ML19263B563
| ML19263B563 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/04/1979 |
| From: | Nechodom W SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901220011 | |
| Download: ML19263B563 (9) | |
Text
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fpt E(ON NUCLEAR COMPANY,Inc.
REsEA ACH AND TECHNOLOGY CENTER 2055 George Wasnington Way RicNand. WasNngton 99352
. 3 to 0
PHONE: (503)943 7100
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January 4, 1979
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Mr. William T. Crow gg.
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3 Fuel Reprocessing & Fabrication Branch Division of Fuel Cycle and Material Safety
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U.S. Nuclear Regulatory Commission cocgtT ci.td Washington, D.C.
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Dear Mr. Crow:
Your letter of November 3,1978 transmitted a request for additional information regarding the contents of XN-NF-32, our Emergency Plan.
I have attached our responses to that request.
the attachment also responds where appropriate to comments from the NRC Region V office which we received separately. We would appreciate your prompt approval of these changes so that we can issue the final version of the Emergency Plan and begin implementing i t.
Very truly yours, b( W W. S. Nechodom, Manager Licensing and Compliance WSN: sir 790122oOti 1
AN AFFILIATE OF EXXON CORPORATION
RESPONSES TO NRC CUESTIONS Oli EMERGENCY l'LAN 1.
Page 5.3, Paragraoh 5.2.1.2, Emergency Cadre Q.
Who is the Alternate &ergency Director for the Hired 0:ide and Specialty Puela Building? What is the relation of this position to that of the Plant bergency Director?
A.
There are no persons designated as Alternate Emergency Directors for the fuel fabrication buildings. The fabrication building managers are designated as the Emergency Directors for their buildings. As such, they are responsible for the preparation of the emergency procedures for their buildings and provide a c?ntral emergency planning point within the buildings. The building managers are also assigned to the Plant Emergency Cadre based upon their training and experience and being the most knowledgeable persons on the status of their buildings.
In the event of an actual emergency condition, the P5 ant Emergency Director, or an Alternate, is in charge, even if the emergency only involves one building.
Based upon the particular emergency condi-tion, the Plant Emergency Director may delegate various duties to a Building Director.
If a Building Emergency Director is not present, the Plant Emergency Director may perform the duties himself or delegate them to another member of the Emergency Cadre. Thus, there is no specific need for Alternate Building Emergency Directors.
2.
Page 5.6, Paragraph e.,
First Aid Q.
Please relate the ninimum information and skills obtained in the
" basic" and " advanced" first aid courses to the expected de:~. ands that vould be mde on trainees under accident conditions.
A.
Per State of Washington Law (WAC 296-24-060), our managers and supervisors must receive basic first aid training and be certified as having completed the course. The 18-hour Basic Industrial First Aid Course is prescribed by the State's Division of Indus-trial Safety and Health and requires instruction involving student participation in exercises involving the following:
Bleeding control and bandaging Practical methods of artificial respiration, including mouth-to-mouth and mouth-to-nose resuscitation Closed chest heart massage Poisons Shock, unconsciousness, stroke Burns, scalds Sunstroke, heat exhaustion
2-Frostbi.e, freezing Strains, sprains, hernias Fractures, dislocations Proper transportation of injured Bites, stings Subjects covering specific health hazards likely to be encountered by co-workers of first aid students enrolled in the course The 10-hour Advanced Industrial First Aid Course taken by the Emergency Crews covers the same subjects, but is directed towards mass casualty accidents. The course includes a two-hour mass casualty practical exercise.
The basic course provides the necessary skills for a person to adequately handle incidents of the personnel emergency classifi-cation. The advanced course provides the skills for the possible mass casualties of higher emergency classifications.
The Emergency Plan will reference the Washington State Law to define the course contents.
3.
Page 6.2, Paragraph 6.1, Activation of Emergency Organization Q.
This parag mph should include the action tevels and/or criteria that vitt be the basis for notification of off-site agencies.
A.
We believe that the proper place for the action levels and/or criteria is the detailed implementing procedures for the various events. Otherwise, the descriptive section of the Emergency Plan becomes unduly complicated.
The action levels in the implementing procedures will be as follows:
a.
Personnel Emergency Ambulance - Called at any time injuries are such that the injured personnel should not be transported in either private or Exxon Nuclear vehicles.
b.
Emergency Alert Fire Department - Called for desert grass fires within the area specified on Page 4.3, Paragraph e.,
if the fire department is not already on the scene.
c.
Plant Emergency Battelle Northwest Radiological Assistance - Called for any event falling within this classification where any radio-active deposition above normal background is found at the site boundary.
