ML19253C728
| ML19253C728 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 10/30/1979 |
| From: | Row W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kirk W UNITED NUCLEAR CORP., UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 7912120032 | |
| Download: ML19253C728 (4) | |
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s, 0CT 3 01979 FCUP:RLS70-371 SNM-368 United Nuclear Corporation ATTN: Mr. W. F. Kirk, Manager Nuclear and Industrial Safety Department Naval Products Division 67 Sandy Desert Road Uncasville, Connecticut 06382 Gentlemen:
We have reviewed the emergency plan for the Naval Products Division as revised March 7,1979. We find that the plan lacks certain information and commitments called for in Appendix E of Part 50. We request that you provide revised or new pages for the plan to include the information and commitments identified in the attachment.
To permit us to meet the revised schedule for completion of the review of your emergency plan, you should provide us the information and commit-ments within forty-five days of the date of this letter.
Sincerely, g
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(U, 'f W. T. Crow, Section Leader Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety
Attachment:
Conments and Questions on Emergency Plan, United Nuclear Corporation Naval Products Division, March 7, 1979, Docket 70-371 1534 337 b
7912120
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Comments and Questions on Emergency Plan, United Nuclear Corporation Naval Products Division March 7,1979, Docket 70-371
- 1. ' General - It is desirable that the plan be an inspectable identified en ti ty.
It is, therefore, requested that the plan be identified with an up-to-date list of effective pages givino page dates and revision numbers.
The pages of the Emergency Plan are marked "Part II. Safety Demonstration." In spite of this designation, the statements in the plan will become conditions of the license when the plan is ultimately accepted and authorized by license amendment.
It is recommended that in future revisions of the Emergency Plan consideration be given to making the fonnat correspond to that in Regulatory Guide 3.42, " Emergency Planning for Fuel Cycle Facilities and Plants Licensed Under 10 CFR Parts 50 and 70."
The revised format would be helpful in meeting the information requirements suggested in the guide.
2.
Page 6.1-2 (Objectives) - There should be an explanation of the relation of this plan to the emergency plans of the local and State governmental agencies.
3.
Page 6.2-1, Section 6.2 - Since the plan should stand as an independent entity, this section should include a brief description of the normal organization.
4.
Pages 6.2-3 and 6.2-4, - The plan should identify the position responsible for inspection and maintenance of the emergency equipment and state the required frequency for such inspections.
5.
Page 6.2-5, paragraph 6.2 a.
It should be made clear that the assignments of responsibilities under emergency conditions include those positions or individuals responsible for leadership in the functional areas listed, b.
There should be provision for damage control and plant operations and a brief description of the arrangements.
6.
Page 6.2-5A -
a.
Reference to Wood River Junction as a source of a consulting specialist in criticality safety is not correct and should be deleted or corrected.
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2 b.
The reference to USERDA should be corrected.
c.
Why are the State Police the only State agency identified?
7.
Page 6.2 a.
Please describe the arrangements that UNC has made with State agencies for UNC to be notified of impending natural disasters.
b.
How will UNC obtain meteorology data for assessing possible off-site effects of radioactive material releases?
3.
Page 6.3-1, paragraph 6.3 - It is implied that the Connecticut State Department of Environmental Protection is the principal State agency with action responsibilities for radiological emergencies.
Please provide a brief description of the response capabilities of that agency and the designation and location of the Emergency Operations Center.
9.
Page 6.3-5, paragraph 6.3.2.1 - What is the minimum frequency of testing specified for the emergency generator system?
10.
Page 6.3-8, paragraph 6.3.3.1 - It should be confirmed that operations with fuel will be discontinued until the criticality alarm system is functioning.
11.
Pages 6.3-14,15, and 16, Tables 3., 4 and 5 - (It is recognized that the Table lA action levels are consonant with these tables.) How was it detemined that the local and State agencies responsible for emergency planning are in agreement with the action levels implied by these tables?
12.
Page 6.3-17, paragraph 6.3.7.1 - The quoted 1016 fissions do not represent enough thermal energy to eject much water as steam, so that the scenario is fallacious and should be corrected.
- 13. Page 6.4-1, Section 6.4 -
a.
The text should be augmented with the location and brief descriptions of the damage control equipment and supplies.
b.
What is the location of the Emergency Control Center with respect to the prevailing wind direction and the evacuation routes?
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3 14.
Page 6.5 The general criteria relevant to a re-entry decision should be given. Thus, it should be noted that the procedures for recovery and re-entry will include replacement, and/or placing into operating condition, of emergency supplies and equipment.
15.
Page 6.6-1, paragraph 6.6.1, Criteria for Notification - Please state what is specifically meant by "... radioactive materials...in excess of amounts permitted at the site boundaries on a continuing basis."
16.
Page 6.8-3, paragraoh 6.8.1, D - Please state how often the local fire departments send representatives to the plant for re-orientation.
17.
Page 6.8-3, paragraph 6.8.2 - Please state the minimum frequency of drills of the UNC fire brigade and of participation of damage control teams in the emergency drills.
- 18. Appendix A - Agency Agreement Letters - There should be a commitment to review and obtain updated agreement latters at least once every two years.
This comment applies to all important agreements and particularly to the agreenents with the Department of State Police, the liohegan Fire Company, the State of Connecticut Department of Environmental Protection, and the Brookhaven area office of DOE, all of which are over two years old. Copies of updated agreements should be provided.
- 19. Appendix B - Plots should be provided of time-distance dose for accidental criticality.
It should be recognized that not all criticality accidents have terminated promptly, e.g., the " burst" at Hanford in 1962 continued for about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
- 20. Appendix C - Procedure List - Which of the listed procedures covers the requirements for personnel monitoring and decontamination?
- 21. Annex D, UNC/NPD Plant Layout - The plot plan should be revised to show the locations of the emergency control centers (as claimed in paragraph 6.4.1 on page 6.4-1) and drawn to scale with the scale shown.
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