ML20044A404

Forwards Reformatted & Revised Emergency Plan for Armed Forces Radiobiology Research Inst (Afrri) & Afrri Reactor Facility, Incorporating NRC 900522 Comments & Afrri Emergency Response Guidebook.

ML20044A404
Person / Time
Site:	Armed Forces Radiobiology Research Institute
Issue date:	06/20/1990
From:	Irving G ARMED FORCES RADIOBIOLOGICAL RESEARCH INSTITUTE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20044A405	List: ML20044A404 ML20044A805
References
NUDOCS 9006290026
Download: ML20044A404 (5)

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10 CFb'50. 5VQ DicacT 50-176 DEFENSE NUCl. EAR AGENCY AHMr0 rORCrS H ADioplOLCeOY Hi $L ARCH INSTITUTC HLTHESDA, MARYLAND 20814 6145 DIR June 20,1990 ,

SUBJECT:

Incorporation of USNRC Cornrnents to Proposed Einergency Plan for License  ;

No. R-84.

. Docuanent Control Denk '

U.S. Nuclear Regulatory Corninlaston Washington, D.C. 20555 ,

4 Gentlemen:

The AFRRI TRIGA reactor staff han incorporated the U.S. Nuclear Regulatory '

Corninlanlon (NRC) staff review conninents contained in your correspondence dated hiny 22,1000 to the , proposed einergency alan. To facilitate the incorporation of your cointnents, the proposed einergency p an han been refortnatted and revised.

An a result of this revinlon process, editorial changes have been inade to the plan that enhance lin readability and overall effectiveness. Attached in a suininary of the changen inade to the proposed einergency plan as recoininended by the NRC and a copy of the revised plan. ,

i If you have any quentinnn or corninents, please contact the Reactor Facility

Director, hir. hf ark hicore, or the Reactor Executive Ofncer,1st Lt hiatt Fornbacka, at (301) 2051290. Thank you for your cooperation.

Sincerely, c -

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, GEORGE IRVING, III Colonel, F,DSC Director

Enclosure:

as stated ,

cc: USNRC - Region I - Project Engineer Divialon of Reactor Projects hir. P. Kaurinan I 000h290026 900620 - h PDR ADOCK O$000170 I i p PDC / I 1

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USNRC - Region I - Inspector Division of Radiation Safety and Safeguards Einergency Preparedness Section Mr. C. Arnato USNRC Headquarters - Project Manager Nuclear Reactor Regulation Mr. A. Adams USNRC - Headquarters Inspector Ernergency Preparedness Branch Ernergency Preparedness and Radiation Protection Mr. L. Cohen

Ernernency Response .

I NRC Conunent:

Section 7 of NUREG-0849 and Reg. Guide 2.0 indicates that the Emergency Plan should include a notification list of emergency response personnel. The Emergency  :

Plan should direct the reader to a procedure which includes a notification list providing names and telephone numbers of emergency response personnel.

AFRRI Response:  ;

The first two paragraphs on page 51 direct the reader to emergency notification ,

procedures contained in the AFRRI Emereeney Resoonse Guidebook. The AFRRI  !

Emergency Resoonse Guldebook includes a notification list (telephone numbers have l been omitted in this submission).

NRC Conunent: j Section 7 of NUREG-0849 state that the Emergency Plan should describe the proposed method to ensure personnel accountability. In the revised emergency plan, the method is not provided. Please provide in the Emergency Plan a i description of the proposed accountability procedure.

AFRRI Response: f A generic description of accountability procedures are found in the descriptions of i the duties of the Search Team Marshal and AFRRI Search Teams on pages 3 5 to 3-6. Procedures that describe point by point building searches and personnel accountability reports are currently under development and will be included in the  :

AFRRI Emerzenev Resoonsa Guldebook (these specific procedures are due to be i completed by mid July,1990).

Emernency Action Levels (EALei NRC Conunent:

Section 5 of NUREG-0849 state that the the Emergency Plan should contain *

! EALs. In your revised plan, the EALs were removed from the plan and moved to  :

the implemencing procedures. They should be returned to the Emergency Plan i adjacent to the emergency classification systems.  ;

AFRRI Response:

i The EALs and emergency classification system are found in chapter 4 of the j revised plan.

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Ernernency Procedures NRC Conunent:

Regulatory Guide 2.0, Section C.5 states that the implementing procedures should I be in an annex to the Emergency Plan. In the revised Emergency Plan, no list of procedures is available, nor is the reader directed to the procedures in some other l document. l AFRRI Response:

l Chapter 5 of the revised plan defines the content of, and refers to, the AFRRI

, Emerrency Resoonse Gtidebook which contains implementing procedures. These i procedures can be founc, on pages 7 - 35 of the AFRRI Emereenev Resoor,se Guldebook. It should be noted that the AFRRI 3merzenev Resoonse Gu t e :>ook is  :

a "living document" and is continuously being reviewed and improved. '

Maintaininn Ernernency Plan i

NRC Cornrnent:

Section 10 of NUREG-0849 discussed the review and update of the Emergency i

Plan. Please provide in the Emergency Plan to frequency for review and updating i

the plan.

AFRRI Response:

Section 8.3, Emergency Plan Review and Update, on page 8-3, describes the frequency for reviewing and updating the plan.

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AFRRI Response to NRC Staff Conunents i Delhdtlons NRC Comment: l Section 2 of NUREG 0849 Indicates that the Emergency Plan should provide i definitions of terms unique to the facility. To help define the cite and operational i boundarles of your facility, the emergency plan should include diagrams showing  ;

and defining the site boundary and operational boundary sites.

AFRRI Response: l i

l The revised emergency plan defines the operations boundary on page 21 of the j plan. Due to the relatively high frequency of building modifications at AFRRI, a diagram showing the operations boundary is presented in Appendix A of the  ;

AFRRI Emerrency Resoonse Gt,ldebook to facilitate replacing building diagrams as .

necessary. A map of the AFR 11 site boundary can be found on page 1-2. l:

Ornanization and Responsibilities i

NRC Conunent:  ;

i Section 3 of NUREG 0849 discusses the need for arrangements and agreements, '

confirmed in writing, with local ofinite support groups. Such letters of agreement with olisite support organizations should be provided.

AFRRI Response:  ;

The support agreement between AFRRI and the National Naval Medical Center I (NNMC) is updated on a periodic basis. For this reason, a generic description of  !

i the relationship between AFRRI and the NNMC is discussed on pages 3-14 and 6-  :

i 2 to 6-4, and the actual offsite support agreement is presented in Appendix C of (

the AFRRI Emerzenev Resoonse Guldebook. i NRC Conunent:  !

Section 3 of NUREG 0849 states that the Emergency Plan should list the line of i succession by title for the individual in charge of directing emergency operations.  !'

Please provide a line of succession for the Emergency Director. The roster should list the successors by title.

AFRRI Response:  !

The line of succession for the ECP Commander (Emergency Director) can be found  !

on page 3-3. Successors are listed by title. Appendix B of the M Emergency Resoonse Plan lists the AFRRI personnel who will fill the positions within the emergency organization. .

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