ML20039F899
| ML20039F899 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 12/16/1981 |
| From: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Zeff D BABCOCK & WILCOX CO. |
| References | |
| NUDOCS 8201140046 | |
| Download: ML20039F899 (6) | |
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- Docket No. 70-1201
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S GECENEO Babcock and Wilcox DECI Ob 7 ATTN: Mr. D. W. Zeff, Manager Health-Safety and Licensing
_ gDag p 3 Nuclear Materials and Manufacturing me Division k
p P. O. Box 800 m
Lynchburg, Virginia 24505 Gentlemen:
We have completed our pre-acceptance review of the radiological contingency plan that you submitted on August 28, 1981 for your Lynchburg Commercial Nuclear Fuel Plant (License No. SNM-ll68). Our review has revealed several needed changes in content and format in the information submitted.
Those are described in the enclosure.
You are requested to send us additional infonnation concerning these matters by January 20, 1982. Please submit the indicated information as properly numbered replacement or additional pages suitable for insertion into your plan. The information should be prepared in accordance with the " Standard Format and Content for Radiological Contingency Plans for Fuel Cycle and Materials Facilities," which was enclosed with our February 11, 1981 Order.
Please refer to Control Number 19585 in your response. Direct any questions to Dr. J. T. Long or to Dr. Fred D. Fisher on (301) 427-4135.
Sincerely, mene; a. u. ey,.
R. G. Page, Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosure:
As stated DISTRIBUTION:
Docket File No. 70-1201 RGPage NMSS R/F PDR ERESS Licensee OELD WTCrow folder SBurns, OELD TRDecker IE Region II FC Central File JTLong M FDFisJer _
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Staff comments from Initial Review of Radiological Contingency Plan Submitted August 28, 1981, for B&W's Commercial Nuclear Fuel Plant General
'.l Your Radiological Contingency Plan as submitted is generally too brief, often quite superficial in its treatment of a subject, and omits some important elements.
Sufficient detail must be provided to satisfy our informatior, requirements as specified in Enclosure 1 of our Order of February ll, 1981
(" Standard Format and Content for Radiological 3
Contingency Plans for Fuel Cycle and Materials Facilities").
The Radiological Contingency Plan is intended to constitute an upgrading of all those elements of emergency preparedness contributed by CNFP and will, through license amendment, replace and supersede your present authorized Emergency Plan.
Much of the information missing from your plan appears to have been included by reference to your Emergency Plan.
We suggest that you excerpt, as appropriate, from that plan.
Replication of the resource material and its direct incorporation into the body of your Radiological Contingency Plan, after appropriate renumbering, is acceptable.
Comments By Specific Sections 1.1 Licensed Activity Description Indicate the types of waste produced.
1.2 Site and Facility Description The included maps do not conform to the ren,uirements of the
" Standard Format and Content..." (Enclosure 1 to the Order of February ll, 1981).
In particular, provide a 'JSGS 7.5' topographical map and a site plan or aerial photograph with about a 1-mile radius to show near-site structures.
Indicate the contents of the pipeline to B&W.
Figure 2 is of too poor quality to be readable and appears to contain little or no useful information.
Figure 3 is also of poor quality, and has no scale.
Figure 4 does not show near-site structures within one mile of the CNFP. You should provide information, not shown on Figure 5 of elsewhere, concerning areas assigned to and confinement. systems for handling and storage of radio-active materials, ventilation systems, waste handling and disposal, radiation alarms, etc.
(See " Standard Format and Content...")
1.3 Process Description Provide the information specified in the " Standard Format and Content..."
. 2.0 ENGINEERED PROVISIONS FOR ABNORMAL OPERATION The information provided in this chapter of your plan is too brief and general to aid in a meaningful evaluation.
Information is needed on instrumentation for measuring offsite releases, ventilation system effluent controls, etc.
Criteria should be specified for detectors and alarms provided 'to detect accidental releases from a criticality event, fire, explosion, or severe natural phenomenon.
Specify frequencies of calibrations and other performance testing.
Supply alarm set points.
Specify essential equipment and areas supplied with auxiliary power.
3.0 CLASSES OF RADIOLOGICAL CONTINGENCIES Supply referenced materials preferably as suitably paginated materials for direct insertion into the body of your plan.
3.1 Classification System Because most offsite response agencies are already familiar with the terminology, the classification scheme (i.e., Notification of Unusual Event, Alert, Site Area Emergency, General Emergency) recommended in the Standard document must be used unless an overwhelmingly convincing case can be made to justify an exception.
