF) 
for the compliant model from the calculated risk for the variant 
model.
    Furthermore, in Enclosure 1, Section 3.3.5, of the exemption 
request, the licensee identified several conservatisms in the PRA 
model that would overestimate the calculated change in risk. These 
conservatisms include: the assumption that all postulated control 
room fires fail the shorting switches, assumption that the RHR pumps 
are running at the time of the MSO event, and the assumption that 
the loss of containment accident pressure and net positive suction 
head is instantaneous with the MSO event. The NRC staff finds that 
these conservatisms make the model overestimate the calculated 
change in risk because not all control room fires fail the shorting 
switches, because the RHR pumps may not be running at the time of 
the MSO event, and because loss of containment accident pressure and 
net positive suction head may not be instantaneous with the MSO 
event.
    Based on the licensee's description of the fault tree modeling 
of the MSO event in the compliant and variant models, the NRC staff 
concludes that the hot short probability and shorting switch failure 
probability are acceptable, and that the calculated change in risk 
is likely conservative. The NRC staff further concludes that the 
licensee's method for calculating the change in risk is acceptable.

PRA Results and Comparison with Risk Guidelines

    In Enclosure 1, Section 3.3.4, of the exemption request, the 
licensee reported the results of its risk impact assessment. The 
licensee reported the calculated change in risk (variant model risk 
minus compliant model risk) for the proposed plant change to be 
1.8E-08 per year for CDF and 1.4E-08 per year for LERF, which are 
below the RG 1.174, Revision 2, risk guidelines for a ``very small'' 
change.
    Based on its review of the risk impact assessment results, and 
the margin between the reported risk values and the risk guidelines, 
the NRC staff concludes that the increase in CDF and LERF from the 
proposed change is very small per the definition in RG 1.174, 
Revision 2. Also, while the licensee did not provide the total plant 
risk from all hazards, the NRC staff finds this acceptable and 
consistent with RG 1.174, Revision 2, because there is no indication 
that the total CDF and LERF is considerably higher than 1.0E-04 and 
1.0E-05 per reactor year, respectively.

3.2.4 Implementation and Monitoring

    In Enclosure 1, Section 3.4.5, of the exemption request, the 
licensee described the implementation and the monitoring program for 
the shorting switches and the DWS MOVs. The licensee explained that 
the shorting switches were installed in 2012 and that post-
maintenance testing was conducted to ensure that the switches were 
installed in accordance with the approved design and that the MOVs 
continued to operate as expected. The DWS MOVs will continue to be 
regularly exercised in accordance with the Monticello MOV program, 
which has been accepted by the NRC staff, as providing an acceptable 
level of quality and safety, and are monitored under the Monticello 
Maintenance Rule Program.
    In its November 20, 2017, letter, the licensee indicated that 
Monticello will generate a preventive maintenance task for the 
shorting switches to ensure acceptable resistance, and that this 
task will be completed within 180 days of the date of the exemption 
is issued. The licensee will introduce performance monitoring of the 
shorting switches into the Monticello, Appendix R, program, with the 
objective to ensure the shorting switches provide a low impedance 
path to ground in the event of a fire-induced hot short. The program 
will include acceptance criteria, which if exceeded, will cause the 
licensee to enter the issue into its corrective action program.
    The NRC staff concludes that the proposed monitoring program for 
the shorting switches meets the guidelines of RG 1.174, Revision 2, 
and that RI applications include performance monitoring and feedback 
provisions.

3.2.5 Integrated Decision-making

    As described in the previous sections, the licensee's exemption 
request and responses to NRC staff RAIs provided an integrated 
approach to evaluating the proposed change. Specifically, the 
licensee's assessment of the proposed change included:
     Performing a traditional engineering analysis, 
including an evaluation that the proposed change is consistent with 
the DID philosophy and the principle that sufficient safety margins 
are maintained,
     Assessing the technical adequacy of the PRA analysis, 
evaluating the risk impact of the proposed change, and comparing the 
results of the risk impact assessment to the
     RG 1.174, Revision 2, risk guidelines, and
     Defining the implementation of the proposed change and 
of a monitoring program to ensure that no unexpected adverse safety 
degradation occurs due to the proposed change.
    Based on the NRC staff's review of each of these elements of the 
licensee's exemption request, the NRC staff concludes that the 
licensee's evaluations are acceptable and in accordance with RG 
1.174, Revision 2, and that the risk increase of the proposed change 
meets the RG 1.174, Revision 2, risk guidelines for a ``very small'' 
change. Based on this, the NRC staff concludes that the licensee's 
integrated evaluation of the proposed change is acceptable.

3.3 Technical Evaluation Conclusion

    Based on its review of the information provided by the licensee, 
the NRC staff concludes that the licensee's request to credit a 
shorting switch does not create any new accident precursors because 
the plant's operation remains the same in that fire protection for 
structures, systems, and components important to safe shutdown 
continues to be provided, and fire damage continues to be limited so 
that one of the redundant trains is free of fire.
    The NRC staff also concludes that the licensee's evaluations are 
acceptable and in accordance with RG 1.174, Revision 2, and that the 
risk increase of the proposed change meets the RG 1.174, Revision 2, 
risk guidelines for a ``very small'' change. Based on this, the NRC 
staff concludes that the licensee's integrated evaluation of the 
proposed change is acceptable.

3.4 Authorized by Law

    The exemption would allow the licensee to rely on the installed 
shorting switch and other fire protection DID features instead of 
providing separation in accordance with 10 CFR Part 50, Appendix R, 
Section III.G.2. As stated above, 10 CFR 50.12 allows the NRC to 
grant exemptions from the requirements of 10 CFR Part 50. The NRC 
staff has determined, as described in Section 3.7 below, that 
special circumstances exist to grant the proposed exemption and that 
granting of the licensee's proposed exemption will not result in a 
violation of the Atomic Energy Act of 1954, as amended, or

[[Page 21315]]

the Commission's regulations. Therefore, the exemption is authorized 
by law.

3.5 No Undue Risk to Public Health and Safety

    The underlying purposes of 10 CFR Part 50, Appendix R, is to 
provide reasonable assurance of fire protection safe shutdown 
capability. As discussed in Sections 3.1 and 3.2 above, the NRC 
staff found that the crediting of a shorting switch permitted by the 
proposed exemption does not create any new accident precursors or 
degrade detection systems because the plant's operation remains the 
same and the installed shorting switch provides an acceptable level 
of protection as compared to that provided by compliance with the 
regulation.
    Because no new accident precursors are created by the proposed 
exemption, which would allow the licensee to use, or take credit 
using a risk-informed approach, for an installed shorting switch to 
ensure that one redundant train is free of fire damage, the 
probability of postulated accidents is not significantly increased, 
and reasonable assurance of fire protection of safe shutdown 
capability is maintained. Therefore, the NRC staff concludes that 
the consequences of postulated accidents are not significantly 
increased, and there is no undue risk to public health and safety.

3.6 Consistent with Common Defense and Security

    The proposed exemption would allow the licensee to rely on the 
installed shorting switch instead of providing separation required 
by 10 CFR Part 50, Appendix R, Section III.G.2. The NRC staff 
concludes that this change to the plant design has no relation to 
security issues, therefore, the common defense and security is not 
impacted by this exemption.

3.7 Special Circumstances

    Special circumstances, in accordance with 10 CFR 50.12, are 
present whenever an application of the regulation in the particular 
circumstances is not necessary to achieve the underlying purpose of 
the rule. The underlying purpose of 10 CFR part 50, Appendix R, 
Section III.G.2, is to provide reasonable assurance of fire 
protection of safe shutdown capability by providing a means to 
ensure that one of the redundant trains of systems necessary to 
achieve and maintain hot shutdown conditions is free of fire damage. 
The technical evaluation above demonstrates that the shorting switch 
and DID features provide reasonable assurance that the underlying 
purpose of the rule is met because the licensee demonstrated that 
the installed shorting switch provides an acceptable level of 
protection that is similar to that provided by compliance with the 
regulation. The licensee performed a deterministic engineering 
analysis and demonstrated that the proposed change is consistent 
with the DID philosophy and maintains sufficient safety margins. The 
licensee also assessed the technical adequacy of the PRA analysis 
and evaluated the risk impact of the proposed change and compared 
the results to the RG 1.174, Revision 2, risk guidelines, and also 
defined the implementation of the proposed change and of a 
monitoring program to ensure that no unexpected adverse safety 
degradation occurs due to the proposed change. Therefore, the NRC 
staff concludes that since the underlying purpose of 10 CFR 50, 
Appendix R, Section III.G.2 (i.e., ensuring one of the redundant 
trains of Drywell Spray is free of fire damage), is achieved, the 
special circumstances required by 10 CFR 50.12 for the granting of 
an exemption from 10 CFR part 50, Appendix R, Section III.G.2, 
exist.

IV. Environmental Considerations.

    The NRC staff determined that the issuance of the requested 
exemption meets the provisions of categorical exclusion 10 CFR 
51.22(c)(9) because the exemption is from a requirement, with 
respect to the installation or use of a facility component located 
within the restricted area, as defined in 10 CFR part 20 and the 
issuance of the exemption involves: (i) No significant hazards 
consideration; (ii) no significant change in the types or 
significant increase in the amounts of any effluents that may be 
released offsite; and (iii) no significant increase in individual or 
cumulative occupational radiation exposure. Therefore, in accordance 
with 10 CFR 51.22(b), no environmental impact statement or 
environmental assessment need be prepared in connection with the 
NRC's issuance of this exemption. The basis for the NRC staff's 
determination is provided in the following evaluation of the 
requirements in 10 CFR 51.22(c)(9)(i)-(iii).

