ML20033B317
| ML20033B317 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 11/16/1981 |
| From: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| References | |
| NUDOCS 8112010223 | |
| Download: ML20033B317 (4) | |
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ATTN: Mr. William R. Mowry 0
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g San Diego, California 92138 Gentlemen:
We have completed our pre-acceptance review of the radiological contingency plan that you submitted on October 13, 1981, for your San Diego Facility (License No. SNM-0696). Our review has revealed some needed changes in the content and format of the information submitted. These are described in the enclosure.
You are requested to send us additional information concerning these matters by December 19, 1981. Please submit the indicated infomation as properly numbered replacement or additional pages suitable for insertion into your plan. The information should be prepared in accordance with the " Standard Fomat and Content for Radiological Contingency Plans for Fuel Cycle and Materials Facilities," which was enclosed with the February 11, 1981, Order.
Sincerely,
%@d) R. Q. f.%
R. G. Page Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and ttaterial Safety, NMSS
Enclosure:
As stated DISTRIBUTION:
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t Enclosure Changes Needed in the General Atomic Company Radiological Contingency Plan Section 1.1-The description is. inadequate to provide a general characterization of the type of radioactive materials involved in the licensed processes. The type, form, and quantities (possession limits) of radioactive materials involved are to be included in this section as well as the types and amounts of wastes for the various processes.
Section 1.3 The process description should provide information on the kinds and quantities of material in process or storage and the location of the material. The presentation must be sufficient to support an independent assessment of the radioactive consequences of accidents.
Reactants, products, and waste streams, including ficw diagrams, should be included in the description.
Section 2.1 A more detailed description must be provided of the intended performance of the alarm systems and associated equipment provided to promptly detect releases of hazardous materials and to effect correcti've measures. The presentation should also include a description of the intended performance of any other j
systems designed to prevent accidental releases of hazardous material that coul.d occur as a result-of equipment failure or malfunction, operator error, control malfunction, sabotage or severe natural phenomena.
Section 2.2 Plant systems important to safety shall be adequate to meet the performance goals described in Section 2.1.
The description of these systems must be included and shall be sufficiently detailed to permit an independent review to determine that performance goals will be met.
Section 3.2 Provisions for notifying the NRC must be included for the Site Area and General Dnergency classifications.
The specific implementing procedures associated with each classification should clearly identify the emergency action level, the associated Protective Action Guide, or other conditions for declaring the emergency. The procedures should list the titles of the individuals and elements of the emergency organization as well ac their functions and responsibilities.
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s Section 4.1 The description of plant organization for normal operations should identify the positions of those individuals that have the responsibility and authority to declare an emergency and initiate the appropriate response.
Section 4.2 A line of succession for the response coordinator should include the specific conditions for higher -level officials assuming the function.
Section 5.1 The plan does not provide sufficient information to conclude that appropriate notification procedures have been included in the contingency plan. The communication steps taken to alert or activate response personnel should be given as well as a description of alternate means of alerting the appropriate personnel. All lists, including organizational titles and alternates, should be identified and should provide for 24-hour per day notification. The method of communication should be described (i.e, telephone, radio etc.)
Section 5.2 The plan does not provide information sufficient to demonstrate that the radiological consequences from an accident can be assessed. The procedural steps in gathering the data needed for proper analysis as well as a description of the methodology and parameters to be used are to be included. The method for calculating atmospheric dispersion is similarly to be given.
Section 5.3 The plan does not provide information sufficient to demonstrate that the licensee has preplanned actions to mitigate or correct an emergency situation.
Fce each class and type of accident, the corrective action that could mitigate or correct the problem should be identified as well as the procedures for initiating those corrective actions.
Section 5.4 Insufficient information is given to assess whether or not preplanning is adequate to assure that appropriate protective measures will be taken in the event of a radiological emergency.
The plan addresses evacuation initiated by criticality alarms.
It is necessary, however, to provide for each cTiss of emergency required to be defined in Chapter 3.0, a range of protective actions and criteria for establishing the appropriate level of action as a function of the associated accident type. A description of the procedures for performing a missing persons check as well as reporting the results should be included.
The evacuation of the general public is mentioned but more detail about the licensee's role should be given. A description of the procedures to be used for the distribution of protective equipment such as respirators and protective clothing are to be included.
4 Section 5.5 The procedures which will be used to control exposure to emergency workers are insufficiently detailed to judge the adequacy of the proposed control measures. The means for decontamination of skin or wounds of emergency personnel and supplies, instruments and equipment are to be described in more detail. Similarly, provisions for decontaminating relocated personnel should be included. The means for collecting and handling radioactive wastes are to be described.
Section 5.6 The plan should discuss the provisions for ensuring that contamination is eliminated or confined during the transport of injured and contaminated victims.
It is unclear who calls for or who mans the onsite ambulance. For offsite medical services, the plan should describe the facilities to be used as well as the radiation safety instructions to be given to medical personnel assigned to treat contaminated workers.
Section 6.3 The description of facilities designated for use by the assessment teams following an accident should include the location and a list of equipment and supplies available such as engineering drawings and operating procedures manuals which wil_1. be used to assist in the diagnosis of plant conditions and radioactive releases.
Section 7.1 Supply six copies of the G. A. manual of " Emergency Procedures" in order that we may complete the review of this section.
l In revising this plan for the comprehensive review that is to follow, it would be advisable to closely adhere to the guidance in NUREG-0810, " Standard Review Plan for the Review of Radiological Contingency Plans for Fuel Cycle and Materials Facilities."
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