ML20203C413
| ML20203C413 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/1998 |
| From: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| NUDOCS 9802250181 | |
| Download: ML20203C413 (3) | |
Text
-_-____-_____
4 February 20, 1998 4
MEMORANDUM TO: Paul H. Lohaus, Deputy Director
. Office of State Programs FROM:
Donald A. Coo', Director (orig, signed by)-
Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
COMMENTS ON DRAFT EMERGENCY PLANNING REQUIREMENTS (PART P) FOR THE SUGGESTED STATE MEGULATIONS We havo reviewed the November 1997, revision of the draft Part P for the Suggested State Regulations and our comments are attached. Most of the comments we provided to you on March 19,1997, have not been resolved. We are especially concemed about the provision that 4
exercise scenarios shall be known to exercise participants. This contradicts the provision in our regulations that exercise scenarios shall Dat be known to most exercise participants.
We are available to discuss these comments if you have any questions.
Attachment:
As stated CONTACT:
Kevin M. Ramsey, NMSS/IMNS (301)415-7887 DISTRIBUTION: IMNS-6009 COORDINATED WITH:
J. Glitter (AEOD)
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4 IMNS COMMENTS ON NOVEMBER 1997 DRAFT ADDITION TO SUGGESTED STATE REGULATIONS PART P - CONTINGENCY PLANNING FOR RESPONSE TO EMERGENCIES
Contact:
Kevin Ramsey, NMSS/'MNS 301-415-7887 1.
In NRC regulations, these plans are called emergency plans to avoid confusion with safeguards contingency plans. We suggest using consistent terminology.
2.
In our previous Comment 2, we noted that paragraph P.6(g)(i) requires the plan to contain the names and titles of licensee personnel. We suggested requirin0 titles only, to minimize the need for frequent plan revisions, anc placing names in the implementing procedures for the plan. We still believe this should bts changed.
3.
In our previous Comment 3, we noted that the notification provisions in Sections P.6(h) and P.11 fail to include the requirement that all notifications must be completed within one hour of declaring an emergency, consistent with 10 CFR 30.32(i)(3)(viii). These sections sti t fail to include the one-hour limit.
4.
In our previous Comment 5, we noted that Paragraph P.6(h)(iii) failed to state that arrangements with offsite agencies shallinclude the treatment of contaminata.d, injured, onsite workers consistent with 10 CFR 30.32(i)(3)(viii). This section still fails to inciude a clear requirement.
5.
In our previous Comment 6, we suggested changing Paragraph P.6(j)(i) to state that licensees must offet, rather than provide, training to offsite emergency personnel consistent with 10 CFR 30.32(i)(3)(x). Licensees are under no obligation if offsite emergency personnel decline the offer. We still believe this change should be made.
6.
In our previous Comment 7, we suggested changing Paragraph P.C@)(v) to require that exercise scenarios are not known by mQ11 exercise participants because licensees with small staffs must include some personnel in the planning process. This is consistent with 10 CFR 30.32(i)(3)(xii). This paragraph has been changed to state that licensees shall ensure that scenarios are known to exercise participants. We cannot agree with this change. We strongly believe that most exercise participants should not know the exercise scenario.
7.
Sections P.7 and P.12 require that all changes to the plan be provided to offsite response agencies for comment, and to the State for approval, except for updates to names, tiiles, and telephone numbers. This is much more stringent than NRC requirements. We have a more general provision in 10 CFR 30.34(f) which allows licensees to change their plan without prior Commission approvalif the change does not decrease the effectiveness of the phn. This allows licensees to make administrative changes to recognize construction of new facilities and other issues that go beyond names, titles, and telephone numbers. In addition, offsite response agencies are not Attachment e
I required to review all changes. Although not specifically addressed in Parts 30,40, and 70, the provisions in Sections 72.32(a)(14) and 72.32(b)(14) state that subsequent plan changes need not have the offsite comment period unless the plan changes affect the offsite response agencies. We suggest incorporating similar provisions.
8.
In our previous Comment 9, we suggested changing Paragraph P.10(c) to state that individuals critiquing exercises shall not have direct implementation responsibility for the plaD, not just the exercise, consistent with 10 CFR 30.32(i)(3)(xii). We still believe this change should be made, 9.*
In 10 CFR 72.32(d), there is a provision that licensees may take reasonable action that departs from a license condition or technical specification in ar emergency when the action is immediately needed to protect public health and safety, and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protect 5n is immediately apparent You may wish to include a similar provision in this regulation.
10.
In the OSP comments we reviewed when we submitted our previous comments, you noted several errors in the table in Appendix A. These errors still need to be corrected and are listed below; a.
The curie quantity for californium-252 should read "9 (20 mg),"
b.
The parenthetical statement after carbon-14 should read "(non-carbon dioxide)."
c.
The limits for germanium-68 are missing d.
lodine-124 should be changed to iodine.125 e.
The second mercury-203 line is mislabeled. It actually contains the limits for molybdenum-99.
f.
The becquerel quantity for sulfur-35 should be 33.300 GBq.
g.
The limits for mixed corrosion products are missing.
h.
The limits for irradiated material, solid, noncombustible are missing.
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