ML20128D131
| ML20128D131 | |
| Person / Time | |
|---|---|
| Site: | Claiborne |
| Issue date: | 01/29/1993 |
| From: | Leroy P LOUISIANA ENERGY SERVICES |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20128D136 | List: |
| References | |
| NUDOCS 9302100056 | |
| Download: ML20128D131 (21) | |
Text
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January 29,1992 hir. John W. N.1-lickey, Chief Fuel Cycle Safety Ilranch Division of Industrial and hiedical Nuclear Safety Office of Nuclear hiaterial Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Docket No.: 70-3070 Louisiana Energy Services Claiborne Enrichment Center Emergency Plan Requests For Additional Information File: hfTS 6046 00-2001.01
Dear hir. Hickey:
Enclosed in Attachment A are the responses to your requests for additional information (RAl) contained in Enclosure 1 of your letter to LES dated November 20,1992 concerning the Claiborne Enrichment Center (CEC) Emergency Plan (EP). These comments were discussed in detail at a meeting on November 5,1992 with members of your staff. An "Information Only" copy of the revised EP is enclosed. Changes to the EP are highlighted by n vertical bar in the right hand margin. Where a change to the EP has been made in response to a specific question, the questions number is provided in the right hand margin. Other editorial changes have been made to enhance readability. A formal distribution of the EP revision will be made in the near future.
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Januaiy 29,1992 3
Mr. John W. N. tilckey, Chief Page 2-If there are any questions concerning this, please do not hesitate to call ine at (704) 373 l
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8466.
Sincerely.
h4bA' $ tbfb Peter G. LeRoy Licensing Manager PGl/N78.122 Enclosures xc:
(w/ enclosures)
Ms. Diane Curran, Esquire liarmon, Curran, Gallagher, & Spielberg-2001 S Street, NW, Suite 430 Washington, DC 20009 1125 Ms. Nathalie Walker Sierra Club Legal Defense Fund 400 Magazine Street Suite 401 New Orleans, LA 70130 Mr. R. Wascom Office of Air Quality and Radiation Protection-Louisiana Department of Environmental Quality PO Ilox 82135 Baton Rouge, Louisiana 70884 2135 a
January 29,1992 Mr. John W. N. Ilickey, Chief
- Page 3 bxe:
(w/ enclosures)
V. M. Anthony M.T.lloyd W.11. Arnold (LES)
E. F. Kraska (Urenco)
J. M. McGarry (W&S)
I'roject Files Central Records
1 Novcinher 20,1992 Request for Additional Infonnation SAFITIY 9.6 EmerEency Planning On February 3,1992, you submitted the first revision to lamislana Energy Services' Emergency Plan (EP), in response to our request for additional Information (RAl) of June 25,1991. We have reviewed the revised EP and have the following comments and
)
1 RAI.
1.
Regulatory Guide 3.67 was issued in final form in January 1992. The EP Introduction refers to the draft regulatory gulde. You should ensure that the EP conforsns to the final gulde, llesponse:
e
- The EP introduction has been revised to delete the reference to the draft regulatory guide. The introduction has also been revised, as has the remainder of the EP, to icflect the fact that the North Claiborne llospitalis longer operating.
2.
Section 1.2 and figures 1.21 and 1.2 2 should include site features affecting emergency response. This includes lientifying the exact location 9 the following:
f a.
Primary and alternate conunand centers.
b.
Assembly areas for plant evacuation.
c.
Emergency assessment centers, e.g., laboratories, etc.
d.
Medical faelhtles, e.g., first aid room, staging areas for ambulance.
c.
Meteorolopeal monitoring system.
Response
Section 1.2 and Figures 1.21 and 1.2 2 have been revised to provide the requested information.
Attachment A A1 A
3.
Section 1.2 should summartre stack heights, and flow rates and emclency of i
emission control devices, Ergons i
A description of the stack heights, flow rates, and efficiency of emission control devices has been provided in section 1.2.
4.
