|
---|
Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20207L5671999-03-12012 March 1999 Forwards Facility Submitted Outline,Initial Exam Submittal & as Given Operating Exam for Test Administered on 981130,1204-14 & 18 ML20207E6091999-03-0303 March 1999 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 980622-26 ML20236Y6301998-08-0808 August 1998 Forwards Monthly Rept Reflecting Status of 10CFR2.206 Petitions as of 980731.Petitions on Plant GT97494 & GT97339 for Which DD Became Final Actions During Month Were Closed. Portion of Encl Withheld ML20237A0011998-08-0707 August 1998 Informs That Extension Granted on Envirocare Decision of 980904.Two Week Extension on Philadelphia VA Decision of 980828 Requested.Submits Concurrence of Changes.Rept on 2.206 July Status for Plants Encl ML20248L8621998-06-0909 June 1998 Forwards May 1998 Rept on Status of Public Petitioners Under 10CFR2.206.Petition on Seabrook (GT970873) for Which DD 98- 03 Became Final Agency Decision on 980413 Closed.Attachment 3 Withheld ML20203M6681998-02-23023 February 1998 Forwards SER Re TR CENPD-199-P,Rev 1-P-A,Suppl 2-P, CE Setpoint Methodology Proposing CRGR Review Be Waived IAW Suggested Procedures in 890929 Memo ML20202E0141997-11-25025 November 1997 Forwards FOIA Request Received Direct in Region II from E Barton on 971125.Encl Partially Deleted IA-97-461, Forwards FOIA Request Received Direct in Region II from E Barton on 971125.Encl Partially Deleted1997-11-25025 November 1997 Forwards FOIA Request Received Direct in Region II from E Barton on 971125.Encl Partially Deleted IA-99-106, Discusses Concern Identified During Special Design Architect-Engineer Insp Re EQ of Unit 1 Terry Turbine Woodward Governor Controls for Steam Turbine Driven Auxiliary Feedwater Pump1997-08-15015 August 1997 Discusses Concern Identified During Special Design Architect-Engineer Insp Re EQ of Unit 1 Terry Turbine Woodward Governor Controls for Steam Turbine Driven Auxiliary Feedwater Pump ML20205D4281997-08-15015 August 1997 Discusses Concern Identified During Special Design Architect-Engineer Insp Re EQ of Unit 1 Terry Turbine Woodward Governor Controls for Steam Turbine Driven Auxiliary Feedwater Pump ML20205M3331997-07-28028 July 1997 Provides Final Agenda for Region II Enforcement Meeting to Be Held on 970730.OI Attendance Requested for Issue Involving Termination of Turkey Point Radwaste Operator Who Failed to Follow Procedure IR 05000335/19970051997-07-17017 July 1997 Forwards Allegation Evaluation Rept & NRC Insp Repts 50-335/97-05 & 50-389/97-05 Re RII-97-A-0116 ML20202E0261997-04-23023 April 1997 Discusses Technical Staff Actions Associated W/Three Concerns in Allegation RII-96-A-0251 ML20137L2971997-03-31031 March 1997 Forwards Matrix Containing Answer to Listed Questions in ,Rev 1 ML20148A7131997-03-28028 March 1997 Forwards Addl Responses Needed to Grant Exemptions.Items 2,5,6 & 7 Seem Appropriate for St Lucie to Respond to ML20137R8831997-03-27027 March 1997 Provides Info Requested by 960208 Memo from J Stolz Re Review of Spent Fuel Pool Practices & Current Licensing Basis ML20137L0981997-03-25025 March 1997 Forwards Summary of Changes Made to Safeguards Review Rept, Rev 37 to St Lucie Physical Security Plan,Case Control Number N5S63VA50033593.W/o Encl ML20137L2311997-03-25025 March 1997 Forwards Summary of Changes Made to Safeguards Review Rept, Rev 47 to St Lucie Physical Security Plan,Case Control Number N5S76VA50033596.W/o Encl ML20136E9261997-03-0606 March 1997 Forwards SALP Input Feeder Info at St Lucie Facility from 940102-960106 & Requests That Technical Staff Complete Review by 951222 ML20136A9241997-02-28028 February 1997 Partially Withheld Memo Discussing drop-in Visit of J Broadhead,Chairman & CEO FPL Group & Chairman & CEO FP&L Co & J Goldberg