Requirements in 10 CFR 51.22(c)(9)(i)

    The NRC staff evaluated whether the exemption involves no 
significant hazards consideration by using the standards in 10 CFR 
50.92(c), as presented below:
    1. Does the requested exemption involve a significant increase 
in the probability or consequences of an accident previously 
evaluated?
    No. The proposed exemption would allow the licensee to rely on 
the installed shorting switch instead of providing physical 
separation in accordance with 10 CFR Part 50, Appendix R, III.G.2 to 
protect structures, systems or components important to safe shutdown 
of the plant in the event of a fire. The licensee performed a risk 
impact assessment for installation of the shorting switches rather 
than physically separating the control circuitry in accordance with 
the 10 CFR Part 50, Appendix R, III.G.2 separation requirements. For 
the assessment, the risk was evaluated by estimating the change in 
fire risk between an Appendix R-compliant configuration and the as-
installed and as-operated configuration of the shorting switches. 
Based on its review of the licensee's exemption request, the NRC 
staff concludes that the licensee's evaluations are acceptable and 
in accordance with Regulatory Guide (RG) 1.174, ``An Approach for 
Using Probabilistic Risk Assessment in Risk-Informed Decisions on 
Plant-Specific Changes to the Licensing Basis,'' Revision 2, and 
that the risk increase of the proposed change meets the RG 1.174, 
Revision 2, risk guidelines for a ``very small'' change.
    The installation of the shorting switch does not alter plant 
operation or affect fire detection capability because fire 
protection for structures, systems, and components important to safe 
shutdown continues to be provided, and fire damage continues to be 
limited so that one of the redundant trains is free of fire damage 
and, therefore, would not alter the consequences of any accident 
previously evaluated.
    Therefore, the exemption does not involve a significant increase 
in the probability or consequences of an accident previously 
evaluated.
    2. Does the requested exemption create the possibility of a new 
or different kind of accident from any accident previously 
evaluated?
    No. The underlying purposes of 10 CFR Part 50, Appendix R, 
III.G.2 is to provide reasonable assurance of fire protection safe 
shutdown capability. The exemptions' crediting of a shorting switch 
and defense in depth measures does not create any new accident 
precursors because the plant's operation and fire detection 
capability remains the same.
    Therefore, the exemption does not create the possibility of a 
new or different kind of accident from any accident previously 
evaluated.
    3. Does the requested exemption involve a significant reduction 
in a margin of safety?
    No. The installation of the shorting switch and reliance on 
defense in depth measures does not alter plant operation and does 
not impact any safety margins because codes and standards or their 
alternatives approved by the NRC are met, and the safety analysis 
acceptance criteria described in the licensing basis are met.
    Therefore, the exemption does not involve a significant 
reduction in a margin of safety.
    Based on the evaluation above, the NRC staff has determined that 
the proposed exemption involves no significant hazards 
consideration. Therefore, the requirements of 10 CFR 51.22(c)(9)(i) 
are met.

Requirements in 10 CFR 51.22(c)(9)(ii) and (iii)

    The proposed exemption would allow the Monticello Nuclear 
Generating Plant to maintain a hot shutdown train of Drywell Spray 
free of fire damage by using a method that is different from one of 
the acceptable methods listed in 10 CFR Part 50, Appendix R, Section 
III.G.2. Specifically, In lieu of meeting these protection 
requirements, the licensee has installed a shorting switch 
modification on the control circuitry for one motor-operated valve 
(MOV) in each division of the Drywell Spray system to reduce the 
risk impact of a fire-induced multiple spurious operation that fails 
both MOVs. In addition, the licensee will rely on fire protection 
DID features such as administrative controls, plant design features, 
fire protection inspections, installed fire detection and 
suppression systems, and passive fire protection features. The 
exemption does not modify plant operation because fire protection 
for structures, systems, and components important to safe shutdown 
continues to be provided, and fire damage continues to be limited so 
that one of the redundant trains of Drywell Spray is free of fire 
damage. Thus the exemption does

[[Page 21316]]

not result in a significant change in the types or amount of 
effluents that may be released and does not result in any additional 
occupational exposure. Therefore, the requirements of 10 
CFR51.22(c)(9)(ii) and (iii) are met.

V. Conclusions.

    Accordingly, the Commission has determined that, pursuant to 10 
CFR 50.12, the exemption is authorized by law, will not present an 
undue risk to the public health and safety, and is consistent with 
the common defense and security. Also, special circumstances are 
present in that application of the regulation is not necessary to 
achieve the underlying purpose of the rule. Therefore, the 
Commission hereby grants Northern States Power Company, doing 
business as Xcel Energy, an exemption from the requirements of 10 
CFR 50, Appendix R, Section III.G.2, for Monticello Nuclear 
Generating Plant, to allow the use of a shorting switch to ensure 
that one redundant train of Drywell Spray is free of fire damage to 
achieve and maintain hot shutdown conditions in the event of a fire.

VI. Availability of Documents.

    The documents identified in the following table are available in 
ADAMS.

------------------------------------------------------------------------
                Document                       ADAMS  Accession  No.
------------------------------------------------------------------------
Risk-Informed Request for Exemption from  ML17096A599
 10 CFR 50, Appendix R, III.G.2
 Requirements for Multiple Spurious
 Operations of Drywell Spray Motor-
 Operated Valves.
Request for additional information RE:    ML17293A091
 Monticello Request for Exemption from
 Appendix R Requirements (CAC NO.
 MF9586; EPID L-2017-LLE-00012).
Response to Request for Additional        ML17324B361
 Information regarding Risk-Informed
 Request for Exemption from 10 CFR 50,
 Appendix R, III.G.2 Requirements for
 Multiple Spurious Operations of Drywell
 Spray Motor-Operated Valves (CAC No.
 MF9586).
Monticello Nuclear Generating Plant       ML14119A216
 Triennial Fire Protection Inspection
 Report 05000263/2014008.
Letter of Intent to Transition to 10 CFR  ML053460342
 50.48(c)--National Fire Protection
 Association Standard NFPA 805.
 ``Performance-based Standards for Fire
 Protection for Light Water Reactor
 Electric Generating Plants.'' 2001
 Edition.
Notice of Withdrawal of Letter of Intent  ML102000433
 to Transition to 10 CFR 50.48(c)''.
NRC Regulatory Issue Summary 2007-06      ML070650428
 Regulatory Guide 1.200 Implementation.
NEI 05-04, Rev. 2 Process for Performing  ML083430462
 Internal Events PRA Peer Reviews Using
 the ASME/ANS PRA Standard.
NEI 07-12 [REV 1] Fire Probabilistic      ML102230070
 Risk Assessment (FPRA) Peer Review
 Process Guidelines.
NUREG/CR-7150, Vol. 2 Joint Assessment    ML14141A129
 of Cable Damage and Quantification of
 Effects from Fire (JACQUE-FIRE).
Browns Ferry Nuclear Plant, Units 1, 2,   ML15212A796
 And 3--Issuance of Amendments Regarding
 Transition to a Risk-Informed,
 Performance-Based Fire Protection
 Program in Accordance with 10 CFR
 50.48(c) (CAC NOS. MF1185, MF1186, AND
 MF1187).
Arkansas Nuclear One, Unit 1--Issuance    ML16223A481
 of Amendment Regarding Transition to a
 Risk-Informed, Performance-Based Fire
 Protection Program in Accordance with
 10 CFR 50.48(c) (CAC NO. MF3419).
Regulatory Guide 1.189 ``Fire Protection  ML092580550
 for Nuclear Power Plants,'' Revision 2.
Regulatory Guide 1.174 ``An Approach for  ML100910006
 Using Probabilistic Risk Assessment in
 Risk-Informed Decisions on Plant-
 Specific Changes to the Licensing
 Basis,'' Revision 2.
Regulatory Guide 1.200 ``An Approach for  ML090410014
 Determining the Technical Adequacy of
 Probabilistic Risk Assessment Results
 for Risk-Informed Activities,''
 Revision 2.
Monticello Nuclear Generating Station:    ML16047A273
 Evaluation of Risk Significance of
 Permanent Integrated Leak Rate Test
 Extension.
------------------------------------------------------------------------

    Dated at Rockville, Maryland, this 1st day of May 2018.

    For the Nuclear Regulatory Commission.

    Gregory F. Suber,

Acting Director, Division of Operating Reactor Licensing, Office of 
Nuclear Reactor Regulation.

[FR Doc. 2018-09801 Filed 5-8-18; 8:45 am]
 BILLING CODE 7590-01-P



                                             21310                         Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices

