ML20035D649

Forwards Comments Requesting Addl Info Re Revised Emergency Plan,In Response to

ML20035D649
Person / Time
Site:	07001201
Issue date:	04/09/1993
From:	Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Knapp K FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.)
References
TAC-L-21660, NUDOCS 9304130367
Download: ML20035D649 (4)

Text

-.

1 APR 9 1993 Docket 70-1201 License SNM-1168 4

l Ms. K. S. Knapp, Manager j

Safety and Licensing B&W Fuel Company Commercial Nuclear Fuel Plant P.O. Box 11646 Lynchburg, Virginia 24506-1646 i'

SUBJECT:

EMERGENCY PLAN, REVISION 1, (TAC NO. L21660)

We have cc:.,leted our revie,< of the revised Emergency Plan dated August 13, 1992, and concluded that additional information is needed before final action i

can be taken. Our commcnts are enclosed. We reviewed your plan against Regulatory Guide 3.67, " Standard Format and Content for Emergency Plans for Fuel Cycle and Material Facilities." A copy of Regulatory Guide 3.67 is enclosed for your use.

l l

Please submit the requested information (six copies) as page changes to the f

plan or submit a new Emergency Plan. The requested information should be i

i submitted within 90 days of the date of this letter.

If you have any questions, please contact me at (301) 504-3416.

Sincerel MM 6Y:

)

Mic1ael

. Lamastra Licensing Section 2 I

Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS

Enclosures:

i 1.

Comments on Emergency Plan 2.

Regulatory Guide 3.67 E Distribution w/ encl 1 (Control No. 3605) b Docket No. 70-1201 PDR NRC File Center NMSS R/F FCSS R/F FCLB R/F Region II Madams DKasnicki, RII JGreeves 0FC FCLB:,..- E FCLB: V h

FCLB:

N w

NAME MLamastra:

VIh_ 'arpe MToka(I "

DATE 4/l/93 4/$93 4/o/93 2

C = COVER E = COVER & ENCLOSURE N = NO COPY

[G:\\ltrknapp.ml]

i I

1 p

l 3

i a

l l

Request for Additional Information j

Application Dated August 13, 1992 B&W Fuel Company Docket 70-1201 Please provide the following information:

4 1

1.

Section 1.1 should describe the type, form, and quantities of radioactive material authorized by the NRC license and how much is i

normally present. The plan should also state whether any radioactive materials authorized by the State of Virginia are used 4

at the site.

2.

The plan should include a list of the hazardous chemicals used or stored on site.

The list should include the typical quantities 1

possessed and the locations of use and storage of large quantities of chemicals (e.g., tanks).

l 3.

Section 1.1 should include a description of exhaust stack 1

locations, stack heights, typical flow rates, and the efficiency of any emission control devices.

4.

The copy of the topsgraphical map provided in Figure 6 is difficult to read. The plan should contain an original United States Geological Survey 7.5" topographical map. Maps can be i

)

obtained from the U.S. Geological Survey, map distribution, Denver Federal Center, P.O. Box 25286, Denver, CO 80225. - The telephone number is (303) 236-7477.

a 5.

An enlarged (24 x 30 inch minimum) duplicate of the detailed site map (Figure 4) should be included in the plan.

6.

Section 2.1 should be modified to delete " Trivial Incidents" and

" Accidents At Neighboring Facilities."

7.

Since your facility does not currently use uranium dioxide powder, you should delete all accidents associated with this material.

8.

Section 2.1 should be modified to define " major fire" and " major explosions."

9.

Your plan should be modified to add a Section 2.2, " Detection of Accident" (See Regulatory Guide 3.67).

10.

The plan should clearly certify that the licensee has met its responsibilities under the Emergency Planning and Community Right-To-Know Act of 1986.

Section 10.0 implies that the licensee is in i

compliance, but a clear certification should be provided.

l

j s

1 l

2 11.

Assuming that uranium dioxide powder events are removed from your emergency plan, you should reidentify postulated accident (see Section 3.1, Regulatory Guide 3.67.)

12.

Describe in greater detail the decision making process for alerts and site area emergencies.

(See Section 3.2, Regulatory Guide 3.67).

13.

The plan should identify the emergency action levels (EAls) at which an alert or site area emergency will be declared.

EALs are specific initiating conditions relative to particular events or changes in instrument sensors.

General examples are provided in Appendix A of Regulatory Guide 3.67.

If the licensee chooses to establish the EALs in an implementing procedure, a copy of the EAls should be submitted with the licensee's response to these

comments, t

14.

Section 3 should clearly state that offsite response organizations i

will be notified promptly (normally within 15 minutes) of declaring an alert or site area emergency (SAE), and that the NRC operations center will be notified immediately after the offsite response organization but no later than I hour after declaring an alert or SAE.

15.

In addition to classifying an emergency, Section 3 should also describe how decisions are made to initiate protective actions onsite, request offsite assistance, and recommend protective actions for offsite areas.

Initial protective action recommendations (PARS) for offsite officials should be prepared in advance so that a PAR can be selected quickly and transmitted with the initial notification of offsite authorities.

Initial PARS should include whether or not any offsite area should be isolated, railroad traffic should be stopped, residents should be asked to stay inside, etc.

The plan should describe the procedure for selecting one of the prepared PARS and transmitting it with the initial notification of offsite authorities.

16.

Section 4 should be modified to briefly describe the normal plant organization.

17.

Section 4.2 should clearly state what members of the emergency l

response organization are available onsite during nonworking periods. Which onsite personnel have the authority to declare an emergency during nonworking periods?

4

-m,

- ~"

t 4

l l

l 6

3

[

18.

Section 4.3 should discuss site access by offsite response organizations during an emergency. Any provisions to suspend security or safeguards measures should be described.

l 19.

Section 4.4 should describe the rumor control arrangements that i

have been made with the government agencies to ensure that the media and the public have access to accurate information during an t

emergency.

l 20.

The plan should be modified to include the information described i

in Sections 5.2 and 5.3 of Regulatory Guide 3.67.

21.

Section 5 should be modified to describe the criteria for relocating the command center.

22.

Section 7.3 should require nonparticipating observers to evaluate drills and exercises. The plan should describe how criteria for i

acceptable performance will be prepared and provided to observers for evaluating participants.

j 23.

Section 7.4 should specify that the critiques will include the j

findings of the nonparticipating observers and describe how l

deficiencies and corrective actions will be tracked to ensure they l

are completed and closed out.

l i

l i

1 j

i i

.