ML17352A743
| ML17352A743 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/28/1994 |
| From: | Cline W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Goldberg J Florida Power & Light Co |
| References | |
| NUDOCS 9408090035 | |
| Download: ML17352A743 (6) | |
Text
Docket Nos. 50-250, 50-251 License Nos.
DPR-31, DPR-41 Florida Power and Light Company ATTN:
Mr. J.
H. Goldberg President
- Nuclear Division P. 0.
Box 14000 Juno
- Beach, FL 33408-0420 Gentlemen:
SUBJECT:
REVISIONS 26 AND 27 TO RADIOLOGICAL EMERGENCY PLAN FOR TURKEY POINT PLANT, DOCKET NOS. 50-250 AND 50-251 Based on our review of the subject submittals, we have determined that certain changes therein appear to be inconsistent with the emergency planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
Detailed telephonic discussions of these matters have been conducted between D. Mothena of your staff and K. Barr and J.
Kreh of my staff during July 1994.
The referenced inconsistencies are delineated in the Enclosure.
For each of the issues discussed in the Enclosure, additional information is needed in order that we may make an equitable determination as to whether the effectiveness of the Radiological Emergency Plan is decreased.
We are therefore requesting that you provide to us, within 45 days of the date of this letter, detailed justification as to why the changes in question do not decrease the effectiveness of your Plan despite their apparent inconsistencies with NRC regulations and regulatory guidance.
Please be reminded that 10 CFR 50.54(q) requires that proposed changes which decrease the effectiveness of your Radiological Emergency Plan shall not be implemented without application to and approval by the Commission.
- However, changes may be made without Commission approval if such changes do not decrease the effectiveness of the Plan, and the Plan, as changed, continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. If a change is made without approval, you should furnish copies in accordance with 10 CFR 50.54(q).
Also, any changes to the Emergency Plan Implementing Procedures should be made in accordance with the requirements of Appendix E to 10 CFR Part 50.
C.c. '""Pg 9408090035 94072B PDR ADOCK 05000250 F
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Florida Power and Light Company 2
Should you have any questions regarding this letter, please contact Hr. Kenneth P. Barr of our staff on 404-331-0335.
Sincerely,,
William E. Cli e, Chief Radiolo ical Protection and g
Emergency Preparedness Branch Division of Radiation Safety and Safeguards
Enclosure:
"Apparent Inconsistencies in Revisions 26 and 27 of Radiological Emergency Plan for Turkey Point Plant" cc w/encl:
H. N. Paduano, Manager Licensing 8 Special Programs Florida Power and Light Company P. 0.
Box 14000 Juno
- Beach, FL 33408-0420 L.
W. Pearce Plant General Manager Turkey Point Nuclear Plant P. 0.
Box 029100
- Miami, FL 33102 T. F. Plunkett Site Vice President Turkey Point Nuclear Plant P. 0.
Box 029100
- Miami, FL 33102 T. V. Abbatiello Site guality Manager Turkey Point Nuclear Plant P. 0.
Box 029100
- Miami, FL 33102 cc w/encl:
(Cont'd on page 3)
Florida Power and Light Company (cc w/encl:
cont'd)
E. J.
Weinkam Licensing Manager Turkey Point Nuclear Plant P. 0.
Box 4332 Miami, FL 33032-4332 Harold F. Reis, Esq.
Newman and Holtzinger, P.C.
1615 L Street, NW Washington, D.
C.
20036 John T. Butler, Esq.
- Steel, Hector and Davis 4000 Southeast Financial Center
- Miami, FL 33131-2398 Attorney General Department of Legal Affairs The Capitol Tallahassee, FL 32304 Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee, FL 32399-0700 Jack Shreve Public Counsel Office of the Public Counsel c/o The Florida Legislature 111 West Madison Avenue, Room 812 Tallahassee, FL 32399-1400 Joaquin Avino County Manager of Metropolitan Dade County 111 NW 1st Street, 29th Floor Miami, FL 33128 Joe Myers, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 bcc w/encl:
(See page 4)
Florida Power and Light Company bcc w/encl:
R. Croteau, NRR K. Landis, RII Document Control Desk Thomas P. Johnson Senior Resident Inspector U.S. Nuclear Regulatory Commission P. 0.
Box 1448 Homestead, FL 33090 SEND FC RI I:DRS HAHE JKreh ATE
/
ZH4 COPY?
Yes TO PDR?
Yes 'o OFFICIAL CORD COP' No RII:DRP KLBndIs RII:
KBerr
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/94 Yes No Yes OCU T NAME:
A:iPTP26-27.LTR Ho
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ENCLOSURE APPARENT INCONSISTENCIES IN REVISIONS 26 AND 27 OF RADIOLOGICAL EHERGENCY PLAN FOR TURKEY POINT PLANT 1.
Section 5.3. 1 On-Site Radiation Protection Pro ram Revision 26 2.
This section was modified in an effort to incorporate the revised Federal guidance promulgated in EPA 400-R-92-001, "Hanual of Protective Action Guides and Protective Actions for Nuclear Incidents."
- However, the licensee attached 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)(ll), 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).
Table 3-1 Section 1.2 Section 5
et al.
Revision 27 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, "Hanual 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 wherever 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.