The quality of ligure 1.21 is poor and many of the labels are not legible.
Including the scale. In addlllom (a) the location of fences and gates are not clear; (b) the exhaust stacks are not shown; (c) the contour lines nmke the map dimcult to read and should be deleted.
Ersponse:
t The suggested changes have been made to Figure 1.21.
5.
Figure 1.2 2 must contain or be corrected as follows:
a.
The roads leading up to the main gate and the south gate must be i
labelled.
b.
Indicate the proximity of Routes 2 and 9.
c.
The fence line is faded in several places and difficult to read, t
d.
It is not clear what the segmented area, of varying widths and surrounding the site, is supposed to symbolized.
It would also be helpful,if the items discuss in conunent #2 were indicated on this large ma p.-
Enponse:
The suggested changes have been made to Figure 1.2 2.
Attachment A A2 i
r I
w
6.
The plan should contain a table of hazardous chemicals used at the site. The table sliould include t)pleal quantitles possessed, and the locations of use and storage of large quantitles of these materials, e.g., tanks.
Essens Tables 1.2-1,1.2 2,1.2 3, and 1.24 have been added to provide the requested information.
7.
The scale on Figure 1.31 is cut off.
82M1.0RW
- 1 Figuie 1.31 has been reprinted.
8.
The quality of figure 1.3 3 is poor and it is difficult to read. The plan should contain an original copy of the United States Geological Suncy map for the area.
In addition, you should Indicate what inaterial is carried in the pipelines running to the north and south of the site.
Enponse:
Figure 1.3 3 has been reprinted in color for clarity. The pipelines have been labeled to indicate what material is carried in the pipelines.
9.
The quality of Figure 1.3 4 is poor. You may want to consider reducing the circle radius to 10 miles and enlarging the center portion of the map.
Enponse:
Figure 1.34 has been reprinted. The circle radius has been reduced to IC miles.
l Attaciunent A l:
A3
10.
Section 2.0 states that the facility only handles natural uranium.11 sliould recognize that low enriched uranium will also be handled.
llesponse:
Section 2.0 has been revised to indicate that the CEC handles natural and low enriched uranlulu.
11.
The accident descriptions in Section 2.1 should identify the physical locations where potential releases would occur and should identify the possible onsite and offsite consequences (worst case scenarios). For each worst case scenario, the plan should clearly state the maximum exposures that could be experienced by workers at the accident site, as well as, by the public at the site boundary.
Response
Section 2.1 has been revised to indicate possible maximum exposures that could be experienced by workers at the accident site, as well as, by the public at the site boundary.
Section 2.1 has also been revised to provide a reference to SAR Chapter 9 and SAll Table 9.2-2. SAR Chapter 9 provides detailed descriptions of potential incidents at the CEC and possible exposures to radioactivity and chemicals resulting from each incident.
This referencing of detailed infonnation is reconunended in Section A. Introduction of Regulatory Guide 3.67," Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities."
12.
Section 2.2 should contain more than a general description of the detection systems. For cach of the accidents postulated in Section 2.1, the plan should describe: (a) how the accident would be detected; (b) when it would be detected; and (c) how the operatinejfaff would he alerted.
Response; e
Section 2.2.3 has been added to the EP to provide the requested information.
Attachment A A-4 1
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,,,..,,,,.,,,,,,,,,,,,ad
13.
The difference between the alert and the site area emergency (SAE) classifications is the need to implement protective actions offslie. Section 3.1 Indicates that the difference is to assist in recoseiy operations which is incorrect.
Response
Section 3.1 of the EP has been revised to indicate that the difference between an Alert and Site Area Emergency is that during a Site Area Emergency assistance could be required from offsite response organizations to implement protective actions offsite.
14.
Section 3.1 sets what appears to be an arbitrary threshold of 1000 k81ograms of UF release for defining when an alert upgrade to site area emergency should be 6
declared. You should establish emergency action levels (EAl.s), explaining the basis for declaring an alert or site area emergency. EALs are specific conditions related to events or Indications by detection systems. Appendix A of Regulatory Guide 3.67 contains general examples.