. Ambulance - Called any time injuries are such that injured personnel should not be transported in either private or E an Nuclear vehicles.
Fire Department - Called if a fire is associated with the event.
d.
Site Emergency Battelle Northwest Radiological Assistance - Called for any event falling within this classification where any radioactive deposition above normal background is found at the site boundary.
Benton County Sheriff (to activate Benton County portion of Benton/ Franklin Counties' Nuclear Incident Response Plan) -
Called for any event within this classification where there is confirmed off-site release in excess of 50 kg UF
" I "9 plutonium.
6 Franklin County Sheriff (to activate Franklin County portion of Benton/ Franklin Counties' Nuclear Incident Response Plan) -
Called as a courtesy any time the Benton County Sheriff is notified. Called for action for any event within this classi-fication where there is confirmed off-site release in excess of 50 kg UF cr 1 mg plutonium, when the wind is from the g
south to any direction clockwise from south-southwest to north-northwest.
Ambulance - Called any time injuries are such that injured personnel should not be transported in either private or Exxon Nuclear vehicles.
Fire Department - Called if a fire is associated with the event.
e.
General Emergency As stated in 4.2 e (Page 4.10), this classification involves hypothetical events not judged to be credible during the life-time of the facilities and procedures to cope with them are excluded from the plan. Therefore, specific action guides will not be included. The list which would oe called in the event of an incident in this classification is stated in 6.1 e (Page 6.2) and is the same as the list for Site Emergency described above, plus notifying DOE Region 8 Radiological Assistance.
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e 4.
Page 6.3, Paragraph 6.2, Assessment Actions Q.
"his paragraph describes data collection methods but should also describe the methodology of assessment.
A.
A general introductory paragraph will be added to Paragraph 6.2 as follows:
Data collected during any emergency event will be assessed to determine the magnitude of the event, the extent of any spread of radioactive material both on and off-site, the extent of injuries and/or contamination of personnel, the need for Exxon Nuclear emergency personnel, and the need for off-site notifications and/or assistance.
5.
Page 6.7, Paragraph 6.4.lb, Site or Partial Site Q.
E3ference is made, here and elsechere to the Benton/ Franklin Counties' Nuclear Incident Response Plan. A copy of the plan should be provided or a stemry description given in Appendi: 1.
A.
We believe that the general description given in Paragraph 5.4 and the excerpts from the 'lan given in Paragraph 5.4.1 are adequate.
p The Director, Department of Emergency Services, Benton County, has been requesced to forward a copy of the plan to you.
6.
Page 6.11, Paragraph 6.5.4, Medical Treatment Q.
What hospital services are available as backup for Fadlec Rcapital in the treatment of injured or contaninated personnel?
A.
Kennewick General Hospital in Kennewick, WA and Our Lady of Lourdes Hospital in Pasco, WA are available as backup to Kadlec Hospital for the treatment of injured personnel. The Northwest Health Service Energency Decontamination Facility is a special facility which has a complete medical and surgical capability.
It will be used for contaminated personnel. The plan will be revised to include men-tioning of these two hospitals as backup to Kadlec.
7.
Page 7.2, Paragraph 7.2, Communication Systems Q.
Please confirm ocmpletion of the tie-in of the 5:1~1 2a= ids telephone system to the UO, plant emergency generator.
What is the e~ergency pouer scurce for"the Plant Crash Alar t :elephone system?
A.
The tie-in of the Horn Rapids telephone system to the emergency generator will be completed by the end of January 1979. The emergency power source for the Plant Crash Alarm Telephone system is
. a combination of the U09 plant emergency generator and batteries and/or an emergency genBrator at the General Telephone Company Richland Central Office. This information will be added to the Emergency Plan.
8.
Page 7.5, Paragraph 7.5, First Aid and Medical Facilities Q.
Please dtscribe the " General First Aid Kits" and shou their adequacy for the anticipated use.
A.
The contents of the first aid kits are specified by WAC 296-24-065 and are dependent upon the number of personnel assigned to the worksite. One or more 36-package kits are maintained at each of the locations listed in Paragraph 7.5.
A 36-package kit contains the following:
4 packages, absorbent gauze 24" x 72" (1 per package) 2 packages, adhesive bandages, 1" (16 per package) 5 packages, bandage compresses, 4" (1 per package) 2 packages, eye dressing, (1 per package) 1 package, scissors and tweezers (1 each per package) 8 packages, triangular bandages, 40" (1 per package) 1 package, antiseptic soap or pads (3 per package) 13 packages, consulting physicians choice which are:
1 package, assorted patches and spots adhesive bandages 1 package, ammonia inhalents 1 package, eye wash solution 1 package, antiseptic swabs 1 package, cotton 2 packages, 1/2 inch adhesive tape 1 package, cotton tip applicators 2 packages, ice pack 1 package, digel 1 package, aspirin 1 package, tourniquet In addition to the General First Aid Kits maintained per state law, there are two trauma kits also on site. These kits are larger versions of the General First Aid Kits and also include air splints, blankets, burn sheetr, poison antidote kit, and snake bite kit. One kit is located in the U0,3 Building and the other is located in the Office Building 4 emergehcy supplies.