                                             exclusive patent license to Vigilant                    technical questions, contact the                        The facility consists of a boiling water
                                             Aerospace Systems, Inc. The document                    individual listed in the FOR FURTHER                  reactor located in Wright County, Minnesota.
                                             contained an incorrect phone number.                    INFORMATION CONTACT section of this                   II. Request/Action
                                             DATES: The correction is valid May 9,                   document.                                                In its letter dated April 6, 2017
                                             2018.                                                      • NRC’s Agencywide Documents                       (Agencywide Documents Access and
                                                                                                     Access and Management System                          Management System (ADAMS) Accession
                                             SUPPLEMENTARY INFORMATION:
                                                                                                     (ADAMS): You may obtain publicly-                     No. ML17096A599), as supplemented by its
                                             Correction                                              available documents online in the                     letter dated November 20, 2017 (ADAMS
                                                                                                     ADAMS Public Documents collection at                  Accession No. ML17324B361), the licensee
                                               In the Federal Register of May 1,                                                                           requested an exemption from Title 10 of the
                                             2018, in FR Doc. 18–09183, on page                      http://www.nrc.gov/reading-rm/
                                                                                                     adams.html. To begin the search, select               Code of Federal Regulations (10 CFR), Part
                                             19116, in the first column, correct the                                                                       50, Appendix R, Section III.G.2, which
                                             FOR FURTHER INFORMATION CONTACT
                                                                                                     ‘‘ADAMS Public Documents’’ and then
                                                                                                                                                           requires that where redundant trains of
                                             caption to read:                                        select ‘‘Begin Web-based ADAMS                        systems necessary to achieve and maintain
                                                                                                     Search.’’ For problems with ADAMS,                    hot shutdown conditions are located within
                                             FOR FURTHER INFORMATION CONTACT:
                                                                                                     please contact the NRC’s Public                       the same fire area outside of primary
                                             Mark Homer, Patent Counsel, NASA
                                                                                                     Document Room (PDR) reference staff at                containment, that one of the redundant trains
                                             Management Office of Chief Counsel, Jet
                                                                                                     1–800–397–4209, 301–415–4737, or by                   remains free of fire damage by either a 3-hour
                                             Propulsion Laboratory, 4800 Oak Grove                                                                         rated barrier; or 20 feet horizontal separation,
                                                                                                     email to pdr.resource@nrc.gov. The
                                             Drive, M/S 180–800C Pasadena, CA                                                                              no intervening combustibles, and detection
                                                                                                     ADAMS accession number for each
                                             91109. Phone (818) 354–7770. Facsimile                                                                        and suppression system; or a 1-hour barrier,
                                                                                                     document referenced (if it is available in
                                             (818) 393–2607.                                                                                               and detection and suppression systems. The
                                                                                                     ADAMS) is provided the first time that
                                                                                                                                                           licensee requested NRC approval for
                                             Deborah F. Bloxon,                                      it is mentioned in the attached                       Monticello to use a method to maintain a hot
                                             Federal Liaison Officer.                                exemption. In addition, for the                       shutdown train free of fire damage that is not
                                             [FR Doc. 2018–09790 Filed 5–8–18; 8:45 am]              convenience of the reader, the ADAMS                  one of the acceptable methods listed in 10
                                             BILLING CODE 7510–13–P
                                                                                                     accession numbers are provided in a                   CFR part 50, Appendix R, Section III.G.2. The
                                                                                                     table in the ‘‘Availability of Documents’’            licensee’s exemption request is intended to
                                                                                                     section of the exemption.                             justify why the proposed alternative, the use
                                                                                                        • NRC’s PDR: You may examine and                   of a shorting switch, is acceptable in
                                             NUCLEAR REGULATORY                                                                                            accordance with the requirements of 10 CFR
                                                                                                     purchase copies of public documents at
                                             COMMISSION                                                                                                    50.12, Specific Exemptions.
                                                                                                     the NRC’s PDR, Room O1–F21, One
                                                                                                                                                              The regulatory framework that applies to
                                             [Docket No. 50–263; NRC–2018–0090]                      White Flint North, 11555 Rockville
                                                                                                                                                           Monticello is contained in 10 CFR 50.48(b)(1)
                                                                                                     Pike, Rockville, Maryland 20852.                      which requires that plants licensed before
                                             Northern States Power Company:                          FOR FURTHER INFORMATION CONTACT:                      January 1, 1979, to meet Sections III.G, J, and
                                             Monticello Nuclear Generating Plant                     Robert F. Kuntz, Office or Nuclear                    O, of Appendix R to 10 CFR part 50.
                                             AGENCY:  Nuclear Regulatory                             Reactor Regulation, U.S. Nuclear                      Monticello began commercial operations in
                                             Commission.                                             Regulatory Commission, Washington,                    1971. Section III.G.2 of 10 CFR part 50,
                                                                                                     DC 20555–0001; telephone: 301–415–                    Appendix R, requires, that, ‘‘where cables or
                                             ACTION: Exemption; issuance.                                                                                  equipment, including associated non-safety
                                                                                                     3733, email: Robert.Kuntz@nrc.gov.
                                                                                                                                                           circuits that could prevent operation or cause
                                             SUMMARY:   The U.S. Nuclear Regulatory                  SUPPLEMENTARY INFORMATION: The text of                maloperation due to hot shorts, open circuits,
                                             Commission (NRC) has issued an                          the exemption is attached.                            or shorts to ground, of redundant trains of
                                             exemption for the Monticello Nuclear                      Dated at Rockville, Maryland, this 3rd day          systems necessary to achieve and maintain
                                             Generating Plant, Docket No. 50–263, in                 of May 2018.                                          hot shutdown conditions are located within
                                             response to an April 6, 2017, request                     For the Nuclear Regulatory Commission.              the same fire area outside of primary
                                             from Northern States Power Company.                                                                           containment, one of the following means of
                                                                                                     Robert F. Kuntz,                                      ensuring that one of the redundant trains is
                                             Specifically, the exemption is from the
                                                                                                     Senior Project Manager, Plant Licensing               free of fire damage shall be provided: a.
                                             regulation that requires where
                                                                                                     Branch III, Division of Operating Reactor             Separation of cables and equipment and
                                             redundant trains of systems necessary to                Licensing, Office of Nuclear Reactor                  associated non-safety circuits of redundant
                                             achieve and maintain hot shutdown                       Regulation.                                           trains by a fire barrier having a 3-hour rating.
                                             conditions located within the same fire                                                                       Structural steel forming a part of or
                                             area outside of primary containment,                    Attachment—Exemption
                                                                                                                                                           supporting such fire barriers shall be
                                             one of the redundant trains remains free                NUCLEAR REGULATORY COMMISSION                         protected to provide fire resistance
                                             of fire damage by one of three methods                  Docket No. 50–263
                                                                                                                                                           equivalent to that of the barrier; b. Separation
                                             of physical separation.                                                                                       of cables and equipment and associated non-
                                             DATES: The exemption was issued on                      Northern States Power Company                         safety circuits of redundant trains by a
                                                                                                                                                           horizontal distance of more than 20 feet with
                                             May 1, 2018.                                            Monticello Nuclear Generating Plant                   no intervening combustible or fire hazards. In
                                             ADDRESSES: Please refer to Docket ID                    Exemption                                             addition, fire detectors and an automatic fire
                                             NRC–2018–0090 when contacting the                                                                             suppression system shall be installed in the
                                             NRC about the availability of                           I. Background                                         fire area; or c. Enclosure of cable and
                                             information regarding this document.                       Northern States Power Company, doing               equipment and associated non-safety circuits
                                             You may obtain publicly-available                       business as Xcel Energy (the licensee), is the        of one redundant train in a fire barrier having
                                             information related to this document                    holder of Renewed Facility Operating                  a 1-hour fire rating. In addition, fire detectors
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                                             using any of the following methods:                     License Number 50–263, which authorizes               and an automatic fire suppression system
                                                                                                     operation of the Monticello Nuclear                   shall be installed in the fire area.’’
                                               • Federal Rulemaking Web Site: Go to
                                                                                                     Generating Plant (Monticello). The license               In its April 29, 2014, triennial fire
                                             http://www.regulations.gov and search                   provides, among other things, that the facility       protection inspection report 05000263/
                                             for Docket ID NRC–2018–0090. Address                    is subject to all rules, regulations, and orders      2014008, (ADAMS Accession No.
                                             questions about NRC dockets to Jennifer                 of the U.S. Nuclear Regulatory Commission             ML14119A216), the NRC staff identified two
                                             Borges; telephone: 301–287–9127;                        (NRC or the Commission) now or hereafter in           pairs of Drywell Spray (DWS) motor-operated
                                             email: Jennifer.Borges@nrc.gov. For                     effect.                                               valve (MOV) control cables that are not



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                                                                           Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices                                                 21311

