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UR$1TEo STATES NUCLEAR REGULATORY COMMISSION
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l 101 MARIETTA STREET, N.W., SUITE 2900 f
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I ATLANTA, GEORGIA 30323-0199
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MEMORANDUM FOR:
Kenneth P. Barr, Chief p
Emergency Preparedness Section g\\
4 FROM:
James ~L. Kreh, Radiation Specialist i
Emergency Preparedness Section 4
SUBJECT:
REVIEW OF REVISION 23 TO RADIOLOGICAL EMERGENCY PLAN FOR ST. LUCIE PLANT, DOCKET NOS 50-335 AND 50-389 1.
BACKGROUND 1
By transmittal letter dated September 28, 1992, Florida Power and Light Company submitted Revision 23 (effective September 17, 1992) to the Radiological Emergency Plan (REP) for the St. Lucie Nuclear Plant.
As i
indicated by these dates, the licensee submitted this REP revision to the NRC within 30 days of the effective date, in accordance with the regulatory requirement.
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The subject revision was the product of the license's annual review of j
the REP, and incorporated numerous editorial and administrative changes i
which did not modify the meaning or intent of the affected statements.
These included several ainor alterations in the normal plant organizational structure and position titles, new/ improved maps, and routine. updates to letters of agreement with offsite support oroanizations.
Certain changes were found to be of a substantive nature and were reviewed for their impact on the effectiveness of the REP and/or their potential safety significance.
Among these was the addition of two completely new emergency action levels (EALs) to the' classification scheme; Ito other changes were made to the EALs. Only the potentially substantive changes in Revision 23 are evaluated below. All changes which are not discussed in Section II were determined to be nonsubstantive and without impact on the effectiveness of the REP.
References herein to discussions between the reviewer and a licensee representative are in regard to telephone conversations with R. Walker, Site EP Coordinator, and D. Mothena, Corporate EP Manager, on July 29-30, 1993.
II.
EVALUATION OF SUBSTANTIVE CHANGES A.
Section 1.0, General Information 61.2, Definitions:
" Emergency Management Center" in the
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Juno Beach arporate offices was added to the list of definitions.
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l 9704070338 970325
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PDR FOIA Lj BINDER 96-485 PDR N
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Kenneth P. Barr 2
Comment:
This newly added nomenclature is inconsistent with the terminology used in @2.4.7 (" Nuclear Division Management Center") for the same facility. A licensee representative acknowledged this point and stated that corrections will be included in the annual REP revision, due to be issued in the fall of this year.
This minor inconsistency does not decrease the effectiveness of the REP.
B.
Section 2.0, Organization, Facilities, and Support Services 1.
52.3.4, Support to Federal Assistance Teams:
The licensee's specific commitment to provide space and facilities for nine NRC staff at the EOF and five at the TSC was revised to stipulate that "adeauate [ emphasis added] space and facilities for the staff of the NRC" would be reserved at the subject facilities, and that the designated provisions "are routinely exercised and evaluated for adequacy by the NRC."
Comment:
This change actually appears to increase the flexibility to make modifications in the needs and number of NRC personnel on the Site Team, especially in consideration of the statement that the provisions are evaluated for adequacy by the NRC.
This change does not decrease the effectiveness of the REP.
2.
62.4.5, Emergency Operations Facility:
The following statement was added regarding activation of the EOF by the i
Emergency Centrol Officer off-site energency response (ECO):"The EC0 may place the i
staff on standby in the facility for an Alert."
Comment:
This change represents a new mode of operation for the licensee, and was demonstrated (albeit unsuccessfully) i in the June 23, 1993 off-hour exercise.
Implementing procedures provide for deploying a core staff of seven persons to the E0F if the ECO determines that an Alert situation has significant potential to escalate.
This change cc7stitutes an enhancement to the licensee's emergency response capability, which by definition does not decrease the effectiveness of the REP.
C.
Section 3,0, Emergency Classification System 1.
Table i-1, Classification of Emergencies; Event Catego;y 1.B, Abnormal Primary to Secondary Leak Rate:
The licensee added a completely new EAL addressing the initiating condition, " Rapid failure of steam generator tube (s)(GREATER THAN charging pump capacity) with a steam release in progress."
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Comment:
According to a licensee representative, this change was made to address the concern associated with IFI 91-301-01 (an item from a Licensing Examination inspection), which was reviewed and closed in NRC Report Nos. 50-335, 50-389/93-16.
This change represents an enhancement and therefore does not decrease the effectiveness of the REP.
2.