ML20137L2751996-12-16016 December 1996 Requests Guidance in Addressing Issues Re Use of Temporary Fire Pump W/O Evaluation & Construction of Enclosure for Control Rod Drive Electronic Equipment within Cable Spreading Room,W/O Appropriate Evaluation ML20136A6751996-12-0909 December 1996 Partially Withheld Memo Discussing Directors Decision 96-19 Under 10CFR2.206 Re Steam Generator Issued at St Lucie ML20137R5381996-11-22022 November 1996 Informs That Rept IR 94-008 for St Lucie Opens Item 94-008-02-URI Quality Level of PORV & SRV Discharge Piping ML20136E6991996-11-19019 November 1996 Requests Info Re Sheron St Lucie Visit.Info Requested by 961120 ML20136E6221996-11-19019 November 1996 Informs That Draft in on Operator Activities Affecting Reactivity Being Distributed ML20136E6791996-11-18018 November 1996 Forwards Background Info on St Lucie Nuclear Instrumentation Insp ML20136E6881996-11-18018 November 1996 Forwards Background Info on St Lucie Nuclear Instumentation Insp ML20136E6081996-11-15015 November 1996 Provides List of Corrective Actions That Have Been Rolled Into Speakout Program ML20136E5461996-11-14014 November 1996 Forwards File Submitted to Kerry on 961024 Re PIM-like Summary of Events from 92-93 ML20136E4911996-11-13013 November 1996 Forwards Updated Schedule for St Lucie FY1 ML20138G4131996-11-12012 November 1996 Requests Technical assistance,TIA-019,re Discrepancies Between Containment Radiation Monitoring Sys Described in Usfar & Regulatory Guide 1.45 at Plants ML20140E5361996-11-12012 November 1996 Forwards Plant EA Worksheet ML20140E6591996-11-12012 November 1996 Provides Revs of Plant Violations for Current Hour ML20140E5301996-11-0808 November 1996 Forwards Input Received from Dan & Revised EA Worksheet from Incorporating Input.Few Slight Revs Were Made to Notice of Violation ML20140E6521996-11-0707 November 1996 Informs That D Barss Will Be e-mailing Input on Items 5 & 6 for Incorporation Into EA Worksheet ML20140E6201996-11-0707 November 1996 Provides Two Violations That Are Subjects of EA Worksheet ML20140E5941996-11-0606 November 1996 Informs That Plant Violations 1 & 2 Re Emergency Prepardness Program Insp,Being Looked at for Escalated Enforcement.Feedback Requested ML20137R9031996-11-0606 November 1996 Requests That Info Re St Lucie Be Mailed to Author.Info May Be Found in Plan of Day Handout,Provided by Residents ML20137Y5401996-11-0505 November 1996 Forwards Info on Two Issues to Be Discussed W/Panel at Meeting Scheduled for 961106.Partially Deleted ML20138G3651996-11-0505 November 1996 Requests That Listed Info Be Forwarded to Licensee in Connection W/Unescorted Access Visits to Plant by Listed NRC Contractor Employees During 961118-970110 for Purpose of Assisting NRC in Conduct of Design Insp.Partially Deleted ML20136E3011996-10-31031 October 1996 Forwards Schedule for Activities at Plant for Next Few Months ML20136E3961996-10-31031 October 1996 Informs That Violation Withdrawn Re Licensee Use of Ccw/Icw (Svc Water) in Mode 5 at Plant ML20136E4691996-10-31031 October 1996 Discusses Criticality Monitoring Ltr & Requests Response to Listed Question ML20134E9191996-10-29029 October 1996 Forwards Rationale for Inital Plants Selected for Design Insps & for Plants Considered for Second Quarter FY97 Design Insps ML20140E5191996-10-29029 October 1996 Discusses Addl Info for Plant Panel,Just Received from Inspector ML20140E5801996-10-29029 October 1996 Discusses EA Worksheet on Plant Re Wiring Error Affecting Nuclear Instrumentation ML20140E5241996-10-29029 October 1996 Forwards Wordperfect Version as Requested ML20140E5901996-10-29029 October 1996 Forwards Enforcement Action Worksheet ML20136E5641996-10-28028 October 1996 Replies to News Summary Re Escalated Enforcement for Plant on 961025 IR 05000335/19950151996-10-28028 October 1996 Forwards Draft Insp Repts 50-335/95-15 & 50-389/95-15 on 960907-1012 1999-03-03