                                             protected in accordance with an acceptable              Turbine Building East—Engineered                      protected valves, such as MO–2020. Third,
                                             option provided in 10 CFR part 50, Appendix             Safeguards Feature Motor Control Center               the fire would have to cause that same
                                             R, Section III.G.2. In 2012, the licensee               Area, and Fire Zone 19C—Turbine Building              severed cable to MO–2020 to be exposed to
                                             installed a modification, called a shorting             East—Pipe and Cable Tray Penetration Area.            an energized cable fault or hot short.
                                             switch, to mitigate the lack of protection. The         The third room is in Fire Area XII, Fire Zone         Essentially the severed cable would remove
                                             shorting switch modification had been                   19B, Turbine Building East and Engineered             the shorting switch from the circuit, thereby,
                                             approved for use at some plants that had                Safeguards Features Motor Control Center              defeating the design capability of the shorting
                                             adopted a risk-informed (RI), performance-              Cable Tunnel. It is within these three rooms          switch. Similarly, the pair of valves MO-2021
                                             based (PB) fire protection program (FPP)                that the separation required by 10 CFR part           and MO–2023 would be vulnerable to the
                                             under 10 CFR 50.48(c)(4). Although                      50, Appendix R, Section III.G.2, is not               same potential failure mode. Note that both
                                             Monticello had at one time expressed intent             provided.                                             valves in a pair, MO–2020 and MO–2022 or
                                             to adopt a 10 CFR 50.48(c)(4) FPP (ADAMS                  The scenario postulates that a fire in one          MO–2021 and MO–2023, would need to be
                                             Accession No. ML053460342), Monticello                  of these areas could damage the control               impacted to remove the shorting switch from
                                             later withdrew its letter of intent (ADAMS              cables to the two DWS MOVs and cause the              the circuit. A hot short from one cable in the
                                             Accession No. ML102000433).                             normally closed valves to spuriously open. If         first pair and one cable in the second pair
                                                The requirements at 10 CFR part 50,                  these valves were to open while the same              would not create a condition where the RHR
                                             Appendix R, Section III.G.2, require that hot           division’s residual heat removal (RHR) pump           pumps could be damaged.
                                             shorts and open circuits be considered, and             were operating, the scenario postulates that
                                                                                                     the RHR pumps would be damaged and safe               3.2 Risk-Informed Technical Evaluation
                                             the licensee’s analysis showed that the
                                             shorting switch modification could fail to              shutdown capability would be impaired.                   The licensee’s exemption request includes
                                             meet its design purpose if certain hot shorts                                                                 a risk assessment of the proposed plant
                                                                                                     3.1.1 Explanation of Postulated Scenario
                                             and open circuits were to occur due to fire                                                                   change. The use of risk information in a 10
                                                                                                     and Shorting Switch Modification
                                             damage. Therefore, on April 6, 2017, the                                                                      CFR part 50, Appendix R, exemption request
                                             licensee submitted an RI request for an                    The NRC staff evaluated the licensee’s             is in accordance with Regulatory Position 1.8
                                             exemption from the requirements of 10 CFR               analysis of how the protection provided by            of Regulatory Guide (RG) 1.189, ‘‘Fire
                                             part 50, Appendix R, Section III.G.2, to                the shorting switch compares to the 10 CFR            Protection for Nuclear Power Plants,’’
                                             address postulated spurious actuations of the           part 50, Appendix R, Section III.G.2                  Revision 2, dated October 2009 (ADAMS
                                             DWS MOVs that could occur in the event                  requirement that one train be free of fire            Accession No. ML092580550), which says
                                             that an open circuit caused the shorting                damage by comparing the installed shorting            that RI/PB methodologies may be used to
                                             switch to fail to perform its function.                 switch configuration to the configuration             evaluate the acceptability of FPP changes;
                                                                                                     required by the regulation. This section              however, for this approach, the licensee
                                             III. Discussion                                         includes a discussion of how the installed            should use methodologies and acceptance
                                                Pursuant to 10 CFR 50.12, the Commission             shorting switch works to prevent a spurious           criteria that the NRC has reviewed and
                                             may, upon application by any interested                 opening of the DWS MOVs.                              approved. RG 1.174, ‘‘An Approach for Using
                                             person or upon its own initiative, grant                   To reduce the likelihood of a spurious             Probabilistic Risk Assessment in Risk-
                                             exemptions from the regulations when: (1)               actuation, the licensee installed a shorting          Informed Decisions on Plant-Specific
                                             the exemptions are authorized by law, will              switch on one of the valves in series. There          Changes to the Licensing Basis,’’ Revision 2,
                                             not present an undue risk to public health or           are two trains of DWS. A shorting switch is           (ADAMS Accession No. ML100910006),
                                             safety, and are consistent with the common              installed on MOV MO–2020 (Division I), and            includes guidance for RI changes to a plant’s
                                             defense and security; and (2) when special              installed on MOV MO–2021 (Division II).               current licensing bases.
                                             circumstances are present. The licensee                 The other valves in series, MOVs MO–2022                 Accordingly, the NRC staff reviewed the
                                             requested an exemption from 10 CFR part 50,             (Division I) and MO–2023 (Division II), are           licensee’s exemption request using the
                                             Appendix R, Section III.G.2, claiming that the          not equipped with a shorting switch, and              review methodology and criteria contained in
                                             special circumstances of 10 CFR                         therefore may be subject to an energized              RG 1.174, Revision 2, which includes the
                                             50.12(a)(2)(ii), which states that,                     cable fault that could cause a spurious               following elements:
                                             ‘‘Application of the regulation in the                  opening of those valves. Figure 1 of the                 • Defining the proposed change,
                                             particular circumstances would not serve the            licensee’s exemption request includes a one-             • Performing an engineering analysis,
                                             underlying purposed of the rule or is not               line diagram of the system.                           including an evaluation that the proposed
                                             necessary to achieve the underlying purpose                When the control room switch is in the             change is consistent with the defense-in-
                                             of the rule,’’ apply.                                   closed position, the shorting switch creates          depth (DID) philosophy and the principle
                                                The underlying purpose of 10 CFR part 50,            an electrical circuit that provides a low             that sufficient safety margins are maintained,
                                             Appendix R, Section III.G.2, is to provide              impedance path bypassing the valve’s                     • Assessing the technical adequacy of the
                                             reasonable assurance of fire protection of safe         ‘‘open’’ coil. If an energized cable fault or hot     PRA analysis, the methods used to determine
                                             shutdown capability by providing a means to             short were to occur that would energize the           the risk impact of the proposed change, and
                                             ensure that one of the redundant trains of              ‘‘open’’ coil, this low impedance path would          the results of the risk impact assessment,
                                             systems necessary to achieve and maintain               divert enough current away from the ‘‘open’’             • Defining the implementation and
                                             hot shutdown conditions is free of fire                 coil through the shorting switch electrical           monitoring program to ensure that no
                                             damage. The licensee’s position is that the             circuit to prevent the ‘‘open’’ coil from             unexpected adverse safety degradation
                                             safety benefit, when measured using                     actuating. When the control room switch is            occurs due to the proposed change, and
                                             accepted probabilistic risk assessment (PRA)            set to the open position, this low impedance             • Confirming that an integrated approach
                                             techniques, is ‘‘virtually’’ the same as if the         path is removed from the circuit and the              was used to evaluate the proposed change.
                                             plant had used one of the three separation              valve can be opened normally. The shorting
                                                                                                     switch only functions to prevent spurious             3.2.1 Proposed Change to the Appendix R
                                             options described in 10 CFR part 50,
                                                                                                     actuation of the valve in the event of an             Program
                                             Appendix R, Section III.G.2.a, b, or c.
                                                The NRC staff’s evaluation of the licensee’s         energized cable fault. A simplified shorting             Pursuant to 10 CFR 50.12, the licensee
                                             exemption request is provided below.                    switch circuit is shown in Figure 2 of the            requested an exemption from 10 CFR part 50,
                                                                                                     licensee’s exemption request.                         Appendix R, Section III.G.2 requirements
                                             3.1 Deterministic Technical Evaluation                     The fire scenario of concern would involve         with respect to the protection of the control
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                                                The fire scenario, as described in the               three fire-induced failures. First, an                circuitry for the DWS MOVs. In lieu of
                                             licensee’s exemption request, is that there             energized cable fault or hot short would need         meeting the protection requirements of
                                             will be spurious operation of two normally              to occur on control circuitry for the DWS             Section III.G.2, the licensee has installed a
                                             closed DWS MOVs due to a fire. The cables               MOV that does not have a shorting switch              shorting switch modification on the control
                                             are routed from the control room and may be             installed, for example MO–2022. Second, the           circuitry for one MOV in each division of the
                                             subject to a fire in three other rooms. Two of          fire would need to cause a cable to become            DWS system to reduce the risk impact of a
                                             the rooms are in Fire Area IX, the rooms                severed, also called an open circuit, on one          fire-induced multiple spurious operation
                                             (called fire zones) are Fire Zone 13C—                  of the conductors for the shorting switch             (MSO) that fails both MOVs. A detailed



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                                             21312                         Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices

