ML20042C160

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Safety Evaluation Supporting Radiological Contingency Plan
ML20042C160
Person / Time
Site: 07001100
Issue date: 03/17/1982
From: Fisher F, Long J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20042C159 List:
References
NUDOCS 8203300283
Download: ML20042C160 (5)


Text

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DOCKET NO.: 70-1100 LICENSEE:

Combustion Engineering, Inc.

Nuclear Fuel Manufacturing Windsor Plant Windsor, Connecticut SilBJECT:

REVIEW 0FRAbI0LOGICALCONTINGENCYPLAN I.

Background

Combustion Engineering, Inc. (C-E), of Windsor, Connecticut, is authorized by NRC License No. SNM-1067 to possess and use at their Windsor facility up to 500,000 kg of uranium-235 at enrichments not exceeding 4.1%, 4,800 g of uranium-235 at enrichments greater than 4.1% but less than 20%, 10,000 kg of source material,10 g of plutonium-238 in encapsulated form, and 160 g of plutonium as analytical samples. The licensee fabricates low-enriched uranium fuel for LWR's. The current license was last renewed on January 30, 1976, and renewal proceedings are now in progress.

On February 11, 1981, the NRC issued an Order to C-E to submit within 180 days of the effective date of the Order a Radiological Contingency Plan for its Windsor facility in accordance with a standard format and content (Enclosure 1 to the Order).

By letter dated April 8,1981, the licensee requested an additional 60 days in which to prepare and submit a Radiological Contingency i

Plan. The Ofrector, Nuclear Material Safety and Safeguards, found that good cause existed for granting the additional time, and on May 14,1981, an Order was issued modifying the February 11 Order to that effect.

By letter dated November 9,1981, C-E requested another 60-day extension. The letter was sent to the License Fee Management Branch, where.it was held until after the due date for the 1fcensee submittal. Therefore no action was taken on the licensee's request of November 9, 1981.

On December 4,1981, C-E submitted a Radiological Contingency Plan for its Windsor facili.ty in accordance with the provisions of the February 11 and May 14 Orders.

On January 29, 1982, NRC sent the licensee a letter identifying necessary additional infonnation. On March 4,1982, representatives of C-E met with NRC staff to ensure that the additional information adequately responded to NRC's request.

l II.

Discussion The Radiological Contingeiity Plan submitted December 4,1981, as supplemented by information presented to NMSS staff on March 4, 1982, is adequate to demonstrate that the licensee has accomplished the purposes of onsite radiological e203300283 820317 DR ADOCK 07001

' contingency planning except for the three issues addressed below. The licensee has committed to resolving these issues n nd providing the necessary revised pages to his Plan by May 17,1982, which is prior to the date by which the plan must be implemented. With the May 17, 1982, submittal the licensee will have demonstrated (1) that its plant is properly

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configured to limit releases of radioactive materials and radiationexposuresintheeventofanaccident,(2)thata capability exists for measuring and assessing the significance of accidental releases of radioactive materials, (3) that appropriate emergency equipment and procedures 4re provided onsite to protect workers against radiation hadrds that might be encountered followin'g an accident, (4) that notifications are promptly made offsite to Federal, State and local government agencies, and (S) that necessary recovery actions are taken in a timely fashion to return the plant to a safe condition following an accident.

The three issues that the itcensee has comitted to resolve by May 17,1982, are:

1.

Offsite dose estimates from a criticality excursion will be reanalyzed using a more realistic estimate of building holdup delays or an assuredly conservative assumption for such delays; 2.

C-E used emergency level classification categories different from the NRC-FEMA standard categories. The licensee will correlate its; categories with the four standard categories and will commit to using the NRC-FEMA categories when making offsite notifications; 3.

C-E has not yet determined the relationship of the Emergency Planning Coordinator to its normal organization chart but has committed to resolving this internal organiza-tional problem in the May 17 submittal.

The C-E Power Systems facility is isolated on a wooded tract of more than 500 acres, which it shares with other major C-E engineering and development programs.

Radio-active materials in significant quantities are used in only two of the more than a score of buildings on the site:

(1) the fuel fabrication building and (2) the nuclear laboratory building with its annexes.

Manufacturing operations are the' c y, batchwise mechanical steps of uranium dioxide powder blending, pellet making, rod

, loading, and fuel bundle assembly.

Should an accident occur during any manufacturing step, the release of radioactivity would be inherently limited to the small quantity of material in the process batch, thus obviating the need for automatic shutdown provisions.

Stack effluents are sampled continuously, and the samples are checked for radioactive content during each shift. Any initiating event that could lead to a large release through the stacks would be imediately known through the concomitant effects on plant operation.

The C-E Windsor facility's emergency response capability, because of the extensive nonradiological activities on the same site, has the advantage of a large installation (skilled workforce,firebrigade,etc.)

for coping with the non-radiological consequences of any accident or incident in-volving radioactive materials.

Its response capabiitty is further strengthened by its inclusion, by State requirements, in the Connecticut State Emergency Operations Plan.

To remedy the deficiencies in the Radiological Contingency Plan submitted by C-E on December 4,1981, the following itcense condition is proposed:

"The licensce shall, by May 17, 1982, submit replacement pages for his Radiological Contingency Plan that shall provide the additional infomation requested in the NRC letter of January 29,1982, as presented in the meeting of the licensee staff with NRC staff on March 4,1982, and shall include (1) a revised analysis of offsite dose from a criticality excursion based on a more realistic estimate of building holdup delay, (2) a correlation between C-E's incident level categories and the four standardized NRC/ FEMA categories set forth in Enclosure 1 to the Order of February 11, 1981, with a comitment to use the standardized categories for any offsite notifications, and (3) a resolution of the position of the Emergency Planni~ng Coordinator within the C-E organization."

C-E has comitted to complying with this license condition.

III.

Conclusion and Recomendation The C-E Windsor facility license should be amended to incorporate the Radiological Contingency Plan submitted December 4,1981, as a condition of the license. The amendment should also include j

aconditionsuchasthatpropos.dinSectionII(above).

The proposed amendment should have ao adverse effect on the public l

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health and safety or on the quality of the environment and should improve C-E's ability to protect against, respond to,

-and mitigate the consequences of an accident involving radioactive matenfals.

i dh J. T. Long Environmental Radiation and Emergency Support Section Uranium Fuel Licensing Branch

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Division of Fuel Cycle and Material Safety, NMSS Approv F. D. Fisher, Section Leader e

Within ninety (90) days of the date of this amendment, the licensee shall implement, maintain, and execute the response measures of his Radiological Contingency Plan submitted to the Canmission on December 4, 1981.

The licensee shall also prepare and maintain implementing procedures for his Radiological Contingency Plan as necessary to implement the Plan. This Radiological Contingency t

Plan and associated implementi6g procedures supersede the emergency planning requirements of 10 CFR 70.22(i) as they. refer to onsite planning and notification.

The licensee shall make no change in his Radiological Contingency Plan that would decrease the response effectiveness of the Plan without prior Commission approval as evidenced by a license amendment. The licensee shall maintain records of changes that are made to the Plan without prior approval for a period of two years from the date of the change and shall furnish the Chief, Uranium Fuel Licensing Branch, Division of Fuel Cycle and Material Safety, NMSS, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, and the appropriate NRC Regional Office specified in Appendix D of 10 CFR Part 20, a report containing a description of each change within six months after the change is made.

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