ML19263A740
| ML19263A740 | |
| Person / Time | |
|---|---|
| Site: | 07000036, 07001100 |
| Issue date: | 11/17/1978 |
| From: | Crow W, Nixon W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901020247 | |
| Download: ML19263A740 (11) | |
Text
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UNITED STATES 4
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
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November 17, 1978 DOCKET NO.:
70-36 (SNM-33) & 70-1100 (SNM-1067)
PURPOSE:
Review of Combustion Engineering Emergency Plans PLACE & DATE:
NRC Offices, Silver Spring; November 17, 1978 ATTENDEES:
NRC - W. T. Crow CE - H. E. Eskridge N. Ketziach F. Pianki W. A. Nixon G. J. Bakevich A meeting was held on November 17, 1978 with representatives of Combustion Engineering to discuss the emergency plans submitted to NRC for review on April 27, 1978 (70-36) and July 14, 1978 (70-1100).
The attached list of qtiestions and ccmments on the CE emergency plans were discussed with, and copies given to, the CE representatives.
CE was asked to respond to the coments and questions by modification and resubmission of the emergency plans within O days of today's date (11/17/78).
In addition to the emergency plans, the need for additional informa-tion related to the decontamination and decommissioning plans for the Hematite and Windsor facilities were discussed. CE will submit their decontamination and decomissioning plans for both the Hematite and Windsor facilities by January 15, 1979.
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its Tw/4 W. A. Nixon W. T. Crow, Section Leader Fuel Processing and Uranium Fuel Fabrication Section Fabrication Branch Division of Fuel Cycle and Material Safety h%g N. Ketzlach Fuel Processing & Fabrication Branch Division of Fuel Cycle and Material Safety 7901oyog
LIST A COMMENTS AND QUESTIONS APPLICABLE TO BOTH SNM-1067 AND SNM-33 EMERGENCY PLANS 1.
Section 3 The " Scope and Applicability" section should include a sumary of the relationship of the plan with (1) facility operating radiological control and industrial security procedures, (2) other emergency plans of the company, and (3) emergency plans of participating offsite agencies.
2.
Section 4.2 a.
The " Emergency Alert" classification should include specific candidate situations associated with in-plant events involving radioactive materials.
b.
The person or persons responsible for determining when an
" Emergency Alert" condition exists should be identified.
4 3.
Section 4.3 a.
The " Plant Emergency" classification should include notification of corporate headquarters and, in turn, notification of appropriate off-site agencies to alert them to the nature and extent of the accident. Provisions should be included to request that off-site
~;
agencies which may be required to respond to a particular l
emergency assume an alert condition until the emergency is t,hrminatera:
s
2 b.
This section should describe the alarm or alarms used to announce a Plant Emergency and the emergency action levels for initiating a Plant Emergency.
4.
Section 4.4 a.
Mobilization and readiness of principal off-site emergency sponse organizations are recommended measures for Site Emergencies. Associated assessment actions include provisions for monitoring the environment.
b.
Criteria for identifying a Site Emergency should be more specific and should clearly distinguish between Plant and Site Emergency situations.
1 i
c.
Those persons with authority to declare a Site Emergency should be clearly identified.
5.
Regulatory Guide 3.42, Section 4.2, Spectrum of Postulated Accidents.
The emergency plan should include a section which gives the information called for in Section 4.2 of Regulatory Guide 3.42.
6.
Section 5 The description of the emergency organization should be expanded and clarified. Specific topics which should be discussed include:
3 a.
The emergency organization for each class of emergency for day shift, night shift and weekends or holidays should be described. The use of the tenn " Site Emergency Plan" is confusing.
Does this term apply to site emergencies as described in Section 4.4, or does it also apply to plant emergencies and emergency alerts?
b.
The arrangements made to assure that adequate trained personnel are on site at all times to cope with emergencies should be discussed. This discussion should describe the staffing of emergency response groups; for example, the fire brigade, health physics experts, snd first aid specialists for the day, night and seekend or holiday periods.
c.
The line of succession for the emergency director should be specified.
d.
The changes, if any, in emercancy organization if management personnel are recalled to the site during an emergency should be discussed.
e.
The limits of the authority and responsibility of the emergency director should be described and his relationship to upper management personnel clarified. The management documentation granting authority to the emergency director should be described.
4 f.
The procedures to be followed and the approvals needed when issuing public statements concerning emergencies should be specified.
g.
Emergency plans should include provisions for accounting for visitors and contractor personnel during an emergency.
7.
Section 5.4 a.
