ML20198P782

Forwards Proposed Modified Emergency Plan for Dow Triga Reactor & Responses to NRC

ML20198P782
Person / Time
Site:	Dow Chemical Company
Issue date:	01/15/1998
From:	Rigot W DOW CHEMICAL CO.
To:	Alexander Adams NRC (Affiliation Not Assigned)
References
NUDOCS 9801220248
Download: ML20198P782 (63)

Text

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9 The Dow Chefrdcol Company MicWct, McWyn 48667 January 15,1998 Mr. Alexander Adams, Jr., Senior Project Manager Non-Power Reactors and Decommissioning Projects Directorate Division of Project Support Office of Nuclear Reactor ReEulation Dear Mr. Adams Enclosed h 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 highlighted; either in the form of 5thdwesi,5 fennet (deletions) or hold format (addhions); and an explanation for each change. One version has all changes incetporated 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 (517) 636-6584.

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

1. Maps showing the layout of the EPZ, floor plan of the facility and ruaps showing the facility's relationship to the chemical plant and city are included in the appendix of the document. A diagrrun of the emergency organization has been included in the appendix of the document.

2. Siren switches are switches which are manually activated to activate the building evacuation siren. llaving more switches allows for more rapi<1 activation when deerned appropriate.

3. The phrase "and will have portable equipment for taking air samples" has been returned to the text of the document. ,

4. The EALs for a NOUE have been returned to their original script.

5. Letters of agreement with off site support organizations have been included in the appendix of the document.

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, s DOW TRIGA* RESEARCll REACTOR EMERGENCY PLAN

1. Introduction A. The Reactor Facility.

The Dow TRIGA Research Reactor is a 300-KW pool-type nuclear reactor designed as a Training, Research, and Isotopep"roduction facility by General Atomic Company. The reactor U,is fabricated in a U-ZrH fuel, nominally 20% enriched in g form which provides a unique safety factor in terms of a prompt negative temperature coefficient of reactivity. The reactor at Dow is a research and analytical tool within the Michigan Division Analytical Sciences laboratory where it has been used as a source of neutrons for activation analysis and other research functions since 1967, The reactor is found in a below-ground pool with no horizontal beam ports or core-level access. The pool is located in a 20' x 23' Reactor Room which contains sample storage facilities, experimental facilities, spare parts, tools, and files. The Reactor Room is monitored by a Continuous Air Monitor and by an Area Monitor. The Continuous Air Monitor, a Geiger-Mueller detector equipped with an air pump and paper filter, is provided with an alarm setpoint; radiation levels above the setpoint trigger audible and visible signals and also transmit a signal to the Dow Security Dispatcher. Loss of power at the Continuous Air Monitor also triggers a signal to the Dow Security Dispatcher. The Area Monitor, a Geiger-Mueller detector c.dibrated to provide dose rate information, has a readout and alarm at the reactor console. The center of the reactor is at least 100' from the Dow security fence. The reactor console and the associated laboratories are located in adjacent rooms.

The reactor is typically operated for periods of 10 minutes to several hours each day at power levels not exceeding 300 KW. The average energy output is approximately 1.5 megawatt-days per year.

This emergency plan is intended to serve as a framework for responses to circumstances which could threaten the facility or the health and safety of the public. The emergency plan delineates responsibilities, lists resources, defines procedures, and prescribes training and exercises for preparedness.

• TRIGA it a trademark of General Atomics I

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1. a l B. Definitions Emergency. An emergency is a condition that c :!s for immediate action, beyond the scope of nornwl operating procedures, to avoid an accident or to mitigate the consequences of one.

Continuous Air Monitor (CAM). This instrument, situated in the reactor room, pumps air through a Glter which is monitored by an end-window G-M counter. The circuit is equipped with a trip which, when energized, automatically signals Dow Security, energizes a highly visible light, and energizes a loud audible alarm. A loss of power to the CAM will also result in a signal to Dow Security. This system is checked for positive operation during every daily checkout of the TRIGA, at which time the filter is replaced with a new filter.

Emergency Action Levels. Specific instrument readings, or observations; odiological dose or dose rates; or specific contamination levels of airborne, waterborne, or surface-deposited radioactive materials that may be used as thresholds for establishing emergency classes and initiating appropriate emergency measures.

. Emergency Classes. Emerger..;y classes are classes of accidents grouped by severity level for which predetermined emergency measures should be taken or considered.

Emergency Plan. An emergency plan is a document that provides the basis for actions to cope with an emergency. It eutlines the objectives to be met by the emergency procedures and defines the authority and responsibilities to achieve such objectives.

Emergency Planning Zone (EPZL Area for which off-site emergency planning is performed to assure that prompt and effective actions can be taken to protect the public in the event of an accident. The EPZ site depends on the distance beyond the site boundary at which the Protective Action Guide (PAG) could be exceeded. For this plan the EPZ is defined as the reactor room (Lab 51-A of 1602 Building).

Emergency Procedures. Emergency procedures are documented instructions that detail the implementation actions and methods required to achieve the objectives of the emergency plan.

Facility Director. A manager or senior technical leader within the organization of the Analytical Sciences Department who has responsibility for members of the reactor staff.

Offsite The geographical area that is beyond the site boundary.

Onsite The geographical area that is within the site boundary.

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f Oncrations Boundarv. The area within the site boundary such as the reactor building (or the nearest physical personnel barrier in cases where the reactor building is not a principal physical personnel barrier) where the Facility Director has direct authority over all normal activities. The area within this boundary shall have prearranged evacuation procedures known to personnel frequenting the area.

Protective Action Guides (PAG). Projected radiological dose or dose commitment values to individuals that warrant protective action following a release of radioactive material.

Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective action. The projected dose does not include the dose that has unavoidably occurred prior to the assessment.

Radiation Safety Committee (RSC). The RSC is responsible for the administration of all Dow Midland location activities involving the use of radioactive materials and radiation sources including assurance of compliance with United States Nuclear Regulatory Commission (NRC) regulations. The reactor license requires semi annual operational reports to the RSC.