                                             description of the modification is provided in          combustibles or ignition sources at such a            the RHR pumps, the pumps would have to
                                             Enclosure 1, Section 3.1, of the licensee’s             level that necessitates additional controls be        be running at the time of the cable faults.
                                             exemption request.                                      put in place to prevent fires from starting.          Although possible in an actual plant event,
                                                                                                     Fire Protection DID Element 2—Detecting               the licensee did not assume in its evaluation
                                             3.2.2 Engineering Analysis
                                                                                                     and Extinguishing Fires                               that plant operators would turn off the
                                                Regulatory Position 2.1 of RG 1.174,                                                                       pumps before they became damaged. The
                                             Revision 2, indicates that, for RI changes to              The licensee indicated that all three of the       NRC staff considers this assumption to be
                                             the plant licensing basis, the licensee should          rooms addressed in this exemption are                 conservative because the licensee indicated
                                             evaluate the proposed change to determine               equipped with full area ionization smoke
                                                                                                                                                           that operators would initiate a controlled
                                             whether it is consistent with the DID                   detection systems. Only Fire Area IX, Fire
                                                                                                                                                           shutdown to preclude equipment failures.
                                             philosophy and the principle that sufficient            Zone 13C, has significant fixed ignition
                                                                                                                                                              Additionally, the NRC staff determined
                                             safety margins are maintained.                          sources and it is equipped with an automatic
                                                                                                                                                           that hot shorts would have to be of sufficient
                                                                                                     water based suppression system which the
                                             Fire Protection DID                                                                                           duration to open the MOVs enough to result
                                                                                                     licensee indicates is based on the
                                                Regulatory Position 2.1.1 of RG 1.174,               significance of the fire hazards contained            in a flow that would cause RHR pump failure
                                             Revision 2, provides guidance on                        within that room. The smoke detection                 due to runout and that typically, hot shorts
                                             maintaining the philosophy of nuclear safety            system annunciates to the control room                are of a very short duration.
                                             DID and identifies several elements to                  which results in response of the fire brigade.           These aspects of the scenario, the
                                             consider in this evaluation. DID involves                  Each of the three rooms included in this           likelihood of cable faults, the assumption
                                             prevention, protection, and mitigation. With            exemption has fire hose stations and fire             that the RHR pumps are operating, and the
                                             respect to nuclear power plant FPPs, the                extinguishers in the rooms or in adjacent             possible operator actions and timing related
                                             regulations in 10 CFR part 50, Appendix R,              rooms. Fire Area IX, Fire Zone 13C, and Fire          to mitigating the potentially damaging
                                             Section II.A state that the FPP shall extend            Area XII, Fire Zone 19B, are 900 square feet,         configuration were not explicitly credited in
                                             the concept of DID to fire protection in fire           are considered large rooms, and have                  the analysis. The NRC staff has determined
                                             areas important to safety with the following            extinguishers and hose stations within the            that the DID discussion regarding prevention,
                                             objectives:                                             rooms. Fire Area IX, Fire Zone 19C, does not          protection, and mitigation satisfies the RG
                                                • to prevent fires from starting;                    have a fire hose station or extinguisher in the       1.174 guidance for a DID analysis because it
                                                • to detect rapidly, control, and extinguish         room. Because Fire Area IX, Fire Zone 19C,            discussed multiple means to accomplish
                                             promptly those fires that do occur; and                 has a small floor area of 204 square feet, the        safety functions in accordance with the
                                                • to provide protection for structures,              NRC staff concludes that it is reasonable that        guidance provided in Regulatory Position
                                             systems and components important to safety              extinguishers and fire hoses could be brought         2.1.1 of RG 1.174.
                                             so that a fire that is not promptly                     from adjoining areas. The NRC staff also              Safety Margins
                                             extinguished by the fire suppression                    concludes that this exemption does not                   In Enclosure 1, Section 3.4.3, of the
                                             activities will not prevent the safe shutdown           degrade the detecting and extinguishing fires         exemption request, the licensee provided its
                                             of the plant.                                           DID element, because the installation of the
                                                An engineering analysis that evaluates the                                                                 assessment of how sufficient safety margins
                                                                                                     switches (1) does not impact the ability of the
                                             impact of a proposed change to an Appendix                                                                    are maintained. The licensee explained that
                                                                                                     installed detection and suppression systems
                                             R FPP on the balance among these FPP DID                                                                      the design and installation of the shorting
                                                                                                     to detect and extinguish a fire, and (2) does
                                             elements is deemed by the NRC staff to                                                                        switches was completed using applicable
                                                                                                     not impact the fire brigades ability to
                                             satisfy the RG 1.174 guidance. Enclosure 1,                                                                   codes and standards and that the Monticello
                                                                                                     manually extinguish a fire using the installed
                                             Section 3.2, of the exemption request                                                                         safety analyses were not impacted by the
                                                                                                     extinguishers and fire hose stations.
                                             provides the licensee’s evaluation of the FPP                                                                 installation of the switches or the exemption
                                                                                                     Fire Protection DID Element 3—Safe                    request. In its letter dated November 20,
                                             DID elements. Fire protection DID elements              Shutdown
                                             consist of administrative controls such as                                                                    2017, in response to the NRC’s October 18,
                                             plant procedures to limit combustible                      The NRC staff determined that the safe             2017, request for additional information
                                             materials or control hot work activities, plant         shutdown element of fire protection DID is            (RAI) (ADAMS Accession No.
                                             design features, fire protection inspections,           impacted by this exemption request. The               ML17293A091), the licensee indicated that
                                             installed fire detection and suppression                licensee proposes to install an engineered            sufficient safety margins are demonstrated by
                                             systems, and passive fire protection features           feature called a shorting switch, in lieu of the      the design, operation, and performance
                                             such as fire barriers.                                  protection required by 10 CFR part 50,                monitoring of the shorting switches. The
                                                The licensee’s position is that the use of a         Appendix R, Section III.G.2. Compliance               licensee indicated that the RHR system
                                             shorting switch meets the underlying                    with the regulation by use of a barrier, or           currently meets all applicable codes and
                                             purpose of the rule by providing equivalent             separation with fire detection and                    standards (with the exception of the stated 10
                                             protection to one of the separation methods             suppression, protects against possible failure        CFR part 50, Appendix R, Section III.G.2
                                             of 10 CFR part 50, Appendix R, Section                  modes, but the shorting switch modification           noncompliance), and also stated that granting
                                             III.G.2. The licensee chose to install the              results in a possible failure mode involving          the exemption will not affect Monticello’s
                                             shorting switch in lieu of possibly separating          hot shorts and open circuits. 10 CFR part 50,         ability to demonstrate consistency with all
                                             the cables for the valves in series (MO–2021            Appendix R, Section III.G.2, specifically             applicable codes and standards.
                                             from MO–2023, and MO–2020 from MO–                      states that a plant licensed before January 1,           In its November 20, 2017, letter, the
                                             2022) into separate areas. The following                1979, must address these failure modes (i.e.,         licensee also summarized some of the PRA
                                             sections discuss the fire protection DID                ‘‘maloperation due to hot shorts [and] open           bases for ensuring sufficient safety margins.
                                             elements of preventing fires, suppressing               circuits’’).                                          The summarized bases included maintaining
                                             fires that do occur, and protecting safe                   Although the licensee has chosen to use a          a FPP that meets regulatory requirements,
                                             shutdown.                                               RI analysis to compare compliance with the            using a fire PRA (FPRA) that was developed
                                                                                                     regulation and the proposed alternative using         in accordance with NUREG/CR–6850, ‘‘Fire
                                             Fire Protection DID Element 1—Preventing                a shorting switch, the following deterministic        PRA Methodology for Nuclear Power
                                             Fires                                                   features are in place, in addition to the fire        Facilities,’’ having had formal industry peer
                                                The licensee indicated that each of the              prevention, fire detection, and fire                  reviews of internal events PRAs (IEPRAs) and
                                             three rooms has administratively controlled             suppression that are discussed above.                 FPRAs, and using verified and validated fire
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                                             restrictions on combustibles. The licensee                 A fire would have to occur in one of the           models.
                                             described that of the three zones, only Fire            three subject areas and damage the cables to             The NRC staff concludes that the licensee’s
                                             Area IX, Fire Zone 13C, has significant fixed           two of the MOVs. One MOV cable would                  safety margins assessment is acceptable
                                             ignition sources, which are motor control               have to be subjected to an energized fault or         because it demonstrated that codes and
                                             centers. The NRC staff finds that this                  hot short, and the second MOV cable would             standards or their alternatives approved by
                                             exemption does not degrade the preventing               have to be subjected to both a hot short and          the NRC are met, and that the safety analysis
                                             fires DID element, because the proposed                 a severed cable also called an open circuit.          acceptance criteria described in the licensing
                                             change does not introduce additional                    For the combination of cable faults to damage         basis are met.



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                                                                           Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices                                                  21313

                                             3.2.3 PRA                                               supporting requirement (Reference:                    the exemption request enough to increase the
                                                The licensee performed a risk impact                 Monticello ILRT license amendment—                    delta core damage frequency (CDF) and the
                                             assessment for installation of the shorting             ML16047A273). In Enclosure 3 of the                   delta large early release frequency (LERF) by
                                             switches rather than physically separating              exemption request, the licensee provided the          an amount necessary to exceed the RG 1.174
                                             the control circuitry for the DWS MOVs in               peer review finding-level F&Os against the            risk guidelines for very small changes.
                                             accordance with the 10 CFR part 50,                     PRA standard supporting requirements and                 Based on the above, NRC staff concludes
                                             Appendix R, separation requirements. For                its resolution to each of the F&Os. The               that the FPRA model is of sufficient technical
                                             the assessment, the risk was evaluated by               licensee stated that all of the finding-level         adequacy to support the risk impact
                                             estimating the change in risk between an                F&Os have been resolved and that none were            assessment of the proposed change.
                                             Appendix R-compliant configuration and the              determined to affect the exemption request.
                                                                                                        The licensee stated that a focused-scope           Risk Impact Assessment
                                             as-installed and as-operated configuration of
                                             the shorting switches. The risk assessment              peer review of Revision 4.0 of the FPRA                  The licensee stated that the evaluation of
                                             was provided in Enclosure 1, Section 3.3, of            model was performed in December 2016, of              the risk for the proposed change was done
                                             the licensee’s exemption request.                       a subset of high-level requirements impacted          using Revision 4.0 of the Monticello FPRA
                                                                                                     by the use of enhanced fire modeling                  model to estimate the change in risk between
                                             Technical Adequacy of the PRA                           methods that were implemented subsequent              an Appendix R-compliant configuration and
                                                The licensee used Revision 4.0 of the                to the March 2015, peer review. The licensee          the as-installed and as-operated configuration
                                             Monticello FPRA model to perform the risk               provided the two peer review finding-level            of the shorting switches.
                                             impact assessment. For the development of               F&Os from this focused-scope peer review in              In Enclosure 1, Section 3.3.3, of the
                                             the FPRA, the licensee modified its IEPRA               Enclosure 4 of the exemption request. The             exemption request, the licensee described
                                             model to capture the effects of fire. Therefore,        licensee stated that the two finding-level            how it developed the risk of the as-installed
                                             the NRC staff evaluated both the IEPRA and              F&Os have been resolved and that neither              and as-operated configuration of the plant
                                             FPRA quality information provided by the                was determined to affect the exemption                with shorting switches installed. For this
                                             licensee in the exemption request to                    request. The licensee also stated that the PRA        plant configuration, the licensee modified the
                                             determine whether the plant-specific PRA                used in the risk impact assessment represents         FPRA model to include new basic events to
                                             used in the risk impact assessment includes             the current as-installed and as-operated              fail the DWS MOVs due to fire-induced
                                             sufficient scope, level of detail, and technical        configuration of Monticello.                          MSOs (referred to as the ‘‘variant model’’).
                                             adequacy for this assessment.                              The NRC staff reviewed the exemption
                                                                                                                                                           The model modification included identifying
                                                Consistent with the information provided             request to determine the technical adequacy
                                                                                                                                                           the cables that could cause a DWS MOV
                                             in NRC Regulatory Issue Summary 2007-06,                of the Monticello IEPRA and FPRA models
                                                                                                                                                           MSO, identifying the plant locations (fire
                                             ‘‘Regulatory Guide 1.200 Implementation,’’              used for this exemption request. The licensee
                                                                                                                                                           zones) where these cables are located in the
                                             March 22, 2007 (ADAMS Accession No.                     stated that it evaluated its PRA against
                                                                                                                                                           plant, and linking these cables to specific fire
                                             ML070650428), the NRC staff uses RG 1.200,              Revision 2 of RG 1.200 and the ASME/ANS
                                                                                                                                                           scenarios modeled in the FPRA. The
                                             ‘‘An Approach for Determining the Technical             PRA standard. The licensee stated that it had
                                                                                                                                                           exemption request also described the revised
                                             Adequacy of Probabilistic Risk Assessment               resolved all peer review and focused-scope
                                                                                                                                                           fault tree logic that incorporated the new
                                             Results for Risk-Informed Activities,’’                 peer review finding-level F&Os and
                                                                                                     concluded that they had no impact on the              basic events.
                                             Revision 2 (ADAMS Accession No.
                                             ML090410014).                                           exemption request. Based on the information              Each of the two DWS trains includes two-
                                                The licensee stated that a full-scope peer           provided by the licensee, the NRC staff found         normally-closed in-series MOVs that could
                                             review was performed in April 2013, for the             that the licensee’s PRA represents the current        fail open due to a fire-induced MSO and
                                             IEPRA model (Revision 3.2). The peer review             as-installed and as-operated plant, and the           result in core damage. Each in-series pair of
                                             was performed using Nuclear Energy                      margin between the reported risk values and           DWS MOVs were added together in the fault
                                             Institute (NEI) 05–04, Revision 2, ‘‘Process            the guidance recommended values is                    tree and assigned a hot short probability. The
                                             for Performing Internal Events PRA Peer                 acceptable.                                           MOVs without a shorting switch have a hot
                                             Reviews Using the ASME/ANS [American                       The NRC staff concludes that the IEPRA is          short probability of 0.39, which is taken from
                                             Society of Mechanical Engineers/American                adequate and can be used to support the               Volume 2 of NUREG/CR–7150, ‘‘Joint
                                             Nuclear Society] PRA Standard’’ (ADAMS                  FPRA because the licensee demonstrated that           Assessment of Cable Damage and
                                             Accession No. ML083430462), as clarified by             the resolution of the F&Os did not affect the         Quantification of Effects from Fire (JACQUE–
                                             RG 1.200, Revision 2. The PRA standard                  technical adequacy of the licensee’s PRA              FIRE)’’ (ADAMS Accession No.
                                             provides supporting requirements for the                analysis submitted to support the licensee’s          ML14141A129). The MOVs with a shorting
                                             PRA against capability categories (CC) CC–I,            risk evaluation of the proposed exemption             switch are assumed to have a failure
                                             CC–II, or CC-Ill. The peer review resulted in           request.                                              probability of 1.0E–03, which is the assumed
                                             identification of PRA standard supporting                  The NRC staff concludes that the IEPRA is          failure probability of the shorting switch. In
                                             requirements that did not meet CC–II, or that           adequate and can be used to support the               enclosure 1, section 3.3.5 of the exemption
                                             were met and had related findings                       FPRA because the licensee demonstrated that           request, the licensee justified its use of the
                                             (Reference: Evaluation of Risk Significance of          the resolution of the F&Os support the                1.0E–03 failure probability by explaining that
                                             Permanent Integrated Leak Rate Testing                  technical adequacy of the licensee’s PRA              it was found acceptable by the NRC staff in
                                             Extension—ML16047A273). In Enclosure 2 of               analysis submitted for the licensee’s risk            the safety evaluations related to National Fire
                                             the exemption request, the licensee provided            evaluation of the proposed exemption                  Protection Association 805 license
                                             the peer review finding-level facts and                 request.                                              amendment requests by other licensees (see
                                             observations (F&Os) against the PRA                        The NRC staff also concludes that the              ADAMS Accession Nos. ML15212A796 and
                                             standard supporting requirements and the                FPRA is of sufficient technical adequacy and          ML16223A481). The licensee stated that the
                                             licensee’s resolution to each of the F&Os. The          that its quantitative results can be used to          control circuitry configuration for the
                                             licensee stated that all of the finding-level           demonstrate that the change in risk due to            shorting switch application at these plants is
                                             F&Os have been resolved and that none were              the lack of physical separation between the           substantially similar to that for the
                                             determined to affect the exemption request.             DWS division meets the acceptance                     Monticello DWS MOVs.
                                                The licensee stated that a full-scope peer           guidelines in RG 1.174 because the licensee              The NRC staff finds that the use of a hot
                                             review of the FPRA model (Revision 1a) was              demonstrated that the resolution of the               short probability of 0.39 is acceptable
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                                             performed in March 2015, using NEI 07–12,               relevant F&Os supports the determination              because it is the most bounding of the MOV
                                             Revision 1, ‘‘Fire Probabilistic Risk                   that the quantitative results are adequate and        hot short probabilities for grounded and
                                             Assessment (FPRA) Peer Review Process                   have no significant impact on the FPRA. For           ungrounded alternate current control circuits
                                             Guidelines,’’ June 2010 (ADAMS Accession                several F&Os, the NRC staff determined that           as described in Table 8–1 of NUREG/CR–
                                             No. ML102230070), and RG 1.200, Revision                the resolutions could impact the delta risk           7150, Volume 2. The NRC staff also finds that
                                             2. The peer review resulted in identification           results reported in the exemption request, but        the licensee’s use of the 1.0E–3 failure
                                             of PRA standard supporting requirements                 that their resolution is unlikely to change the       probability for the shorting switches is
                                             that did not meet CC–II, or CC–III for one              delta risk results reported by the licensee in        acceptable because the conditions that would



