ML20035G045

Forwards List of Request for Addl Info Re Revision 3 of Claiborne Enrichment Ctr Emergency Plan

ML20035G045
Person / Time
Site:	Claiborne
Issue date:	04/20/1993
From:	Roche L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Arnold W LOUISIANA ENERGY SERVICES
References
NUDOCS 9304260071
Download: ML20035G045 (9)

Text

e APR 2 01993 Docket No. 70-3070 Louisana Energy Services, L.P.

ATIN:

W. Howard Arnold President 2121 K Street, N.W.

Suite 850 Nashington, DC 20037 i

Gentlemen:

We have completed our review of Revision 3 of the Claiborne Enrichment Center Emergency Plan, dated April 1,1993. Based on our review, we have prepared a list of requests for additional information (see enclosure).

Sincerely, Onginal Signed By Lidia A. Roche' Certification Section Enrichment Branch Division of Fuel Cycle Safety and Safeguards

Enclosures:

Request for Additional Information l

cc: Attached list DISTRIBUTION:

Docket No. 70-3070 PDR/LPDR NRC Central File RFonner, 0GC GBidinger JGreeves RCastaniera JSpraul EHoller, 0GC WFisher, RIV IMSB R/F.

CNilson, RES YFaraz AGiarratana

-NMSS R/F FBrown

.DJoy, SG LRoche

EShum RBrady, SEC TCombs, GPA RMilstein MHorn gjmseg I _

0FC FCEB E

I IMI.F, FCEB NAME LRoche:tl '

FBrown JW[fTc~ key DATE 4/f'/93 4,(s/93 4/.f7/93 C= Cover E= Cover &. Enclosure N= No Copy 0FFICIAL RECORD COPY G: lesltr.lr O

9304260071 930420 Q

PDR ADOCK 07003070 c

eO 9

Request for Additional Information j

We have reviewed your Emergency Plan, Revision 3 submittal and have the i

following comments:

1.

Although the attachment to your transmittal letter states that all i

potentially radioactive gaseous effluents exhaust through Stack 1, the revised wording in Section 1.2 of the EP does not identify Stack 1 as j

the only stack that would see airborne releases.

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2.

The List of Effective Pages should be reviewed against the act331 plan, i

page per page, to ensure consistency.

For example, figure 1.2-1 has no revision number or date, Figure 1.3-1 has a different date on it than the list indicates, pages 11-2 through 11-7 are not listed and the actual pages need revision numbers and dates, etc.

i 3.

Section 2.1.1.2 identifies the Technical Services Area (TSA) as the onlyL area within the CEC where a criticality could possibly occur but does not contain a summary of the worst-case-criticality scenario that we previously requested.

A summary of the consequences similar to the summary in Section 2.1 for the worst-case UF6 release should be i

provided.

In addition, the sentence in 2.0 that reads, "There is no credible probability of nuclear criticality." should be changed to reflect your analysis.

i 4.

The discussion of emergency action levels (EALs) in Chapter 3 should be corrected as shown in the markup of the applicable pages (attached).

The plan must clearly define EALs as criteria established in advance for classifying incidents within a few minutes of the initial report. The purpose of an EAL is to provide the appropriate decision maker with criteria for declaring an Alert or Site Area Emergency based on an initial report that may contain very sketchy _information.

Attachment:

Markup pages i

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i Enclosure l

t h

~

up 0

h-t uaQt V

i gen ng i9 ?? u.. d Emergency Listed below arepexamples of pm~M==

Action Levef(EAlg.

Conditions that Initiate an Alett Condidons that Irutsate a Site Area Emercency 1.

Fire onsite that might affec'. radioacuve 1.

Fire onsite that involves radioacuve f

matenal or safety systems.

matenal or compromises safety systems.

2.

Severe natural phenomenon that might 2.

