ML20197K235
| ML20197K235 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/07/1986 |
| From: | Julie Winslow, Winslow T GENERAL ELECTRIC CO. |
| To: | Barr K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 26975, NUDOCS 8605200298 | |
| Download: ML20197K235 (3) | |
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DN0 GENERALOe'ecraic NUCLEAR FUEL & COMPONENTS MANUFACTURING GENERAL ELECTRIC COMPANY + P.O. BOX 780
- WILMINGTON, NORTH CAROUNA 28402 12 p
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, In May 7, 1986 Mr. Kenneth P.
Barr, Chief Nuclear Materials Safety & Safeguards Branch U.
S.
Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 2900 Atlanta, Georgia 30323
Dear Mr. Barr:
References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/86-02 dated 4/08/86, received 4/11/86
'1 hank you for your letter reporting the results of the inspection conducted on February 24-28, 1986 at our licensed fuel fabrication plant by Mr.
R.
R.
Marston of your office.
This inspection report does not contain any information which we believe to be proprietary.
Regarding the unresolved item identified during this inspection, General Electric offers the attached clarification.
If further information is required, please contact me.
Very truly yours, GENERAL ELECTRIC COMPANY
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Preston Winslow, Manager Licensing & Nuclear Materials Management M/C J26 TPW :bsd NSD-I cc:
Director, ONMSS h52OO298860507 C
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GENERAL $ ELECTRIC Mr. Kenneth P.
Barr May 7, 1986 Page 1 of 2 ATTACHMENT 1 COMMENTS ON UNR 86-02-01 Inspection Report 86-02 identified the following unresolved item:
The inspector noted that the procedures did not provide for notification of responsible State and local governmental agencies within 15 minutes upon declaration of Unusual Events.
The inspector identified aspects of the issue as an Unresolved Item (70-1113/86-02-01) pending review by the NRC of the acceptability of the time used for Notifications of Unusual Event - Prompt notification to State and local governmental agencies upon declaration of an emergency.
Although not indicated by the inspection report, we believe this interpretation is, in part, taken from 10 CFR Part 50.54(q) which states:
A licensee authorized to possess and/or operate a research reactor or a fuel facility shall follow and maintain in effect emergency plans which meet the requirements in Appendix E of this part.
and Appendix E, Part IV. D.
3.,
which states:
A licensee shall have the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency.
However, Appendix E addresses mainly requirements for emergency plans applicable to power reactor licensees.
Appendix E,Section I,
Introduction, correctly notes that "the potential radiological hazards to the public associated with the operation of fuel facilities licensed under 10 CFR Parts 50 and 70 involve considerations different than those associated with nuclear power reactors.
Consequently, the size of Emergency Planning Zones for Facilities other than power reactors and the degree to which compliance with the requirements of this section and sections II, III, IV, and V [of Appendix E] as necessary will be determined on a case-by-case basis."
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F GENERAL $ ELECTRIC Mr. Kenneth P.
Barr May 7, 1986 Page 2 of 2 Specifically, for a fuel facilities license, 10 CFR Part 70.22(i) applies, and provides that:
Each application for a licensee to possess and use special nuclear material for processing and fuel fabrication, scrap recovery, or conversion of uranium hexafluoride shall contain, in addition to the other information required by this section, plans for coping with emergencies.3 3
fn :
Emergency plans shall contain the elements that are listed in Section IV, " Content of Emergency Plans", of Appendix E to Part 50 of this chapter.
10 CPR Part 70.22(i) thus invokes only Section IV of Appendix E as providing requirements for fuel fabrication facilities.
As discussed above, however, applications of Section IV's requirements are to be " determined on a case-by-case basis" for fuel fabrication facilities.
This case-by-case determination has been made by NRC for our facility, and our facility-specific requirements for compliance with Section IV are as set forth in our NRC-approved Radiological Contingency & Emergency Plan.
As approved 3/29/82 (see letter from R. G. Page to C. M. Vaughan, which is Attachment 2), "the Radiological Contingency Plan and implementing procedures supersede the emergency planning requirements of 10 CFR Part 70.22(i), as they refer to onsite planning and notification,"
i.e., Appendix E,Section IV.
The 3/29/82 approval letter continues to be a referenced supplement to our current approved Radiological Contingency & Emergency Plan.
Finally, the approved Radiological Contingency Plan does require, through its implementing procedures, immediate notification to State and local governmental agencies in any site emergency when a potential hazard to the public is determined to exist.
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NUCLEAR REGULATORY COMMISSION
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,a g3g C. '.L VAUGHAN FCUP:GHB 70-1113 SNM-1097, Amendment No. 24 General Electric Company ATTN:
C. M. Vaughan, Acting Manager Licensing & Compliance Audits M/CJ26 P.O.' Box 780 Wilmington, North Carolina 28401 Gentlemen:
In accordance with your application transmitted by letter dated August 27, 1981 and supplement dated January 14, 1982, and pursuant to Title 10. Code of Federal Regulations, Part 70, Materials License No. SNM-1097 is hereby amended to incorporate your Radiological Contingency Plan. Accordingly, effective within ninety days froii) the date of this amendment, Conditien 13 of-SNM-1097 is amended to read:
Cendition 13. The licensee shall implement, maintain, and execute the Radiological Contingency Plan, submitted by letter dated August 27, 1981 and supplement dated January 14, 1982. The licensee shall maintain implementing procedures for the Radiological Contingency Plan.