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20207L5671999-03-12012 March 1999 Forwards Facility Submitted Outline,Initial Exam Submittal & as Given Operating Exam for Test Administered on 981130,1204-14 & 18 ML20207E6091999-03-0303 March 1999 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 980622-26 ML20236Y6301998-08-0808 August 1998 Forwards Monthly Rept Reflecting Status of 10CFR2.206 Petitions as of 980731.Petitions on Plant GT97494 & GT97339 for Which DD Became Final Actions During Month Were Closed. Portion of Encl Withheld ML20237A0011998-08-0707 August 1998 Informs That Extension Granted on Envirocare Decision of 980904.Two Week Extension on Philadelphia VA Decision of 980828 Requested.Submits Concurrence of Changes.Rept on 2.206 July Status for Plants Encl ML20248L8621998-06-0909 June 1998 Forwards May 1998 Rept on Status of Public Petitioners Under 10CFR2.206.Petition on Seabrook (GT970873) for Which DD 98- 03 Became Final Agency Decision on 980413 Closed.Attachment 3 Withheld ML20203M6681998-02-23023 February 1998 Forwards SER Re TR CENPD-199-P,Rev 1-P-A,Suppl 2-P, CE Setpoint Methodology Proposing CRGR Review Be Waived IAW Suggested Procedures in 890929 Memo ML20202E0141997-11-25025 November 1997 Forwards FOIA Request Received Direct in Region II from E Barton on 971125.Encl Partially Deleted IA-97-461, Forwards FOIA Request Received Direct in Region II from E Barton on 971125.Encl Partially Deleted1997-11-25025 November 1997 Forwards FOIA Request Received Direct in Region II from E Barton on 971125.Encl Partially Deleted IA-99-106, Discusses Concern Identified During Special Design Architect-Engineer Insp Re EQ of Unit 1 Terry Turbine Woodward Governor Controls for Steam Turbine Driven Auxiliary Feedwater Pump1997-08-15015 August 1997 Discusses Concern Identified During Special Design Architect-Engineer Insp Re EQ of Unit 1 Terry Turbine Woodward Governor Controls for Steam Turbine Driven Auxiliary Feedwater Pump ML20205D4281997-08-15015 August 1997 Discusses Concern Identified During Special Design Architect-Engineer Insp Re EQ of Unit 1 Terry Turbine Woodward Governor Controls for Steam Turbine Driven Auxiliary Feedwater Pump ML20205M3331997-07-28028 July 1997 Provides Final Agenda for Region II Enforcement Meeting to Be Held on 970730.OI Attendance Requested for Issue Involving Termination of Turkey Point Radwaste Operator Who Failed to Follow Procedure IR 05000335/19970051997-07-17017 July 1997 Forwards Allegation Evaluation Rept & NRC Insp Repts 50-335/97-05 & 50-389/97-05 Re RII-97-A-0116 ML20202E0261997-04-23023 April 1997 Discusses Technical Staff Actions Associated W/Three Concerns in Allegation RII-96-A-0251 ML20137L2971997-03-31031 March 1997 Forwards Matrix Containing Answer to Listed Questions in ,Rev 1 ML20148A7131997-03-28028 March 1997 Forwards Addl Responses Needed to Grant Exemptions.Items 2,5,6 & 7 Seem Appropriate for St Lucie to Respond to ML20137R8831997-03-27027 March 1997 Provides Info Requested by 960208 Memo from J Stolz Re Review of Spent Fuel Pool Practices & Current Licensing Basis ML20137L0981997-03-25025 March 1997 Forwards Summary of Changes Made to Safeguards Review Rept, Rev 37 to St Lucie Physical Security Plan,Case Control Number N5S63VA50033593.W/o Encl ML20137L2311997-03-25025 March 1997 Forwards Summary of Changes Made to Safeguards Review Rept, Rev 47 to St Lucie Physical Security Plan,Case Control Number N5S76VA50033596.W/o Encl ML20136E9261997-03-0606 March 1997 Forwards SALP Input Feeder Info at St Lucie Facility from 940102-960106 & Requests That Technical Staff Complete Review by 951222 ML20136A9241997-02-28028 February 1997 Partially Withheld Memo