ML19282C069
| ML19282C069 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/27/1979 |
| From: | Kaplan A GENERAL ELECTRIC CO. |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19282C070 | List: |
| References | |
| 12129, NUDOCS 7903200186 | |
| Download: ML19282C069 (7) | |
Text
GENER AL h ELECTRIC NUCLEAR ENERGY PRODUCTS DIVISION WILMINGTON M ANUFACTURING C
CASTLE H AYNE ROl60. P. O. BOX 780. W1LMINGTON, N. C. 2340t. (919) 343-5000 l
Febntary 27, 1979 Director Office of Nuclear Material Safety & Safeguards WN U. S. Nuclear Regulatory Ccmnission y
Washington, D. C.
20555 c
U r ND '4 Attention: Mr. W. T. Crow, Section Ieader ll-c-i Uranium Fuel Fabricaticn Section 2
r,, j lpJ Division of Fuel Cycle & Material Safety ep
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Dear Sir:
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References:
(1) NPC License SNM-1097, Docket #70-1113 a,i M '
(2) Ietter, A. L. Kaplan to W. T. Crow,1/9/79
Subject:
QUESTIONS FELATED 'IO GE-MD EMEPGE;CY PIAN With reference to activities authorized by SNM-1097, Cencral Electric Conpany submitted a copy of its new Emergency Plan for your review on January 9,1979, pertaining to the GE fml fabrication plant in Uilmington, N. C.
As a result of your review, scce questions were raised concerning the content of the plan.
Attached is the infoncation related to these questions.
General Electric perronnel muld be pleased to discuss this plan further with you and your staff as you may deem re ssary.
Very truly yours, GENEPAL ELECGIC CCt@ANY
~
h Arthur L. Kaplan, P.ager Licensing & Corpliarse iu:dits M/C J26 JIK:trw Attadrent
.. E t cc: Mr. J. B. Kahle, NPC-Atlanta Mr. D. J. Pe:~otti, NPC-Atlanta g ; q,,j g
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GENER AL Q ELECTRIC Mr. W. T. Crow February 23, 1979 Wilmington,anufacturing Department General Electric (bnpany ANSWERS TO NpC QUESTIONS CONCIFNING itm EMERGENCY PIAN The following is inforn.ation related to questions raised by your staff on 2 7/79 conmrning the General Electric Dnergency Plan subnitted on 1/9/79.
/
- 1) General - The commitments in the plan are not always clearly worded.
Wording such as "the emergency plan provides for" would be interpreted as introducing a requirement of a plan.
Sections of the plan have been clarified in places where needed following our review of the plan in connection with these questions.
- 2) Concerns - Paragraph 5:
a) This general paragraph fails to identify the communications links called for in the introductary paragraph under Paragraph 5.0 of Regulatory Guide 3.42.
paragraph 5.0 has been expanded to identify these catr,unication links.
b) Page 15, first paragraph under 5.2.1 - It isn't clear as to who is to be the Building Manager.
What specific position is meant by Senior Operations Manager?
e The Building Manager positiens have been clarified in Paragraph 5.2.1.
e The organizational position titles for each Building P2 nager have been added to Table 5.2.
c) Page 15, next to last paragraph - The line of succession by job titles should be given in the plan.
e The 13 of Luccession by job titles is given in each p_ccedure as ca%
ed cy incident, for each erergency organizatica positica involved.
of successicn only for the Emrgeraf Director has been added 9 Paragrcgh 5.2.1.
Mr. W. T. Crcw February 23, 1979 Page 2 d) Page 17, Paragraph 5.4 - The designation and location of the Emergency operation Center of each State / local governmental agency should be given here as called for in Regulatory Guide 3.42, raragraph 5.4-4.
- Iocations have been added to Paragraph 5.4 as the city only as actual street addresses and telephone nu:rhers may change.
e Telephone nurbers will appear on a wall of the Emergency Control Center.
e Agencies to be notified at offsite locations concerning an emergency and their telephone nu:rbers are identified in the prowdures for each type of incident.
e) Page 21, Table 5.3 - What distinction is intended between " medical services" and " medical services (personnel) ?"
