ML20092C524

Requests Delay of Implementation of Pulstar Emergency Plan to Allow Completion of Revised Version of Emergency Plan.Submittal of Revised Plan Expected within 60 Days

ML20092C524
Person / Time
Site:	North Carolina State University
Issue date:	06/15/1984
From:	Geoffrey Miller North Carolina State University, RALEIGH, NC
To:	Thomas C Office of Nuclear Reactor Regulation
References
NUDOCS 8406210223
Download: ML20092C524 (2)

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= * >7 School of Engineering "4o g a 8 Department of Nuclear Engineering June 15, 1984 Nuclear Reactor rrugram But 799 ZIP 28E-79u9 (989) 737-2321 Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing United State Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Thomas:

We have received your notification of May 29, 1984, that the PULSTAR Emer-gency Plan, Docket No. 50-297, submitted November 3,1982, has been approved for full implementation.

It is hereby requested that the implementation of the specified Emergency Plan be delayed to allow processing of a revised version of the Emergency Plan to be completed. Specifically, it is our expectation that the revised Emer-gency Plan we have prepared will be ready for submittal to the Nuclear Regula-tory Commission within 60 days of this date. Note that we have received a commitment from our Radiation Protection Council review body to meet the pro-posed schedule for submittal to the NRC.

The revision of the Plan was necessary because of organizational changes and recently finalized regulatory guides for the development of Emergency Plans for research and test reactors. The Plan submitted to the Commission on Novem-ber 3,1982, was developed using. ANSI-15.16-2982, " Emergency Planning for Research Reactors" and NUREG-0849 (For Interim Use and Comments), " Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors."

NUREG-0849 has now been issued in final form with significant revisions from the interim use version. The revised PULSTAR Emergency Plan incorporates the latest guidelines of NUREG-0849 and the present organizational structure of the PULSTAR Facility. Note that it is our understanding that NUREG-0849 is the NRC document used to ascertain the acceptability of a research reat'or emergency plan. If this is not the case, please advise what NRC guideline / document is used as the review basis such that an appropriate revision can be generated.

The principle justification for the proposed delay is to avoid the develop-

, ment and personnel trainir.g of an Emergency Plan version that would be in effect for probably less than two months. In the existing scenario of implementing with-in 120 days, and then implementing a revised version possibly 60 days later, the L possibility of personnel confusion between the various plans will be present. Thus to make a more orderly transition from our existing Emergency Plan to a revised Emergency Plan, developed in accordance with NUREG-0849, a single emergency pro-L cedure development and personnel training effort is deemed the logical course of 8406210223 840615 F

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North Carolina State University is North Carolina's original land-grant institution 0 and is a constituent institution of The University of North Carolina. '

Cecil 0. Thomas, Chief Page 2 i Standardization and Special Projects Branch i

action. ,

With Commission approval of the proposed delay and concurrent submission ,

of the revised Emergency Plan within 60 days, we would require significantly less ^

than the standard 120 days to implement the revised Emergency Plan. It is,there-fore, proposed that 30 days would be the specified time interval for full imp'le-  !

mentation of the revised Plan. The net effect of the proposed delay is on the l order. of 30 to 60 days from the original implementation date.  ;

It is requested-that the Commission consider the proposed implementation 1 Jelay and advise NCSU of your decision in this matter as soon as possible. If '

you have any' questions concerning this matter, feel free to contact me at (919) 737-2321.

~ Sincerely ,

dt.

Garry D r Associate Director and Nuclear Operations Administrator GDM:1pe

. cc: ' Chancellor Bruce Poulton Chairman, Radiation Protection Council Dr. Paul J. Turinsky Dr. Bernard Wehring Mr. T. C. Bray Dr. K. V. Mani  ;

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