No such justification was provided. Omission of the " General Emergency" classification may be permitted if it is demonstrated that an uncontrolled release of large in-ventories cannot occur. No such demonstration was provided.
Section 3.1 should contain specific implementing procedures for each identified class of radiological contingency.
i 3.2 Recommended Classification Scheme f
For an " Alert" (referred to in your plan as " Plant i
Emergency"), the Description column indicates that a response by the Emergency Response Organization would be required whereas the Emergency Response t;L Lon column indicates that the Emergency Response Orgari3l1 tion will be mobilized only in exceptional cases.
Please clarify. The scheme should provide for escalating events if necessary.
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. 4.1 Normal Plant Organization Provide a brief description of the normal plant organization.
An abbreviated organization chart is acceptable.
Tne description or chart should begin with the first position above the Pldnt Manager and should include all positions that may participate in the response to a radiological. contingency.
4.2 Onsite Radiological Contingency Response Organization Identify (e.g., by position title) the persons and alternates for each key position (PM, EMO, HSO, EV0, Security Officer) of the Emergency Response Organization.
4.3 Offsite Assistance To Facility Document the support arrangements made with the Concord Volunteer Fire Department and Lynchburg General Hospital.
Are they capable and willing to handle radiologically contaminated persons or equip-ment?
5.1 Activation Of Radiological Contingency Response Organization Identify action leve1s more prscisely than "as needed" or "if
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situation dictates," e.g., what size forest fire? How close to plant? What if 'the National Weather Service declares a " tornado alert?" How is Plant Manager notified if PA system is inoperative?
Does evacuation alarm function in case of loss of offsite power?
Assessment Actions This section appears to be missing from your Plan.
For each class of emergency, discuss the actions to be taken to determine the extent of the problem and to decide what corrective actions should be taken.. Renumber subsequent sections.
Corrective Actions Discuss the response actions to mitigate or correct the problem in further detail. For example, identify the location of -the
" provision...made to remotely shut down ventilation systems" mentioned in Section 2.0.
5.2 Protective Actions This section makes no commitment that can be enforced. More specific information is needed.
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. 5.3 Exposure Control In Radiological Contingencies The information called for in Section 5.5.1.2 of the
" Standard Format and Content..." is missing.
Please provide.
Provide materials now incorporated by reference.
5.3.3 Monitoring Information in d, e, and f, should be more specific, i.e.,
provide criterii fir applying these monitoring techniques.
5.4 Medical Transportation Assurance should be provided, here or elsewhere in the plan, that the members of the Concord Volunteer Rescue Souad are prepared, qualified, and willing to transport injured personnel who may also be radiologically contaminated.
5.5 Medical Treatment The plan implies that only one local physician associated with the Lynchburg General Hospital has received training in handling radiation accident patients.
Describe the course of action if this physician is not available. Describe any provision for backup. hospital services in case the capacity of the local hospital is exceeded.
6.2 Communication Equipment Describe the storage location of the portable radio units to be used if the Guard Station is not accessible.
6.3 Facility For Assessment Teams Assure that equipment and supplies needed by the assessment team would be available at the trailers or at other B&W facilities used by the assessment team. Greater specificity in the location of the assessment team is desirable.
6.4 Onsite Medical Facilities List the " standard first aid equipment" in the CNFP emergency kit, describe its location, and indicate steps to assure that all supplies are maintained in the kit.
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.... 6.5 Emergency Monitoring Equipment B&W should acknowledge a responsibility to check for offsite contamination in the event of an accidental release from the plant.
7.0 Referenced material, if suitable, should be 6xcerpted and included in the plan.
Greater detail is needed in all sections of this chapter to confoni to the " Standard Format and Content..."
Examples of information needed follow. What provision is made for a review of the Plan by an organizational element not directly responsible for the radiological contingency response program? Who is responsible for maintaining and updating the plan? How many hours of training are provided for each group or individual? What subjects are covered?
(Distinguish betweenclassroomandon-the-jobtraining.) How frequently are members of the Emergency Response Organization retrained?
Specify frequency of tests and drills, not "as necessary" or "as agreed to."
Provision should be made for critiquing tests and for changing the Plan'to reflect lessons learned from the test.
Communications drills with onsite response personnel should be held monthly, including a verification that the messages were properly received and understood.
Fire drills should be conducted three times. per year for onsite personnel.
Health physics and radiological monitoring drills should provide for the use of those instruments designated in Chapter 6 of your Plan.
8.3 Reporting Arrangements Identify a spokesperson for the plant who has access to all necessary information following an accident and describe procedures for keeping offsite individuals informed of the current state of events.
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