ML19310A139
| ML19310A139 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 02/01/1980 |
| From: | Kirk W UNITED NUCLEAR CORP., UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19310A140 | List: |
| References | |
| 15439, NUDOCS 8006060158 | |
| Download: ML19310A139 (11) | |
Text
_ _ _
UnC NAVAL PRODUCTS O, s.cn v U+ 'ec %c ear Crccut cn
- ' 3arcy Cese-Acad e ecrc e 203 84815 1 UnC s unc nasounces c w,
_ cas.ve cc~ect.ca :eae2 In reply, please refer to: NIS:
80-2-1 g
February 1, 1980
/f NCQQ 3
OE~f gE8 Mr. W. T. Crow, Section Leader Uranium Fuel Fabrication Section
" 8. %f y 1960
- --4 Division of Fuel Cycle and Shterial Safetv 3
U. S. Nuclear Regulatory Comission 6
D W
=
Washington, D. C.
20555 0
Subject:
Docket 70-371, SNM License No. 368
\\O cp Frergency Flan Peference:
(1)
Letter, N. T. Crow to W. F. Kirk, dated October 30, 1979 (2) Letter, W. F. Kirk to W. T. Crow dated Shrch 7, 1979 (3) Letter, N. T. Crow, hRC to W. F. Kirk, UNC on subject, dated Jan. 2,1979.
(4) Letter, N. F. Kirk, UNC to W. F. Crow, NRC on subject, dated Feb. 5,1979.
(5) Letter, W. T. Crow, NRC to W. F. Kirk, UNC on subject, dated Shrch 9,1978.
(6) Letter, W. F. Kirk, UNC to W. T. Crow, NRC on subject dated April 4, 1978.
(7) Telecon, W. T. Crow /J. Delaney to N. F. Kirk, f
UNC on subject dated August 28, 1978.
(8) Letter, N. F. Kirk, UNC to W. T. Crow, NRC on subject dated September 12, 1978.
(9) Letter, W. F. Kirk, UNC to L. C. Rouse, NRC on subject dated July 22, 1977.
Dear Sir:
In reply to reference (1) we are submitting attached revised Emergency Flan and comments.
3is submission is made for the convenience of the Nuclear Regulatory Cccmission in a matter of extensive past com:ulications and is exempted from any fee as per 10 CFR 170.31 Note 1 (d).
Vere tm1v our,
6'I 5Mu j
nus DOC 0gtn c 15439 W. F. Kirk, ohnager POOR QUN Nuclear and Industrial
/ u.
Safety Department attac' rents 8006060 g
Response to NRC comments and questions dated October 30, 1979 on UNC Emergency Plan.
- 1) A list of effective pages is submitted current with this letter.
- 2) See revised page 6.1-2, revision 1, dated 1/25/80.
- 3) See revised page 6.2-1, revision 2, dated 1/25/80.
- 4) See revised page 6.2-4, revision 1, dated 1/25/80 and page 6.4-1, revision 2, dated 1/25/80.
- 5) a) See revised page 6.2-5, revision 2, dated 1/25/30.
b) See revised page 6.2-5, revision 2, dated 1/25/30.
- 6) a) See revised page 6.2-5A, revision 2, dated 1/25/80.
b) See revised page 6.2-5A, revision 2, dated 1/25/30.
c) The State Police have been designated as the prime telephone contact within State plans.
- 7) a) No arrangements have been made with state agencies for UNC to be notified of impending natural disasters. The " prior notice" in pg. 6.2-7 of our plan referred to public ccamunications such as radio alerts or weather bulletins. We have the capability, via a Weather Radio Alert, to receive weather infomation broadcast by the National Oceanic and Atmospheric Administration Service.
This is a continuously updated all weather broadcast which can trip the receiver on autcmatically for bulletin type information.
b) UNC operates meteorological equipment with continuous readout recorded on a strip chart recorder.
For a non-criticality l
1 emergency with postulated radioactive release, the charts would be available. For a criticality emergency we can detemine wind speed and direction by means of_ a portable aneacmeter.
- 7) b) continued Direction only can also be obtained by visibly observing the meteorological vane on the mast. (' At night a spot light can beused.)
- 8) Re principal state agency for all emergency or disaster situations is the Office of Civil Preparedness. H e State's Emergency Operations Plan is the basic plan for all emergency or disaster situations and is also the basis of emergency plans for all state agencies and depart-ments as well as all local jurisdictions.
The State repartment of Environmental Protection is responsible for protecting the public health and will respond to any request for radiological assistance, initiate protective action and otherwise cooperate with the Office of Civil Preparedness. The Department's i
j Coordinator for radiological assistance is one of several pre-assigned individuals who assumes administrative emergency response functions.
Annex V of the Connecticut State Emergency Operations Plan addresses radiological emergencies for fixed nuclear facilities. The response capability of the Office of Civil Preparedness involves staffing and planning to enable evaluation of the emergency; alerting pre-designated support agencies, departments and individuals; emergency data dissemination; Emergency Operations Center function; communi-cations coordination ; radiological defense and hazard analysis; l
coordination of emergency public information.