"(Personnel)" refers to the " item" for which the organization is concerned with decontaminacing (i.e., Medical Services and Regulatory Conpliance are concerned with personnel decontanunation, while Fuel Manufacturing is conwrned with decontanunation of facilities and ecuipnent).
- 3) Concerns - Paragraph 6.0:
a) Page 24, third paragraph - The title list in Appendix B is not an acceptable summary of the essential provisions for activating the emergency organization and communications which ir called for in Paragraph 6.1 of Rer ulatory Guide 3.42.
We have summarized the information from the procedures for each type of incident and included it as Table 6.1.
b) Page 25, Paragraph 6.2.3 What has been done to arrange for radicactivity analyses by,an offsite contractor?
e GE has inhouse capability at the Wil."tington, N. C. site and at the GE Vallecitos Nuclear Center in Pleasanton, California.
e In addition, we can utilize the services and resources of Padiaticn Management Corporation on demand withcut a fonral contract sin these activities are within their nonral capabilities offered to the general
- public, c) Page 26, Paragraph 6.4.1 - Appendix B does not provide an acceptable summary of the basic criteria and i:=ediate protective action called for in RG 3.42, Paragraph 6.4.
Furthe rcre, Paragraph 6.2.3.1-1 refers to Paragraph 4.1.3 for mechanisms but gives no action levels, while 4.1.3.1 refers to " concentrations in uncontrolled areas in execss of the applicable exposure limits for that area (as re:ards ei ther airborne or liquid H ent)."
(Continued)
~
Mr. W. T. Crew February 23, 1979 Page 3 Also, there is no mention of action criteria for notification of persons involved and no mention of notification of visitors or contractor personnel.
e A stm. nary of these basic criteria and imediate protective actions has been added to Paragraph 6.4.
e We refer back to Paragraph 4.1.3 frcm Paragraph 6.2.3-1, not for-
"nechanisms" but only for 'a definition of " plant energency." Th.ts point has been clarified in Paragraph 6.2.3-1.
e A discussion of action criteria for notification of persons involved, including contractors and visitors by virtue of the notification nuthods, has been added to Paragraph 6.4.
e Quantitative values for action levels rust be considered along with the extent of the problem (e.g., concentration of radioactive material in liquids and volune of liquids involved). Such considerations are nude by the Building Manager in his decision-making process concerning involvement of the energency organizaticn in an' unusual incident, as specified in the procedures related to each type of incident.
e Imediate protective actions have been added to Table 6.2.
d) Page 28, Paragraph 6.5.4 - Is either the plant doctor or the doctors on the staff of the Hanover Memorial Hospital qualified to treat persons who are exposed to radiation?
e The plant doctor is qualified to treat people exposed 'to radiation by virtue of his years of experience at his specialized trauung at Oak Ridge National Laboratory.
e New Hanover Menorial Hospital nedical personnel are being trained by a physician (MD) en the staff of Radiation Managenent Corporation.
- 4) Paragraph 7.0 - Emergency Facilities & Equipment a)
Page 31, Paragraph 7.1 - What substitute arrangements have been made for the Emergency Control Center?
An alternate location has been added to Paragraph 7.1.
b) Page 32, Paragraph 7.3.1 -
i) What is the Autocall system?
The Autocall systen provides a redundant alarm for fire, criticality and scre equipment related to r/ironrental protecticn, which is operating cutside of nor. mal cperational parameters. This alarm is enuciated in the guard shack and is indepe". dent of all other related alar s.
Mr. U. T. Cror February 23, 1979 Page 4
- 11) What prior detection systems are provided?
Specification of these systems has been added to Paragraph 7.3.1.
These include the fire alarm systens (equipped with snoke detectors in some locations of the fuel ranufacturing building), the criticality warning system and the Autocall system.
c) Page 32, Paragraph 7.4 - A description should be provided of specific facilities and equipment that are intended to serve a protective function, as called for in RG 3.42, Paragraph 7.4.