Reactor Oncrations Committee (ROC). A group of persons including a representative of management, the Radiological Safety Officer, the Reactor Supervisor, and other qualified persons. The ROC meets at least quarterly and as necessary to review operation of the reactor, special experiments, unexplained automatic shutdowns of the reactor, proposed changes in operating procedure, and to act as a resource team in the event of emergencies.

Research Reactor. A device designed to suppott a self-sustaining neutron chain reaction for research, developmental, educational, training, or experimental purposes, and which may have provisions for production of nonfissile radioisotopes.

Shall. Should and Mav. The word "shall" is used to denote a requirement; the word "should" to denote a recommendation; and the word "may" to denote permission, neither a requirement nor a recommendation.

Siren Switch. Wall mounted switches, which activate the building evacuation signal.

Site Boundarv. The site boundary is that boundary, not necessarily having restrictive barriers, surrounding the operations boundary wherein the reactor supervisor may directly initiate emergency activities. The area within the site boundary may be frequented by people unacquainted with the reactor operations, TRlGA. An acronym from the words Iraining, Research, and Isotne Production, General Atomics. TRIGA refers to a generic reactor featuring a unique fuel design which reduces significantly the possibility of a nuclear accident.

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11. Organizations and Resno isibilities A. Governmental Agencies with Responsibilities

1) Midland County Emerpecy Services Depanment. This department, established under Michigan P.A. 390 (1976), the " Emergency Preparedness Act" and the Midland County Emerge :y Services Resolution (Nov. 25,1980), serves to coordinate emergency services within the c anty. These services / organizations include the American Red Cross, Midland County lleath Department, Social Services Department, Midland Public Schools, and law enforcement agencies.

2) State of Michigan, Under P.A. 390 (1976) the Radiological Health Services Divi; ion of the Department of Public IIcalth and Emergency Services Division of the State Police can be mobilized by the Governor to respond to emergencies. The Radiological Health Services Division is equipped to provide offsite radiation monitori g; the State Police are prepared to handle evacuation and protective actions as required.

B. Dow Emergency Organization The reactor's emergency organization is headed by the Reactor Superv'sor and consists of the Reactor Staff of licensed Senior Reactor Operators. This orgaidntion k, augmented by the:

(1) Persons responsible for the normal Analytical Sciences Laboratory safety program in 1602 Building; (2) The Reactor Operations Committee, v,hich includes the Radiological Safety Officer and a line manager from the Michigan Division Analytical Lahoratory; (3) The Dow Security Department, which provides communications and int:rfaces with response organizations; (4) The Dow Industrial flygiene Expertise Center, which provide the people and equipment to measure and evaluate radiological hazards during the state of emergency and the recovery period. One person from the Environmental, Health and Safety organization will be on call at all times to respond te er. :rgencies. This person is trained in making measurements and surveys and will have ponable equipment for taking air samples. The Radiological Safety Officer will be notified by the Dow Security Department at any emergency involving the TRIGA, will evaluate the virveys and assist the Reactor Supervisor to make decisions concerning protective and amelicrative actions. The reactor staff and the Industrial Hygiene Department, through the Radiation Safety Officer, share the responsibilities of maintaining the emergency preparedness program.

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4 The Dow Fire Department, Ambulance Team, Medical Department, and Se.ority personnel respond as necessary upon call from the Reactor Supervisor and the Security Department.

- The Dow Radiation Safety Committee is responsible for notification of the NRC and the Michigan Department of Public 11ealth of events classified " Notification of Unusual Event"as required by the pertinent licenses and regulations.

C. Offsite Support Organizations The Midland City Police and Fire Departments, the Midland County Sheriff's Department, and the Midland 11ospital Center will provide law enforcement, fire protection, ambulance and mediev services, as appropriate, upon call from Dow Security. The Midland Ilospital Association has an agreement with the University of Michigan Hospital, which is a resource for information concerning nuclear medicine, and is also equipped for back-up assistance in cases of extended emergencies involving the reactor.

D. Person in Charge of Directing Emergency Operations The Reactor Supervisor is responsible for the safe performance of the reactor operations and the maintenance of proper security of the facility. In cases of emergency involving the reactor the Reactor Supervisor is the first individual who needs to be notified about the existence of the emergency. lie has the authority to conduct the handling of the emergency situation within the facility itself. It is his duty to remain informed of the immediate conditions of the reactor facility and conduct any actions or operations related to the proper handling of the emergency situation. Personnel operating in the facility during the emergency act under his authority with his permission and are to abide by his decisions concerning the facility U.self.

The Reactor Supervisor will assess the extent of the emergency, as far as the facility is concerned, and select the proper procedures to follow in handling the emergency at hand. He is to notify any other groups which need to be brought in to handle the emergency situation. He is to notify the Plant Protection Dispatcher and ascertain that the dispatcher is sufficiently supplied with information with regard to the handling of the emergency.

The Reactor Supervisor will decide when the emergency is over and institute the proper reporting of the incident to the Reactor Operations Committee and subsequently to the Radiation Safety Committee.

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The line of succession for the Reactor Supervisor as emergency director starts with those Senior Reactor Operators who are at any time designated as Assistant Reactor Supervisor with full authority and training to act in place of the Reactor Supervisor, and then passes to any Senior Reactor Operator. In the absence of any of these persons Dow Management may appoint responsible persons to act as emergency director with the assistance of the reactor emergency organization and outside support groups. The emergency director shall not delegate the responsibilities for notifications or protective action decisions.

The Reactor Supervisor is in charge of coordinating emergency preparedness, including responsibility and authority for emergency preparedness, planning, updating emergency plans and procedures and coordinating plans with other organizations.

E. Information to the Public An Information Officer, designated by the management of the Michigan Division of Dow Chemical USA, will communicate to the public through the Emergency Operations Center of the Midland County Emergency Services Department in the event of activation of this emergency plan at the Alert level or higher.

F. Radiological Assessments The Radiological Safety Officer, assisted by the staff of the Dow Industrial Hygiene Departments, is in charge of radiological assessments. The Radiological Safety Officer reports any findings to the Reactor Supervisor and advises the Reactor Supervisor on matters of exposures, regulations, and protective sns.

t G. Recovery The Reactor Supervisor is in charge of recovery operations and is assisted by the reactor l

staff, the Industrial Hygiene Department, and the Reactor Operations Committee.

