ML20138C777
| ML20138C777 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/1997 |
| From: | Schneider K NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Kathy Weaver COLORADO, STATE OF |
| Shared Package | |
| ML20137B193 | List: |
| References | |
| NUDOCS 9704300196 | |
| Download: ML20138C777 (24) | |
Text
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{)dD($fb l g, 4 UNITED STATES j
t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 4 001
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%, *****p April 11, 1997 I
Mr. Kenneth L. Weaver Environmental Protection Specialist IV Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80222-1530
Dear :
We have reviewed the draft Part P, Planning for Licensee Response to Contingencies, emergency planning requirements you sent us for our review and comments. In order for Part P to be compatible with 10 CFR Part 30.32, the following Division 2 changes should be made:
- 1. Section P.6(h) should include a requirement that the licensee commit to notify the Agency immediately after notification of appropriate offsite response organizations and not later than one hour after the licensee declares an emergency (30.32(i)(3)(viii)). Paragraph P.11(b) should be revised to reflect this commitment also.
- 2. Paragraph P.6(h)(iii) should state that tiie arrangements for assistance from offsite agencies shnjiinclude medical assistance for the treatment of contaminated injured onsite workers (30.32(i)(3)(viii)).
- 3. Paragraph P.10(c) should state that individuals critiquing exercises will not have direct implementation responsibility for the pja_rl, not just the exercise (30.32(i)(3)(xii)).
- 4. Part P, Appendix A, Quantities of Radioactive Materials Requiring Consideration of the Need for a Contingency Plan for Responding to a Release requires the following changes: (a) the quantity of Californium 252 corresponding to 9 Ciis 20 mg; (b) GermanitIm-68 needs to be on the list; (c) the listing for lodine 124 should be for lodine-125; (d) Mercury-203 is ,
listed twice while Molybdenum-99 has been omitted; (e) the GBq quantity for l Sulfur-35 release is low by a factor of 10; (f) release fractions and Curie l quantities are needed for Mixed Corrosion Products and Irradiated Material, Solid Noncombustible.
I Although not required for compatibility, we suggest you also incorporate the following revisions:
/'
- 1. Section P.5 should include a paragraph similar to 30.32(i)(2)(vii) stating that C0 2 the applicant may take into account other factors appropriate for the specific -
facility that would prevent or reduce the dose to persons offsite. <
OnnnAc bh 9704300196 970411 PDR STPRG ESGC q
. D .
Kenneth L. Weaver 2 1E
- 2. Paragraph P.6(g)(i) requires that the plan contain names and titles. We suggest requiring titles only to minimize the need for formal plan revisions.
Names can be provided in the implementing procedures for the plan.
- 3. Paragraph P.6(h)(ii) refers to "using offsite assistance on site." We suggest deleting the word "using" because it implies that the licensee will be directing offsite agencies. In some cases such as fires, an official from the ,1 offsite agency (i.e., Fire Chief) may be in charge of the scene with the licensee providing technical support. We believe the reference to effective coordination of offsite assistance is sufficient.
- 4. Paragraph P.6(k)(v) requires that exercise scenarios are not known to exercise participants. 30.32(i)(3)(xii) uses the wording "... scenarios shall not be know to mQ11 participants." Some licensee have small staffs that make it ,
very difficult to exclude all participants from the planning process. We '
suggest you adopt this wording.
- 5. Sections P.9 and P.6(j) appear to be redundant. We suggest consolidating these sections.
When the regulations are finalized, NRC will review the regulations for compatibility and concurrence per the procedure approved by the CRCPD. If you have any questions, please contact me at (301) 415-2320.
Sincerely, h icNr k Kathleen N. Schneider Senior Health Physicist !
Office of State Programs l
1 l
'I 1
a Kenneth L. Weaver 2 IE
- 2. Paragraph P.6(g)(i) requires that the plan contain names and titles. We suggest requiring titles only to minimize the need for formal plan revisions. j Names can be provided in the implementing procedures for the plan. l 4
- 3. Paragraph P.6(h)(ii) refers to "using offsite assistance on site." We suggest l deleting the word "using" because it implies that the licensee will be l
directing offsite agencies. In some cases such as fires, an official from the offsite agency (i.e., Fire Chief) may be in charge of the scene with the I licensee providing technical support. We believe the reference to effective coordination of offsite assistance is sufficient.
- 4. Paragraph P.6(k)(v) requires that exercise scenarios are not known to exercise participants. 30.32(i)(3)(xii) uses the wording "... scenarios shall not I j'
be know to most participants." Some licensee have small staffs that make it i very difficult to exclude all participants from the planning process. We l suggest you adopt this wording, t
- 5. Sections P.9 and P.6(j) appear to be redundant. We suggest consolidating these sections.
I
- When the regulations are finalized, NRC will review the regulations for compatibility and concurrence per the procedure approved by the CRCPD. If you have any questions, please contact me at (301) 415-2320.
