ML20040H157
| ML20040H157 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 01/29/1982 |
| From: | Page R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lichtenberger ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| NUDOCS 8202170311 | |
| Download: ML20040H157 (7) | |
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JAN 2 91982 q.
Docket No.
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Combustion Engineering Inc.
- y ATTN: Mr. H. V. Lichtenberger y
Vice President-Nuclear Fuel cn Nuclear Power Systems Manufacturing 1000 Prospect Hill Road Windsor, Connecticut 06f95 Gentlemen:
We have completed our pre-acceptance review of the radiological contingency plan that you submitted on December 4,1981. Our review has revealed several deficiencies in content and format in the information submitted.
Those are described in the enclosure.
You are requested to send us additional information concerning these matters by March 1,1982. 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, 1931, Order.
Sincerely, j
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R. G. Page Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS o.OE
Enclosure:
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NRC FORM 318 h0.801 NRCM O240 OFFICIAL RECORD COPY
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Staff Comments from Initial Review of Radiological Contingency Plan Submitted December 4,1981, for Combustion Engineering's Windsor Facility General Comments Figures and tables should be numbered in accordance with the chapter number. Thus, in Chapter 1, the figures and tables should be numbered 1-1, 1-2...., not 2-1, 2-2,.... or 4-1, and 4-2.
Graphic presentations should be clearly legible and of suitable scale for the intended purpose, with symbols and notations identified in legends or tables.
Specific Comments by Section Section 1.2 This section should indicate the location, preferebly on an area map, of offsite response organizations such as:
St. Francis Hospital Windsor Police Department i
Windsor Fire Department Wilson Fire Department Poquonock Fire Department Nearest Connecticut State Police post Connecticut Office of Civil Preparedness Nearest Office of Civil Defense office This section should also identify population centers (not just nearest resident) within one mile of your facility, with approximate resident and/or commuter population of each center.
Examples:
G. E. Prototype Reactor, Griffin Office Center.
Are there others?
Some specific questions / comments on the figures in this chapter are:
Figure 2-2 What is C. E. M. H. I. Fan? What is the significance, if any, of Bloomfield 2, Bloomfield 4, Bloomfield 5,....?
Figure 2-3 This figure is illegible in the form submitted.
It should be reproduced more clearly.
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Figure 2-4 Identify the very large building in Sector 11 one mile southwest of the plant.
Figure 2-5 The figure is illegible and should be replaced.
Figure 2-7 Identify the large building just below (southeast.of) Building 14.
Figure 2-8 The figure is illegible and should be replaced.
Figure 2-9 The drawing title reads " Proposed Site Boundary." Are we to understand that the proposed boundary is now an actuality?
State the design criteria important to controlling /containing radioactive materials during normal operation.
Include the engineering and design requirements important to mitigate or prevent an uncontrolled release following an accident, and all other information required by Section 1.2 of the " Standard Format and Content...." (Enclosure 1 to the Order issued on February 11, 1981). Reference may be made to other Chapters of tne Contingency Plan, if appropriate and if the reference is clearly and correctly stated.
Section 1.3 What is the average and maximum amount of powder in the Pellet Shop Annex at any one time? Where are powder containers opened? What provisions are made for con-tainment of powder during the weighing and blending steps? At any one time, what quantity of uranium oxide powder is on the dryer belt, in the blender hoods, and the powder spread funnels (two parallel systems)?
Section 1.3.3 All cross references for the effluent treatments in the tables labeled 4-1 and 4-2 are incorrect. These references must be corrected to agree with the parag*aph numbers in the text.
Section 2.1.1 As submitted, this section addresses the prevention of abnormal operations, not the accommodation of abnormal operations.
Has any provision been made for automatic or manual safe shutdown after a serious accident?
. Section 2.1.2 Describe effluent monitor alarms. Also indicate the administrative controls used when alarm systems are inoperable.
2.1.3 Analysis of postulated Incidents Having Off-Site Impact Criticality Accident This section appears to be out of place. Almost identical material appears again in Section 3.0.
Some subsection numbering and/or introductory remarks or its relocation seem to be indicated. The doses calculated in this section, however, are inexplicably different from those in Section 3.0.
Please reconcile those differences.
In both sections credit is taken for holdup in the building for delay of release of fission gases assuming, in effect, that the criticality excursion occurs in the upstream end of the building with fission gases released to the room atmosphere at that point, that all air exhausts from the other end of the building, and that plug flow of the building air prevails between the two ends of the building. That assumption is very likely to be invalid and quite nonconservative.
Much more likely is that fission gases are more or less contained in process ventilation systems and move rapidly to an exhaust point with little or no delay. Where such gases are released to room air, rapid mixing with the room air is more likely than is plug flow.
In such cases, some releases would occur much more rapidly than with plug flow but the release would be smeared out over a longer time than the 7.5 minute delay you've used corresponding to no mixing (plug flow).