In addition, the licensee shall make no change in the Plan, without the approval of the Commission, if the change would decrease the effectiveness of the Plan.
The licensee may make changes to the Plan provided the changes do not decrease the effectiveness of the Plan. The licensee shall maintain a record of each change for a period of two years.
In addition, the licensee shall provide a cescription of each change to the Chief, Uranium Fuel Licensing Branch, Division of Fuel Cycle and Material Safety, NMSS, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the Administrator, NRC Region II, 101 Marietta Street, Suite 3100, Atlanta, Georgia 30303, within six months after the change is made.
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This amendment supersedes Amendment Nos. 8 and 23, dated April 23, 1979 and December 24, 1981, respectively, in their entirety. The Radiological Contingency Plan and implementing procedures supersede the emergency planning requirements of 10 CFR 70.22(1) as they refer to onsite planning and notification.
All other conditions of this license shall remain the same.
The above condition was discussed and agreed to by your Mr. Vaughan and Mr. Bidinger of my staff on March 24, 1982.
Enclosed for your information is a copy of our report on the review of the Radiological Contingency Plan.
FOR THE NUCLEAR REGULATORY COMMISSION 8M R. G. Pag ef Uranium Fuel Licensing Branch Division of Fuel Cycle and flaterial Safety, NMSS
Enclosure:
Review of Radiological Contingency Plan
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Enclosure _
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DOCKET N0:
70-1113 LICENSEE:
General Electric Company Wilmington Manufacturing Division Wilmington, North Carolina
SUBJECT:
REVIEW 0F RADIOLOGICAL CONTINGENCY PLAN:
SAFETY EVALUATION REPORT I.
Background
General Electric Company, Wilmington Manufacturing Division, of Wilmington, North Carolina (GE-WMD) is the holder of Special Nuclear Material License N0. SNM-1097 issued by the Nuclear Regulatory Commission. The license authorizes the possession and use of up to 50,000 kg of U-235 and 7 g of plutonium in encapsulated form. The licensee fabricates low-enriched uranium fuel for LWRs. The license is currently under timely renewal status.
On February 11, 1981, the NRC issued an Order to GE-UMD to submit within 180 days of the effective date of the Order a
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Radiological Contingency Plan in accordance with a standard format and content (Enclosure 1 to the Order) or, alternatively, to reduce their possession limits below those listed in to the Order.
On August 27, 1981, the licensee submitted the subject Radiological Contingency Plan in accordance with the February 11,1981 Order. On December 4, 1981, the NRC staff requested additional information from GE-WMD.
On January 14, 1982 GE-WMD submitted that information.
II.
Discussion The GE-WMD facility is located on a large rural site six miles north of Wilmington, N.C.
The Radiological Contingcncy Plan for the site submitted on December 4, 1981, and supplemented on January 14, 1982, is adequate to demonstrate that the licensee has accomplished the purpose and intent of radiological contingency planning, viz, assuring (1) that the facility is properly configured to limit releases of radioactive materials and radiation exposures in the event of an accident, (2) that a capability exists for measuring and assessing the significance of accidental releases of radioactive materials, (3) that appropriate emergency equipment and procedures are provided onsite to protect workers against radiation hazards that might be encountered following an accident, and (5) that necessary recovery actions are taken in a timely fashion to return his plant to a safe condition following an accident.
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h The GE-W'1D facility is equipped with a ventilation system which exhausts effluent gases through liquid scrubbers, where appropriate, for removal of soluble uranium and thence through HEPA filters for removal of particulate uranium. The facility is equipped with numerous process instruments which alarm and/or operate equipment (switches and valves) to either return the process conditions to specified limits or to terminate operations.
The process areas are equipped with continuous air monitors. The system of instruments, alarms and controls are considered sufficient to assure that all systems are operating as designed to insure integrity of the radioactive material containment capability.
Corrective and protective actions described in the plan demonstrate that adequate pre-planning has been made to detect, preclude or mitigate the effects of accidental releases of licensed material.
III.
Conclusions and Recommendations The GE-WMD license should be amended to incorporate the Radiological Contingency Plan as a condition of the license.
The proposed amendment should have no adverse effect on the public health and safety or on the quality
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of the environment and should improve GE-W'iD's ability to protect against, respond to, and mitigate the consequences of an accident involving radioactive materials.
So as to afford the licensee sufficient time to implement the Plan, it is recommended that the effective date for implementation should be 90 days subsequent to the date of this amendment.
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F. D. Fishet, Section Leader Environmental Radiation and Emergency Support Section Uranium Fuel Licensing Branch Division of Fuel Cycle and f/ 7 Material Safety, NMSS Approved b :.-
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~~ F. D. Fishsr, Section Leader s
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