. Sincerely, l 4
G"k*1tml Mc- od by*
. ::. wwc1acr t
Kathleen N. Schneider Senior Health Physicist Office of State Programs i
hktt : fc Distribution:
SDroggitis PDR (YES v' NO )
DSollenberger CRCPD File l DOCUMENT NAME: G:\LJR\ COREG. DOC *See previous concurrence.
Ts receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure *N* p No copy OFFICE OSP l OSP l OSP:DDl NMSS l RES l OCG l OSP:E)Qff NAME LRakavan:nb KSchneider:kk PHLohaus DCool BMorris HHNewsome RLBangart' DATE 02/27/97* 02/28/97* 02/28/97* 03/19/97* 03/17/97* 04/04/97* OA/g /97 j via memo if OSP FILE CODE: SP-C-7
. . c. . . j "N" = No copy !
OFFICE OSP l OSP l OSP:DD l NMSS l RES l OCG l OSP:D l NAME LRakavan:nb KSchneider:kk PHLohaus DCool BMorris FC - crcn RLBangart l DATE 02/27/97* 02/28/97* 02/28/97* 03/19/97* 03/17/97* s'fes/O(/p7 03/ /97 via memo M-M I OSP FILE CODE: SP-C-7 l
l l
l j
Mr. Kenneth L. Weaver Environmental Protection Specialist IV Colorado Department of Public Health and Environment I 4300 Cherry Creek Drive South Denver, CO 80222-1530
Dear Mr. Weaver:
We have reviewed the draft Part P, Planning for Licensee Response to Contingencies, emergency planning requirements you sent us for our review and comments. in order for Part P to be compatible with 10 CFR Part 30.32, the following Division 2 changes should be made:
3h
- J Section P.5 should include a paragraph similar to 30.32(i)(2)(vii) stating that the applicantM1af takeNinto account other factors appropriate for the 7
,; ., / specific facility that would prevent o'r reduce the dose to persons offsite.
yW \,-
'7 2. Section P.6(h) should include a requirement that the licensee commit to I (p
y notify the Agency immediately after notification of appropriate offsite response organizations and not later than one hour after the licensee
, . gI (F;
declares an emergenc]. TL - - ._. ^rt t;2 00.320'0;'..j0s \ j Paragraph P.11(b) should be revised to reflect this pniancalso. '
p, , .w e oAgn m
- 3. Paragraph P.6(h)(iii) should' state that the arrangements offsite agencies shallincludd(he\ treatment of contaminated injured onsite worker . TMs a ennd ""P 30.02ttitSttviii). ajg gf
- 4. ,
Paragraph P.10(c) should state that individuals critiquing exercises will
' g\ ot have direct implementation responsibility for the plan, not just the exercise / This is enncietert y;:th 30.32(!)l3)]3ii).
W '
use 0~.-+g o s M h 5. Part P, Appendix A, Quantities of Radioactive Materials Requiring Consideration of the Need for a Contingency Plan for Responding to a Release requires the following changes: (a) the quantity of Californium-252 corresponding to 9 Ci is 20 mg; (b) Germanium-68 needs to be on the list; (c) the listing for lodine-124 should be for lodine-125; (d) Mercury-203 is listed twice while Molybdenum-99 has been omitted; (e) the GBq quantity for Sulfur-35 release is low by a factor of 10; (f) ;
release fractions and Curie quantities are needed for Mixed Corrosion Products and Irradiated Material, Solid Noncombustible.
Although not required for compatibility, we suggest you also incorporate the following
revisions:
- 1. Paragraph P.6(g)(i) requires that the plan contain names and titles. We suggest requiring titles only to minimize the need for formal plan '
revisions. Names can be provided in the implementing procedures for the plan.
i 1
1
- i f
fa 2.
g 4 Paragraph P.6(h)(ii) refers {o using offsite assistance on site. We suggest deleting the word usingYbecause it implies that the licensee will be directing offsite agencies. In some cases such as fires, an official from the offsite agency (i.e., Fire Chief) may be in charge of the scene with the licensee providing technical support. We believe the reference to effective coordination of offsite assistance is sufficient.
- 3. Paragraph P.6(j)(i) requires a description of the special instructions and orientation tours that the applicant will provide to fire, police, medical, and other emergency personnel. 3g.32(i)(3)(x) uses the wording
...would offer to any fire, police.... We suggest you adopt this wording
- 4. Paragraph P.6(k)(v) r b(st ires that t exerc,b bod GAbboIU 0 ise scenanos are not uswm to exercise participants 30.32(i)(3)(xii) uses the wording ... scenarios shall not be know to most participants. Some licensee have small staffs that make it very difficult to exclude all participants from the planning process. We suggest you adopt this wording.
- 5. Sections P.9 and P.6(j) appear to be redundant. We suggest consolidating these sections.
- 6. One minor grammatical point, in P.7 " comments" should be plural such that the regulation reads: "The licensee shall provide any comments received within the 60 days to the Agency with the contingency plan or amendment."
When the regulations are finalized, NRC will review the regulations for compatibility and concurrence per the procedure approved by the CRCPD. If you have any questions, please contact me at (301) 415-2320.
Sincerely, Kathleen N. Schneider Senior Health Physicist Office of State Programs