The Emergency Operations Center is located in the Hartford, CT office, l
with an alternate operations center at the Pocky Hill Veterans Homes l
Mospital.
-,,-p.,
- 9) See revised page 6.3-5, revision 2, dated 1/25/80,
- 10) UNC maintains an emergency evacuation alarm such that all required areas of the facility are monitored at all times.
Contingency plans and implementing procedures have been drafted to assure continuous manual coverage under certain circumstances where maintenance may be required due to a system console malfuncticn/ power failure, single unit malfunction or horn malfunction. On such occasions all fuel movement between criticality zones is prohibited.
Criticality evaluations have been mde to support the continuation of some routine route card operations within a criticality zone based on control to sub critical quantities by design, piece count, configu-ration, or condition.
Special situations requiring fuel movement between ::enes are eval-uated and then conducted on a case by case basis only under specific conditions which will preclude the possibility of criticality.
A draft procedure implementing this contingency is provided for your information.
- 11) The infomation in these tables have been adopted by the State Department of Environmental Protection and the Office of Civil Preparedness and are incorporated into the Connecticut Emergency Operations Plan: Annex V - Fixed Nuclear Facility, Radiological Emergency Response Plan.
- 12) See revised page 6.3-17, revision 2, dated 1/25/80.
- 13) a) See revised page 6.4-3, revision 1, dated 1/25/80.
j l
1
- 13) b) ne prevailing west to east movement of air carries the majority of weather systems into the area from the west.
The primary emergency control center is located west of the production facilities as shown in the UNC/NPD Plant Layout in Annex D.
The evacuation routes are shown in the evacuation i
route layout attached.
i
- 14) See revised page 6.5-2, revision 1, dated 1/25/80.
- 15) Specifically, our stacks discharge within a restricted area. Concen-trations of radioactive material are detemined with respect to the point where the material leaves the stack and recorded.
If stack samples were high, a boundary concentration may be detemined by
~ applyin'g appropriate factors for dilution and dispersion between the point of discharge and the site boundary. We reserve the option of using this latter value for notification criteria, which is within the regulations of 10 Part 20.
- 16) See revised page 6.8-3, revision 1, dated 1/25/80.
- 17) See revised page 6.8-3, revision 1, dated 1/25/80.
- 18) See revised page 6.8-4, revision 2, dated 1/25/80.
Liaison has been maintained at least every two years with agencies which would support us in an emergency, particularly with the agencies you mention,ed. These contacts and dates have been noted on the file ccpies of the agreement letters.
1
i
- 18) continued 4
We have frequent contact with the Connecticut State Police and
.Nbhegan Fire Company.
t A new Appendix A is being submitted which re-numbers the agreement letters and provides updated letters available now. A request for i
updated written letters has been issued and copies will be sent when I
received.
- 19) See revised page B-1, revision 1 and new pages B-2, B-3, B-J all revision 0, dated 1/25/80.
- 20) These specific procedures are covered in the Frergency Training r
l Program - Medical and First Aid.
- 21) See revised page D-4, revision 1, dated 1/25/80.
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UNITED POLICIES AND PROCEDURES MANUAL Uf1C OUCLEAR CO R PO R ATIO N MAINTENANCE AFFECTING THE RADIATIJN nav4L pacoucts-EMPLOYEE RELATICNS MONITORING.OR THE EVACUATION ALARM ctAssmcAtioN sua;Ect SYSTEMS PURPOSE To define NPD polf.cy regarding actions to be taken during the performance of work on the sul ject system 9.
SCOPZ This policy applies to the perform?.nce of any work affec';ing the radiation monitoring or evacuation alarm systems, including tests, calibrations, maintenance or construction.
POLICY NPD shall maintain a radiation menitoring system such that all required areas of the facility are monitored at all times, and an emergency evacuation alarm system that is automatically activated by "on-line" monitors or which may be activated manually.
RESPONSIBILITIES AND PROCEDURES 1.
Nuclear and Industrial Safety shall:
Specify when tests and/or calibradons of the monitoring a.
and alarm systems are to be performed.
b.
Specify the manner in which radiation monitors are to be calibrated and participate in calibration.
Take steps necessarf to assure coverage when any rcdiation c.
monitor is taken off line.
2.
Plant Maintenance and Services shall:
a.
Perform all maintenance, calibration and testing of the radiation monitoring and evacuation alarm systems.
b.
Notify Security, NIS and the Emergency Director prior to performing any work affecting the radiation monitoring er evacuation alarm systems.
Notify Security and the Emergency Director upon completion c.
of work affecting the sv5 ject syste=s.
l
- ct 1
- CT **
EF8ECriVE catE SuPEACECES APopoVAL
UNITED POLICIES AND PROCEDURES MANUAL UCC NUCLEAR CO R P O R ATION MAINTENANCE AFFECTING THE RADIATION NAVAL Pacoucis EMPLOYEE RELATIONS MONITORING OR THE EVACUATION ALARM etAssiricArioN susaEc7 RESPONSI3ILITIES A'ID PROCE'DURES (Continued) 3.