Discussing drop-in Visit of J Broadhead,Chairman & CEO FPL Group & Chairman & CEO FP&L Co & J Goldberg ML20137L2751996-12-16016 December 1996 Requests Guidance in Addressing Issues Re Use of Temporary Fire Pump W/O Evaluation & Construction of Enclosure for Control Rod Drive Electronic Equipment within Cable Spreading Room,W/O Appropriate Evaluation ML20136A6751996-12-0909 December 1996 Partially Withheld Memo Discussing Directors Decision 96-19 Under 10CFR2.206 Re Steam Generator Issued at St Lucie ML20137R5381996-11-22022 November 1996 Informs That Rept IR 94-008 for St Lucie Opens Item 94-008-02-URI Quality Level of PORV & SRV Discharge Piping ML20136E6991996-11-19019 November 1996 Requests Info Re Sheron St Lucie Visit.Info Requested by 961120 ML20136E6221996-11-19019 November 1996 Informs That Draft in on Operator Activities Affecting Reactivity Being Distributed ML20136E6791996-11-18018 November 1996 Forwards Background Info on St Lucie Nuclear Instrumentation Insp ML20136E6881996-11-18018 November 1996 Forwards Background Info on St Lucie Nuclear Instumentation Insp ML20136E6081996-11-15015 November 1996 Provides List of Corrective Actions That Have Been Rolled Into Speakout Program ML20136E5461996-11-14014 November 1996 Forwards File Submitted to Kerry on 961024 Re PIM-like Summary of Events from 92-93 ML20136E4911996-11-13013 November 1996 Forwards Updated Schedule for St Lucie FY1 ML20138G4131996-11-12012 November 1996 Requests Technical assistance,TIA-019,re Discrepancies Between Containment Radiation Monitoring Sys Described in Usfar & Regulatory Guide 1.45 at Plants ML20140E5361996-11-12012 November 1996 Forwards Plant EA Worksheet ML20140E6591996-11-12012 November 1996 Provides Revs of Plant Violations for Current Hour ML20140E5301996-11-0808 November 1996 Forwards Input Received from Dan & Revised EA Worksheet from Incorporating Input.Few Slight Revs Were Made to Notice of Violation ML20140E6521996-11-0707 November 1996 Informs That D Barss Will Be e-mailing Input on Items 5 & 6 for Incorporation Into EA Worksheet ML20140E6201996-11-0707 November 1996 Provides Two Violations That Are Subjects of EA Worksheet ML20140E5941996-11-0606 November 1996 Informs That Plant Violations 1 & 2 Re Emergency Prepardness Program Insp,Being Looked at for Escalated Enforcement.Feedback Requested ML20137R9031996-11-0606 November 1996 Requests That Info Re St Lucie Be Mailed to Author.Info May Be Found in Plan of Day Handout,Provided by Residents ML20137Y5401996-11-0505 November 1996 Forwards Info on Two Issues to Be Discussed W/Panel at Meeting Scheduled for 961106.Partially Deleted ML20138G3651996-11-0505 November 1996 Requests That Listed Info Be Forwarded to Licensee in Connection W/Unescorted Access Visits to Plant by Listed NRC Contractor Employees During 961118-970110 for Purpose of Assisting NRC in Conduct of Design Insp.Partially Deleted ML20136E3011996-10-31031 October 1996 Forwards Schedule for Activities at Plant for Next Few Months ML20136E3961996-10-31031 October 1996 Informs That Violation Withdrawn Re Licensee Use of Ccw/Icw (Svc Water) in Mode 5 at Plant ML20136E4691996-10-31031 October 1996 Discusses Criticality Monitoring Ltr & Requests Response to Listed Question ML20134E9191996-10-29029 October 1996 Forwards Rationale for Inital Plants Selected for Design Insps & for Plants Considered for Second Quarter FY97 Design Insps ML20140E5191996-10-29029 October 1996 Discusses Addl Info for Plant Panel,Just Received from Inspector ML20140E5801996-10-29029 October 1996 Discusses EA Worksheet on Plant Re Wiring Error Affecting Nuclear Instrumentation ML20140E5241996-10-29029 October 1996 Forwards Wordperfect Version as Requested ML20140E5901996-10-29029 October 1996 Forwards Enforcement Action Worksheet ML20136E5641996-10-28028 October 1996 Replies to News Summary Re Escalated Enforcement for Plant on 961025 IR 05000335/19950151996-10-28028 October 1996 Forwards Draft Insp Repts 50-335/95-15 & 50-389/95-15 on 960907-1012 1999-03-03
