ML20058N513
| ML20058N513 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 10/01/1993 |
| From: | Knapp K FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20058N517 | List: |
| References | |
| NUDOCS 9310180205 | |
| Download: ML20058N513 (5) | |
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wd An Amencen Company wrth Worldwide Resources P.O. Box 11646 Lynchburg, VA 24506-1646 Telephone:804-522-6000 October 1, 1993 Robert C.
Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS United States Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Pierson:
REFERENCE:
Docket No. 70-1201, S!TM-1168 B&W Fuel Company has revised it's Emergency Plan to incorporate the comments you requested in correspondence dated April 9, 1993.
Per 10 CFR 70, the Plan was sent to offsite agencies to review prior to submitting the Plan to you.
The Plan is dated 8-6-93, revision 2 and should replace the Plan dated 8-13-92, revision 1 in it's entirety.
Until you approve the submitted Plan, we will continue to operate under the Plan submitted to the Commission on October 17, 1990 and supplemented on January 7, 1991 and January 14, 1993.
Attachment I provides the details of the changes.
If you should require any additional information concerning this matter, please feel free to contact me at (804) 386-5202.
Sincerely, B&W FUEL COMPANY Commercial Nuclear Fuel Plant Mj\\ b. h iT Kathryn S.
Knapp, Manager, Safety and Licensing l
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NRC Region II l
101 Marietta St. N.
W.
Atlanta, GA 30323
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a ATTACHMENT I Please provide-the following information:
1.
Section 1.1 should describe the type, form, and quantities of radioactive material authorized by the NRC license and how much is normally present.
The plan should also state whether any radioactive materials authorized by the State of Virginia are used at the site.
Section 1.1, page 2, has been expanded to include the type, form, and typical quantities of licensed material.
2.
The plan should include a list of the hazardous chemicals used or stored on site.
The list should include the typical quantities possessed and the locations of use and storage of large quantities of chemicals (e.g., tanks).
Section 1.2, page 3, Description of Chemical Usaae has been
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added to provide the information requested above.
3.
Section 1.1 should include a description of exhaust stack locations, stack heights, typical flow rates, and the efficiency of any emission control devices.
A paragraph describing our ventilation system was added.
However, we felt that it was more appropriate to be included in section 1.3, page 5, instead of section 1.1.
4.
The copy of the topographical map provided in Figure 6 is difficult to read.
The plan should contain an original United States Geographical Survey 7.5" topographical map.
Haps can be obtained from the US Geographical Survey, map distribution, Denver Federal Center, P.
O.
Box 25286, Denver, CO 80225.
The telephone number is (303) 236-7477.
A more legible copy of the origital topographical map has been included.
5.
An enlarged (24 x 30 inch minimum) duplicate of the detailed site map (figure 4) should be included in the plan.
t An enlarged copy of the site map has been included.
However, I believe it is figure 2 not figure 4.
6.
Section 2.1 should be modified to delete " Trivial Incidents" and " Accidents at Neighboring Facilities."
" Trivial Incidents" and " Accidents at Neighboring Facilities" has been deleted.
7.
Since your facility does not currently use uranium dioxide f
powder, you should delete all accidents associated with this material.
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A revised accident analysis has been conducted to reflect
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the worst case accident scenario with current operations.
It has been-included under section 2.1, page 8, Descriotion of Postulated Accidents.
.1 8.
Section 2.1 should be modified to define " major fire" and
" major explosions."'
The definition of major fire and major explosion has been defined in section 2.1, page 10.
9.
Your plan should be modified to add a Section 2.2,
" Detection of Accident" (See Regulatory Guide 3.67).
l Section 2.2, pages 14-15, has been added to describe the
" Detection of Accident."
10.
The plan should clearly certify that the licensee has met its responsibilities under the Emergency Planning and i
Community Right-To-Know Act of 1986.
Section 10.0 implies that the license is on compliance, but a clear certification should be provided.
A stronger commitment has been added to clarify that we comply to the Community Right-To-Know Act of-1986.
11.
Assuming the uranium dioxide powder events are removed form your emergency plan, you should re-identify postulated accident (see Section 3.1, Regulatory Guide 3.67)
A revised accident analysis has been conducted to reflect the worst case accident scenario with current operations.
It has been included under section 2.1, page 8, Descriotion of Postulated Accidents.
i 12.
Describe in greater detail the decision making process for alerts and site area emergencies.
(See section 3.2, Regulatory Guide 3.67)'
section 3.2 has been expanded to provide general guidance for the decision making process.
Detailed instructions are provided in internal procedures.
13.
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 the licensee chooses to establish EALs in an implementing procedure a copy of the EALs should be.
- L submitted with the licensee's response to these comments.
Emergency action guidelines have been included in section 3.2, page 19-20.
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E t-14.
Section 3 should clearly state that offsite response organizations will be notified promptly~(normally within 15 minutes) of declaring an alert or site area emergency (FAE),
and that the NRC operations center will be notified immediately after the offsite response organization but no later than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after declaring an alert or SAE.
This commitment for prompt notification has been added to section 3.2.1 and section 3.2.2 e
15.
In addition to classifying an emergency, Section 3 should also describe how decisions are made to initiate protective 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 official notification of offsite authorities.
Initial PARS should include whether or not ant offsite area should be isolated, 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 authorities.
Section 3 has been expanded to provide general guidance for protective actions.
Our internal procedures contain detailed protective actions to include a prepared list of information to be conveyed by the administrative assistant to the agency she is notifying.
16.
Section 4 should be' modified to briefly describe the normal plant organization.
Section 4.2.1 has been expanded to describe Emergency Personnel's position during the normal course of business.
17.
Section 4.2 should clearly state what members of the emergency response organization are available onsite during nonworking periods.
Which onsite personnel have the authority to declare an emergency during nonworking periods.
Section 4.2.2, page 24, Onsite Direction Durina Nonworkina Hours, has been added.
18.
Section 4.3 should discuss site access by offsite response organizations during an emergency.
Any provisions to suspend security or safeguards measures should be described.
Section 4.3 has been expanded to clarify that security shall allow support agencies onsite to provide assistance.
19.
Section 4.4 should describe the rumor control arrangements that have been made with the government agencies to ensure that the media and the public have access to accurate information during an emergency.
Section 3.2.3.4 has' been added to inform agencies of a emergency telephone number that they may call to verify information that they have received is factual.
20.
The plan should be modified to include the information l
described in Sections 5.2 and 5.3 of Regulatory Guide 3.67.
General information for assessment and mitigating actions i
have been added section 5.2 and 5.3.
Our internal emergency procedures provide more detailed directions.
21.
Section 5 should be modified to describe the criteria for relocating the command center.
Section 6.1, page 38, Command Center, has been modified to address relocation of the command center.
22.
Section.7.3 should require nonparticipating observers to
' i evaluate drill and exercises.
The plan should describe how criteria for acceptable performance will be prepared and provided to observers for evaluating participants.
Critianes, section 7.4, page 42, has been added to describe how we evaluate drills and exercises.
23.
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 they are completed and closed out.
The section noted above, critiques, section 7.4, page 42, includes a tracking system for such items.
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