Response
Section 3.1 of the EP has been revised to provide the basis for the threshold release of UF. that requires upgrade of an incident ham Alert to Site Area Emergency.
Additional examples of incidents and their Emergency Action Level have also been provided.
15.
Section 3.2 shou!J clearly state that the NRC will he notified immediately after the state and local authorities, but no later than an hour after declaring an Alert or SAE.
Response
Section 3.2 has been revised to indicate that the NRC will be notified immediately after the state and local authorities, but no later than an hour after de.claring in Alert or SAE.
Attachment A A5 H
16.
The content of Section 3.2 is confusing. This section should describe the decision making process during an emergency. For example,it should contain the following:
a.
Who are the decision makers?
b.
Ilow are they notifled that a problem exists?
What criteria or guidance would they use to snake the decisions listed in c.
Section 3.2 of Regulatory Guide 3.677
Response
Section 3.2 has been revised to describe the decision making processes during an emergency.
17.
The first paragraph on page 3 3 appears to discuss detection systems. It seems more appropriate to hase this paragraph in Section 2.2.
Response
The information in the first paragraph on page 3 3 has been reworded and relocated to section 2.2.
18.
The second paragraph on Section 3.2.1 states that the Shift Supervisor declares an alert upon verification of incident. If" verification" means to do a survey of the incident, it is not acceptable to us to wait for survey resuits before declaring an emergency. The applicant must establish EALs for declaring an emergency based cn information available within the 11rst few minutes of an accident. (This -
comment also applies to Section 3.2.2).
Response
Section 3.2.1 has been revised to indicate that the Shift Supervisor confirms the incident.
This confirmation may be by other personnel who relate the incident to the Shift Supervisor. Using the criteria provided in a Emergency Plan Implementing Procedule specifically written to provide criteria for determining EAL (specific examples of these criteria are provided in section 3.1), the Shift Supervisor determines the EAL.
An ment A A-6
19.
The second paragraph in Section 3.2.1 is confusing, it says that the Central Control Room Operator sounds the evacuation alarm upon notification of the incident. Ilut it also says that the evacuations are directed by the Shift Supervisor. Who actually decides to inillate an evacuation?
It is also unclear:
Who decides whether the person reporting a fire can atternpt to extinguish a.
it?
b.
Who decides which systems to shut down and which operations to suspend?
Response
Section 3.2.1 has been revised to provide the requested infonnation.
20.
At the top and bottom of page 3 4, Section 3.2.1 and 3.2.2, the follow up investigation items appear to response measures that should he discussed in Section 5.
Response
Section 5 has been revised to discuss the follow up investigation ituns, 21.
Section 3.3 should discuss the protective action reconunendations that the licensee will transmit with the initial notification of a site area emergency. The ba:1: for each reconunendation and the procedure for selecting a reconunendation should be discussed.
Response
Dased upon the review of the possible incidents at the CEC, there is only one recommendation that need be transmitted with the initial notification of a Site Area Emergency. That recommendation has been added to section 3.3.
Attachment A A-7
22.
The offsite response organizations identified in Section 3.3, Figure 31, do not inatch the organizations listed in Section 4.4. For example, Figure 31 Indicates that the licensee must go through two other agencies to contact the local f1rchnedical authorities.
Response
Figure 31 has been revised to agree with the organizations listed in Section 4.4.
23[a]. Section 10 of Table 31, should identify each offsite organization for uhleh notification is always required to ensure that notifications and updates are not missed.
Responsm Table 31 has been revised to include the organizations for which notification is always required.
23[h). Table 4.1 1 does not Indicate where the shift supervisor is located in the normal organization. Is he under the operations superintendent?
Response.;
Tables 4.11 and 4,2-1 have been revised to indicate the Shift Supervisor reports to the Operations Superintendent in the normal and emergency organizations.
24.