Table 3-1, Classification of Emergencies; Event 4
Category 8.A. Loss of Plant Control Functions:
The licensee added a completely new EAL addressing the initiating condition, " Complete loss of functions needed to maintain i
cold shutdown."
Comment: According to a discussion between the reviewer and a licensee representative, this EAL was developed at the licensee's initiative following evaluation of recent 4
industry events, Generic Letter 88-17, and the intent of i
guidance contained in NUREG-0654 and NUMARC NESP-007. This i
4 change represents an enhancement and therefore does not decrease the effectiveness of the REP.
D.
Section 4.0, Notification and Communication 1.
54.3, St. Lucie County and Martin County Department of Public Safety Directors:
In the subsection entitled
" Initial Notification," this statement appeared:
" Follow-up 1
messages concerning the emergency (Alert Class and higher) may come from the TSC staff or the EOF."
The word " Alert" N:ilaced the term " Site Area Emergency."
Comment: This change corrects an inconsistency with statements in other sections of the REP, and does not decrease the effectiveness of the REP.
2.
64.6, Communications Equipment:
The subsection now entitled "NRC FTS 2000 Emergency Telecommunications System" was 4
vastly expanded to include. descriptions of the purpose, capabilities, and use of the ENS, HPN, RSCL, PMCL, ERDS, MCL, and LAN, as found in Generic Letter 91-14.
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Comment:
This is considered a minor enhancement which by definition does not decrease the effectiveness of the REP.
a E.
Section 5.0, Response to Accident Conditions 55.3.1, On-Site Radiation Protection Program:
The following
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paragraph was added:
For those remote circumstances involving an event in progress, and obtaining EC (Emergency Coordinator] approval will result in leaving the
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accident scene or decrease the victim (s) chance of survival, lifesaving actions may be performed 3
without EC approval.
The EC shall be notified immediately following the rescue operation, j
i In addition, the following sentence (in reference to
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i re-entry missions / actions that may involve exceeding regulatory exposure limits) was deleted:
" Women capable of L
reproduction SHALL N9T take part in these actions."
Comment: According to a discussion with a licensee representative, the added paragraph resulted from numerous internal discussions' associated with training and drills.
The licensee emphasized tha: this provision applies only to a situation in which the wouid-be rescuer is already at the lj scene.
The subject deleted sentence was said by a licensee representative to be the result of a high-level corporate decision associated with a reexamination of the applicable regulations and regulatory guides.
These changes do not 4
decrease the effectiveness of the REP.
III.
SUMMARY
AND CONCLUSION Based upon review of the subject revision, the' undersigned determined that all of the changes therein were consistent with the provisions of i
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.
finding.
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b ames L. Kreh cc: C. T. Banks J
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ST. LUCIE EXERCISE February 7,1996 I
Facilities Observed: Control Room Simulator (CRS)
I Technical Support Center (TSC)
Observer: J. L. Kreh POSITIVE FINDINGS 1.
The crew demeanor and the EC command and controlin both the CRS and the TSC were very good.
2.
Half-hourly briefings in the TSC were concise and informative, although some personnel used more abbreviations than actual words in their briefings.
NEGATIVE FINDINGS 1.
Several inconsistencies were observed in the use of the State of Florida Notification Message Form. Although none were considered debilitating, they indicated that improvements in training of communicators and changes in the form itself may be in crder. The following problems / inconsistencies were noted at the CRS:
a.
EPIP-3100021 E,
" Duties and Responsibilities of the Emergency Coordinator", specified (in section 3.4.2) that the process of notifying offsite authorities of an emergency declarationincludes "Approvalof the information by the Emergency Coordinator." However, the State of Florida Notification Message Form did not include a signoff for the EC/RM. Messages 1 through 3, prepared by the CRS crew, were not approved in W.iting by the EC, and the inspector specifically observed that the EC did not review Message.3 prior to its transmission to the State.
Message 3 contained the following under item 5, INCIDENT DESCRIPTION OR UPDATE: " Increase in RCS leakage to greater than 20 gpm."
It was not clear to the inspector whether the Alert classification vas anticipatory to the EAL criterion of "RCS leakage greater than 50 gpm", or whether this information was simply erroneous and should have stated 50 gpm. A designated space for signoff by the EC/RM should oe added at the end of the message form. (This issue was raised durng the 1994 exercise, and is documented in IRN 94-04, Paragraph 6.)
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b.
Messages 1 and 3 indicated (in item 1.8) " Reported by: Weller/NPS".
Weller was the NPS, but was not the person who reported the information to the State.
c.
