ML102520281

Dow Chemical Company - Request for Additional Information Regarding the Emergency Plan for the License Renewal and Power Uprate Application Review

ML102520281
Person / Time
Site:	Dow Chemical Company
Issue date:	09/16/2010
From:	Geoffrey Wertz Research and Test Reactors Licensing Branch
To:	Krahenbuhl M Dow Chemical Co
Meyer W, NRR/DPR/PRLB, 301-415-0897
References
TAC ME1595
Download: ML102520281 (5)

Text

September 16, 2010 Melinda P. Krahenbuhl, Ph.D.

Facility Director Dow Chemical TRIGA Research Reactor Dow Chemical Company Building 1602 Midland, MI 48674

SUBJECT:

DOW CHEMICAL COMPANY - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE EMERGENCY PLAN FOR THE LICENSE RENEWAL AND POWER UPRATE APPLICATION REVIEW (TAC NO. ME1595)

Dear Dr. Krahenbuhl:

The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009 (a redacted version of the application is available on the NRCs public Web site at www.nrc.gov under Agencywide Documents Access and Management System Accession No. ML092150443).

We require additional information and clarification on questions that have arisen during our review. Please provide responses to the enclosed request for additional information within 30 days of the date of this letter. In accordance with Title 10 of the Code of Federal Regulations Section 50.30(b), you must execute your response in a signed original document under oath or affirmation.

If you have any questions about this review or if you need additional time to respond to this request, please contact Walter Meyer by telephone at 301-415-0897 or by electronic mail at Walter.Meyer@nrc.gov.

Sincerely,

/LTran for RA/

Geoffrey A. Wertz, Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-264

Enclosure:

As stated cc w/encl: See next page

Dow Chemical Company Docket No. 50-264 cc:

Office of the Mayor 333 West Ellsworth Midland, MI 48640 Office of the Governor Room 1 - Capitol Building Lansing, MI 48913 Alex Pollock Chair, Radiation Safety Committee 2030/410 Dow Center Midland, MI 48674 Dr. Kevin Hool, Level 1 Manager The Dow Chemical Company 1897 Building Midland, MI 48667 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

ML102520281 *Concurrence via email NRR-088 Office PRLB:PM PRLB:PM*

PRLB:LA NSIR-BC*

PRLB:BC PRLB:PM Name WMeyer GWertz GLappert JAnderson JQuichocho LTran for GWertz Date 9/8/10 9/8/10 9/10/2010 9/10/2010 9/16/10 9/16/2010

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING THE EMERGENCY PLAN FOR THE RENEWAL REVIEW FOR THE DOW CHEMICAL COMPANY TRIGA RESEARCH REACTOR LICENSE LICENSE NO. R-108 DOCKET NO. 50-264 The U.S. Nuclear Regulatory Commission (NRC) is continuing its review of your application for the renewal of Facility Operating License No. R-108 for the Dow Chemical TRIGA Research Reactor (DTRR), dated April 1, 2009. We require additional information and clarification on questions that have arisen during our review.

The requests for additional information (RAI) are based on a comparison of the DOW Emergency Plan, dated July 27, 2007, with Regulatory Guide 2.6, Emergency Planning for Research and Test Reactors; American Nuclear Standard Insitution/American Nuclear Society (ANSI/ANS)-15.16-2008, Emergency Planning for Research Reactors; and NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors. The documents above are referenced as guidance documents in Section 12.7, Emergency Planning, to NUREG-1537, Guidellines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria.

1.

The DTRR Emergency Plan did not have references listed. Please consider referencing ANSI/ANS-15.16-2008 or provide justification as to why this is not necessary.

2.

ANSI/ANS-15.16-2008, Section 3.1 requests the location of the reactor facility. In Section I.A of the Emergency Plan, the map does not show where the reactor facility is located. Please include detail to provide a general orientation and common understandingfor those members oflocal, county, state and federal agencies that will read and study the plan, or provide justification as to why this requested detail is not needed.

3.

Section II.B(4) of the Emergency Plan states the Dow Radiation Safety Committee is responsible for notification of the NRC and the Michigan Department of Public Health of events classified Notification of Unusual Event as required by the pertinent licenses and regulations. Please explain how these notifications are delegated given the statement in Section II.D(4) of the Emergency Plan which states The emergency director shall not delegate the responsibilities of notifications

4.

ANSI/ANS-15.16-2008, Section 3.3(9) requests the identification by title of the individual with a line of succession, in charge of radiological assessments. Please identify in Section II.F of the Emergency Plan the line of succession for the Radiation Safety Officer in the event that he or she is unavailable, or provide justification as to why this detail is not needed.

5.

ANSI/ANS-15.16-2008, Table 1 provides examples of Emergency Action Levels (EALs) for the Notification of Unusual Events classification. The Emergency Action Levels in III.B of the Emergency Plan for Notification of Unusual Events classification do not conform to the guidance provided in Table 1. Please justify the differences or consider adding relevant EALs to the Emergency Plan.

6.

Section 7.0, Emergency Response to NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors, requests a description of the contents of initial and follow-up emergency messages to the NRC and other offsite authorities. Sections II.B.4 and VI.A of the Emergency Plan do not provide such detail. Please describe the timelines and content of initial and follow-up messages to the NRC and offsite authorities or provide justification as to why such detail is not needed.

7.

ANSI/ANS-15.16-2008, Section 3.8.4 requests descriptions of communication systems available to the Emergency Organization to communicate instructions and information both on-site and off-site throughout the course of the emergency. Please consider adding more detail to Section VII.D of the Emergency Plan or provide justification why such detail is not needed.

8.

ANSI/ANS-15.16-2008, Section 3.3(3) and 3.8.3(5) requests arrangements and agreements, confirmed in writing with local support organizations and assurance that hospital and medical services can provide required services...Section VII.C of the Emergency Plan states, The Dow Medical Departmenthas agreements to transfer patients to the Midland Hospital Center. Please clarify the following or provide justification as to why this detail is not needed:

a.

Is there a written agreement between Dow and the Midland Hospital Center to provide services?

b.

Is the Midland Hospital Center equipped, trained and qualified to handle radiological emergencies?

9.

ANSI/ANS-15.16-2008, Section 3.10.1(1) requests a description of training provided to off-site personnel.Section IX.A of the Emergency Plan does not appear to address the subject. Please identify what types of training are provided to off-site personnel who have specific emergency assignments and with what frequency the training is provided, or provide justification as to why this detail is not needed.