The description has been added as parts of Paragraph 7.4.1 and Paragraph 7.4.2, and as a new Paragraph 7.4.3.
d) Page 33 - A summary description should be given of damage control equipment.
o This has been added to Paragraph 7.6.
e The designation for such equipnunt has been properly changed to " facilities damage centrol equipnent."
e) Page 33, Paragraph 7.6 - What arrangements have been made to insure access to the damage control equipment and supplies?
A descriptien of these arrangements has been added to paragraph 7.6.
The majcrity of the facility damage control equipment is located in the
!!aintenance Building which is open dunng day-shift opration.
During off-shift hours, supervisors and guards have access to this building by possession of keys thereto.
- 5) Paragraph 8.0 - thintaining Emergency Preparedness a) Page 35, Paragraph 8.1.3 - The position assigned the duties of Emergency Preparedness Coordinator should be identified.
Paragraph 8.1.3 has been e>:panded to incitrle this information.
The Emergency Preparedness Ccordinator has tan established as a permanent position for GE-Wilmington.
b) Page 36, Paragraph 3.3 - Mininum incpa:-ira frequencies and positions responsible should be stated for emergancy equipment and su;.pli.es.
e Minimum frequency of inspections and positions respcnsib)e vary with the type of equiprent and stcrage locaticn. These have bem surmarized in a new Tabb S.I.
. Minirm frequencies for inspections vary frem once per renth for fire protection and radiaticn/criticali;y equipment, to no special inspecticns related to use only as emergencf e=irment, for maintenance / facility damage centrol cquipment which is usal en a routine basis during plant operatiCn.3.
Mr. M. T. Crew
. February 23, 1979 Page 5 c) Table 8.1 - Initial Training & Periodic Retraining i) The periodicity of retraining should be at least annually for personnel in categories 1, 3 and 5.
e Table 8.2 (formerly Table 8.1) concerning initial training and periodic retraining, has been nodified to provide for annual re-training of personnel in categories 1 (Emrgency Director) and 3 (Survey Teams and Pa-Entry Team).
- For personnel in category 5 (Facilities Damage Control Team),
emergency activities would be so similar to their normal work-related activities that they need no additional retraining related 'to emergency activities in which they may need to become engaged.
ii) It should be confirmed that the Emergency Dire-tor is a participant in the annual drill.
This has been confirmed in Paragresh 8.1.2.
- 6) Appendicles a) Plots should be provided of calculated time-distance-dose for the most serious postulated design basis accident as called for in RG 3.42 These plots have been provided in Appendix G which was inadvertently cmitted from the copies of the Emergency Plan sent to the NPC on 1/9/79.
Appendix G will be included in the revised pages to the Emergency Plan which will be suhnitted as a result of these questions raised during NFC review of our plan.
b) What back-up exists for the New Hanover Memorial Hospital?
The Padiation Emergency Assistance Center Training Site (REACI'S) of the Oak Ridge National Laboratories provides this backup.
(See Page 28 of our Ebergency Plan.)
c) Appendix C, Page 59 - Why shouldn't the emergency equipment include damage control equipment?
A list of typical facility damage cen'rcl equipmnt has been added to Appendix C, Page 53.
d) Appendix B, Statement of Policy - The excerpts from OPG 100-5 omit reference to protection of the public.
e The sccpe of CFG 100-5, a policy of Se GE-Nuclear Energy Eusiness Group, covers e. erprcy planning for emrgr.cy situations affec-ing cnsite personnel, CE property and onsite gipmnt. Paferences to environmntal protecticn app aar in other CFG dec=ents.
(Continued)
Nr. W. T. Crow
~ February 23, 1979 Page 6 e Reference to OPG 100-5 has been deleted from cur n: urgency Plan because the OPG by itself does not cover cenprehensively all aspects of emergency planning as related to offsite activities and considerations.
A. L. Kaplan
- Erw
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