ML20153B545

Forwards Proposed Modified Emergency Plan,Including Version in Form of Strikethrough Format (Deletions) or Bold Format (Additions) & Explanation for Change & Version Incorporated Into Text of Plan.With One Oversize Drawing

ML20153B545
Person / Time
Site:	Dow Chemical Company
Issue date:	09/14/1998
From:	Rigot W DOW CHEMICAL CO.
To:	Alexander Adams NRC (Affiliation Not Assigned)
Shared Package
ML20153B549	List: ML20153B545
References
NUDOCS 9809230173
Download: ML20153B545 (4)

Text

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rn,oo. cn,mic.icom ,,ny September 14,1998 Mdland, Michigan 48667 Mr. Alexander Adams, Jr., Senior Project Manager Non-Power Reactors and Decommissioning Projects Directorate Division of Project Support

- Office of Nuclear Reactor Regulation Dear Mr. Adams Enclosed is a proposed modified emergency plan for The Dow TRIGA Reactor, Facility Operating License No. R-108. Responses requested from your letter dated October 2, 1996 are submitted. Enclosed are two versions of the plan. One version has all changes i

highlighted; either in the form of strikdhreg,h fornist (deletions) or bold format (additions); and an explanation for each change. One version has all changes incorporated into the text of the plan. Specific responses to your requests are addressed in the attachments. If you have any questions regarding these proposed changes, please contact me at ($17) 636-6584.

Regards

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-f Ward L. Rigot Reactor Supervisor (O

Dow TRIGA Research Reactor Dow ChemicalCompany V

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l RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION DOW TRIGA RESEARCH REACTOR EMERGENCY PLAN l

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1. The dennition of EPZ has been changes to be consistent. All references are to the reactor room (lab 51-A,1602 Building).

All references to operations boundary have been removed, including the definition.

All references to fenceline have been eliminated; therefore, no definition is  !

necessary.

The definition of Site boundary has been changed for clarity.

I 2. I have included maps with the EPZ and site boundary labelled.

3. I have included a document from the manufacturer of ion chambers and G-M monitors to support our request for changes to calibration frequency.

4. I have included internal documents which describe the current training programs.

These documents are not intended for inclusion in the emergency plan, only as an explanation of the current practices..

5. Backups for the reactor supervisor are already included in the plan. There is no need for internal backups for other members of the emergency organization, since these roles are filled 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day,7 days a week. In the event additional emergency personnel are required they will be supplied by outside organizations, which are also l

described in the plan.

6. The training programs supplied annually by the Radiation Safety Officer is similar in scope to that received by the emergency organization and is included. Biennial training is required. We wish to have our training consistent with regulations.

Additionally, on-the-job training is a valuable training tool which can be tailored to the individual needs of the facility users, whether they are operators, experimenters or other laboratory personnel.

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8. TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS.

l Training will be provided to all users of radioisotopes commensurate with the level of hazard.

I This training will be conducted prior to the use of radioisotopes and whenever there is a l

. si gnificant change in duties, regulations, of the terms of the License. Training is provided by the RSO, Alternate RSO, an Authorized User or Supervisor.

l 8.1 Incidental Personal All personnel that have a potential for exposure to radioactive materials will participate in a one

! hour orientation training session. This training is provided to incinerator operators, j medical / nursing staff, personnel receiving licensed material, housekeeping, and emergency j response / security staff,it is repeated annually, and includes the following topics:

r j- 1. Applicable regulations and license conditions l 2. Areas where radioactive material is used and stored l 3. Potential hazards associated with radioactive material

4. Appropriate radiation safety procedures

5. Individual's obligation to report unsafe conditions to the RSO

6. Appropriate response to emergencies or unsafe conditions

7. Workers' right to be informed of occupational radiation exposure and bioassay, results

8. Locations of pertinent regulations, licenses and other material required by regulations

9. Individual's responsibilitics

! The training courses for the groups named above are tailored for each group's special needs.

l Specific information is added to the above listed information for the following groups:

i i e Medical /Nursine staff: information on what isotopes and general quantities are used in what areas, what are the most likely incidents involving radioactive material to occur, level of I hazard based on isotope and quantity, priority of treatment (e.g. treat a serious physical j injury before decontamination of minor C-14 contamination), what type of injuries may be

, expected when using various sources of radioactive material (e.g. radiography sources may

( cause high level radiation exposures, X-ray diffraction machines may cause localized l extremity burns etc.).

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e Emercency Response / Security Staff: information on what isotopes and general quantities are used in what areas, what incidents involving radioactive material are most likely to occur, level of hazard based on isotope and quantity, priority of treatment (e.g. treat a serious physical injury before decontamination of minor C-14 contamination), where to set up access control boundaries, which individuals are authorized to enter controlled areas, how to use a radiation survey meter, health effects of acute exposures.

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12/12/95 14.56 U505 473 9221 EBERLINE @ WW3 D>vilmE Instr uments -

501AirportRoad (505) 471 3232 RG Bat 2109 FAX:S05-473 9221 \

Santa Fa, NM87504-2108 Telax:170S15EICSFE December 12,1995 1

DOW CHEMICAL COMPANY 1803 BUILDING 1 MIDLAND,MI48674 l

Attention JanetGrappin Fax:(517)638-9975 l

Dear Ms. Grappin;

)

Per our telephone conversation about changing the calibration interval for any instnunent.

If the instrument is checked for functionality and acuraccy prior to each use then the interval of calibration maybe extended as far as one calendar year.

Note; If the functionality test does not pass then the instnunent is not serviceable anyway. If the accuracy test fails the unit will be requm:d to be calibrated before it can be placed into service. -

Respectfully, w

Albert C. Briggs

, Eberline Service Engineer e

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A subsidiaryof

, 2bmaslastrumment SystemsInc.

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