H. Termination of Emergency The Reactor Supervisor is authorized to terminate the emergency and institute recovery

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I. Radiation Exposures in Excess of Normal Occupational Limits The Reactor Supervisor, in consultation with the Radiation Safety Officer, may authorize emergency workers to incur radiation exposures in excess of normal occupational limits.

J. Re-entry into a previously evacuated area The Reactor Supervisor may authorize re-entry into a previously evacuated area.

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III. Emergency Classifications A. UnclassiGed At the Dow TRIGA Research Reactor there is potential for emergency situations which do not have consequences severe enough to activate the lowest standard classincation but which would require activation of some portion of the emergency response team to deal with injuries and property damage while preventing escalation. Examples of such situations include chemical exposure of workers, small fires in the building, severe weather watches, and injury or sudden illness of personnel. The 1602 Building Emergency Plan and safety organization exist to cope with these situations. Written procedures corresponding to these emergencies are provided to employees and regular training exercises are established as part of the overall Dow safety program.

The reactor operation may be affected by these emergencies and the reactor staff may be involved but within this classi0 cation there is only minimal thceat to the reactor and only minor releases of radioactive materials.

B. Notification of Unusual Events This class includes those man-made events or natural occurrences which create a radiological hazard or a potential radiological hazard.

Emergency situations within this classincation would include breaches of security, tornado warnings, prolonged fires in the reactor facility, fuel damage, or release of airborne radioactive materials which would be in excess of 10 times the effluent concentration, averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, at the Dow fenceline, as defined in 10CFR20.2203 C. liigher Levels of Classification There are no reasonable combinations of cucumstances which could lead to emergencies classified as Alert, Site Area or General emergencies.

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IV. Emergency Action Levels Introduction. The release of radioactive materials from TRIGA fuel elements has been the subject of some experimental study and analysis. The Dow TRIGA Safety Analysis Report (1966) addresses the results of a fuel cladding failure based on data in ORNL 2127,(1957), while experimental data on the release fraction of radioactive fission products from TRIGA fuel are presented and reconciled in a report from Gulf Energy and Environmental Systems (F. C.

Fousbee and R.11. Peters, " Summary of TRIGA Fuel Fissica Product Release Experiments,"

Gulf EES A10801,1971). A detailed examination of accidents is presented by S. C. Ilawley and R. L. Kathren in " Credible Accident Analyses for TRIGA and TRIGA-Fueled Reactors" (NUREGiCR-2387 PNL4028, April 1982).

Assuming the Dow TRIGA Reactor has been operated at 300 KW for a period of time sufficient to establish equilibrium of the radioactive fission products, the average inventory of noble gases and halogens in a fuel element is calculated to be almost 42 conservative estimate of the low-temperature release fraction

, the release of about of 1.5 x 21 mci ofiodines,27 mci of total halogens, and 36 mci of noble gases can be expected from a single failed fuel element.

The volume of the reac'~ vm is about 1.3 x 108cm and 3 the air tumover rate, with the intake and exhaust systems 4, is 1700 cfm. Even in an unventilated room the air exchange rate is expected to be v.s to 2 per hour under average conditions, so that the airborne radioactive material will be expected to leak out of the room or settle on room surfaces within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

It is expected that all of the halogens will be retained in the reactor pool and all of the nob]e gases will be vented. The pool water ' vill have an average concentration of about 1.5 x 10' pCi/mL- of radioactive halogens, well below the technical specifications maximum permissible level of 0.1 pCi/mL.

The use of the Dow TRIGA since 1967 indicates that the reactor has not been continuously operated for a sufficient period of time to achieve saturation of the noble gas fission products and is not likely to be so operated.

Snecific Emergency Action Levels. It is expected that the Continuous Air Monitor, located in the reactor room within 15 feet of the pool, will respond to the release of radioactive materials due to failure of a fuel element (this did indeed occur during the initial start-up of the reactor in July,1967). The Continuous Air Monitor is set to alarm at a level which is sufficiently lower than that expected from a release from a damaged fuel element that any such event would surely be detected. At the same time this alarm level is set sufficiently higher than the maximum observed natural background that no alarms due to natural background are expected.

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9 Emergency Action Level (EAL)

Detection system (Location) EAL (Alarm Level) Interpretation Continuous Air Monitor (4000 cpm) Radiation level is well above (Reactor Room) background 9

V. Emergency Planning 7Jmt The Emergency Planning Zone for the Dow TRIGA Research Reactor shall be the operations boundary.

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VI. Emergency Resoonse A. Activation of Emergency Organization Any Icrson observing a situation which !.as led or could lead to injuries or propeny damage may activate the Emergency Response System. There are several methods of activation and the partic dar method is left to the judgment of the initiator.

Method 1: Activate the evacuation siren signal (any one of 7 switches located throughout the building) and meet with building supervisor at the designated assembly point outside the building to decide appropriate action.

Method 2: Activate the Alen siren signal and meet with ouilding supervisor at tue designated assembly point inside the building to decide appropriate action.

Method 3: Dial 1-2-3 on the nearest telephone and describe the situation to the Dow Security dispatcher.

Notification and nobilization of the suppon organizations requires a specific notification of the Dow Security Department, either by telephone (1-2-3 or 6-4400) or by radio communication from the scout car which responds to emergency alarms during off hours.

Emergency situations which arise outside the building (severe weather or chemical release, for example) will result in activation of the telephone emergency alert system, whereby alert messages are transmitted to a number of telephones throughout the Dow plant (including the telephone at the reactor console). Personnel may then take shelter or evacuate, using the siren system as a signal, as necessary.

Current notification lists are maintained by the Dow Security dispatcher who will notify Dow end effsite support organizations as required. The Dow Security dispatcher is on duty at all times. All notification of support groups is performed by the Dow dispatcher.

The Continuous Air Monitor automatically signals the Dow Security dispatcher whenever the response is greater than the action level or whenever 110 VAC power is lost. The dispatcher will notify persons on the notification list for this situation.

B. Assessment Actions The primary effluent monitor is the Continuous Air Monitor, located in the reactor room.

This monitor is tested daily and calibrated semi-annually. Portable monitoring instruments including air samplers would be used to provide quantitatis e data.

