ML17228A849

Forwards Responses to NRC 940728 RAI Re Revs 25 & 26 of Plant Radiological Emergency Plan

ML17228A849
Person / Time
Site:	Saint Lucie
Issue date:	09/02/1994
From:	Sager D FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-94-222, NUDOCS 9409130218
Download: ML17228A849 (8)

Text

P R.jt: C3 R.XMY' (ACCELERATED RIDS PRCCESSINC}g l

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9409130218 DOC.DATE: 94/09/02 NOTARIZED: NO DOCKET N FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50-389 St. Lucie Plant, Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION SAGER,D.A. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards responses to NRC 940728 RAI re Revs 25 & 26 of plant radiological emergency plan.

DISTRIBUTION CODE: A045D COPIES RECEIVED':LTR ENCL SIZE:

TITLE: OR Submittal: Emergency Preparedness Plans, Imp ement'g Pr cedures, C NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 NORRIS,J 1 1 INTERNAL: NRR/DRSS/PEPB 1 1 NUDOCS-ABSTRACT 1 1 REG IBE.- Ol 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 NOTE TO ALL'RIDS'ECIPIENTS:

PLEASE HELP US TO REDUCE WASTEr CONTACTTHE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 7

P.O. Bex 120, Ft. Pierce, FL 34954-0128 September 2, 1994 10 CFR ti50.47(b)

PIPll 10 CFR 550.54(q) 10 CFR Part 50 Appendix E L-94-222 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Revi ions 25 and 26 Radiolo i al Emer en Pl n for S . Lucie Plan By letter dated July 28, 1994 (William E. Cline to J. H. Goldberg), the NRC informed Florida Power 8c Light Company (FPL) that certain changes to the St. Lucie Plant Radiological Emergency Plan appear to the NRC staff to be inconsistent with the emergency planning standards of 10 CFR 550.47(b) and 10 CFR Part 50 Appendix E.

In the July 28, 1994, letter, the NRC requested additional information in order to make-a determination as to whether the effectiveness of the St. Lucie Plant Radiological Emergency Plan is decreased, The purpose of this letter is to respond to the NRC's request for additional information.

Attached are responses to the request for additional information regarding Revisions 25 and 26 of the St. Lucie Plant Radiological Emergency Plan. After consideration of the NRC's July 28, 1994, request for information, FPL has reconfirmed its earlier determination that the changes made in Revisions 25 and 26 of the St. Lucie Plant Radiological Emergency Plan do not decrease the effectiveness of the Emergency Plan.

If you should have any additional questions regarding the information provided in this response, please contact us.

Sincerely, D. A. S er Vice P e ident St. Lucie Plant DAS/JWH/kw DAS/PSL 01199-94 Attachment cc: Stewart Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St. Lucie Plant William E. Cline, Chief, Radiological Protection and Emergency Preparedness Branch, Division of Radiation Safety and Safeguards, Region II, USNRC g,-" 'lP c,'g 9P09130218 940902 n PddVongcompany "

PDR ADOCK 05000>>5 F PDR

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Response to NRC Request for Additional Information Regarding Revisions 25 and 26 of the St. Lucie Plant Radiological Emergency Plan

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1. Sec ion 5.3.1 On-Si e Radia ion Pro ec ion Pro ram Revision 25 This section was modified in an effort to incorporate the revised Federal guidance promulgated in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." However, the licensee retained a restriction to the basic 5-rem dose limit for emergency workers which states, "Limits should include current annual (sic)." This restriction means that an emergency worker's 5-rem limit during an emergency response effort would be reduced by an amount equal to that individual's current annual occupational dose. According to 10 CFR 50.47(b)(11), the licensee's Radiological Emergency Plan must include means for controlling radiological exposures to emergency workers using "exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides,"

Current EPA guidance applicable to this area is contained in Section 2.5 of EPA 400-R-92-001, and does not endorse the above restriction added by the licensee. The licensee's Plan therefore appears to be inconsistent with the emergency planning standard of 10 CFR 50.47(b)(11).

FPL R n FPL approved Revision 25 to the St. Lucie Plant Radiological Emergency Plan on December 30, 1993. FPL has determined that the changes to the St. Lucie Plant Radiological Emergency Plan resulting from Revision 25 do not decrease the effectiveness of the St. Lucie Plant Radiological Emergency Plan. FPL's rationale for this determination is provided below.