Severe natural phenomenon that actually -

i affect radioacuve material or safety compromises safety systems or the.

j systems (e.g., eanhquake. flood, tsunanu, integnty of radioactive matenal (e.g.,

l humcane, tidal surge, hurncane force earthquake. flood, tsunami. hurncane force

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winds, tornado sinking facility).

winds, tornado stnking facility).

3.

Other severe incidents that might affect 3.

Other severe incidents that actually radioactive material or safety systems-compromise safety systems or the imegnty aircraft crash into the facility, damage to of radioacuve matenal-aircraft crash into the facility from explosives, uncontrolled the facility, damage to the facihty from -

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release of touc or flammable gas in the explosives, uncontrolled release of touc or

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facihty.

flammable gas in the facility.

4.

Elevated radiation levels or airborne 4.

Elevated radiation levels or airborne contamination levels within the facility contamination levels outside the facility l

that indicate severe loss of control (factor that indicate a significant release to the of 100 over normal levels),

environment (factor of 100 over normal 1

levels).

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S.

Ongoing security compromise (greater 5.

Imminent or actual loss of physical control j

than 15 mmutes),

of the facility.

t 6.

Discovery of a cntical mass quantity of 6.

Imminent or actual occurrence of an special nuclear matenal in an unsafe uncontrolled enticality.

geometry container or other condition that creates a enticality hazard.

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7.

Other conditions that warrant 7.

Other conditions that warrant activauon of -

precautionary activation of the licensee's offsite emergency response organizations l

emergency response organization. -

or precautionary notification of the public.

i near the site.

i mhcdAmkcab l

e.m Listed below in secuons 3.1.1 and 3.1.2 are examples of site-specific incidents dt

"'" E *.L that would be declared for each event. Specific instructions for declaring an Alert or Site Area Emergency are centamed in the CEC Emergency Plan Implementing Procedures.

Louisiana Energy Services 3-2 Apnl 1993 Emergency Plan Revision 3 r

4

3.1.1 Alen An Alen is defined as an incident that has led to or could lead to a release to the environment of radioactive or other hazardous material, but the release is not expected to require a j

i response by an offsite agency to protect persons off site. Although no incidents of this type are likely to occur. a release judged to be of more than 1. but less than 100 kilograms of UFs l l

shall be classified as an Alen.

Incidents postulated in Section 2.1 if one were to occur, which would be applicable to (iassification as an Alen are:

a)

Desublimer Pipe Rupture

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b)

Opening of a Contaminated Autoclave c)

UF. Reactions in a Cylinder d)

Pipe Heat Tracing / Hot Box Failure e)

Cenain Fires 3.1.2 Site Area Emergency t

A Site Area Emergency is defined as an incident that has led or could lead to a release to the environment of radioactive or other hazardous material and that could require a response by an offsite response organization to protect persons off site. Although no likely incidents have been postulated for the facility which would be applicable to this classification, a release judged to be of more than 100 kdograms of UF. shall be classified as a Site Area Emergency. l Incidents postulated in Section 2.1, if one were to occur, which would be applicable to f

classification as a Site Area Emergency are:

i a)

Severe natural phenomena which causes sufficient damage to cause the release of l

significant quantities of UF..

i b)

Failure of Autoclave Heater Louisiana Energy Services 3-3 Apnl 1993 l

Emergency Plan -

Reviswn J

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i c)

Major Storage Yard Fire t

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'l d)

Criticality

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3.2 NOTIFICATION AND COORDINATION LES personnel are in facility areas on a routine basis. All are trained in the hazards of I'F.

i and the indications that a UF. release has occurred or is in progress (e.g., white smoke.

ammonia-like smell). The response of facility personnel to an Alert and Site Area Emergency is outlined in Sections 3.2.1 and 3.2.2.