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Actual or projected radioactivity releases would be correlated to offsite dose projections by a simple diffusion model and hand calculations. Onsite radiation doses to personnel will be determined by pocket dosimeters and film badges. Assessments of tsan-radiological emergencies-will be made by the persons on the site at the time of the emergency.

C. Corrective Actions In any emergency at any classification level the i.rst action will be to secure the reactor, if--

the reactor is in operation at the time In case of the release of radioactive materials the reactor room may be sealed by shutting off the ventilation system and closing the outside dampers.

In case of threatened or actual breach of security the Dow Security dispatcher will be informed by telephone, Security Department personnel may call upon law enforcement agencies as necessary.

Fires, chemical spills, personnel injury or illness will result in telephone notification of the Dow Security dispatcher who will notify the appropriate support groups.

A tomado warning would result in an Alert signal and personnel would take shelter in a designated area.

The reactor supervisor and building supervisory personnel will determine the detailed corrective and recovery actions following the initial responses noted above.

D. Protective Actions In case of any emergency requiring evacuation of the building all persons will congregate at the primary site just north of the building or at the secondary site just cast of the building, depending on the hazard involved and the wind direction. The evacuation procedure includes accounting for all personnel in the building by comparison with current lists of visitors, and sign-out boards for regular 1602 inhabitants, all of which are routinely carried to the designated congregation area. Typically during quarterly exercises the accounting takes place in less than five minutes. Potentially contaminated personnel remain segregated if possible, within the building with the deluge shower, and if not, in an area just cast of the building.

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Emergency personnel have protective clothing, monitoring equipment and respiratory protection gear available. The 1602 Building staff is equipped with full face respirators, disposable coveralls with pencil dosimeters, film badges, survey meters, and a portable air sampler. The Dow Ambulance and Fire Department crews arrive in turnout gear and equipped with self-contained breathing equipment, respirators, and survey instruments. Industrial 11ygiene staff arrive with survey instruments and are prepared to record radiation survey results and keep time for personnel exposed to radiation fields. The Dow Security personnel arrive with survey meters and portable communication equipment.

During an evacuation the Dow Security personnel control access to the area. All entries to the building are under observation and access is controlled by the Security personnel with advice from the Reactor Supervisor. After re-entry into the building the affected areas are isolated by signs and physical barrius while detailed surveys and subsequent cleanup take place.

Radiation dose rates and contamination levels are monitored by Industrial Hygiene personnel and the results and data are transmitted to the Reactor Supervisor. In case of a spread of radioactive material offsite the Reactor Supervisor then informs the Security Dispatcher either by radio communication gear operated by Security personnel onsite or by means of an automatic-dial telephone located some 300 feet north of the building.

The Dow standard for radiation exposure of emergency workers is 25 rem for life-saving situations; otherwise the standard is 5 rem, t-I I

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Vll. Emergency Facilities A.- Emergency Support Center

- The Emergency Support Center is the conference room of the 1002 Building. For short

, periods of evacuation the Emergency Support Center may be the congregation area outside the building; for longer periods of evacuation or during inclement weather the Emergency Support Center will be locat:d in 1603 Building, some 300 feet east of the reactor. facility. The Emergency Support Center will be activated by the Reactor Sep rvisor immediately upon recognition of an emergency situation. Response personnel will be guided to the Center by members of the facility emergency response team.

Buildings 1602 and 1603 are equipped with deluge showers and eye showers for first-aid treatment of chemical exposures. All major decontamination takes place at the Dow Medical Building under supervision of medical personnel. There are no first-aid supplies kept in the buildings; first-aid is supplied by the Ambulance crew.

B. Assessment Facilities

1) Fixed radiological monitors.

(a) Continuous air monitor in reactor room.

(b) Area monitor in reactor room.

2) Portable radiological monitors.

(a) Survey meters (ionization chambers and G.M. detectors) in control room and adjoining laboratories.

(b) Laboratory monitors and frisking monitors in the control room and adjoining laboratories.

3) Sampling equipment.

Portable air sampling devices located in 1803 Building. (Health Physics) and in 1602 Building.

4) Instrumentation for specific radionuclide identification and analysis.

(a) Ge and Nal(TI) detectors at the facility.

- (b) Ge and Nal(TI) detectors at 1803 Bldg.

5) Fire detection devices.

(a) Smoke detector in control room.

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C. First Aid and Medical Facilities initial decontamination of personnel, in case of serious contamination or of chemical exposure in addition to radioactive contamination, takes place within the 1602 Building at deluge showers and eye showers. The decontamination areas are closed off and access is controlled by the facility staff until the area can be decontaminated. If the emergency situation requires evacuation of 1602 Building then contaminated clothing is removed and secured at a designated area outside the building, personnel are clothed in disposable covers and are transported to contamination facilities at the Dow Medical building. The ambulance crew is trained to provide first-aid. The Dow Medical Depanment has facilities for treatment ofinjured personnel and has arrangements to transfer patients to the Midland Hospital Center if necessary. The Midland llospital Center has an agreement of assistance with the University of Michigan Hospital (Ann Arbor, Michigan) which is equipped for back-up assistance in cases of extended emergencies involving the reactor.

D. Communications Equipment An emergency alert system using a special emergency telephone system will warn each building in zoned areas of the plant and laboratory locations of emergency situations in other buildings. This telephone alert system also provides notice of utility failures, low water pressure, power, etc. Storm warnings or tornado alerts are received from this system. The telephone alert system is manned continuously by the central dispatcher's office of Plant Security.

Emergency situations due to hazardous conditions inside the building are made known by an electrically operated siren for which there are seven wall-mounted switches in the main corridors of the building near each exit door. The siren can be operated by any person desiring to initiate an alert or evacuation.

Dow Security peisonnel are equipped for two-way radio communications with the Security dispatcher. The Dow Ambulance crews are equipped for two-way radio communications with the Dow Medical Department.

Communications systems are checked during practice evacuations and hypothetical emergency exercises.