Section 4.2 should describe the emergency organization during non regular hours.
The plan should clearly identify which positions are staffed by personnel onsite and which must he sununoned to the plant.
Responw:
Section 4.2 has been revised to provide the requested information.
Attachment A A8
25.
The responsibilities in Section 4.2.1 should he clarifled. The Emergency Coonlinator only activates the facility emergency organization. Offsite organizations will decide whether or not to activate their personnel, in addition, the Emergency Coonlinator only has the authority to impicinent inutective actions onsite. Offsite response organizallons are responsible for offsite protective actions.
hponSe*
Section 4.2.1 has been revised to indicate that the Emergency Coordinator only activates the facility emergency organization.
26.
Section 4.2.2 should state what position the Shift Supervisor assumes after the CEC Manager relleves him during the incident. (Would the Shift Supervisor be in charge of plant coming back to regular conditions after the incident is over with?)
Besponse:
Section 4.2.2 has been revised to indicate that upon being relieved (by the CEC Manager or designee) the Shift Supervisor continues to provide assistance to the Emergency Coordinator to contain any material released, to assess the hupact of any material i
released and to restore the facility to a normal and safe status. The Emergency Coordinator only activates the facility emergency organization.
27.
It is unclear who is responsible for staffing the command center. Section 3 states that it is the Shift Supervisor, whereas Section 4.2.3 Indicates that it is the CEC -
Manager, and Section 4.2.4 states that it is the Superintendent of Operations.
llesponse.1 Sections 4.2.3 and 4.2.4 have been revised to indicate that the Emergency Coordinator is responsible for staffing the Emergency Operations Center (EOC).
Attachment A A9 i
28.
Table 4.21 sliould Indicate that tiie Emergency Coort inator is the llead of tiie t
Emergency Organization. It is not clear which of thi.rganizational groups identined in this table are assigned the functions specined in Section 4.2.2 of Regulatory Guide 3.67. The plan should clearly Identify which groups are assigned which functions. It sliould also identify any changes in staff assignments during non regular hours, when all the groups may not be available.
Responsti Tabic 4.21 has been revised to indicate that the Emergency Coordinator is the head of the Emergency Organization. Table 4.21 also provides information as to what groups are assigned which functions during an emergency. The entire organization is staffed anytime the EOC is activated, 29.
The Emergency Response Team and the IIcalth and Safety Orncer were not identified as part of the emergency organization in Section 4.2 and Table 4.21.
Response
+
The titles " Emergency Response Team" and "licalth and Safety Officer" have been revised to agree with their names in the Emergency Organization.
30.
Section 4.3 should describe prmisions for site access of offsite emergency workers. The description should identify any security or safeguards measures that will be suspended to allow firemen, ambulance, technicians, etc., access to the site.
He_sponse:
Section 4.3 has been revised to provide the requested information, y
i.
Attachment A A 10
31.
Section 4.4 should describe how onsite and offslie personnel will countinate their activities. For example:
Are lleensee radios compatible with radio systems used by offsite a.
organizations such as fire and police departments, and medical units?
b.
Who is in charge when offsite fire or medical units come onsite?
Who is in charge when security personnel coordinate with offsite law c.
enforcement agencies?
Response
Section 4.3 has been revised to indicate how onsite and offsite emergency personnel coordinate their activities.
32.
Section 4.4 should describe nnnor control arrangements with offsite organizations to minimlre flie release of inaccurate Information during an emergency.
Enponse:
Section 4,4 has been revised to indicate the rumor control arrangements with offsite organizations to minimize the release of inaccurate information during an emergency.
33.
Table 4,41 should suimnarize the different jurisdictions of the Claiborne Sheriffs Department and the liighway Patrol.
Response
Table 4.41 has been revised to summarize the different jurisdictior.s of the Claiborne Sheriff's Department and the flighway Patrol.
Attachment A A-11 i.
l
i 34.
