ML18030A797
| ML18030A797 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/19/2018 |
| From: | Framatome |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| TJT:18:010 E10-08-008 | |
| Download: ML18030A797 (6) | |
Text
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 8 Emergency Management E10-08-008 Version 2.1 Page i EHS&L Document SNM-1227 - Chapter 8 Emergency Management Nature of Changes Item Paragraph Description Justification
- 1.
Entire Document Changed AREVA Inc. to Framatome Inc.
Company Name Change
- 2.
- 3.
- 4.
- 5.
- 6.
- 7.
- 8.
- 9.
- 10.
List Below any Documents, including Forms & Operator Aids which must be issued concurrently with this document revision:
This Document contains a total of 6 pages excluding the signature page.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 8 Emergency Management E10-08-008 Version 2.1 Page ii DOCUMENT REVIEW/APPROVAL/DELETION CHECKLIST All new and/or revised procedures shall be approved by the change author, cognizant manager(s) of areas affected by the changes, and by applicable manager(s) of any function that approved the previous revision of the document unless responsibility for such approval has been transferred to another organization. Also, the procedure shall be approved by manager(s) of functional organizations that provide technical reviews with the exception of the Training Department. Finally, Document Control shall verify that the required approvals have been properly obtained and that any documents that must be issued concurrently are ready to be issued.
Document Reviews Document Approvals Purpose/Function of Review Specify Reviewer(s)
(Optional except for change author)
(Check all that apply)
Title of Approver (Check all that Apply)
Document Control (Automatic)
Document Control (Automatic)
Change Author CD Manning Author Independent Technical Review Operability Review(s)
Mgr, Richland Operations(1)
Conversion Mgr, Uranium Conversion &
Recovery Operations(1)
Recovery Ceramics Mgr, Ceramic Operations(1)
Rods Mgr, Rods & Bundles(1)
Bundles Components Mgr, Component Fabrication(1)
Maintenance Review Mgr, Maintenance(1)
Lab Review Mgr, Production Support(1)
Transportation Mgr, Ops Strategy & Supply Chain EHS&L Review(s)
Mgr, EHS&L(2)
Criticality Mgr, Nuclear Safety(2)
Radiation Protection Safety Mgr, Safety(2)
Security/Emergency Prep.
JM Deist Mgr, Security & Emergency Preparedness(2)
Fire Safety MC&A CD Manning Mgr, Licensing & Compliance(2)
Transportation Environmental Mechanics Richland Review Mgr, Mechanics Richland Mechanics Lynchburg Review Thermal-Hydraulics Richland Review Mgr, Thermal-Hydraulics Richland Thermal-Mechanics Richland Review Mgr, Materials & Therm-Mechs Project & Reliability Review Mgr, Project & Reliability Eng.
Quality Review Mgr, Richland Site Quality Purchasing Review Mgr, PP&CPC Others:
Mgr, Richland Site/Other Document Control Richland Records Management Training & Employee Dev.: (3)
Training & Employee Dev.
(1)Note: If approvals include 2 or more product center managers, the Operations manager can be substituted for the applicable product center managers.
(2)Note: If approvals include 2 or more EHS&L functional managers, the EHS&L manager can be substituted for the applicable EHS&L functional managers.
(3)Note: Training department review is required for all procedures that require or affect a Learning Plan and if additional training materials or curriculum must be revised before issuing procedure.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 8 Emergency Management E10-08-008 Version 2.1 Page iii 23371 (Rev. 001, 01/09/2018)
EHS&L CHANGE IMPACT EVALUATION FORM The scope and content of this document have been determined by EHS&L to not impact the safety disciplines checked below. Future revisions do not require review by those EHS&L component(s) unless the scope changes such that a previously excluded safety discipline may be impacted.
Criticality Radiation Protection Safety/Security Emergency Preparedness MC&A Transportation Environmental DOCUMENT VERSION:
EHS&L REVIEW COMPONENT:
EVALUATION DATE:
CHANGE EVALUATOR*:
2 ND PARTY APPROVAL*:
The scope and content of this document have been determined by EHS&L to not directly impact the safe handling of licensed materials (enriched uranium). Future revisions to this document do not require the 10CFR 70.72 change evaluation unless the scope of the document changes such that it directly impacts the handling of licensed materials.
DOCUMENT / ECN NO**:
E10-08-008 EVALUATION DATE:
1/19/18 CHANGE EVALUATOR:
CD Manning Does the change potentially impact Criticality Alarm System (CAS) coverage?
YES NO EVALUATION OF NRC PRE-APPROVAL:
IS NRC PRE-APPROVAL ( LICENSE AMENDMENT ) NEEDED?
Based on YES answer to any of five questions below.
Based on NO answer to all five questions below.
YES NO
- 1.
Does the change create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 (create high or intermediate consequence events) and that have not previously been described in Framatomes ISA Summary?
YES NO
- 2.
Does the change use new processes, technologies, or control systems for which Framatome has no prior experience?
YES NO
- 3.
Does the change remove, without at least an equivalent replacement of the safety function an item relied on for safety (IROFS) that is listed in the ISA Summary?
YES NO
- 4.
Does the change alter any item relied on for safety, listed in the ISA Summary, that is the sole item preventing or mitigating an accident sequence of high or intermediate consequences?
YES NO
- 5.
Does the change qualify as a change specifically prohibited by NRC regulation, order or license condition?
YES NO Evaluation of Actions Required PRIOR TO OR CONCURRENT with Change Implementation:
- 6.
Modification / Addition to CAS system or system coverage documentation YES NO
- 7.