At the time of implementation of EPA 400-R-92-001, FPL consciously elected to continue the practice of incorporating current annual exposure towards the 5-rem emergency worker exposure limit. FPL is of the position that other procedural controls that permit dose limit extensions are in place such that at no time would this Radiological Emergency Plan provision unnecessarily restrict emergency response efforts. Procedural guidance is available which promptly allows for extending the dose limit of an emergency worker in the event of a radiological emergency at St. Lucie Plant without the need to account for current annual exposure already incurred.

FPL has concluded that the emergency worker exposure guidelines which were implemented by Revision 25 to the St. Lucie Plant Radiological Emergency Plan do not decrease the effectiveness of the St. Lucie Plant Radiological Emergency Plan since

4 no change was made. Nonetheless, based on clarification provided in an NRC

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document on Questions and Answers on 10 CFR Part 20 implementation (dated May 26, 1994), FPL acknowledges that the removal of annual dose consideration may, in fact, augment the St. Lucie Plant Radiological Emergency Plan's effectiveness regarding emergency worker exposure. Accordingly, FPL intends to incorporate this guidance regarding emergency worker emergency exposure in the next revision of the St. Lucie Plant Radiological Emergency Plan.

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2. Table 3-1 Sec ion 1.2 Section 5 et al. Revision 26 In 10 CFR 20.1003, the terms "total effective dose equivalent" (TEDE) and "committed dose equivalent" (CDE) are defined as standard radiation protection terminology. The licensee's Radiological Emergency Plan defines and uses "total whole body dose" and "thyroid dose", respectively, as substitute terms for "TEDE" and "thyroid CDE" to ostensibly minimize confusion for local officials when considering the need for protective actions for the public based on offsite dose projections provided by the licensee. This usage is inconsistent with regulatory terminology as defined and used in 10 CFR Part 20 and as used in EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." During exercises or actual emergencies, the licensee's use of the subject nonstandard terminology could lead to substantive communications problems when interfacing with the NRC and other Federal agencies. The desirability of using standard terminology whenever possible in emergency response communications has long been recognized, and is reflected most conspicuously in the requirement that all nuclear power plant licensees must use standard nomenclature for the four emergency classes associated with their classification scheme.

FPL Res ons FPL approved Revision 26 to the St. Lucie Plant Radiological Emergency Plan on March 28, 1994. FPL has determined that the changes to the St. Lucie Plant Radiological Emergency Plan resulting from Revision 26 do not decrease the effectiveness of the St. Lucie Plant Radiological Emergency Plan. FPL's rationale for this determination is provided below.

The decision to use Total Whole Body Dose in lieu of Total Effective Dose Equivalent (TEDE) was a conscious decision between FPL and the agencies assigned primary responsibility for public health and safety (State of Florida and risk counties). FPL and the state and local governments felt the use of the term "total whole body dose" to describe the revised 10 CFR Part 20 and EPA 400-R-92-001 concept of TEDE was preferable to ensure clear and consistent lines of communications are maintained

4 between FPL, the state and local governments, and Federal government agencies. The use of this terminology is considered the most effective means for developing and issuing protective actions, as well as communicating the terminology to decision makers and to the media. As a result, FPL, the State of Florida and local governments, determined that this change in terminology did not decrease the effectiveness of emergency communications.

Notwithstanding the above, FPL recognizes the desirability of using standard terminology in emergency response communications with Federal agencies. FPL is sensitive to the NRC's concerns regarding the use of standard terminology and considers that the St. Lucie Plant Radiological Emergency Plan contains sufficient information to "convert" from one terminology to the other. FPL itself is extremely familiar with the application of both terminologies and is able to communicate with the NRC and other Federal agencies using the "standard terminology."

FPL has discussed the NRC's concern with the use of the "nonstandard terminology" with the State of Florida, Florida Power Corporation, and the involved local governments during the State of Florida Radiological Emergency Preparedness Task Force meeting on August 10, 1994 in Marathon, Florida. The Federal Emergency Management Agency (FEMA) and the NRC were represented at that meeting.

Consensus was achieved on the terminology to be used to describe the revised dose concept. "Total Dose (TEDE)" and "Thyroid Dose (CDE)" will be used in lieu of "Total Whole Body Dose" and "Thyroid Dose." Involved parties concluded that this would minimize the potential for confusion between the state, counties, utilities, Federal agencies, and the media.

FPL intends to include the above described change in the next revision of the St. Lucie Plant Radiological Emergency Plan.