Section 5.1 does not clearly describe what system is used to tell onsite emergency personnel to report to their duty stations. Are there different activation lesels or does the entire organization report every time? The plan should describe how emergency workers are sununoned from offsite, i.e., automatic pager systems, manual pager systems, Individual telephone calls, etc.
Response
Section 5.1 has been revised to more clearly describe what system is used to activate the EOC and how emergency workers are sununoned from offsite.
35.
Section 5.2 should describe the types and methods of monitoring and sampling that will be done for e.ach of the accidents postulated in Section 2. Statements such as, " personnel will respond as necessary," are not adequate. The plan should also describe the methods for estimating offsite exposures.
Beyonse:
Section 5.2.3 has been added to the EP to describe the types and methods of sampling and monitoring performed in the event of an incident at the CEC.
36.
Section 5.3 should discuss mitigating actions for all postulated accident scenarlos.
Response
Section 5.3 has been revised to include information coacerning mitigating actions during postulated incidents at the CEC.
37.
Section 5.4.1 should identify the evacuation routes and assembly areas.
Response
Section 5.4.1 has been revised to identify the evacuation routes and assembly areas.
Attachment A A-12 l
38.
Condition h in Section 5.4.3 only addresses direct radiation exposure. Criteria for surface contamination should address the potential for personnel intake,1.c.,
Inhalation / Ingestion, further spread of contamination, and resuspension in air, llemonse:
Section 5.4.3 b. has been revised to address the potential for personnel intake, i.e.,
inhalation / ingestion, further spread of contamination, and resuspension in air.
h 39.
Section 5.4.4 should describe the protective action reconunendations that the licensee has developed to conununicate with inillal notincation to offsite organinitions. The description should identify what offsite areas would be affected. Recommendations for residents to stay out of potentially contaminated areas or restrict use of streams and creeks should be addressed,
Response
Section 5.4.4 has been revised to indicate the protective action reconunendations LES has developed to conununicate to offsite assistance organizations.
40.
Section 5.5.1.1 Impiles that anyone in the Emergency Operations Command Center (EOC) can authorize emergency doses. This should be clarined. Only specluc managers should have this authority.
Rejponse:
Section 5.5.1.1 has been revised to indicate that only the Emergency Coordinator can authorize emergency doses.
t 41.
Section 5.5.1 should descrlhe how the lleensee verines that both onsite and ofTsite emergency workers are providing Informed consent when they volunteer for emergency doses.
l
Response
Section 5.5.1.1 has been revised to describe how the licensee verifies that both onsite and offsite emergency workers are providing informed consent when they volunteer for l
emergency doses.
Attachment A A 13 l
42.
Section 5.5.1.3 should address how offsite eniergency workers are inonitored if they coine onsite.
llDponse; Section 5.5.1.3 has been revised to address how offsite einergency wolkens are monitored if they corne onsite.
43.
Section 5.6 and 5.7 should describe containination control procedures and prmistons for health physics support for ambulances and hospitals. Section 5.7 should also discuss the hospital's ability to diagnose and treat radiation inquiries, including the use of consulting physicians.
l(esponse:
Sections 5.6 and 5.7 have been revised to describe contamination control procedures and provisions for health physics support for ambulances and hospitals. -Section 5.7 has been revised to discuss the hospital's ability to diagnose and treat radiation inquiries, including the use of consulting physicians.
44.
Section 6.3 should identify where the medical equipnient is located, llesponse:
Section 6.3 has been revised to identify where the medical equipment is located.
45.
Section 6.4.2 should discuss how the results of the fenceline samplers are obtained, i.e., automatic rendout or inanual analysis. The locations of the samplers should be ludicated on one of maps,
_ Bnponse:
Section 6.4.2 has been revised to discuss how the results of the fenceline samplers are obtained, i.e;, automatic readout or manual analysis. The locations of the samplers are provided in section 6.2, Table 6.2-1 of the Environmental Report.
Attachment A A-14 1
l.
1m"
45.
Section 6.4.4. Specify inininiuni equipment required for eniergencies, e.g.,
respirator (and what kind).
