ML17229A081

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Safety Evaluation Accepting Proposed Changes to Table 3-1 of Plant Emergency Plan
ML17229A081
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 10/17/1996
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML17229A077 List:
References
NUDOCS 9610220344
Download: ML17229A081 (4)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20M5OOM T

V UAT N BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELAT D TO AN EMERGENCY ACTION LEVEL REVISION F ORIDA POWER AND LIGHT COMPANY ET AL.

ST.

LUCI PLANT UNIT NOS.

1 AND 2 DOCKET NOS. 50-335 AND 50-389

1. 0 INTRODUCTION By letter dated July 25, 1996, Florida Power and Light 'Company (FPL) proposed a revision to Table 3-1 of their. Emergency Plan.

They requested

approval, prior to implementation, of a change to an Emergency Action Level (EAL) regarding reactor coolant system (RCS) leakage.

The proposed EAL change revises the declaration threshold for an Unusual Event involving RCS leakage.

2.0 BACKGROUND

The proposed EAL change was reviewed against the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR 50.

Section 50.47(b)(4) specifies that onsite emergency plans must meet the following standard:

"A standard emergency classification and action level

scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee...."

Section IV.C. of Appendix E to 10 CFR 50 specifies that, "Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be

'described....

The emergency classes defined shall include:

(1) notification of unusual

events, (2) alert, (3) site area emergency, and (4) general emergency."

The current EAL followed the general guidelines for EALs set forth in Appendix 1 of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency

Response

Plans and Preparedness in Support of Nuclear Power Plants" (November 1980).

The proposed revision incorporates the enhancements and clarifications to the EALs based on the guidelines for EALs set forth in NUMARC/NESP-007, Revision 2,

"Methodology for Development of Emergency Action Levels" (January 1992).

The NRC endor sed the use of either NUREG-0654 or NUMARC/NESP-007 in Regulatory Guide 1. 101, "Emergency Planning and Preparedness for Nuclear Power Reactors,"

Revision 3, August 1992.

Regulatory Guide

1. 101 provides acceptable methods by which licensees may meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR 50.

In Emergency Preparedness Position (EPPOS)

Number 1, "Emergency Preparedness Position on Acceptable Deviations from Appendix 1 of NUREG-0654 Based Upon the Staff's Regulatory Analysis of NUMARC/NESP-007" (June 1, 1995), the NRC staff recognized that NUREG-0654-based EALs could be enhanced and clarified by application of the technical bases for NUMARC/NESP-007-based EALs.

The staff relied upon the guidance in these documents as the basis for its review of the St.

Lucie proposed EAL revision.

3. 0 EVALUATION The licensee followed the guidance and logic presented in NUMARC/NESP-007 for determining the level of leakage to declare an Notification of an Unusual Event (NOUE).

The licensee revised the threshold for an NOUE and EAL based upon RCS leakage from two values:

(1) greater than 1

gpm for unidentified leakage and (2) greater than 10 gpm for identified leakage; to one threshold value:

greater than 10 gpm for all leakage.

The new proposed threshold leakage value is higher for unidenti'fied sources than the current EAL'nd is the same as leaks from identified sources.

The value for identified leaks are more conservative than the value shown in NUMARC guidance.

However, the licensee indicated that the selected value and the establishment of a single threshold value makes the declaration of an NOUE quicket and easier.

The determination of the quantity and the source of the leak will be simpler and more timely under the proposed EAL.

The licensee will not have to confirm the leakage levels through mass inventory balances and the licensee will not have to spend time to differentiate between identified and unidentified leaks.

Although Regulatory Guide 1. 101 admonishes against the mixing of the emergency classification guidance in NUMARC/NESP-007 with that in Appendix 1 to NUREG-0654, it is recognized that licensees who continue to utilize the example initiating conditions in Appendix 1 to NUREG-0654 as the basis for their classification scheme could benefit from the guidance in NUMARC/NESP-007.

To that end, licensees could utilize the technical bases under the example EALs in NUMARC/NESP-007 to enhance and clarify some of their site-specific EALs developed from NUREG-0654.

The chosen classification

scheme, whether based on Appendix 1 to NUREG-0654 or NUMARC/NESP-007, must remain internally consistent.

The staff found the proposed revisions and associated justification, provided by the licensee, to be acceptable.

The'roposed EAL revision for the St.

Lucie Plant, is consistent with the guidance provided by NUREG-0654 and allowable deviations, as discussed in EPPOS 1 in accordance with the technical bases for EALs in NUMARC/NESP-007.

4.0

~COMCLUSIO As a result of our. review, we have concluded that the proposed EAL meets the requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 for emergency classification and action level schemes.

'However, in addition to NRC approval of EAL changes,Section IV.B of Appendix E to 10 CFR Part 50 requires agreement by State and local government authorities to changes to the plant'.s EALs.

Therefore, the licensee should obtain such agreement prior to implementation of the proposed EAL.

Principal Contributor:

L. Cohen Dated:

.October 17, 1996

Hr. T. F. Plunkett Florida Power and Light Company ST.

LUCIE PLANT CC:

Jack Shreve, Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, Florida 32399-1400 Senior Resident Inspector St.

Lucie Plant U.S. Nuclear Regulatory Commission 7585 S.

Hwy AIA Jensen

Beach, Florida 34957 Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 J.

R.

Newman

Morgan, Lewis

& Bockius 1800 M Street, NW.

Washington, DC 20036 John T. Butler, Esquire

Steel, Hector and Davis 4000 Southeast Financial Center
Miami, Fl orida 33131-2398 Mr. Thomas R.L. Kindred County Administrator St.

Lucie County 2300 Virginia Avenue Fort Pierce, Florida 34982 Mr. Charles Brirtkman, Manager Washington Nuclear Operations ABB Combustion Engineering, Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32399-0700 Regional Administrator Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, NW. Suite 2900 Atlanta, Georgia 30323 H. N. Paduano, Manager Licensing

& Special Programs Florida Power and Light Company P.O.

Box 14000 Juno

Beach, Florida 3340&-0420 J.

A. Stall, Site Vice President..

St. Lucie Nuclear Plant P. 0.

Box 128 Ft. Pierce, Florida 34954-0128 J. Scarola Plant General Manager St.

Lucie Nuclear Plant P.O.

Box 128 Ft. Pierce, Florida 34954-0128 Hr. Kerry Landis U.S. Nuclear Regulatory Commission 101 Harietta Street, N.W. Suite 2900 Atlanta, Georgia 30323-0199 E. J.

Weinkam Licensing Manager St.

Lucie Nuclear Plant P.O.

Box 128.

Fort Pierce, Florida 34954-0128

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