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. j Vlil. Recovery In the event of an emergency involving radioactive contamination, the facility will be restored to a safe status under the direction of the Reactor Supervisor using health physics practices which are generally applicable to the particular circumstances of the situation. In the case of contamination with a short-lived isotope decontamination may be aided by waiting for the radionuclide to decay followed by cleanup of remaining low level contamination.

in case of a contained spill, the area will be immediately roped off and posted.

Decontamination operations are planned in such a way that further uncontrolled release is avoided. The source of the release may be covered with absorbent material and polyethylene film to avoid spreading the activity.

The contaminated area is subsequently decontaminated by systematically wiping and washing with soap and water on moist paper towels, etc. The latter are subsequently disposed of as radioactive waste.

Contamination of air in the facility requires an identification of the radionuclides and decontamination procedures are based on the chemical properties of the radionuclide. Air filtering, scrubbing or alternate decontamination procedures will be employed. All decontamination of the facility will be conducted by the Reactor Supervisor and his staff with the advice of IIcalth Physics personnel.

Re-entry into previously evacuated portions of the building will be authorized by the Reactor Supervisor. The staff will be suitably clothed and equipped to monitor radioactive contamination. Decontamination will follow assessment of contaminated areas and re-entry of employees into decontaminated areas will be authorized by the Reactor Supervisor upon advice of the Industrial llygiene personnel.

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IX. Maintaining Emergency Prenaredness A. Training Industrial liygiene conducts periodic retraining for Dow emergency response personnel likely to be involved in a radiation emergency. The Micrdgan Division Medical Department, Security Department and the Fire Department are annually trained by reviewing radiation fundamentals and specific radiation havards likely to be encountered in an emergency.

Radiation fundamentals discussed with all emergency response personnel include the concepts of radiation types, radiation protected by time, distance and shielding, properties of radiation, biological effects, background radiation sources, current exposure standards, assessment of radiological hazards and the ALARA philosophy.

In addition, the Medical Department Staff reviews the transport, receipt and care of the contaminated or exposed patient. This includes contamination control, patient, equipment and personnel isolation, contamination monitoring, decontamination had waste control. The Fire Department and Plant Protection personnel are given training by reviev ing the radiation hazards likely m be encountered in the reactor facility. Emphasis is placed on contamination monitoring and instrumentation, respiratory protection, equipment and personnel isolation, radiation warning signs, and fire control relative to the radiation hazard.

Persoas involved in protective action decision making, including the Reactor Supervisor and the reactor staff, receive specific training as part of the biennial requalification program for Senior Reactor Operators (includinc an annual building evacuation involving the TRIGA) and as part of the annual hypothetical emergency exercises.

B. Drills and Exercises Emergency procedures are tested quarterly in the form of building and facility evacuation drills which include all personnel present in 1602 Building at the time of the drill. These drills satisfy the requirements of the 1602 Building emergency plan. At lease one drill per year is to be pre-planned with a scenario which will test the preparedness of on-site personnel in medical-and contamination-control procedures. At least once every two years a drill is to include a scenario which is appropriate to test serious emergency situations. This drill will include coordination with off-site emergency personnel and will test, at a minimum, the communication links and notification procedures with those off-site agencies.

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C. Reviewing and Updating of the Plan ,

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The emergency plan will be reviewed every two years. This review will_be conducted within 3 months of the biennial emergency drill and will involve updating to incorporate changes '

in the facility and results of emergency tests and drills, Written agreements pertaining to.the emergency plan will be reviewed and updated,if necessary, at this time also Critiques of the drills, comments arising durine ^ requalil'ication program for Senior Reactor Operators, as well '

as day-to-day comments and ( racrvations will be used as necessary to correct and improve the emergency plan. .,

D. Maintenance and Inventory of Emergency Equipment and Supplies e

Fixed radiological monitors (Continuous Air Monitor and Area Monitor)in 1602 Building are tested each day the reactor is operated as part of the daily checklist. Portable survey meters '

are calibrated ann _ ally. The emergency kit and its cortents are checked monthly as part of the monthly checklist. Air monitors and back-up survey instrumentation is maintained by Industrial liygiene.

l APPENDIX I Site Maps

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'i APPENDIX 11 Letters of Agreement With Off Site Support Groups i

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gC Y o, \ l Mi:lland rue vnunmem ase, ca nIs, sm . suaa sue n.e .m <,.sI. mI . S a t.<I u,n r.n 16 April 1997 Mr. Wud Rigot The Dow Chemical Company 1602 lluilding Midland, MI 48667 RE: Emergency Response to the Dow Chemical Research Reactor

Dear Mr. Rigot:

This letter is to confirm that the Midland Fire Department will respond to calls for assistance at your facility, within The Dow Chemical Company, which contains a research nuclear reactor. As taxpayers and corponrte citizens of Midland you can be assured that this depanment will respond and provide all of the assistance that we are technically able to provide.

The Fire Department wculd like to schedule training exercise, with your facility on an at least

. yearly basis. I will con u you so that we can arrange familiarization tours for our personnel.

Should you have any questions, please contact me.

Sincerely,

[ -

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Daniel J. Ilargarten Fire Chief ec: Karl Tomion, City Manager Patti Halm, City Attorney File -

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DEPARTMENT OF EMERGENCY SERVICES MF '%HtGAN 44640 5194 220 W. ELLSWoRTH

" " # MIDLAND COUNTY SERVICES BUILDING TELErNoNE (SIT) 8324750 Roger Garnar OttiCfOR OF tuth3tNCY StMVCt8 January 29, 1997 Ward L. Rigot, Research Associate Dow Chemical Company .

1602 Building Midland, Michigan 48667 q

Dear Mr. Rigots With regard to any community emergency resulting from a problem at the Dow Triga Research Reactor; the Midland County Department of Emergency Services will support the emergency response operations of the Dow Chemical company and the City of Midland Fire Department, by carrying out emergency management functions as described in the County of Midland / City of Midland Emergency Operations Plan and supporting standard operating procedures.

Please do not hesitate to contact me if you have further questions or concerns.

Si g ely,

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Roger darner Diredter of Emergency Services County of Midland

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APPENDIX 111 Emergency Organization i

1

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Dow Chemical Emgency Organitation Rervlanva l l

[ i i i I I EtKWDptmlDS $838 BOG Ilbf) OP.4f INII Ottd hid4M OMl 8%f DN U8dd bfl##l OIIN !WMN I I r,,y.. llt.,wn ,s sat.:umil um l

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Page 1: amf a : This is a correction of a misplaced word, "a".