The storage locations for the equipment described should be Indicated on a map.
Also, describe how these locations will ensure that adequate equipment will lie accessible for each of the accidents postulated in Section 2.
jltsmnKl Section 6.4.4 has been revised to indicate what emergency equipment is necessary, its location in the facility, and how the location ensures that adequate equipment will be accessible during emergencies.
47.
Section 7.2 should describe the training and orientation tours that the licensee will offer to fire, medical, pollec, and other offsite emergency response personnel.
Response
A new section 7.2.3 has been added to describe the training and orientation tours that the licensee will offer to fire, medical, police, and other offsite emergency response personnel.
48.
Section 7.2.2 appears to describe general employee training. It should also describe the additional training provided to emergency response team / workers.
The minimum number of hours and the frequency of retraining should also be specirled.
Restwnse:
i Section 7.2.2 has been revised to describe the additional training provided to emergency response teamAvorkers including the minimum number of hours and the frequency of retraining.
Attachment A A 15
---l.-
r
49.
The first paragraph of Secilon 7.3 refers to quarterly exercises, but the third paragraph states that exercises are conducted on a biennial basis. This should be clarlfled.
The third paragraph states thht the participation of offsite agencies is required.
l'articipation of offsite agencies is not required by 70.22(l)(2)(sil).
Section 7.3 should describe how criteria for acceptable performance will be prepared and provided to evaluators.
NRC Regulatory Guide 3.67 states that the objecthes and scenario for the biennial exercise should be submitted at least 60 days before the exercise for NRC retlew and conunent. Section 7.3 should address this requirernent.
llesponse:
Section 7.3 has been revised to reflect the stated suggestions.
50.
Section 7.4 should identify who is responsible for tracking deficiencies and ensuring that corrective actions are completeri.
Response
Section 7.4 has been revised to indicate that the Emergency Preparedness Manager is responsible for tracking deficiencies and ensuring corrective actions are implemented.
l-1 Attachment A A l
51.
Section 7.6 should describe the Inventory pmcedures lucluding instruinent calibrations and checking snaterial slielf life.
J1r_syonse:
Section 7.6 has been revised to describe the inventory procedures including instrument calibrations and checking material shelf life.
52.
Section 7.8 should Identify who is responsible in the fleensee's organization for the quarterly communications check. Verification by an offslie agency is not adequate.
Resnonse:
Section 7.8 has been revised to indicate that the Emergency Preparedness Manager is responsible for the quarterly communications check.
53.
Section 8.0 should Identify who is responsible for r.aalntaining reconis.
Response
Section 8.1 has been icvised to indicate the CEC Licensing Manager is responsible for maintaining the r nords associated with UF6 Release incident Reports.
54.
Section 8.2 should specify that training reconis must include copics of lesson plans and test questions used. Records of excrelses should include the critiques and the corrective actions.
Response
Section 8.2 has been revised to specify that training records must include copies of lesson plans and test questions used. Records of exercises will include the critiques and the corrective actions.
l Attachment A A 17 L
1'
55.
Section 9.0 should Id;ntify who is responsible for assessing dainage, cornpleting I
repairs, and restoring and testing safety related equipment, it should also identify who is responsible for documenting the recovery effort.
lWromt Section 9.0 has been revised to indicate that the Emergency Coordinator is responsible for assessing damage, completing repairs, restoring and testing safety related equipment, and for documenting the recovery effort.
56.
The page number in Section 9 is wrong. Ilydrofluorie acid (IIF), is written II.F.
throughout the plan.
Response
The page number has been corrected. 'llic abbreviation for hydrogen fluoride has been changed to "IlF."
57.
The letters in Section 11.0 should have page numbers. Letters d ami e should have letterhead or other indleation who the originators arc. They only promise to devote resourecs pursuant to another unidentified document.
Response
The letters' pages have been numbered and have been revised to indicate who the originator is.
Attachment A A-18
,-,