ML20147A893
| ML20147A893 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 11/16/1978 |
| From: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Martin J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20147A897 | List: |
| References | |
| 696-995, NUDOCS 7812150011 | |
| Download: ML20147A893 (2) | |
Text
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Refer To: 696-995~
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5 Mr. John B. Martin, Asst. Director f
Fuel Cycle Safety & Licensing
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Ed O
U.S. Nuclear Regulatory Commission
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Washington, D.C.
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U /y Subj ect: Submittal of Emergency Plan.
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Dear Mr. Martin:
General Atomic earlier this year has been requested to submit our Emergency Plan pursuant to the Commission's practice implementing a revision to 10CFR70 effective March 31, 1977.
We previously had been asked to submit for Commission review our plans for coping with emergencies.
Refer to NRC correspondences dated 5/25/73 and 12/24/74. We in response submitted copies of our Emergency Plan as part of our Demonstrations information supporting our license. We also included statements which commit GAC to maintaining an Emergeacy Plan. Note Section 9.1 of the SNM-696 License Specifications which essentially verbatim restates the Commission's guidance in the form of Annex B issued also as a license con-dition #12.
Attached is a most recently revised copy of our Emergency Plan which has been maintained and followed.
The plan has been modified on occasion to incorporate changing situations relating to on and offsite emergency planning activities.
Region V has typically reviewed and commented as well as received copies of changes to our plan.
We believe our Emergency Plan as currently written contains all the elements specified in 10CFR70.22(1) and its footnote.
hefeelcompelledtomakeonecommenthowever. We are concerned that the Commission, presumably for expediency sake, has not developed separate guidance for part 70, licensed fuel processing, etc., plants which by their nature are likely to have accidents of a different nature and magnitude. Part 70 licensed plants and their accidents characteristically will affect plant personnel, even small limited numbers, with minimal effect on public indivi-duals in the surrounding environs. The 10CFR70.22(1) footnote and the Regula-tory Guide tend to substantiate the Commission's unfortunate practice.
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John B. Martin 696-995 Ue remain hopeful that the staff will consider the above in its activity surrounding this plan submitted.
Very truly yours, AtAM William R. Mowry Licensing Administrator Nuclear Materials Control Divisi'on i
I WRM:hes
Enclosure:
GAC Emergency Plan (GA-D13153) - 1 copy 3,,
I cc: NRC, Region V - 1 copy l
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