Message 2 indicated (in item 1.8) "Rf ren' E v: Marple/NPS". Marple was the person who reported the informai._ i to the State, but he was not the N'S.
d.
On Messages 1 through 3, the CRS communicator erroneously indicated a time and date in Item 13 in conjunction with a "NO" in answer to the question, "Has the event been terminated?" This did not make sense, and could be confusing to State personnel.
A time and date is appropriate in Item 13 only when "Yes" is indicated. This item was correctly completed by the communicator in the EOF beginning with Message 4.
2.
As indicated in 1.a above, the Alert declaration may not have been made in accordance with the EALs.
3.
The ERDADS printerr., in the TSC produced a very high noise level which was unnecessarily obtrusive.
4.
Crew briefings by the EC in the CRS would have been helpfulin ensuring that all personnel were fully aware of changing plant conditions.
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ELMk w'w Monday May 24, 1993 l
XO es MEMORANDUM FOR:
Albert F. Gibson J Ob som Thomas A.
Peebles g,
'FROM:
Jeffrey L.
Shackelford hh
SUBJECT:
Update of Regional Risk Based Information The Region has received most of the IPE submittals as required by NRC Generic Letter 88-20.
The only facilities remaining are as follows:
FACILITY PROJECTED SUBMITTAL DATE Bellefonte Indefinite Crystal River 3/1/93 Farley 6/30/93 Shearon Harris 8/31/93 St. Lucie 12/31/93 V.
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Summer 6/30/93 I
Additionally, Enclosure 1 to this me.mo provides the latest update on Region II risk-based information.
provides information on Loss of Service Water Events.
This information may prove to be useful in structuring / scheduling the upcoming Service Water team inspections.
I have provided a copy of the Service Water Matrix to Walt Rogers.
Jeff
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i ENCLOSURE 1
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Realon H Risk Profile Summarv 4
Facility CDF CDF IPE RI6 Results/Coments (IE)
(EE)
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Bellefonte N/A N/A N/A No Under Construction 1
Browns Ferry 4.8E-05 N/A Received No LOSP, SB0
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Brunswick 2.7E-05 N/A Received Yes LOSP, SBO, 2hr Battery life, Switchyard control
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power dependent on station batteries, SARA Model available 1
j Catawba 4.lE-05 3.4E-05 Received AFW Level 3 FRA, Loss of CCW, Full flow to RCP seals yta SSS not tested operationally i
Crystal River 1.4E-05 N/A 3/1/93 Yes SLOCA MLOCA.LOSP, IPE is updated version of 1987 i
PRA f
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Farley N/A N/A 6/30/93 AFW i.
Grand Gulf 1.7E-05 N/A Received Yes SBO, SARA Model Available,NUREG-1150
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Harris N/A N/A 8/31/93 No HHS! ASP results (1.CE-03)
Hatch 2.2E-05 N/A Received No LOSP. Loss of Support Systems j
McGuire 4.0E-05 3.4E-05 Received No SBO, Loss of Nuclear Service Water North Anna 6.8E-05 N/A Received No LOCA. LOSP, 3.6E-06 for internal flooding Oconee 2.3E-05 8.7E-05 Received Yes Medium LOCA & Failure of Long-term j
recirculation, Seismic dominates external i
analysis, Recent 50.72s highlight j
Keowee/ Emergency power issues, SARA Model i
a Available 2
Robinson 2.5E-04 N/A Received ho Internal Flooding =7,0E-05, CCW dependency modification Sequoyah 1.7E-04 N/A Received Yes Level 2 analysis, Loss of CCW. SARA Model j
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l St. Lucie 1.0E-05 6.0E-05 12/31/93 No TAP A-45 Results (Note 21 Sumer N/A N/A 6/30/93 No Preliminary estimate of C0F = 2.0E-04/vr
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Surry 7.4E-05 9.9E-05 Received Yes Loss of Switchgear Room Cooling, LOSP, Internal i
Floodino issue t
Turkey Point 9.6E-04 N/A Received AFW SBO, Hurricane (1.0E-04). Updated C0F via FPL ltr L-93-024 (2/5/93)
Vogtle 4.9E-05 N/A kcceived Yes SED, LOSP, loss of RHR ASP (1)
Watts Ear 3.3E-04 N 'A Received No less cf CCW
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Legeno/ Notes:
i N/A
'.ct ava lable D i r.