[Table view] |
Text
/(d K'49*o UNITED STATES
.A NUCLEAR REGULATORY COMMISSION a
3 ReGron n 101 MARIETTA STREET, N.W., SUITE 2000 g
l ATLANTA, GEORGIA 303210190
i MEMORANDUM TO: Kenneth P. Barr, Chief Emergency Preparedness Secti FROM:
James L. Kreh, Radiation Specialist,/
Emergency Preparedness Section
SUBJECT:
REVIEW 0F REVISIONS 25 AND 26 TO RADIOLOGICAL EMERGENCY PLA FOR ST. LUCIE PLANT, DOCKET NOS. 50-335 AND 50-389
)
1.
BACKGROUND AND DISCUSSION By transmittal letters dated January 24 and April 6, 1994, the licensee i
submitted Revision'25 (effective December 30, 1993) and Revision 26 (effective March 28, 1994),
Plan for the St. Lucie Plant.respectively, to the Radiological Emergency Accordingly, it can be seen that the licensee submitted each of these Plan revisions to the NRC within 30 days of the effective date, as required.
i Revision 25 resulted from the licensee's annual review of the Plan.
This revision incorporated many minor editorial and administrative changes and corrections which did not alter the meaning or intent of the affected statements.
Revision 26 dealt primarily with implementation of the revised Federal guidance promulgated in EPA 400-R-92-001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" (except dose limits for licensee emergency workers, which were modified in Revision 25).
The changes in these two revisions were reviewed for their impact on the effectiveness of the Plan and/or their potential safety significance.
Only those changes which actually or potentially decreased the effectiveness of the Plan are discussed in Section II below; all other changes in the subject revisions were determined to be free of negative impact upon the effectiveness of the Plan.
Several telephonic discussions between the reviewer and licensee representatives (D.' Mothena, F. King, and R. Walker) were conducted during July-August 1994 in a partially successful effort to resolve the questions / issues that arose during the subject review.
All mentions herein of discussions between the reviewer and a licensee representative are in reference to those conversations.
Further information regarding this evaluation may be found in the reviewer's annotations of the subject revisions and in the licensee's justification package for Revision 25 (maintained in Section files).
A justification document was not provided for Revision 26.
II.
EVALUATION OF SUBSTANTIVE CHANGES A.
Section 5.3.1, On-Site Radiation Protection Program (Revision 25):
This section was modified in an effort to incorporate the revised i
Federal guidance promulgated in EPA 400-R-92-001. " Manual of 9704070200 970325 Q
PDR FOIA BINDER 96-485 PDR
o N
K. Barr 2
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]."
i Evaluation:
This restriction quoted above 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 i
by the licensee. The licensee's Plan therefore appears to be inconsistent with the emergency planning standard of 10 CFR 50.47(b)(11).
In response to our letter of July 28, 1994, requesting additional information on this issue, the licensee stated (letter dated September 2, 1994) that its Plan would be revised in accordance with the position presented in our letter.
B.
Section 1.2, Table 3-1, Section 5, et al. (Revision 26):
Section 1.2, Definitions, introduces the terms " total whole body dose" (actually presented as "whole body dose" there, but used with " total" elsewhere in the Plan) and " thyroid dose",
respectively, as substitute terms for "TEDE" and " thyroid CDE",
with this surrogate nomenclature subsequently used throughout the P1an.