Acquire NRC pre-approval (LICENSE AMENDMENT)
YES NO
- 8.
Conduct/modify ISA YES NO
- 9.
Modify /
update the following:
None Other ISA Database Red-Line Drawings/P&ID NCSA NCSS NCSP PHA RHA FHA ChHA Procedures Evaluation of Actions Required SUBSEQUENT TO Change Implementation:
- 10. Modify /
update the following:
None Other ISA Database AS-Built Drawings/P&ID NCSA NCSS NCSP PHA RHA FHA ChHA Procedures Justification Section for YES preceding Questions 1 - 8 or other for 9, 10: Being prepared as part of a License Amendment, however pre-approval of the amendment prior to issuing is not required.
(*)
Only required if one or more of the boxes to exclude a particular safety discipline review is checked.
(**)
If this form exists as a part of a document, the document number is not required.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 8 Emergency Management E10-08-008 Version 2.1 Page iv 23371 (Rev. 001, 01/09/2018)
EHS&L CHANGE IMPACT EVALUATION FORM The scope and content of this document have been determined by EHS&L to not impact the safety disciplines checked below. Future revisions do not require review by those EHS&L component(s) unless the scope changes such that a previously excluded safety discipline may be impacted.
Criticality Radiation Protection Safety/Security Emergency Preparedness MC&A Transportation Environmental DOCUMENT VERSION:
EHS&L REVIEW COMPONENT:
EVALUATION DATE:
CHANGE EVALUATOR*:
2 ND PARTY APPROVAL*:
The scope and content of this document have been determined by EHS&L to not directly impact the safe handling of licensed materials (enriched uranium). Future revisions to this document do not require the 10CFR 70.72 change evaluation unless the scope of the document changes such that it directly impacts the handling of licensed materials.
DOCUMENT / ECN NO**:
EVALUATION DATE:
CHANGE EVALUATOR:
Does the change potentially impact Criticality Alarm System (CAS) coverage?
YES NO EVALUATION OF NRC PRE-APPROVAL:
IS NRC PRE-APPROVAL ( LICENSE AMENDMENT ) NEEDED?
Based on YES answer to any of five questions below.
Based on NO answer to all five questions below.
YES NO
- 1.
Does the change create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 (create high or intermediate consequence events) and that have not previously been described in Framatomes ISA Summary?
YES NO
- 2.
Does the change use new processes, technologies, or control systems for which Framatome has no prior experience?
YES NO
- 3.
Does the change remove, without at least an equivalent replacement of the safety function an item relied on for safety (IROFS) that is listed in the ISA Summary?
YES NO
- 4.
Does the change alter any item relied on for safety, listed in the ISA Summary, that is the sole item preventing or mitigating an accident sequence of high or intermediate consequences?
YES NO
- 5.
Does the change qualify as a change specifically prohibited by NRC regulation, order or license condition?
YES NO Evaluation of Actions Required PRIOR TO OR CONCURRENT with Change Implementation:
- 6.
Modification / Addition to CAS system or system coverage documentation YES NO
- 7.
Acquire NRC pre-approval (LICENSE AMENDMENT)
YES NO
- 8.
Conduct/modify ISA YES NO
- 9.
Modify /
update the following:
None Other ISA Database Red-Line Drawings/P&ID NCSA NCSS NCSP PHA RHA FHA ChHA Procedures Evaluation of Actions Required SUBSEQUENT TO Change Implementation:
- 10. Modify /
update the following:
None Other ISA Database AS-Built Drawings/P&ID NCSA NCSS NCSP PHA RHA FHA ChHA Procedures Justification Section for YES preceding Questions 1 - 8 or other for 9, 10:
(*)
Only required if one or more of the boxes to exclude a particular safety discipline review is checked.
(**)
If this form exists as a part of a document, the document number is not required.
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 8 Emergency Management E10-08-008 Version 2.1 Page v Table of Contents 8.0 Emergency Management..............................................................................................8-1 8.1 Emergency Plan...............................................................................................8-1 8.2 Emergency Plan Implementing Procedures......................................................8-1 8.3 Amendment of the Emergency Plan..................................................................8-1 8.4 Agreements with Offsite Emergency Response Resources..............................8-1
EHS&L Document Licensing - NRC Materials License SNM-1227 - Chapter 8 Emergency Management E10-08-008 Version 2.1 Page 8-1 8.0 Emergency Management 8.1 Emergency Plan Framatome Inc. (Framatome) has and will maintain an emergency plan (E08-01-1.0, Version 3,0, or as subsequently revised) for its Richland fuel fabrication facility in accordance with the requirements of 10 CFR 70.22(i). Content of the plan is in accordance with 10 CFR 70.22(i)(3) and considers U.S. Nuclear Regulatory Commission (NRC) guidance in Regulatory Guide 3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities.
8.2 Emergency Plan Implementing Procedures Framatome has developed and will maintain approved written procedures to assure effective implementation of its facility emergency plan.
8.3 Amendment of the Emergency Plan In accordance with 10 CFR 70.32(i), Framatome will not implement changes to the plan that decrease its effectiveness without prior application to, and prior approval by, the NRC.
Changes that do not decrease the effectiveness of the plan may be made without NRC approval. Copies of such changes will be provided to the NRC and appropriate organizations within six months of making the changes, in accordance with 10 CFR 70.32(i).
8.4 Agreements with Offsite Emergency Response Resources Framatome has established and maintains formal written agreements with appropriate offsite emergency response organizations (fire, police, medical, etc.) as needed to assure implementation of its emergency plan and associated response procedures. These agreements are reviewed and renewed as appropriate and maintained on file at the Richland site.