ML20044H148
| ML20044H148 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 06/04/1993 |
| From: | Lamastra M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Christopher Boyd BABCOCK & WILCOX CO. |
| References | |
| TAC-L21623, NUDOCS 9306070474 | |
| Download: ML20044H148 (5) | |
Text
..
JUN 4 1933 Docket 70-824 License SNM-778 Mr. Charlie C. Boyd, Jr.
j Licensing & Compliance Officer l
Babcock & Wilcox Nuclear Environmental Services Division Lynchburg Technology Center P.O. Box 11165 Lynchburg, VA 24506-1165
Dear Mr. Boyd:
SUBJECT:
EMERGENCY PLAN, REVISION 0 (TAC N0. L21623) j We have completed our review of the new Emergency Plan, Revision 0, dated April 12, 1993, and concluded that additional information is needed before final action can be taken. Our comments are enclosed. We reviewed your Plan against Regulatory Guide 3.67, " Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities." A copy of Regulatory Guide 3.67 is enclosed for your use.
Please submit the requested information (six copies) as page changes to the Plan or submit a new Emergency Plan. The requested information should be submitted within 120 days of the date of this letter.
Please reference the above TAC N0. in future correspondence related to the request.
If you have any questions, please contact me at (301) 504-3416.
Sincerely, Mi
.Lm tra Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS
Enclosures:
1.
Request for Additional Information 2.
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l' Request for Additional Information Application Dated April 12, 1993 Babcock & Wilcox Lynchburg Technology Center Docket 70-824 Please provide the following information:
1.
Section 1.1 should be modified to state whether any radioactive materials authorized by the State of Virginia are used at the site.
2.
The copy of the topographical map provided in Figure 1-5 is difficult to read. The Plan should contain an original United States Geological Survey 7.5" topographical map.
3.
An enlarged (24x30-inch minimum) duplicate of the detailed site map (Figure 4) should be included in the Plan. The map should include all the onsite and near-site structures listed in Section 1.2 of Regulatory Guide 3.67.
4.
In the last paragraph of Section 1.3 you state, "Due to the large number of different type; of hazardous materials (hundreds) and the non-static Nature of this listing in the laboratery environment, a detailed list of all the hazardous chemicals used at the site is not provided." While all hazardous chemicals need not be listed, the major chemicals used, approximate quantities, and potential for accidents should be evaluated.
5.
While sharing the emergency site organization with the Naval Nuclear Fuel Division (NNFD) is acceptable, you should describe the types of accidents pertinent to your facility.
For each accident identified, describe the cause of the accident (equipment malfunction, instrument failure, human error, etc.); the process and physical location; possible complication factors; and possible onsite and offsite consequences.
For criticality accidents, evaluate the direct radiation exposure in addition to the dose from released radioactive materials (see Regulatory Guide 3.67, Section 2.1).
6.
For each postulated accident listed in response to question 5 above, please describe the means for detecting the accident and any release of radioactive or other hazardous material, the means for alerting the operating staff, and the anticipated response of the operating staff (see Regulatory Guide 3.67, Section 2.2).
]
2 7.
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 you choose to establish the EAls in an implementing procedure, a copy of the EAls should be submitted in response to these comments.
8.
Section 3.2, Classifying an Emergency, should describe the decision making used for initiating protective actions onsite, requesting offsite assistance, and recommending protoctive 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 areas should be isolated, highway traffic should be stopped, 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 l
authorities.
9.
Section 4.2 should clearly state what members of the emergency response organization are available onsite during nonworking periods and which onsite personnel have the authority to declare an emergency during nonworking periods.
10.
Section 4.1.3 should discuss site access by offsite response organizations during an emergency.
11.
Section 4 should identify the principal State agency responsible for radiological emergencies at the site. The Plan should clearly require notification of this agency every time an alert or site emergency is declared. The purpose of this notification is to allow the agency to evaluate the need for protective action offsite, not just to request assistance.
In addition, the authority and response capability of each of the State agencies listed should be described.
12.
For the events identified in response to question 5, briefly describe the means and equipment provided for mitigating the consequences of each type of accident.
Include the mitigation of consequences to workers onsite, as well as to the public offsite.
In the event of a warning of impending danger, describe the criteria that will be used to decide whether a single process or l
the entire facility will be shut down.
1
1 3
13.
Section 5.4.1, " Personnel Evacuation and Accountability," should be modified to include (a) search and rescue procedures, (b) procedures for monitoring evacuees for contamination, and (c) provisions for determining and maintaining the accountability of assembled and evacuated personnel.
14.
Section 5.4.2 should be modified to describe:
(a) criteria for issuance of emergency equipment, if appropriate; (b) locations of emergency equipment and supplies; (c) inventory lists indicating the emergency equipment and supplies at each specified location; and (d) means for distribution of these items.
15.
Section 5.5.1 should be modified to include procedures for permitting onsite volunteers to receive radiation doses in the course of carrying out life saving and other emergency activities.
Procedures should provide for expeditious decision making and a reasonable consideration of relative risks.
16.
Section 5.5.2 should be modified to include the action levels for decontaminating personnel and the methods for obtaining decontaminating supplies, instruments, and equipment and for collecting and handling radioactive wastes.
17.
In Section 6.1 you state that "The Emergency Officer may, at his discretion during emergencies that are confined to a specific area, establish a temporary emergency operations center." Please clarify whether this is the Emergency Officer defined in Section 4.2.1 or the Emergency Director defined in Section 4.2.1.
If it is the Emergency Officer's responsibility, please modify Figure 4-2, " Emergency Organization," to include the Emergency Officer.
18.
Section 7.3 should require nonparticipating observers to evaluate drills and exercises. Describe the performance criteria to be used by observers for evaluating the participants.
Specify that the exercise objective and scenario will be provided for comment to the NPC at least 60 days prior to the exercise and that the NRC will be invited to participate in the exercise.
i 19.
Section 7.4 should specify that the critiques will include the findings of the nonparticipating observers and describe how deficiencies and corrective actions will be tracked to ensure completion and close out.
4 20.
Section 9.2, " Plant Restoration," should state that during any planned restoration operations, personnel radiation exposures will be maintained within 10 CFR Part 20 limits and as low as reasonably achievable.
21.
The Plan should clearly certify that the licensee has met its responsibilities under the Emergency Planning and Community Right-tr-Know Act of 1986. Section 10.0 implies that the licensee is in compliance, but a clear certification should be provided.
i l
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