We believe that the emergency medical supplies are adequate for the intended use for the casualties expected at this site. This infor-mation will be added to the plan, either by reference to the Washington State Law or in detail.
. 9.
Page 8.2, Paragraph 8.1.id, Fire Extinguishers Q.
Please confim that the D:ergency Creu has been trained in the use of large exting:dsher units and 'Luter rults" using fire hoses.
A.
The training was conducted on November 15,16 and 17,1978.
It will be conducted annually thereafter.
- 10. Page 8.2, Paragraph 8.1.le, UO Building Chemical Ocerations Personnel 3
Q.
Please describe the training of the creo responsible for d=r:ge control for the Mixed 0:ide a:d Specialty Fuels Plant.
A.
This paragraph refers to unique training conducted in the UO2 plant chemical operations area.
The, e is not a comparable area in the Mixed 0xide and Specialty Fuels Plant Specific training in damage control, other than the above, is not routinely conducted as part of the Emergency Crew training. Building personnel and plant main-tenance forces are trained in " equipment protection" aspects; their normal job duties to handle problems such as broken lines, water, and electrical outages, etc.
- 11. Pages 8.3 and 8.4, Paragraph 8.1.2, Drills and Exercises Q.
a.
Provide justification for the annual frequency for drilis of the emergency fire brigade instead of quarterly frequency suggested in Regulatory Guide 3.42.
A.
a.
The Emergency Crews have been established as a combined emer-gency re*.ponse force rather than establishing separate crews for each type of emergency response. As the Richland Fire Department has the primary responsibility for fire fighting at the site, the Emergency Crew is only trained in "first aid" fire fighting techniques. Thus, annual training in the use of small fire extinguishers, plus annual training in the use of large extinguisher use and " water walls" is deemed adequate.
Q.
b.
Provide justification for not involving the state and local govern:~ient agencies in the annual Major Off-Site Release Eredse and not testing the coma:ication links and notifi-cation procedures.
A.
b.
The annual exercise is now being prepared and state and local government agencies will be invited to participate. At a minimum, we will include a specific test of the comunication links and notification procedures for both Benton and Franklin Counties.
Our cormunication link to the Emergency Dispatch Center (which includes the Benton County Sheriff) is already tested three times a day.
This information will be added to the Emergency Plan.
. Q.
c.
Please describe the procedure for critique of drills.
A.
c.
A letter is prepared for each of the semi-annual practice evacuations describing any problems encountered. The letter is reviewed by the Plant Emergency Director and the Nuclear Fuels Department Health and Safety Council and any necessary corrective action taken.
The results of the mass casualty simulation were discussed with Emergency Crew members immediately following the exercise.
The results of the large extinguisher exercise were discussed with each Emergency Crew member during the exercise. No critique is necessary for the small extinguisher training.
The results of the air pack rescue simulation will be discussed with each participant immediately after the exercise.
The results of the Major Off-Site Release Exercise will be discussed with members of the Emergency Cadre upon the com-pletion of the exercise. A Section 8.1.2f " Critique of Drills" will be added to the Emergency Plan describing this information.
Q.
d.
Provide,fustification for not involving the z pir and damge tec=s in the annual drills.
A.
d.
This subject is discussed in the response to Question 10.
Normal job training provides almost all the required training.
A specific drill was established for the U0 Building Chem-7 ical Operations Area where specific training to minimize UF releases was deemed necessary.
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- 12. Page 8.5, Paragraph 8.2, Review and Updating of the Plan and Procedures Q.
a.
Please describe hou the participants in the emergency creus are informed of changes.
A.
a.
Hinor changes are conveyed to emergency crew members through their team leader. Major changes will be conveyed through formal training sessions.
Q.
b.
Please confirm that written agreements with outside agencies vill be updated at least every two years.
A.
b.
Our intent is to update the agreements at two-year intervals and will work to that schedule.
However, it is not possible to guarantee that the new agreement will be completed on the biennial date.
These commitments will be added to the Emergency Plan.
.g.
- 13. Appendix 5 - Emergency First Aid Kits Q.
Wirs are emergency first aid kits o.-stted from the equipment category list?
A.
We will add the kits to the list.
.