ML23198A260
| ML23198A260 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 07/27/2023 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | Triso-X |
| Shared Package | |
| ML23198A257 | List: |
| References | |
| Download: ML23198A260 (2) | |
Text
KMott - Emergency Plan Emergency Management Request for Additional Information for the TRISO-X License Application Review RAI-1 Emergency Response Agreement:
Regulatory Basis:
This information is necessary to demonstrate compliance with the regulations in the Title 10 of the Code of Federal Regulation (10 CFR) 70.22(i)(3)(viii), Notification and Coordination, which states, in part, that the notification and coordination of offsite response organizations and request for offsite assistance must be planned so that unavailability of some personnel, parts of the facility, and some equipment will not prevent the notification and coordination.
The guidance in NUREG1520, revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications, includes the regulatory acceptance criteria in section 8.4.3.1.8, Responsibilities, which states that NRC reviewers should evaluate the application descriptions to determine if mutual cooperation agreements exist or will be entered into with local agencies, such as fire, police, ambulance and rescue, and medical units.
Describe Issue: of the application, section 8.4, Agreements with Offsite Emergency Response Resources, states that formal written agreements with appropriate offsite emergency response organizations (fire, police, medical, etc.) have been established and will be maintained to assure implementation of the TRISO-X Site Emergency Plan (SEP) and emergency response procedures. However, SEP section 4.3.2, City of Oak Ridge Fire Department, and section 4.3.3, Law Enforcement/Security, both state that agreements have been requested. In addition, SEP section 4.3.1, Medical Treatment, is silent as to whether a mutual emergency response agreement has been established with the Methodist Medical Center of Oak Ridge or the University of Tennessee Medical Center, which, as stated in the SEP, has staff trained in radiological decontamination.
Thus, the license application does not provide clear and unambiguous descriptions of the TRISO-X facility local offsite emergency response organizations mutual cooperation agreements that have been established.
Information Needed:
Clarify in the TRISO-X facility application the descriptions of the mutual cooperation emergency response agreements that have been entered into with local offsite agencies.
RAI-2 Ambulance Service Emergency Response Agreements:
Regulatory Basis:
This information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(i)(3)(viii), Notification and Coordination, which state, in part, that an emergency plan must include a commitment to and a brief description of the means to promptly
KMott - Emergency Plan 2
notify offsite response organizations and request offsite assistance including medical assistance for the treatment of contaminated injured onsite workers when appropriate.
The guidance in NUREG1520, revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications, includes the regulatory acceptance criteria in section 8.4.3.1.2, Onsite and Offsite Emergency Facilities, that states an emergency plan should include a description of the onsite and offsite services that support emergency response operations including ambulance services.
Describe Issue:
The TRISO-X SEP section 4.3.1, Medical Treatment, states that for serious injuries or medical conditions, an ambulance service is called to transport a patient to one of two nearby medical centers. However, the staff was not able to identify TRISO-X application description details of the identity of the ambulance service or the emergency response mutual cooperation agreement established with the ambulance service. It is not clear that there is agreement to transport a contaminated injured person from the site.
Information Needed:
Submit a description with details of the mutual cooperation emergency response arrangements that have been established for the ambulance service that will be called to transport a TRISO-X facility patient to one of two nearby medical centers.
RAI-3 Site Emergency Plan Comments:
Regulatory Basis:
This information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(i)(4), which state, The licensee shall allow the offsite response organizations expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to NRC. The licensee shall provide any comments received within the 60 days to the NRC with the emergency plan.
The guidance in NUREG1520, includes the regulatory acceptance criteria in section 8.4.3.1.14, Responsibilities for Developing and Maintaining the Emergency Program and Its Procedures, Item 3, that states that the emergency plan should describe the procedures for allowing offsite response organizations 60 days to comment on an emergency plan before it is submitted to the NRC and that any comments received within the 60 days shall be provided to NRC with the emergency plan.
Describe Issue:
The staff was not able to identify offsite organization comments received from the review of the SEP from offsite response organizations expected to respond in case of a facility accident within the application.
Information Needed:
Submit to the NRC any comments received from the review of the TRISO-X Facility SEP by offsite response organizations expected to respond in case of an accident at the facility.