3.2.1 Alert Indicators. alarms and automatic shutdown are in place to control chemical hazards by -

automatic intermption or termination of specific operations. LES operations personnel are l

trained to judge the severity of an emergency incident based upon the type of emergency.

plant area or zone, equipment involved.'and surrounding conditions. The ability to judge a l

condition to be more than 1 kilogram or more than 100 kilograms exists because of the l

enrichment process, equipment safeguards, and plant layout. For example, the size of the l

cylinder limits the amount of release (i.e. a 50 kg cylinder could not exceed that amount of l-

-j release). The LES CEC Safety Analysis Report defines radiation protection objectives, onsite l

contamination control. guidelines and approaches, abnormal operations, and accidents in j

sections 8.1. 8.2. 9.0. 9.1, and 9.2 respectively.

l If a person observes a UF release, the person leaves the area and contacts Control Room.

1 personnel providing initial information regarding the release. Control Room personnel initiate the following actions:

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Evacuate the area by either dispatching operators or security personnel to the.

release area and/or by sounding the evacuation alarm in the affected area..

Contact the Shift Supervisor who confinns the incident. This confirmation may be by other personnel who relate the incident to the Shift Supervisor.

EALs i

Using thegnaena provided in a EmergengPlan,Imple e specifically written to provide criteria for determin!ng{.g;g duregg

n. exarthlesof-

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these criteria are provided in section 3.1), the Shift Supenisory CIA 15 bes N emgeac i

Louisiana Energy Services 34

_Apnl1991 i

Emergency Plan.

Reviswn 3

Upon determinig the incident is an Alert, the Shift Supervisor declares the facility to be in the Alen an sumes the responsibility of the Emergency Coordinator. The Shift Supervisor retains this responsibility until relieved by the CEC Manager or his designee.

Upon being relieved the Shift Supervisor continues to provide assistance to the Emergency Coordinator to contain any material released. to assess the impact of any material released and to restore the facility to a normal and safe status.

The Emergency Coordinator (either the Shift Supe *isor or CEC Manager or designee) upon declaration of the facility being in an Alen%in'itiItes the following actions:

cerAb Notifies facility personnel of the facility being in an Alen %by sounding g-determined alarm, followed by notification that the facility is in an Alen.

and l

a brief description of the incident.

j This is followed by instnictions for facility personnel (e.g., proceed to muster area

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'A', staff the primary EOC).

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Notifies the appropriate offsite assistance organizations and the Nuclear Regulatory

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gmi iog(g" "The offsite organizations will be notified within 15 minutes

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of Immediately following notification of the offsite j

u.., _,..

assistance organizations, e NRC will be notified. In all cases, the h"RC will be l

1"D bL.

l notified within I hour ofg Small fires within any process area are reponed to the Central Control Room and the Shift Supervisor. If trained, the person reponing the fire may attempt to extinguish the fire using r

penable fire extinguishers. If necessary the Fire Brigade shall respond to extinguish the fire.

I All Alert condition activities which have occurred are reported to facilit and corporate w

management. If the above measures are successful in controlling th o further immediate action is required. Followup investigation that must be done is as follows.

P k

a)

Special urine or fecal samples may be required for personnel involved. Facility personnel who have urine sample results above the action level are put on work l

restriction and additional investigative samples are requested.

i b)

Fenceline samples are counted to determine the extent of the release within the controlled access area. These samples would be counted daily.

r Louisiana Energy Services 3-5 Apnl 1993 Emergency Plan Renswn3

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c)

Decontaminate facility personnel in the first aid room if necessary.

If actions are not successful in controlling the condition. the emergency is escalated to Site Area Emergency.

3.2.2 Site Area Emergency me(u4

% mdid

,JecAve.

g achas recommee Adwn (FAk, if a person observes a UF, release that he judges be more than 100 kilograms. the person l

leaves the affected area and notifies the Cen - Control Room operator who in turn sounds usq As cat.se..c.- 4 the evacuation alarm to clear the affected are ss). The Shift Supervisorg:p shall declare a Site Area Emer ency. staff the Emergency Operations Center

+'

(EOC) and perform the actions described i section 3.2.1 for an Alert. This would involve i

notification of necessary off site personnel (e.g., NRC. local and state emergency response groups). All facility personnel shall evacuate the affected area and may re-enter the affected area with appropriate respiratory protection. obtained from the safety equipment storage locanons as directed by the Shift Supervisor. Control of this type of condition would probably necessitate the shutdown and isolation of the affected system or suspension of all operations. His decision to shutdown and/or isolate systems or operations is made by the Emergency Coordinator.

