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MEMORANDUM FOR:
Kenneth P. Barr, Chief EmergencyPreparednessSectionh5 FROM:
James L. Kreh, Radiation Specialist Emergency Preparedness Section
SUBJECT:
REVIEW 0F REVISION 24 TO RADIOLOGICAL EMERGENCY PLAN FOR ST. LUCIE PLANT, DOCKET NOS. 50-335 AND 50-389 I.
BACKGROUND AND DISCUSSION By transmittal letter dated August 3, 1993, the licensee submitted Revision 24 to the Radiological Emergency Plan for the St. Lucie Plant.
The effective / approval date of this revision was July 26, 1993. As indicated by these dates, the licensee submitted this Plan revision to the NRC within 30 days of the effective date, as required.
The subject revision involved changes only to Event Categories 5.8 cnd 5.C (in Table 3-1), which address hurricanes and tornadoes, respectively.
These changes are evaluated in detail in Section II below.
Further information regarding this evaluation may be found in the reviewer's annotations of the subject revision and in the licensee's i
justification document (maintained in Section files).
II.
EVALUATION OF SUBSTANTIVE CHANGES Table 3-1, Classification of Emergencies A.
Event Category 5.B. Hurricane 1.
The EAL for Alert, predicated upon an initiating condition of " Hurricane warning with winds near design basis," was changed as follows:
l Previous:
" Notification by NOAA that a hurricane warning is in effect with on-site winds expected to exceed 100 mph."
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Revision 24:
" Confirmed hurricane warning is in effect with on-site winds expected to exceed 175 mph."
Immediately below this EAL was added the following conspicuously boxed " NOTE":
At FPL's request. NOAA will provide an k
i accurate projection of wind speeds onsite 1
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the onset of hurricane P
9704070335 970325
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Kenneth P. Barr 2
force winds.
If that projection is not t
available within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of entering into the warning, classify the event using current track and wind speeds to project onsite conditions.
For example, projected onsite wind speed would be less than maximum huiricane wind speed if the track is away from PSL.
Evaluation: As part of the licensee's corrective action for lessons learned from Hurricane Andrew, EALs for St. Lucie and Turkey Point were compared.
This led to the determination that the hurricane EALs for St. Lucie were 1
considerably more conservative than those for Turkey Point, apparently because the " design basis" wind speed chosen for the St. Lucie EALs was derived from the South Florida Building Code for standard plant structures (viz., 120 mph) rather than from the FSAR for Class I nuclear plant structures (viz., 194 mph).
The licensee plausibly established the "near design basis" wind speed criterion of 175 mph for the Alert EAL by using 90% of 194 mph.
The new j
wind speed criteria for St. Lucie are still somewhat lower than those used at Turkey Point (which are 200 mph and 1
225 mph, respectively). The " NOTE" prescribes a reasonable approach to follow in the event that current hurricane forecast information is unavailable from NOAA for some reason.
This change does not decrease the effectiveness of the Plan.
2.
The EAL for Site Area Emergency, predicated upon an initiating condition of " Hurricane warning with winds GREATER THAN design basis," was changed as follows:
Previous:
" Notification by NOAA that a hurricane warning is in effect with on-site winds expected to exceed 120 mph AND plant not at cold shutdown."
Revision 24:
" Plant not at cold shutdown AND confirmed hurricane warning is in effect with on-site winds expected to exceed 194 mph."
Immediately below this EAL was added the same conspicuously boxed " NOTE" as is quoted above for the Alert EAL.
j Evaluation:
As discussed above, the design basis wind speed was ascertained from the FSAR to be 194 mph, whereas
' previously a spurious figure had been used in this EAL.
Through post-Hurricane Andrew discussions with State and local emergency planners, the licensee additionally realized i
Kenneth P. Barr 3
that an Alert or SAE declaration at St. Lucie based on hurricane wind speed values far below plant design specifications and NRC guidance (in NUREG-0654) would cause the unnecessary expenditure of State and local emergency management energy and deplete resources at a time when they were most needed in the community.
This change does not decrease the effectiveness of the Plan.
B.
Event Category 5.C. Tornado The following EAL for Site Area Emergency was deleted in its
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entirety:
" Tornado or sustained winds in excess of design (120 mph) with plant not at cold shutdown."
Evaluation: This EAL again contains the spurious criterion of 120 mph, discussed above.
The licensee's justification document cites the St. Lucie FSAR design basis tornadic wind i
speeds as 300 mph rotational and 60 mph translational.
Historical data provided to the licensee by NOAA indicates a maximum tornadic wind speed for Florida of 200 mph.
The applicable NRC guidance is contained in NUREG-0654 Example Initiating Condition 15.c, " Severe natural phenomena being experienced or projected with plant not in cold shutdown
... Sustained winds or tornadoes in excess of design i
levels." As is the case with most nuclear power plant
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onsite meteorological systems, St. Lucie's has the capability to measure wind speeds only to about 100 mph, which is far below the EAL which would be derived from use i
of the design basis wind speeds.
The deleted EAL may also have been deficient relative to the generically desirable attribute that an EAL should be based on readily observable parameters.
Because of the relatively compact nature of a tornado, the licensee argues that a tornado could strike the plant and still be too far from the meteorological tower to register wind speeds in excess of those specified in an EAL.
It should be noted that the licensee is retaining the Alert EAL for "Any tornado striking the facility," thus activating the ERO immediately upon detection of a tornado strike.
Any emergency classification higher than Alert would be based upon resultant physical damage affecting plant control functions.
The licensee's Turkey Point Plant and numerous other Region 11 facilities have adopted this approach-in their approved emergency plans.
This change does not decrease the effectiveness of the Plan.
l
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s l
Kenneth P. Barr 4
1 III.
SUMMARY
AND CONCLUSION
.The reviewer's conclusion, in the case of each of the three EAL i
modifications discussed herein, is that the greater conservatism of the "old" EAL does not mean that it afforded greater Plan effectiveness.
Based upon review of the subject revision, the undersigned determined i'
that all of the changes therein 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.
The letter to the licensee will convey this i
finding.
eL, James L. Kreh t
cc:
C. Banks l
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