Risk Based Inspection Guide I
- F (IE)
've Dama.ie Frequency (Internal Events-hint Estimate) j CDF (EE)
Core me e Frecuency (External Events-Fotnt Estimate) i (Note 1)
'!ogtle Rlb based on Generic Westingnouse insig'its l
l Note Z}
~4P A-45 study constcers O M c51y, yenet-t t data vety li oteu ncLe
,c::ated May 24, 1993 l
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l ENCLOSURE 2 LOSS OF SERVICE WATER COMPARISON STUDY i
REGION II FACILITIES 1
Facility CDF f(LSW)
(IE)
Bellefonte N/A N/A Browns Ferry 4.8E-05 4.41E-03 Brunswick 2.7E-05 3.29E-03 Catawba 4.4E-05 1.80E-04 i
Crystal River 1.4E-05 2.20E-03 Farley N/A N/A l
Grand Gulf 1.7E-05 6.00E-03 Harris N/A N/A Hatch 2.2E-05 1.22E-04 McGuire 4.0E-05 3.00E-03 North Anna 6.8E-05 6.27E-06 conee 2.3E-05 4.30E-03 Robinson 2.5E-04 1.10E-03 Seauoyah 1.7E-04 1,13E-06 St. Lucie 1.0E-05 N/A Surrme r N/A N/A Surry 7.4E-05 6.65E-02 Turkey Point 9.6E-04 6.88E-04 Voatle 4.9E-C5 1.40E-04 Watts Ear 3.3E-04 1.51E-05 NOTES / LEGEND:
CCF (II) - Core Damage ~*eauency due to Internal Ese1ts per ;eactor Year
." f(LW) - Frecuency Cf Lcss of Nuclear Service Wate* Events ce* Reactcr Year
- 3. N/A - Not Available All e:11 rates are mean.aives.
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Facility CDF CDF IPE RIG Results/Coments (IE)
(EE)
Sched.
Bellefont e N/A N/A N/A No Under Construction Browns Ferry 4.BE-05 N/A Received No LOSP SB0 Brunswick 2.7E-05 N/A Received Yes LOSP, SBO, 2hr Battery itfe, Switchyard control l
power dependent on station batteries, SARA Model available Catawba 4.4E-05 3.4E-05 Received AFV Level 3 PRA, Loss of CCV, Full flow to RCP seals via SSS not tested coerationally Erystal River 1.4E-05 N/A Received Yes SLOCA.MLOCA,LOSP. IPE is updated version of 1987 i
PRA Fa rley 1.3E-04 N/A Received AFV SLOCA. Loss of SV, Loss of CCV. LOSP Grand Gulf 1.7E-05 N/A Received Yes 580, SARA Model Available.NUREG-1150 Harris 7.0E-05 N/A Received No SLOCA. LOSP, HHS! ASP results (1.0E-03)
Hatch 2.2E-05 N/A Received No LOSP, loss of Support Systems McGuire 4.0E-05 3.4E-05 Received No SBO, Loss of Nuclear Service Water North Anna 6.BE-05 N/A Received AFV LOCA, LOSP, 3.6E-06 for internal flooding Oconee 2.3E-05 B.7E-05 Received Yes Medium LOCA & Failure of Long-term recirculation, Seismic dominates external analysis, Recent 50,72s highlight Keowee/ Emergency power issues, SARA Model Available Robinson 2.5E-04 N/A Received No Internal Flooding =7.0E-05, CCV dependency modification Seouoyah 1.7E-04 N/A Received Yes Level 2 analysis, Loss of CCV, SARA Model Available St. Luete 1.0E-05 6.0E-05
!?/31/93 No TAP A-45 Results (Note 2)
S unner 2.0E-04 N/A Received No LOSP, LOCA. Loss of Chilled Water Surry 7.4E-05 9.9E-05 Received Yes Loss of Switchgear Room Cooling, LOSP, Internal Flooding Issue. SARA Moce) Avails.ble Turkey Point 9,6E-05 N/A Received AFV SBO, Hurricane (1.0E-04), Updated C0F via FPL ltr L-93-024 (2/5/93) vogtle 4.9E-05 N/A Received Yes SBO, LOSP, Loss of RHR ASP (1)
Vatts Bar 3.3E-04 N/A Received No Loss of CCW Legend / Notes:
N/A hot available RIG Risk Based *.pection Guide CDF (IE)
Core Damage irecuency (Internal Events-Point Estimate)
C0F (EE) -
Core Damage Frecuency (External Events-Point Estimate)
(Note 1)
Vogtle RIG based on Generic Westinghouse insights (Note 2)
TAP A-45 study consicers DHR only, generte data, very limited scooe Updated October 14, 1993 I
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