Sciences: The Department is now known as the Analytical Sciences Laboratory.

rnGeiger-M'iellectietecteettuipped wibernir pump and pepcr fdter;: This deletion is intended to improve the clarity of this sentence, a Geiger Mueller detector etiulpped with an air pump and paper filter,: This insertion is intended to provide information about the Continu >us Air Monitor, calibrated to provide dose rate information: This insertion is intended to provide information about the Arca Monitor.

upio not exceeding: This change is intended to clarify the sentence; the reactor is not necessarily operated at power levels up to 300 kilowatts each day.

Page 2: EadulLlHrector. A manager or senior technicalleader within the organizatlun of the Analytical Sciences Department who has resgxmsibility for members of the reactor staff. This new dennition is designed to identify a person with specific responsibilities, renetermiministrate Facility Director: There is no person or function labeled

" reactor administrator"; a Facility Director is denned.

normal: This addition is intended to reflect the differences between the normal management organization and the emergency management organintion.

Emergency Planning Zone WPZ). Area for which off site emergency planning is performed to assure that prompt and effective actions can be taken to protect the public in the event of an accident. The EPZ site depends on the distance beyond the site boundary at which the Protective Action Guide (PAG) could be exceeded. For this plan the EPZ is defined as the reactor room (Lab 51 A of 1602 Huilding).

This addition defines the reactor room as the EPZ for this plan.

Page 3: administrutor supervisor: This change is intended to clarify the identity of the person who will initiate emergency activities; there is no reactor administrator, withwnleef: Delete reference to the specific rank of the member of managemer.t as this changes from time to time.

to: a grammatical change resp (msible for the administration of all Dow Midland location activities involving the use of radioactive materials and radiation sources including assurance of compliance with United States Nuclear Regulatory Commission (NRC) regulations. n groupef-knowicdgcubic grsomfrom scvc rel srcas of The Dow-EhemicaFCernpeny which dcterminesihc pelicics and safetystani&rds en all page iof vi

o ,

m ;;cra cermerning r dislegicel sefc y 3: n.c Mid and ic,etian and everges thc f ci incewhich n;il ire idaiem end rmiis.w ;vc mearielm : The Radiation Safety Conunittee has defined itself thus.

Sken Swikh. Wall mounted switches, whlch activate the hullding evacuation signal. This is added to clarify the mechanism for activating the building evacuation signal.

Page 4: Seic y Cwidine:or end 0,c itc-!:n:ry TeamttfibePersons responsible for the normal Analytical Sciences Laboratory safety program inerganic Anelysis Grenp, which is henwd : Management and organizational changes have climinated the specine fui.ctions of Safety Coordinator and the Re Entry team but the safety program remains. Persons working in this building are ne 'onger an independent group within the Analytical Sciences Laboratory.

Ikw Cerpete-imd-Michigen Division industriaH!ygicnc Depenments Dow industrial liyglene Expertisc Center,. This reflects a change in the name of the organization providing llealth Physics coverage.

Michigen Division indas;rinH4ygicac Ikpertment Environmental, IIcalth and Safety organization. This reDects a change in the name of the organization performing this function.

Sciences: See above.

Page 5: er hig!,cr chistttfemergency: There is no credible way for this facility to experience an emergency classified higher than " Notification of Unusual Event".

Page 6: salaried: All Senior Reactor Operators, salaried and bargained for, are included in the line of succession.

his-any: This is intended to remove references to gender.

Ile-and: This is intended to remove refereces to gender.

Page 7: Re-entry into a previously evacuated area: This is the addition of a previously missing heading

[radioh gical hazard or a potential radiological hazard. -er ceux demeges to thc ficili:y er 0.c 3:sif wbich in gencrel tic not inclnde ic cess of significent quendtics of redio.wiivc meterial ner significent risk ;c the gcncrei public. Thcsc cmcigencics will have effccis which ;ced to bc confincd to the fecility end which cen bc c:nriccica wnh thc eveliebic pcisonnc! end cquipn,cnt, Emergency situations within this classification would include breaches of security, tornado warnings, prolonged fires in the reactor facility : The emergency regeU of vi

l classincation is changed to include only radiological hazards; other ha7ards mentioned in the original timergency Plan do not credibly lead to radiological hazards at this small research reactor.

• ite4mundary Dow fence line: This is intended to identify a specine boundary.

[e)C. /,lert The,adertvinss-inehtdeHhosc cycnts-whtehemid,-thrtmphnmnnbinatitnroMaihtres of-fttel-eladding-and-ercrinicnt*;-lend-to-a-relen;c of indiometive-tnnterinbwhich couldneecd-504dl2C-nt-the- ite botmdery, svcingcd ever-24+ours;451nreni whcie body-dowc nccitmulatecHn-24-hours,--201nrem/h:4tn+hottewhole-bmly-dtnc retc. Or 400-mrem-indine-tlose-Thin-claw-inehtdes-entnstruphic natarnt-end ninn-nindc events;-sttehnwtornadcror-tmeentrolled-release-ofioxiepe*;-which would severely injttreihe-inhnhitants- There are no credible circumstances which could lead to this level of classification at this research reactor.

l pageiiior vi

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l Page 8: Alert: There is no credible combination of circumstances that could lead to an emergency classified as Alert at this facility.

1 A detailed examination of accidents is presented by S. C. Itawley and R. L. l Kathren in "Credibic Accident Analyses for TRIGA and TRIGA. Fueled  !

Reactors"(NUREG/CR.2387 PNI 4028, April IP82). : This reference is added to j provide more information about the evaluation of ha: 4. l tivci:hc psst-t% since 1967: This change is intenA . rflect the passing of time.