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                                             21314                         Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices

                                             have to occur to fail a shorting switch are             containment accident pressure and net                 meets the guidelines of RG 1.174, Revision 2,
                                             considered extremely unlikely.                          positive suction head may not be                      and that RI applications include performance
                                                The exemption request further explained              instantaneous with the MSO event.                     monitoring and feedback provisions.
                                             that the flow diversion created by the failure             Based on the licensee’s description of the
                                             of just one train of DWS MOVs (i.e., spurious           fault tree modeling of the MSO event in the           3.2.5    Integrated Decision-making
                                             opening of both in-series MOVs) was                     compliant and variant models, the NRC staff              As described in the previous sections, the
                                             assumed to result in damage of the RHR                  concludes that the hot short probability and          licensee’s exemption request and responses
                                             pumps because activation of the Drywell                 shorting switch failure probability are               to NRC staff RAIs provided an integrated
                                             Sprays would result in lowering the drywell             acceptable, and that the calculated change in         approach to evaluating the proposed change.
                                             pressure. This in turn could result in the              risk is likely conservative. The NRC staff            Specifically, the licensee’s assessment of the
                                             potential loss of containment accident                  further concludes that the licensee’s method          proposed change included:
                                             pressure, which leads to a loss of net positive         for calculating the change in risk is                    • Performing a traditional engineering
                                             suction head and which, in turn, would fail             acceptable.                                           analysis, including an evaluation that the
                                             the RHR pumps. All RHR pumps are                        PRA Results and Comparison with Risk                  proposed change is consistent with the DID
                                             potentially damaged because the RHR                     Guidelines                                            philosophy and the principle that sufficient
                                             removal cross-tie valves are normally kept                                                                    safety margins are maintained,
                                                                                                        In Enclosure 1, Section 3.3.4, of the
                                             open. The failure of the RHR pumps and loss                                                                      • Assessing the technical adequacy of the
                                             of net positive suction head result in failure          exemption request, the licensee reported the
                                                                                                                                                           PRA analysis, evaluating the risk impact of
                                             of all associated functions modeled in the              results of its risk impact assessment. The
                                                                                                                                                           the proposed change, and comparing the
                                             PRA (except DWS), specifically:                         licensee reported the calculated change in
                                                                                                                                                           results of the risk impact assessment to the
                                                • Shutdown cooling,                                  risk (variant model risk minus compliant
                                                                                                                                                              • RG 1.174, Revision 2, risk guidelines,
                                                • Low pressure coolant injection (LPCI),             model risk) for the proposed plant change to
                                                                                                                                                           and
                                                • Torus cooling (which fails high pressure           be 1.8E–08 per year for CDF and 1.4E–08 per
                                                                                                                                                              • Defining the implementation of the
                                             coolant injection and reactor coolant                   year for LERF, which are below the RG 1.174,
                                                                                                                                                           proposed change and of a monitoring
                                             isolation cooling when suction is from the              Revision 2, risk guidelines for a ‘‘very small’’
                                                                                                     change.                                               program to ensure that no unexpected
                                             torus),                                                                                                       adverse safety degradation occurs due to the
                                                • Core spray,                                           Based on its review of the risk impact
                                                                                                     assessment results, and the margin between            proposed change.
                                                • Alternate injection with condensate                                                                         Based on the NRC staff’s review of each of
                                             service water, the fire protection system, or           the reported risk values and the risk
                                                                                                     guidelines, the NRC staff concludes that the          these elements of the licensee’s exemption
                                             RHR service water, and                                                                                        request, the NRC staff concludes that the
                                                • Primary containment.                               increase in CDF and LERF from the proposed
                                                                                                     change is very small per the definition in RG         licensee’s evaluations are acceptable and in
                                                Because of the failure of RHR pumps, the                                                                   accordance with RG 1.174, Revision 2, and
                                                                                                     1.174, Revision 2. Also, while the licensee
                                             torus sprays would also fail, which is not                                                                    that the risk increase of the proposed change
                                                                                                     did not provide the total plant risk from all
                                             modeled in the PRA.                                                                                           meets the RG 1.174, Revision 2, risk
                                                                                                     hazards, the NRC staff finds this acceptable
                                                In Enclosure 1, Section 3.3.2, of the                                                                      guidelines for a ‘‘very small’’ change. Based
                                                                                                     and consistent with RG 1.174, Revision 2,
                                             exemption request, the licensee described                                                                     on this, the NRC staff concludes that the
                                                                                                     because there is no indication that the total
                                             how it developed the risk of the Appendix                                                                     licensee’s integrated evaluation of the
                                                                                                     CDF and LERF is considerably higher than
                                             R-compliant configuration. For this plant                                                                     proposed change is acceptable.
                                                                                                     1.0E–04 and 1.0E–05 per reactor year,
                                             configuration, the licensee revised the FPRA
                                                                                                     respectively.                                         3.3 Technical Evaluation Conclusion
                                             model to assume the DWS MOVs do not fail
                                             due to a fire-induced MSO (referred to as the           3.2.4 Implementation and Monitoring                      Based on its review of the information
                                             ‘‘compliant model’’). The licensee explained               In Enclosure 1, Section 3.4.5, of the              provided by the licensee, the NRC staff
                                             that its assumption is conservative because it          exemption request, the licensee described the         concludes that the licensee’s request to credit
                                             assumes a failure probability of zero for the           implementation and the monitoring program             a shorting switch does not create any new
                                             DWS MOVs due to a fire-induced MSO. The                 for the shorting switches and the DWS                 accident precursors because the plant’s
                                             NRC staff concludes that this assumption is             MOVs. The licensee explained that the                 operation remains the same in that fire
                                             conservative because, although unlikely,                shorting switches were installed in 2012 and          protection for structures, systems, and
                                             there is a greater-than-zero probability of a           that post-maintenance testing was conducted           components important to safe shutdown
                                             large enough fire that could defeat the                 to ensure that the switches were installed in         continues to be provided, and fire damage
                                             Appendix R protection requirements and                  accordance with the approved design and               continues to be limited so that one of the
                                             produce a MSO that would fail the MOVs.                 that the MOVs continued to operate as                 redundant trains is free of fire.
                                                In Enclosure 1, Section 3.3.4, of the                expected. The DWS MOVs will continue to                  The NRC staff also concludes that the
                                             exemption request, the license explained that           be regularly exercised in accordance with the         licensee’s evaluations are acceptable and in
                                             it calculated the change in risk for the                Monticello MOV program, which has been                accordance with RG 1.174, Revision 2, and
                                             proposed change by subtracting the                      accepted by the NRC staff, as providing an            that the risk increase of the proposed change
                                             calculated risk (CDF) and LERF) for the                 acceptable level of quality and safety, and are       meets the RG 1.174, Revision 2, risk
                                             compliant model from the calculated risk for            monitored under the Monticello Maintenance            guidelines for a ‘‘very small’’ change. Based
                                             the variant model.                                      Rule Program.                                         on this, the NRC staff concludes that the
                                                Furthermore, in Enclosure 1, Section 3.3.5,             In its November 20, 2017, letter, the              licensee’s integrated evaluation of the
                                             of the exemption request, the licensee                  licensee indicated that Monticello will               proposed change is acceptable.
                                             identified several conservatisms in the PRA             generate a preventive maintenance task for
                                             model that would overestimate the calculated                                                                  3.4 Authorized by Law
                                                                                                     the shorting switches to ensure acceptable
                                             change in risk. These conservatisms include:            resistance, and that this task will be                  The exemption would allow the licensee to
                                             the assumption that all postulated control              completed within 180 days of the date of the          rely on the installed shorting switch and
                                             room fires fail the shorting switches,                  exemption is issued. The licensee will                other fire protection DID features instead of
                                             assumption that the RHR pumps are running               introduce performance monitoring of the               providing separation in accordance with 10
                                             at the time of the MSO event, and the                   shorting switches into the Monticello,                CFR Part 50, Appendix R, Section III.G.2. As
                                             assumption that the loss of containment                 Appendix R, program, with the objective to            stated above, 10 CFR 50.12 allows the NRC
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                                             accident pressure and net positive suction              ensure the shorting switches provide a low            to grant exemptions from the requirements of
                                             head is instantaneous with the MSO event.               impedance path to ground in the event of a            10 CFR Part 50. The NRC staff has
                                             The NRC staff finds that these conservatisms            fire-induced hot short. The program will              determined, as described in Section 3.7
                                             make the model overestimate the calculated              include acceptance criteria, which if                 below, that special circumstances exist to
                                             change in risk because not all control room             exceeded, will cause the licensee to enter the        grant the proposed exemption and that
                                             fires fail the shorting switches, because the           issue into its corrective action program.             granting of the licensee’s proposed
                                             RHR pumps may not be running at the time                   The NRC staff concludes that the proposed          exemption will not result in a violation of the
                                             of the MSO event, and because loss of                   monitoring program for the shorting switches          Atomic Energy Act of 1954, as amended, or



