ML17347A401

Provides Info Necessary for NRC & IAEA to Arrange for Inspectors to Arrive at Facility in Time to Observe Breach of Containment or Surveillance & to Assure Integrity of Inventory.Notification of Events Required 24 H in Advance

ML17347A401
Person / Time
Site:	Turkey Point
Issue date:	04/08/1987
From:	Novak T Office of Nuclear Reactor Regulation
To:	Woody C FLORIDA POWER & LIGHT CO.
References
NUDOCS 8704170016
Download: ML17347A401 (8)

Text

ApL3.1 8 I 1987 Docket Nos.".50-250/251 Mr. C. 0.

Woody, Group Vice President Nuclear Energy Department Florida Power and Light Company Post Office Box 14000 Juno Beach, Florida 33408

Dear Mr. Woody:

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Grey Fi.le During the past several

weeks, our staffs have been working closely to resolve some operational difficulties that have impacted the application of inter'national safeguards at your facility.

Such events at licensed facilities that are under International Atomic Energy Agency

( IAEA) safeguards indicate that the basic requirements and the consequences associated with a breach of the IAEA safeguards system may not be fully understood by all levels of facility management.

As you know, the US/IAEA Safeguards Agreement or treaty has been in force since July 31, 1980.

The commitments by the U.S. in this treaty, which carries the force of law, are defined in a series of documents including Part 75 of Title 10 of the Code of Federal Regulations, the treaty itself, the subsidiary arrange'ments to the treaty, and site-specific Facility Attachments.

These Facility Attachments explain in detail how international safeguards will be applied at an IAEA selected facility such as yours.

Some of the specific requirements that are critical in complying with the US/IAEA Agreement and also in meeting the IAEA safeguards criteria are summarized below for your future reference.

a.

Any loss of or interference with IAEA surveillance or containment equipment, e.g.,

broken seals, camera interruption, or loss of surveillance lighting, will require a reinventory of the area where the event occurred, whether or not the NRC or the IAEA were notified in advance, unless an IAEA inspector i's present at the time of the event.

b.

Notification requirements (facility to NRC) are specified in Facility Attachments for events such as operational program changes, inventory taking, and refueling.

In addition, notifications are required in advance, except under emergency situations, for any activity that will interfere with the application of international safeguards, e.g., breaking of IAEA seals, inter-fering with surveillance equipment, or extinguishing of lights required for surveillance.

The purpose of these notifications is to provide the information necessary for the NRC and,the IAEA to arrange for inspectors to arrive at the facility in time to observe the breach of the containment or surveillance and to assure the integrity of the inventory.

The minimum time needed for an IAEA inspector to travel from the field office in Toronto,

Canada, to a U.S. facility is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

More time is needed if an inspector has to travel from"'AEA headquarters in Vienna, Austria.

Therefore, notification for these events is required at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance.

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The facility point of contact for the NRC and the IAEA is specified in the Design Information guestionnaire and the Facility Attachment.

The points of contact within NRC were provided to your utility in NRC correspondence dated tray 27, 1986.

All operational

matters, communications, and decisions affecting IAEA safeguards should be coordinated through these specified contacts and documented in writing.

d.

Any activity that would interfere with the application of international safeguards but does not pose an immediate threat to the health and safety of the public or to the reactor operations staff must be scheduled to provide the IAEA a reasonable opportunity to arrange for an inspector to travel to'the facility in time to witness the activity.

Failure to satisfy the IAEA safeguards criteria by a selected NRC facility results in a failure of the U.S. to comply with its international treaty obligations and can have a serious impact on U.S. foreign nuclear policy, the U.S. nuclear industry, and how the U.S. support to non-proliferation is perceived.

From an international perspective, such a failure could preclude the IAEA from concluding unambiguously that the U.S.

was 'not diverting nuclear material from peaceful purposes into its nuclear weapons program.

Obviously it is in the interest of all parties to assure that the U.S. is in full compliance with its treaty obligations.

If you need further information or clarification, please call me (301-492-7980).

Sincerely,

/s/

Thomas N. Novak, Acting Director Division of PMR Licensing-A Office of Nuclear Reactor Regulation e~.E

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The facility point of contact for the NRC and the IAEA i specified in the Design Information guestionnaire and the Facility Attachme The points of contact within NRC were provided to your utility in NRC c respondence dated Nay 16, 1986. 'll operational

matters, communications, nd decisions affecting IAEA safeguards should be coordinated through these sp ified contacts and documented in w iting.

d.

Any activity at would interfere with the appl'cation of international safeguards but doe not pose an immediate threat the health and safety of the public or to the eactor operations staff mu be scheduled to provide the IAEA a reasonable oppo tunity to arrange for an inspector to travel to the facility in time to wit ss the activity.

Failure to satisfy the IAE safeguards cri eria by a selected NRC facility results in a failure of the

.S. to comp with its international treaty obligations and can have a se

'ous imp t on U.S. foreign nuclear policy, the U.S. nuclear industry, and w tI U.S. support to non-proliferation is perceived.

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spective, such a failure could preclude the IAEA from concluding unambigu

'ly that the U.S.

was not diverting nuclear material from peaceful purposes

'nto 'ts nuclear weapons program.

Obviously it is in the interest of all part'es to as re that the U.S. is in full compliance with its treaty obligations.

If you need further infor ation or clarificat' please call me (301-492-7980).

Sincere Thomas M. Novak, Acting Director Division of Pt'R Licensing-A, Office of Nuclear Reactor Regulation NAYiE:

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Mr. C. 0. Moody Florida Power and Light Company Turkey Point Plant CC:

Harold F. Reis, Esquire Newman and Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 Mr. Jack Shreve Office of the Public Counsel Room 4, Holland Building Tallahassee, Florida 32304 Norman A. Coll, Esquire

Steel, Hector and Davis 4000 Southeast Financial Center Miami, Florida 33131-2398 Mr. C.

M. Methy, Yice President "Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102 Mr. M. R. Stierheim County Manager of Metropolitan Dade County Miami, Florida 33130 Resident Inspector U.S. Nuclear Regulatory Comission Turkey Point Nuclear Generating Station Post Office Box 57-1185 Miami, Florida 33257-1185 Mr. Allan Schubert, Manager Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Blvd.

Tallahassee, Florida 32301 Intergovernmental Coordination and Review Office of Planning 8 Budget Executive Office of the Governor The Capitol Building Tallahassee, Florida 32301 Administrator Department of Environmental Regulation Power Plant Siting Section State of Florida 2600 Blair Stone Road Tallahassee, Florida 32301 Regional Administrator, Region IT U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street Atlanta, Georgia 30323 Martin H. Hodder, Esquire 1131 NE, 86th Street Miami, Florida 33138 Joette Lorion 7269 SM, 54 Avenue Miami, Florida 33143 Mr. Chris J. Baker, Plant Manager Turkey Point Nuclear Plant Florida Power and Light Company P.O.

Box 029100 Miami, Florida 33102 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304

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