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UNm1D STATES 3
g NUCLEAR REGULATORY COMMISSION a*
WASHINGTON, o.C. seneMeet
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SAFETY EVALUATION BY THE NRC 0FFICE OF NUCLEAR REACTOR REGULATION RELATED TO AN EMERfJNCY ACTION LEVEL REVISION FOR THE ST. LUCIE PLANT DOCKET N05. 50-335/389
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.
1.0 RACKGROLAS The proposed EAL changes were 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 standarrt "A standard emergency classification and action level scheme, the bases of which include fact ity 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 monitor < ng information, but also an readings from a number of sensors that indicate a potential
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emergency, such as the pressure in containment and the response of the i
emergency core cooling system) for notification of offsite agencies shall be described.. The emergency classes defined shall include:
(1) notification of l
unusual events: (2) alert, (3) site area emergency, and (4) general j
emergency.'
l The current EAL followed the general guidelines for Eats set forth in Appendix I of NUREG-0654, " Criteria for Preparation and Evaluation of Radiological l
Emergency Response Plans and Preparedness in Support of Nuclear Power Plants
- l (November 1980). The proposed revision incorporates the enhancements and j
clarifications to the EAls based on the guidelines for EALs set forth in IRMutC/NESP-007, Revision 2, " Methodology for Development of Emergency Action i
Levels * (January 1992). The NRC endorsed the use of either NUREG-0654 or NUNhRC/NCSP-007 in Regulatory Guide 1.101, " Emergency Planninq and Preparedness for Nuclear Power Reactors," Revision 3. August 992.
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Regulatory Guide 1.101 provides acceptable methods by wh'ch licensees may meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR 50.
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Emergency Preparedness Position (EPP05) Number 1. " Emergency Preparedness i
Position on Acceptable Deviations from Appendix a of NUREG-0654 Based Upon the i
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.' 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 appl cation of the technical bases for NUMARC/NESP-007-based Eats. 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 detemining)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 one gpa for unidentiff 6d leakage and (2) greater than (10) gpa for identified leakage to a single threshold value greater than ten (10) gpa for all leakage. The new proposed threshold leakage values is higher for unidentified sources than the cLrrent EAL and is the same as leaks from identified sources. The value for identified leaks are more conservative than the value shown in NLf1 ARC guidance. However, the licensee indicated that the selected value and the establishment of a single threshold value makes the declar.ation of an NOUE quicker and easier. The detemination 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 confim 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 the mixing of the emergency classificat'on 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 (ICs) in Appendix 1 to NUREG-0654 as the basis for their classification scheme could benefit from the guidance in 4
NUMARC/NESP-007. To that end, licensees could utilize the technical bases under the example emergency action levels (EALs) in NUMARC/NESP-007 to enhance and clarify some of their site-specific EALs developed from NUREG-0654. The e
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 licenses, to be acceptable. The proposed EAL revision for the St. Lucie Plant, is consistent with the guidance provided by NUREG-0654 and alloweble deviations, as discussed in EPPOS I in accordance with the technical bases for EALs in NUMARC/NESP-007.
4.0 CONCLUSION
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 50 for emergency classification and action level schemes.
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