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                                                                           Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices                                                  21315

                                             the Commission’s regulations. Therefore, the            of a monitoring program to ensure that no             detection capability because fire protection
                                             exemption is authorized by law.                         unexpected adverse safety degradation                 for structures, systems, and components
                                                                                                     occurs due to the proposed change.                    important to safe shutdown continues to be
                                             3.5 No Undue Risk to Public Health and                                                                        provided, and fire damage continues to be
                                                                                                     Therefore, the NRC staff concludes that since
                                             Safety                                                                                                        limited so that one of the redundant trains is
                                                                                                     the underlying purpose of 10 CFR 50,
                                               The underlying purposes of 10 CFR Part                Appendix R, Section III.G.2 (i.e., ensuring           free of fire damage and, therefore, would not
                                             50, Appendix R, is to provide reasonable                one of the redundant trains of Drywell Spray          alter the consequences of any accident
                                             assurance of fire protection safe shutdown              is free of fire damage), is achieved, the             previously evaluated.
                                             capability. As discussed in Sections 3.1 and            special circumstances required by 10 CFR                 Therefore, the exemption does not involve
                                             3.2 above, the NRC staff found that the                 50.12 for the granting of an exemption from           a significant increase in the probability or
                                             crediting of a shorting switch permitted by             10 CFR part 50, Appendix R, Section III.G.2,          consequences of an accident previously
                                             the proposed exemption does not create any              exist.                                                evaluated.
                                             new accident precursors or degrade detection                                                                     2. Does the requested exemption create the
                                             systems because the plant’s operation                   IV. Environmental Considerations.                     possibility of a new or different kind of
                                             remains the same and the installed shorting                The NRC staff determined that the issuance         accident from any accident previously
                                             switch provides an acceptable level of                  of the requested exemption meets the                  evaluated?
                                             protection as compared to that provided by              provisions of categorical exclusion 10 CFR               No. The underlying purposes of 10 CFR
                                             compliance with the regulation.                         51.22(c)(9) because the exemption is from a           Part 50, Appendix R, III.G.2 is to provide
                                               Because no new accident precursors are                requirement, with respect to the installation         reasonable assurance of fire protection safe
                                             created by the proposed exemption, which                or use of a facility component located within         shutdown capability. The exemptions’
                                             would allow the licensee to use, or take                the restricted area, as defined in 10 CFR part        crediting of a shorting switch and defense in
                                             credit using a risk-informed approach, for an           20 and the issuance of the exemption                  depth measures does not create any new
                                             installed shorting switch to ensure that one            involves: (i) No significant hazards                  accident precursors because the plant’s
                                             redundant train is free of fire damage, the             consideration; (ii) no significant change in          operation and fire detection capability
                                             probability of postulated accidents is not              the types or significant increase in the              remains the same.
                                             significantly increased, and reasonable                 amounts of any effluents that may be released            Therefore, the exemption does not create
                                             assurance of fire protection of safe shutdown           offsite; and (iii) no significant increase in         the possibility of a new or different kind of
                                             capability is maintained. Therefore, the NRC            individual or cumulative occupational                 accident from any accident previously
                                             staff concludes that the consequences of                radiation exposure. Therefore, in accordance          evaluated.
                                             postulated accidents are not significantly              with 10 CFR 51.22(b), no environmental                   3. Does the requested exemption involve a
                                             increased, and there is no undue risk to                impact statement or environmental                     significant reduction in a margin of safety?
                                             public health and safety.                               assessment need be prepared in connection                No. The installation of the shorting switch
                                             3.6 Consistent with Common Defense and                  with the NRC’s issuance of this exemption.            and reliance on defense in depth measures
                                             Security                                                The basis for the NRC staff’s determination           does not alter plant operation and does not
                                                                                                     is provided in the following evaluation of the        impact any safety margins because codes and
                                                The proposed exemption would allow the
                                                                                                     requirements in 10 CFR 51.22(c)(9)(i)–(iii).          standards or their alternatives approved by
                                             licensee to rely on the installed shorting
                                             switch instead of providing separation                                                                        the NRC are met, and the safety analysis
                                                                                                     Requirements in 10 CFR 51.22(c)(9)(i)                 acceptance criteria described in the licensing
                                             required by 10 CFR Part 50, Appendix R,
                                                                                                        The NRC staff evaluated whether the                basis are met.
                                             Section III.G.2. The NRC staff concludes that
                                                                                                     exemption involves no significant hazards                Therefore, the exemption does not involve
                                             this change to the plant design has no
                                                                                                     consideration by using the standards in 10            a significant reduction in a margin of safety.
                                             relation to security issues, therefore, the
                                                                                                     CFR 50.92(c), as presented below:                        Based on the evaluation above, the NRC
                                             common defense and security is not
                                                                                                        1. Does the requested exemption involve a          staff has determined that the proposed
                                             impacted by this exemption.
                                                                                                     significant increase in the probability or            exemption involves no significant hazards
                                             3.7 Special Circumstances                               consequences of an accident previously                consideration. Therefore, the requirements of
                                                Special circumstances, in accordance with            evaluated?                                            10 CFR 51.22(c)(9)(i) are met.
                                             10 CFR 50.12, are present whenever an                      No. The proposed exemption would allow
                                                                                                     the licensee to rely on the installed shorting        Requirements in 10 CFR 51.22(c)(9)(ii) and
                                             application of the regulation in the particular                                                               (iii)
                                             circumstances is not necessary to achieve the           switch instead of providing physical
                                             underlying purpose of the rule. The                     separation in accordance with 10 CFR Part                The proposed exemption would allow the
                                             underlying purpose of 10 CFR part 50,                   50, Appendix R, III.G.2 to protect structures,        Monticello Nuclear Generating Plant to
                                             Appendix R, Section III.G.2, is to provide              systems or components important to safe               maintain a hot shutdown train of Drywell
                                             reasonable assurance of fire protection of safe         shutdown of the plant in the event of a fire.         Spray free of fire damage by using a method
                                             shutdown capability by providing a means to             The licensee performed a risk impact                  that is different from one of the acceptable
                                             ensure that one of the redundant trains of              assessment for installation of the shorting           methods listed in 10 CFR Part 50, Appendix
                                             systems necessary to achieve and maintain               switches rather than physically separating            R, Section III.G.2. Specifically, In lieu of
                                             hot shutdown conditions is free of fire                 the control circuitry in accordance with the          meeting these protection requirements, the
                                             damage. The technical evaluation above                  10 CFR Part 50, Appendix R, III.G.2                   licensee has installed a shorting switch
                                             demonstrates that the shorting switch and               separation requirements. For the assessment,          modification on the control circuitry for one
                                             DID features provide reasonable assurance               the risk was evaluated by estimating the              motor-operated valve (MOV) in each division
                                             that the underlying purpose of the rule is met          change in fire risk between an Appendix R-            of the Drywell Spray system to reduce the
                                             because the licensee demonstrated that the              compliant configuration and the as-installed          risk impact of a fire-induced multiple
                                             installed shorting switch provides an                   and as-operated configuration of the shorting         spurious operation that fails both MOVs. In
                                             acceptable level of protection that is similar          switches. Based on its review of the                  addition, the licensee will rely on fire
                                             to that provided by compliance with the                 licensee’s exemption request, the NRC staff           protection DID features such as
                                             regulation. The licensee performed a                    concludes that the licensee’s evaluations are         administrative controls, plant design
                                             deterministic engineering analysis and                  acceptable and in accordance with                     features, fire protection inspections, installed
                                             demonstrated that the proposed change is                Regulatory Guide (RG) 1.174, ‘‘An Approach            fire detection and suppression systems, and
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                                             consistent with the DID philosophy and                  for Using Probabilistic Risk Assessment in            passive fire protection features. The
                                             maintains sufficient safety margins. The                Risk-Informed Decisions on Plant-Specific             exemption does not modify plant operation
                                             licensee also assessed the technical adequacy           Changes to the Licensing Basis,’’ Revision 2,         because fire protection for structures,
                                             of the PRA analysis and evaluated the risk              and that the risk increase of the proposed            systems, and components important to safe
                                             impact of the proposed change and compared              change meets the RG 1.174, Revision 2, risk           shutdown continues to be provided, and fire
                                             the results to the RG 1.174, Revision 2, risk           guidelines for a ‘‘very small’’ change.               damage continues to be limited so that one
                                             guidelines, and also defined the                           The installation of the shorting switch does       of the redundant trains of Drywell Spray is
                                             implementation of the proposed change and               not alter plant operation or affect fire              free of fire damage. Thus the exemption does