Page 9: which is sumelently lower than that expected from a release from a damaged fuel element (see July 1%7) that any such event would surely be detected. At the same time this alarm level is set sumelenmtly higher than the maximum observed natural background that no alarms due to natural background are expected. ebGii :hicc :imc5 :hc maximsiti Ghncrved as: sial b;ckgiGsnd. If & ickese Ofi6disus: IVC iii&:ctials-i; 5Unpccicd, chhci by nii nl6iiii fiGin thc COndi.GGii3 Air MOnits- Gi :hc Arce "Gni:Gi, sii 5ampling wi!! bc initie:cd ;G dc crmitic the agni:ndc Uf :hc icicanc and-thu5 the classifics:iGri !cycl Gf the cmcigcncy.

The-nir-sampling will bc cGndscica :G a!!oW en c5:imn:c Of thc emGnn Of iGdinc-!M hnd Odici iiis:ci!&l; icienscd. This Wi!! cGiisini Gi a 10-Hiisis:C 4S-cubic-fcc:-pci-niliiU C 5&iiiplc Uf Lii cGI!cc cd :liiGUgli 5 l-hicli TEDA clinicGhl ft!:ci chiliidgc nad H philic0!5:c picfilici. Thc ;Gidl hci!vily Gii IIic chhicGh! chiiidgc

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,1 64_v a u s s at u ur trv nn3413V 3.rA. O u ' Avg g itaa sv 6tssb ubabbiva vi l t: 5 sa a. /t va ns% Abirby vi s a s trv tiscd iG inGiii:Gi;hc indiG6c;iViiy Gii dic clihicGnl fil ci. IIic iGGdc!5 End VhlUc5 [GUsid in-IC-Rf' 2, l0 end 30 hevc bccn n5cd :G csicuin:c & cGun: istc cGirenpGiiding :G e 100 iGicin 0 h! :hyrsid dG5c,555uiiiing & l-hGUi cxpGsuic Liid d bichdiing id:C Of 20 Inci5 per-mimetc. Such en cxpG5 sic cGuld Gidy bc pG55ihic if-:hc :G al iclca5c frection r.._i_i____._.....

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. u t a . . _ n . . _ _ . . _ . _ r , i _4 r,1.OktIs a v s V uw s : va m e..irn ir3E gun s ubs E gy sisv ana vi sta s quinatra susta sasi b Inray vs s ais. s l ft!c55cd G :hc hiGiG5p'.icic WiNi!ii Giic hGUT (SitttOfi s fGiiiiU!5 fGi di5psiniGii) i&N5Lg iiG cicdit fGimny ic:catiGri Gf iGdinc itt :hc pOGi Gi fGi eny ple:c-Gv;.

drf0ftShIc iGii cIihiiiIs'i WifI bC iibcd (G cv&!Ud c Nic pG5hih!c WhG!c bGdy dG5c 6; :hC 2 . _ m _ .i _ _. .

3314 L%stsa su gas y ,

pageiv of vi

Thc icects room erce monitor (a C41 dctccier) is sci to slicio et 2 micm/hr. This 4

coric4,undes epproximatcly 3 x 10 pGi/ml:rthe-total scicawc frsciion inventory of nobic gescs si thc cquilibrium of onc of thc TRICA fuci cicments, essnining pcifcc mixing-in-tic scector sc(.m. Using Sutton%-formtria for dispcr3 ion this emennt of nobic gas would give u 24-houravcregc conccatmtion of epj,iuximatcly 0.02 MPE-et the-nearest 3;tc boundsry in slightly stabic wind conditions.: These changes have been made as a result of a review of the design basis accident (damage of one fuel element containing the maximum burden of radioactive fission products and the subsequent release of a fixed fraction of these radioactive fission fragments) as follows:

The Dow TRIGA research reactor achieved initial criticality 6 July 1967. On 10 July 1967 the cor.tinuous air monitor alarmed after the very first operation at 100 kilowatta. Testing indicated the presence of a leaking fuel element in the F (outer) ring which was identiGed and removed from the core. This event had effects far lower than the design basis accident in that the fuel element was in the outer ring (lowest fission activity) and the reactor had been operated for only a few minutes before the ahtrm, not the many hours necessary to approach the maximum fission product inventory.

During the testing period in 190'7 the continuous air moaitor background (radon daughters in the air) was about 100 counts per minutet v, hen the reactor was operated at 100 kilowatts the monitor usually alarmeo at 1000 counts per minute within about 75 seconds and leveled off at 4000-4500 counts per minute. If the present continuous air monitor were no more sensitive that the unit used in 1967 we would expect a leaking fuel element incated at the lowest neutron Dux, at far from the maximum inventory of radioactive fission products, to register more than 10,000 counts per minute on the continuous air monitor during operation at 240 kikowatts.

For comparison the normal background from radon daughters on particulates in the air ranges from about 30-40 counts per minute on a clean day (early Spring in Midland or a north-easterly wind) to some 400-500 counts per minute (late summer in Midland or a temperature inversion).

Thus the choice of the alarm setpoint for the continuous air monitor (4000 counts per minute) is well above the normal background levels and well below the levels expected from the design basis accident.

page v of vi

4 0 From Table 4 (Gaseous Fission Product Activity in the TRIGA Element Containing the Greatest Activity Following Operation at 365 MWD) of llawley and Kathren we choose those noble gas isotopes likely to be present after a three-hour operation, ignoring those with half lives too long (days or years) or too short (32 seconds). This includes the krypton isotopes 85m,87,88, and 89, and xenon isotopes 135 and 135m.

We correct the saturation activity values for the 300-kilowatt maximum operating power of the Dow TRIGA reactor and the 78 fuel elements (rather than 50, as in llawley and Kathren), apply the calculation for a three-hour operation, apply a low-temperature release fraction of 1.5115 proposed by Foushee and Peters, and assunie that all of these materials are released from the water at the top of the pool as noble gases. The result is that we would expect the release of about 10 millicuries of noble gases, of which mare than half is due to the 3.2-minute krypton 89 which decays to 15 minute rubidium 89, following damage of the cladding of one fuel element in the il or C rings.

The air exhaust rate in the reactor room is 1700 cubic feet per minute, which is equivilant to 6.91!10 milliliters / day. The release of radioactive materials as above would result in a concentration of about 1.4117 rnicroCuries/ milliliter, averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, from the exhaust stack at the east side of the reactor room. The nearest Dow fenceline is about 160 feet west of this stack, some 40 feet west of the western-most portion of 1602 Iluilding.