All Site Area Emergency condition activities which occur are reported to facility and corporate management. If the above measures are successfulin controlling the Site Area Emergency, then the action turns to a follow-up investigation which would be done as follows:

a)

Special urine or fecal samples may be required for personnel involved. Facility personnel who have urine sample results above the action level are put on work restriction and additionalinvestigative samples are requested.

b)

Fenceline and offsite samples are counted to determine the extent of the relerse within the controlled access area. These samples would be counted daily.

c)

Decontaminate facility personnelif necessary.

Louisiana Energy Services 3-6 Apnl 1993 Emergencv Plan Rension 3

9 J8 i

LES SERVICE-LIST t

Mr. Peter G. LeRoy Mr. Michael Mariotte Licensing Manager Executive Director Louisiana Energy Services Nuclear Information and.

i c/o Duke Engineering & Services, Inc.

Resource Service l

P.O. Box 1004 1424 16th Street, NW Charlotte, NC 28201-1004 Suite 601 Washington, DC 20036 Mr. J. Michael McGarry, III Winston & Strawn Administrative' Judge 1400 L Street, NW Richard F. Cole Washington, DC 20005 Atomic. Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ronald L. Wascom Deputy Assistant Secretary Administrative Judge Office of Air Quality and Frederick J. Shon Radiation Protection Atomic Safety and Licensing: Board-Louisiana Dept. of Environ. Quality U.S. Nuclear Regulatory Commission P.O. Box 82135 Washington, DC 20555

- i Baton Rouge, LA 70884-2135 Office. of Commission Appellaie Ms. Diane Curran Adjudication Harmon, Curran, Gallagher, &

U.S. Nuclear Regulatory Commission :

Spielberg Washington, DC -20555 i

2001 S Street, NW Suite 430 Washington, DC 20009-1125 Nathalie M. Walker, Esq.

Morton B. Margulies, Chairman Sierra Club Legal Defense Fund, Inc.

Atomic Safety and' Licensing Board t

400 Magazine Street, Suite 401 U.S. Nuclear Regulatory Commission New Orleans, LA 70130 Washington, DC 20555 r

i

.e.

a cc:

LES SERVICE LIST Dr. W. Howard Arnold Mr. Michael Mariotte President Executive Director Louisiana Energy Services Nuclear Information and 2121 K Street, NW Resource Service Suite 850 1424 16th Street, NW Washington, DC 20037 Suite 601 Washington, DC 20036 Mr. J. Michael McGarry, III

-Winston & Strawn Administrative Judge 1400 L Street, NW.

Richard F. Cole

-Washington, DC 20005 Atomic Safety ~and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Ronald L. Wascom Deputy Assistant Secretary Administrative Judge Office of Air Quality and Frederick J.-Shon Radiation Protection Atomic Safety and Licensing Board Louisiana Dept. of Environ.. Quality U.S. Nuclear Regulatcry Commission P.O. Box 82135 Washington, DC 20555 Baton Rouge, LA 70884-2135 Office of Commission Appellate Ms. Diane Curran Adjudication

'Harmon, Curran,-Gallagher, &

U.S. Nuclear Regulatory Commission Spielberg Washington, DC -20555 2001 S Street, NW Suite 430 Washington, DC 20009-1125 Nathalie M. Valker, Esq.

Morton B.-Margulies,. Chairman Sierra Club Legal Defense Fund, Inc.

Atomic Safety and Licensing Board 400 Magazine Street, Suite 401 U.S. Nuclear Regulatory Commission New Orleans, LA _70130 Washington, DC 20555

)