The Emergency Director, whenever work is to be performed which necessitates " keying off" the evacuation alarms or which may result i
in monitors being taken off line, shall:
Assign a qualified technician to observe the radiation a.
monitoring system control panel.
(1)
If red light goes on in any panel, i= mediately alert Security to =ake announcement per 4. c.
below.
b.
Implement any additional safety precautions that may be required.
4.
Security shall:
Upon being notified that work is to be performed on the a.
monitoring / alarm systems, notify the General Manager or Shift Superintendent, and make the following announcements throughout the plant:
(1) 10 minutes orior E the commencement of such work:
" Work to do on the radiation alarm system.
In 10 minutes - Stop movement of fuel between zones.
If the alarm sounds, do not evacuate."
(2)
Afeer 10 minutes:
" Work to do on the radiation alarm system.
Stop movement of fuel between zones.
If alarm sounds, do not evacuate."
(3)
Everv 30 minutes - Repeat Paragraph 4. a. (2) announce=ent.
b.
Upon receipt of notification that all work has been completed, make the following vnouncement:
" Alarm work apleted.
You can move fuel.
React to any alarm."
c.
If directed by the Emergency Director, his designee, or =onitor, make the following announce=ent:
(When a real alarm condition appears to have occurred coincident with work affecting the systems)
" Evacuate at once. This is not a test."
(Reoeat Several Times)
PAGE.
2 WCY NWBER EsrECTi% E o ATE SLPERCE0E3 APP 9 OVAL
i UNITED POLICIES AND PROCEDURES MANUAL UnC NUCLEAR COR PO R ATIO N E E N G H E RAD M ION EMPLOYEE RELATIONS MONITORING OR THE EVACUATION ALARM NAvat racoucTs ctassiricAftoN SUBJECT SYSTEMS RESPONSIBILITIES MD PROCEDURES (Continued) 5.
When special situations require fuel movement between zones, it shall be conducted only under the following conditions:
One alarm unit'is inoperative, but the central system control a.
panel is on:
(1)
The Health Physics Specialist or NIS Manager determines that overlapping coverage is still present from another nuclear alarm.
OR (2)
An NIS Department Technician is assigned as a monitor to caordinate the routine movement of fuel within the area.
He must first familiarize himself with the zones and posted, criticality regulations and the fuel containing items and their locaticas.
OR (3)
An area production employee, with thorough knowledge of the criticality control zones and postings, coordinates the routine movement of fuel within the area. This person is selected by the area supervisor with the concurrence of the NIS Department.
(4)
The monitor will have a radiation detection instrument and radio communicator to the central guard station.
Any radiation above 5 mR/hr will be co=municated to the guard station for ic=ediate svacuation announcement.
b.
Plant wide system is down. The nuclear alarm system is not functioning, g, the system is functioning but an announcement has been =ade to ignore the alarm horns while maintenance is being performed. Then the fuel movement from one criticality zone to another is prohibited throughout the plant.
Limited fuel movement will be considered on a case-by-case basis within the fellowing guidelines:
(1)
One of the following will assu=e the role of Fuel Movement Coordinator - Health Physics Specialist; Criticality Engineer; Criticality Specialist; Industrial Safety Specialist; NIS Manager, or qualified delegate, Emergency Director.
PAGE-3 O'
b acucv NuveEm EFFECTIVE o ATE SUPEACEoES ApoaCVAL
UNITED POLICIES AND PROCEDURES MANUAL UMC MUCLEAR
.. /
CO RPO R ATION
' MAINTENANCE AFFECTING THE RADIATION N ORM OR M MAUM M NAV AL PAoOUCTS EMPLOYEE RELATIONS oivisicN SYSTEMS CLASSIF'P ATICN SUBJECT RESPONSIBILITIES AND PROCEDURES (Continued) 5.
b.
(Cont'd.)
(2) ' Requests for movement of fuel between zones should be directed to the Fuel Movement Coordinator by the area Supervisor. These requests must be justified as important to plant operations since it is not the intention of this guide to permit normal operations.
(3)
Monitors as described in 5.a. (2) or 5.a. (3) must be designated and available during the fuel movement in the area of fuel movement.
(4)
The Fuel Movement Coordinator must authorize the fuel movement through the on-site area monitor.
(5)
Mo 11 tors will have radiation detection instruments and radio communications to the central guard station. Any radiation above SmR/hr will be communicated to the guard station for immediate evacuation announcement.
c.
Work situations considered for approval by the NIS Department or Emergency Director under Paragraph 5.a. and 5.b. above:
(1)
Only normal route card operations will be considered for authorization, with the exceptionof clean line, vertical assembly element pickling and sectioning which will not be approved for between zone movement.
(2)
The following non-route card or non-routine work will not be authorized and no work will be allowed either within a zone or between zones.
a.
Chem Lab Work b.
Cutomatic Clean Outs c.
Rad Waste Standpipe Cleanouts d.
Decon Operations e.
Raw Fuel Unioading d.
All work and fuel movement / storage shall remain in compliance with existing requirements, Specific written procedures may be posted in criticality e.
authorizations for selected areas.
ence. 4 k
CY M BER EFFEOTIVE o A'!
SUPERCEDES APDQoVAL
.