Evaluation:
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 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 classif'ication
e K. Barr 3
scheme. The licensee's adoption of the indicated nonstandard terminology decreases the effectiveness of the Plan.
In response to our letter of July 28, 1994, requesting additional information on this issue, the licensee stated (letter dated September 2,1994) that it intended to adopt " total dose (TEDE)"
in place of " total whole body dose", and " thyroid dose (CDE)" in place of " thyroid dose" in the next revision of the Plan. As of the date of preparation of this evaluation, this matter is under consideration by the Office of General Counsel for "rulemaking" (formal interpretation of regulatory requirements).
The Regional Counsel-indicated to the reviewer on September 28, 1994 that a response from OGC would probably take 30-60 days. The reviewer recommends that our response to the licensee's letter of September 2 should state that this issue is under review by OGC, and that a final determination relative to Plan effectiveness will be made upon issuance of OGC's ruling.
C.
Table 3-1, Classification of Emergencies (pp. '3-5, 3-7, 3-9, and 3-12) (Revision 26):
In selected Site Area and General Emergency EAls, the licensee changed mR and R units to m em, but retained the use of dose-rates for dose projection thresholds.
Evaluation: The reviewer discussed with a licensee representative the invalidity of expressing total whole body dose (equivalent to TEDE) and thyroid dose (equivalent to thyroid CDE) as dose rates, as in the EALs cited above. The licensee representative indicated that this approach had been carefully ~ considered after much technical discussion, and reflected what cognizant plant staff felt was most technically appropriate. Although the licensee should be encouraged to address this technical inconsistency, it does not affect the usability of the subject EALs in-terms of appropriate numerical thresholds for the respective emergency classifications, and does not decrease the effectiveness of the Pl an.
(NOTE:
This evaluation finding regarding impact on Plan j
effectiveness is the same as for the analogous finding for Revision 14 of Crystal River's Plan.
In that case, however, the I
licensee readily agreed to modify its EALs, probably to be expressed in terms of dose thresholds based on a one-hour release.]
l D.
Figure 4-1, State of Florida Notification Message Form for Nuclear Power Plants:
[The reviewer learned through discussion with the licensee representative that the form was updated in July 1994 to s
supposedly address EPA 400 changes.
The licensee representative l
provided the reviewer with a copy of this latest revision of the notification form by facsimile transmission, and it was this version which was reviewed.] Most of the changes in this form l
l were to the graphics rather than the substance.
The principal substant we change was that Section 10 on " Projected Offsite Dose Rate" was revised to replace "whole body" with " total dose rate",
l l
and " child thyroid" with " thyroid dose rate".
O
s K. Barr 4
Evaluation:
The reviewer discussed with a licensee representative the invalidity of expressing total whole body dose (TEDE) and thyroid dose (thyroid CDE) as dose rates (same issue as discussed above in connection with the EALs). The licensee representative contended that this was what the State of Florida wanted.
However, even if the technical inconsistency of expressing TEDE and thyroid CDE as dose rates is ignored (which it shouldn't be),
the reviewer noted that the provision of projected dose rates alone does not allow for a direct comparison with PAGs by cor:lzant offsite authorities (they would have to use the estimate of release duration to calculate integrated doses).
Guidance in Section II.E.4 of NUREG-0654 states that the licensee shall provide offsite authorities with projected dose rates and integrated doses (when appropriate and if known) at the site boundary and at 2, 5, and 10 miles.
It should be pointed out that the previous revision of the notification form also provided dose rates only -(no integrated doses). 'The current version of the notification form is not consistent with Part 20 terminology. The reviewer's recommendation is that Region II should continue to work closely with both FPC and FP&L to encourage those licensees to develop a notification message which conveys the appropriate information and uses standard radiation-protection terminology.
III.
SUMMARY
AND CONCLUSION The reviewer determined that all of the changes in the subject revisions were consistent with the provisions of 10 CFR 50.54(q), 10 CFR 50.47(b),
Appendix E to 10 CFR Part 50, and Section II of NUREG-0654, except as noted above in Sections II.A, II.8, and II.D.
The letter to the licensee will communicate these findings in detais.
i cc:
C. Banks i
l i
J