The section on " Coordination with Participating Government Agencies" (5.4) should include a description of the authority and responsibility of the agency for emergency preparedness planning for the emergency response, particularly in relation to the authority and responsibility of the licensee and of other agencies (see Section 5.4 of RG 3.42 for additional requirements of this section of the plan).
b.
How is a determination made that contact with the cognizant government agencies in the event of an emergency is only in the form of " notification" rather than for a request for emergency r.ssistance? Some of emergency classifications ms; require emergency assistance.
c.
The criteria to be used to determine whether outside agencies should be contacted should be specified.
5 8.
Section 6.2 a.
What are the " normal channels" used to instruct personnel?
b.
What are the action levels for notification of offsite agencies and how are they notified?
c.
How does activation of the emergency alarm signify termination of the alert?
9.
Section 6.3 a.
What means of communication (normal and backup) exist for calling in outside assistance to combat the emergency?
b.
How does the Director determine the plan of action without the assistance of personnel other than those listed key members of the emergency organization (e.g., fact finding comnittee and radiological safety advisor)?
c.
Who contacts the appropriate offsite support group for additional assistance?
d.
Direction for care of injured personnel, combating specific problems, preventing unauthor'.2ed entry, etc., should be pre-planned and not ad hoc decisions by the Emergency Director.
6
- 10. Section 6.4 a.
In the event of a nuclear criticality incident, whatis the maximum dose at the nearest site boundary?
b.
What instructions are given the re-entry team in order to minimize the chances of a second criticality accident?
c.
What criteria are used for permitting the return of the facility to normal use?
d.
What provisions are provided for monitoring in case of a non-criticality site emergency and what action levels will be used to determine the need for off-site assistance?
e, Are all of the actions listed; for example, arrange for treatment of it.,Jred or exposed personnel preplanned and included in the emergency procedures?
- 11. Section 7.2 a.
Is there an in-plant loudspeaker system?
b.
Are both normal and emergency telephones located in the emergency center?
c.
Has a message authentification scheme been developed for use when communicating with off-site agencies (see R.G. 3.42, Para. 6.1)?
7
- 12. Section 7.4 It would be preferable, in this section, to refer to the Appendix for a listing of emergency equipment. The Appendix list should, however, be complete.
- 13. Section 8.0 a.
A description of the specialized initial training and retraining programs should be provided for each of the categories outlined in Section 8.1.1 of R. G. 3.42.
b.
Although retraining on an annual basis is adequate for operating personnel, it is not adequate for all members of the emergency organization (e.g., fire birgade).
c.
Training given personnel should be documented.
d.
The annual review of the emergency plan should be documented.
- 14. Section 8.3 a.
Testing of alarm systems should be documented, b.
Is the Nuclear and Industrial Safety group responsible for testing all emergency equipment? Inspections and testing should be documented.
8
- 15. Section 9 a.
General plans for recovery should be described, including applicable criteria for re-entry, recovery and for restoring the facility as nearly as possible to a safe operating condition.
b.
Deficiencies identified in the investigation of the incident shall be resolved prior to resumption of operations.
LIST B COMMENTS AND QUESTIONS APPLICABLE TO SNM-1067 EMERGENCY PLANS 1.
General The emergency plan should be adcressed to both the Nuclear Laboratories and the Nuclear Fuel Manufacturing Facility.
Both facilities are part of License No. SNM-1067.
Particular attention should be given to assuring that the emergency organization covers the laboratories and that those responsible for emergency response have authority to take appropriate action if an emergency occurs at the laboratory. The organization charts in the SNM-1067 license indicates no interaction between the Nuclear Fuel Manufacturing and the Nuclear Laboratories below the level of Vice President, Nuclear Power Systems.
2.
Section 4.5 Although no hypothetical accident has been postulated that has sufficiently severe consequences to be identified as a General Emergency, the reference sited should be replaced by one that provides the indicated conclusion.
3.
Figure 5.1 Clarify the portion of the Emergency Organization Chart that shows the
" Fire Brigade" reporting to the " Fire Brigade".
4.
Section 5,3 a,
The availability of ambulance services for the transport of radiation casualties to a hospital should be included under the local services support.
2 b.
Evidence of the arrangements and agreements with the local fire fighting organization should be included.
5.
Section 6.0 A map (s) should be provided that indicates the location of buildings where radioactive materials are handled and support areas (e.g.,
emergency control center, emergency and alternate emergency assembly areas, site medical department, Building No. 5, East Guard House, site boundaries).
6.
Section 7.6 The presence of fire extinguishers in the Nuclear Laboratories should be verified, 7.
Appendix Requirements a.
Copies of agreements with local fire departments and ambulance services to provide supporting services should be included.
b.
The emergency equipment should include environmental sampling supplies, radiation survey instruments and decontamination supplies.