Most real cases of release into a ventilated room would exhibit behavior intermediate between the no-mixing and the complete mixing cases and require case-by-case assessment. Assumption that all fission gases promptly enter process enclosure exhaust ventillation ductwork and, thus, experience minimal holdup prior to release to atmosphere is conservative and is recommended for these consequence estimation calculations.
Please reanalyze your estimates of offsite dose from a criticality excursion to make the dose result estimates in Section 2.0 consistent with those in Section 3.0 and to use either a more detailed and more realistic estimate of building holdup delays or an assuredly conservative assumption for such delays, i.e. essentially none.
In Section 2.1.3.2, consider the impact of an accident at the neighboring KAPL-Windsor site.
Contrary to the assertion in Section 2.1.3.4, Chapters 3.0 and 4.0 do not address access and egress of operating personnel and emergency response teams. This information should be provided.
. Section 2.1.4 Procedures should be described for assuring that the stated criterion is met.
Chapter 3 A developing awareness by various participating agencies of the importance of a standard nomenclature in the response
~to radiological conti gn encies has made it necessary that each plan contain the four categories of the classification scheme described in ths Standard Format. Thus, classes of radiological contingencies must include at least the four standardized categories, viz, Notification of Unusual Event.
Alert, Site Area Emergency, and General Emergency, in order that response agencies at several governmental levels can readily determine an appropriate response.
Section 4.1 Clarify whether the Vice President to whom the VP-Development reports is VP-Products, Services and Development (as shown on Figure 2.2.1) or VP-Engineering and Development (as shown on Figure 5.la).
Section 4.1.3 Titles of responsible persons are not always consistent Section 4.2.2 with titles shown on the accompanying organization charts.
These inconsistencies should be resolved.
Section 4.3 A letter of agreement is needed from St. Francis Hospital confirming willingness to accept and treat patients actually or potentially contaminated with radioactivity.
Letters of agreement should also be provided from the Windsor, Wilson, and Poquonock fire departments.
Section 5.2 Procedural steps should be described for data gathering after an accident.
Section 5.4.1 Some consideration should be given to radiological monitoring and decontamination of evacuees.
Section 5.4.2 Use of protective clothing should be mentioned.
Section 5.4.3 Some consideration should be given to area access control and isolation and to criteria for return to normal use.
Section 2.2.4 provides action levels for routine contamination surveys of areas. Action levels for areas, equipment, and personnel during emergency conditions should be included here.
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. Section 5.5.1 It is required that reentry team (s) have a capability for measuring radiation fields that may be encountered (Table 2.3 lists fields to 1000 R/hr.)
Indicate how this capability is to be fulfilled. The survey meter described reads only 20 mr/hr full scale.
(A backup high-range instrument or instruments should also be available.)
Information should be presented on pro-cedures for decision making and risk evaluation for voluntary doses by persons performing emergency activities.
Describe provisions for assuring that dose commitment records are maintained for emergency workers.
3 Section 5.5.2 Describe action levels for determing the need for personnel decontamination.
Section 5.7 Describe alternate treatment-facilities to be used in case the capacity of St. Francis Hospital is exceeded.
Section 6.3 Describe arrangements for providing assessment team members -with equipment drawings, operating procedure manuals, or other reference material useful in postaccident and recovery assessment.
Section 6.5 Operational data should be provided for the available instrumentation.
Describe procedures for verifying the operability of instrumentation at the time of its use 1
during an emergency. Also describe maintenance and calibration requirenents.
Section 7.'i Indicate the relationship of the Emergency D]annjpg Coordinator to the organization charts in Chapter 4.
How is the composition of the Review Connittee determined?
(An independent review is recommended, i.e., one conducted by a competent group or organization either. internal or external to the licensees' organization, but that is not directly responsible for the radiological contingency response program.)
Section 7.5 Describe procedures for corrective actions to be taken when deficiencies are found during checks.
Describe steps taken to keep essential emergency equipment secured to prevent pilfering and misappropriation.
Section 8.1 Assure that records for the four stipulated classes of emergencies include the cause of the incident, personnel and/or equipraent involved, extent of injury and/or damage resulting from the incident, corrective actions taken to y
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. terminate the emergency, and the action taken or planned.to prevent a recurrence of the incident.
The records should also include the onsite and offsite support assistance requested and received for recovery action.
Section 8.2 Describe and locate records of drills and tests, inventories and locations of emergency equipment and supplies, and maintenance, surveillance, and testing of equipment and supplies.
If these records are described elsewhere in your plan, a specific cross-reference will be acceptable.
Section 8.3 Identify a spokesperson for the plant who has access to all necessary information following an accident.
(In the immediate aftermath, the Emergency Director will be too busy with directing recovery and restoration operations to answer questions from outsiders.)
Section 9.3 Indicate acceptable levels of radiation / contamination that must be achieved before resumption of operations.
An investigation to determine the cause of an incident should be completed before operation is resumed.
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