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                                             21316                             Federal Register / Vol. 83, No. 90 / Wednesday, May 9, 2018 / Notices

                                             not result in a significant change in the types               present an undue risk to the public health                    Generating Plant, to allow the use of a
                                             or amount of effluents that may be released                   and safety, and is consistent with the                        shorting switch to ensure that one redundant
                                             and does not result in any additional                         common defense and security. Also, special                    train of Drywell Spray is free of fire damage
                                             occupational exposure. Therefore, the                         circumstances are present in that application                 to achieve and maintain hot shutdown
                                             requirements of 10 CFR51.22(c)(9)(ii) and (iii)               of the regulation is not necessary to achieve                 conditions in the event of a fire.
                                             are met.                                                      the underlying purpose of the rule.
                                                                                                           Therefore, the Commission hereby grants                       VI. Availability of Documents.
                                             V. Conclusions.                                               Northern States Power Company, doing
                                               Accordingly, the Commission has                             business as Xcel Energy, an exemption from                      The documents identified in the following
                                             determined that, pursuant to 10 CFR 50.12,                    the requirements of 10 CFR 50, Appendix R,                    table are available in ADAMS.
                                             the exemption is authorized by law, will not                  Section III.G.2, for Monticello Nuclear

                                                                                                                                                                                                                   ADAMS
                                                                                                                          Document                                                                                Accession
                                                                                                                                                                                                                     No.

                                             Risk-Informed Request for Exemption from 10 CFR 50, Appendix R, III.G.2 Requirements for Multiple Spurious Operations of                                           ML17096A599
                                               Drywell Spray Motor-Operated Valves.
                                             Request for additional information RE: Monticello Request for Exemption from Appendix R Requirements (CAC NO. MF9586;                                              ML17293A091
                                               EPID L–2017–LLE–00012).
                                             Response to Request for Additional Information regarding Risk-Informed Request for Exemption from 10 CFR 50, Appendix                                              ML17324B361
                                               R, III.G.2 Requirements for Multiple Spurious Operations of Drywell Spray Motor-Operated Valves (CAC No. MF9586).
                                             Monticello Nuclear Generating Plant Triennial Fire Protection Inspection Report 05000263/2014008 ..........................................                        ML14119A216
                                             Letter of Intent to Transition to 10 CFR 50.48(c)—National Fire Protection Association Standard NFPA 805. ‘‘Performance-                                           ML053460342
                                               based Standards for Fire Protection for Light Water Reactor Electric Generating Plants.’’ 2001 Edition.
                                             Notice of Withdrawal of Letter of Intent to Transition to 10 CFR 50.48(c)’’ ....................................................................................   ML102000433
                                             NRC Regulatory Issue Summary 2007–06 Regulatory Guide 1.200 Implementation .....................................................................                   ML070650428
                                             NEI 05–04, Rev. 2 Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard ...............                                          ML083430462
                                             NEI 07–12 [REV 1] Fire Probabilistic Risk Assessment (FPRA) Peer Review Process Guidelines ...............................................                         ML102230070
                                             NUREG/CR–7150, Vol. 2 Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE–FIRE) ...........                                           ML14141A129
                                             Browns Ferry Nuclear Plant, Units 1, 2, And 3—Issuance of Amendments Regarding Transition to a Risk-Informed, Perform-                                             ML15212A796
                                               ance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (CAC NOS. MF1185, MF1186, AND MF1187).
                                             Arkansas Nuclear One, Unit 1—Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire                                                 ML16223A481
                                               Protection Program in Accordance with 10 CFR 50.48(c) (CAC NO. MF3419).
                                             Regulatory Guide 1.189 ‘‘Fire Protection for Nuclear Power Plants,’’ Revision 2 ...........................................................................        ML092580550
                                             Regulatory Guide 1.174 ‘‘An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific                                          ML100910006
                                               Changes to the Licensing Basis,’’ Revision 2.
                                             Regulatory Guide 1.200 ‘‘An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for                                           ML090410014
                                               Risk-Informed Activities,’’ Revision 2.
                                             Monticello Nuclear Generating Station: Evaluation of Risk Significance of Permanent Integrated Leak Rate Test Extension .....                                      ML16047A273



                                               Dated at Rockville, Maryland, this 1st day                  notice is hereby given that on May 2,                         Cboe Exchange, Inc. Rules
                                             of May 2018.                                                  2018, Cboe Exchange, Inc. (the                                *        *       *       *       *
                                               For the Nuclear Regulatory Commission.                      ‘‘Exchange’’ or ‘‘Cboe Options’’) filed                       Rule 24.9. Terms of Index Option Contracts
                                               Gregory F. Suber,                                           with the Securities and Exchange
                                                                                                                                                                           (a)–(d) (No change).
                                             Acting Director, Division of Operating                        Commission (the ‘‘Commission’’) the                             (e) Nonstandard Expirations Pilot Program
                                             Reactor Licensing, Office of Nuclear Reactor                  proposed rule change as described in                            (1)–(2) (No change).
                                             Regulation.                                                   Items I and II below, which Items have                          (3) Duration of Nonstandard Expirations
                                             [FR Doc. 2018–09801 Filed 5–8–18; 8:45 am]                    been prepared by the Exchange. The                            Pilot Program. The Nonstandard Expirations
                                             BILLING CODE 7590–01–P                                        Exchange filed the proposal as a ‘‘non-                       Pilot Program shall be through [May
                                                                                                           controversial’’ proposed rule change                          3]November 5, 2018.
                                                                                                           pursuant to Section 19(b)(3)(A)(iii) of                         (4) (No change).
                                                                                                           the Act 3 and Rule 19b–4(f)(6)                                  . . . Interpretations and Policies:
                                             SECURITIES AND EXCHANGE                                                                                                       .01–.14 (No change).
                                                                                                           thereunder.4 The Commission is
                                             COMMISSION                                                                                                                  *        *       *       *       *
                                                                                                           publishing this notice to solicit
                                             [Release No. 34–83165; File No. SR–CBOE–                      comments on the proposed rule change                             The text of the proposed rule change
                                             2018–038]                                                     from interested persons.                                      is also available on the Exchange’s
                                                                                                           I. Self-Regulatory Organization’s                             website (http://www.cboe.com/
                                             Self-Regulatory Organizations; Cboe
                                                                                                           Statement of the Terms of Substance of                        AboutCBOE/
                                             Exchange, Inc.; Notice of Filing and
                                                                                                           the Proposed Rule Change                                      CBOELegalRegulatoryHome.aspx), at
                                             Immediate Effectiveness of a Proposed
                                                                                                                                                                         the Exchange’s Office of the Secretary,
                                             Rule Change To Renew the
                                                                                                              The Exchange proposes to renew an                          and at the Commission’s Public
                                             Nonstandard Expirations Pilot
                                                                                                           existing pilot program until November                         Reference Room.
                                             Program
                                                                                                           5, 2018.
                                                                                                                                                                         II. Self-Regulatory Organization’s
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                                             May 3, 2018.
                                                                                                           (additions are italicized; deletions are                      Statement of the Purpose of, and
                                                Pursuant to Section 19(b)(1) of the                        [bracketed])                                                  Statutory Basis for, the Proposed Rule
                                             Securities Exchange Act of 1934 (the                                                                                        Change
                                             ‘‘Act’’),1 and Rule 19b–4 thereunder,2                        *          *      *       *      *
                                                                                                                                                                           In its filing with the Commission, the
                                               1 15 U.S.C. 78s(b)(1).                                          3 15 U.S.C. 78s(b)(3)(A)(iii).                            Exchange included statements
                                               2 17 CFR 240.19b–4.                                             4 17 CFR 240.19b–4(f)(6).                                 concerning the purpose of and basis for


                                        VerDate Sep<11>2014     17:39 May 08, 2018     Jkt 244001   PO 00000      Frm 00060      Fmt 4703   Sfmt 4703   E:\FR\FM\09MYN1.SGM           09MYN1



Document Created: 2018-05-09 03:18:09
Document Modified: 2018-05-09 03:18:09
CategoryRegulatory Information
CollectionFederal Register
sudoc ClassAE 2.7:
GS 4.107:
AE 2.106:
PublisherOffice of the Federal Register, National Archives and Records Administration
SectionNotices
ActionExemption; issuance.
DatesThe exemption was issued on May 1, 2018.
ContactRobert F. Kuntz, Office or Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; telephone: 301-415-3733, email: [email protected]
FR Citation83 FR 21310 

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