This quantity is not sufficient to warrant declaration of an emergency classified as

" Notification of Unusual Event".

In such a case, however, an emergency clasdfied as " Notice of Unusual I! vent" would be declared because of the fuel damage.

Page 10: [G-M45menke TEDA-Ehnraml 2000cjni 100 inicin thyrmd-(Siteilotmdary) Mmve4mekprmtnd dmeistossible Pmtabledon-Ehnmbcr 3-t nireni'br 15 nircnilwhole4mdy (Siteile:mdm, , desc/24 hoursir possible-

& mrem #hr- 75 niicni/wholc body-desc/ 24 hourrir possible):

There is no credible way for these Emergency Action Levels to be attained at this facility.

5 7: The number of siren switches has been increased. Switches are now located at all exits from the building. llaving more switches allows for more rapid communication of building emergencies.

page stof vi

Page i1: enlibratedweekly-with-n knowersettree tested daily and calibrated semi nunually:

The calibration and testing procedures have been changed.

Page 12: vnention4ists: There is no longer a vacation list that can be used for accotmting for persons during emergencies, re-entryienmstaff: There is no re-entry team; the reactor staff performs this function..

tworettablemelf-etmtninedbreathing kitrand: The breathing apparatus has been removed from the laboratory; the Dow fire department people arrive equipped with this type of equipment paper..... boots: The coveralls are a lightweight impermeable composite material, and the foot coverings are connected.

I Page 13: (hi): Lithium-drifted detectors are no longer used.

Imrkittbahtmd-17021803: Larkin and 1702 facilities have closed; equipment is available at 1803 Iluilding Page 14: five: seven: The number of siten switches has been increased.

Page 15: re-entryienm staff: There is no longer a re-entry team; see above.

Page 16: nnmmi biennial: The requalification program is now on a biennial basis, biennini annual: Training is now a part of the annual hypothetical exercises, fireftghting-: Most emergency scenarios do not include fires, nonual: The requalification program is now on a biennial schedule.

quntterly : annually. The need to assure that meters are operable is essential; but the cost in time, manpower and the need to maintain an inventory of spare meters places a great burden on our program. We have letters of file from the manufacturers that annual calibrations are adequate to assure operability of meters, assuming battery checks and positive responses to :adiation souices are performed.

These drills satisfy the requirements of the 1602 Ilullding emergency plan. This is added to clarify the frequency of drills covered by this plan.

Appendix 1 has been added and contains the floor plans and maps of the facility with respect to the city of Midland Michigar..

Appendix 11 has been added which contains the letters of agreement with the offsite support services.

Appendix 111 has been added whleh contains an organization chan.

tiaFe 5ilUI Vi

l. .

DOW TRIGA* RI!SliARCil RilACTOR !!MiiRGliNCY Pl.AN

41. latadunion mA. The Reactor Facility.

The Dow TRIGA Research Reactor is a 300 KW pool type nuclear reactor designed as n Training, Research, and isotope;"noduction facility by General Atomic Company. The re.ctor fuel, nominally 20% enriched in U,is fabricated in a U Zrlig,,, form which provides a v 'ue safety factor in terms mor a prompt negative temperature coefheient of reactivity. The reac. t Dow is a research and analytical tool within the Michigan Division Analytical Sciences 1,almratory where it has been used as a source of neutrons for activation analysis and other research functions since 1967.

The reactor is found in a below ground pool with no horizontal beam ports or core-level acceks. The pool is h>cated in a 20' x 23' Reactor Room which contains sample storuge facilities, experimental facilities, spare parts, tools, and files. The Reactor Room is monitored by a Continuous Air Monitorrn-Geiger-Muellerdetector-equippedwith-an-airrump-andtaper filter; and by an Area Monitor. The Continuous Air Monitor, a Geiger 41ueller detector equipped with an air pump and paper 111ter, is provided with an alarm setpoint; radiation levels abo.e the setpoint trigger audible and visible signals and also ' ansmit a signal to the Dow Security Dispatcher. less of power at the Continuous i 1r Monitor also triggers a signal to the Dow Security Dispatcher. The Area Monitor, a Geiger-Mueller detecter calibrated to provide dose rate in.ormation, has a readout and alarm at the reactor console. The cen'er of the reactor is at least 100' from the Dow security fence. The reactor console and the associated laboratories are hicated in nn-adjacent rooms.

The reactor is typically operated for periods of 10 minutes to several hours each day at power levels urto not exceeding 300 KW. The average energy output is approximately 1.5 megawatt-days per year.

This emergency plan is intended to serve as a framework for responses to circumstances which could threaten the facility or the heahh and safety of the public. The emergency plan delineates responsibilities, lists resources, defines procedures, and prescribes training and exe rises for preparedness.

Mt. Definitions timergency. An emergency is a condition that calls for immediate action, beyond the scope of nonnal operating procedures, to avoid an accident or to mitigate the consequences of one.

• 'IRIGA is a tralenwk or General Atomics 1

Continuous Air Monitor (CAM). This instrument, situated in the reactor room, pumps air through a filter which is monitored by an end window G M counter. The circuit is equipped with a trip which, when energized, automatically signals Dow Security, energizes a highly visible light, and energizes a loud audible alarm. A loss of power to the CAM will also result in a signal to Dow Security. This system is checked for positive operation during every daily checkout of the TRIGA, at which time the filter is replaced with a new filter.

Emergency Action Ixvels. Specific instrument readings, or observations; radiological dose or dose rates; or specific contamination levels of airborne, waterborne, or surface-deposited radioactive materials that may be used as thresholds for establishing eme gency classes and initiating appropriate emergency measures.

Emergency Classes. Emergency classes are classes of accidents grouped by severity level for which predetermined emergency measures should be taken or considered.

Emergency Plan. An emergency plan is a document that provides the basis for actions to cope with an emergency, it outlines the objectives to be met by the emergency procedures and defines the authority and responsibilities to achieve such objectives.

Emergency Planning Zone (EEZ). Area for which off site emergency planning is performed to assure that prompt ar.d effective actions can be taken to protect the public in the event of an accident. The EPZ site depends on the distance beyond the site bounday at which the Protective Action Guide (PAG) could be exceeded. For this plan the EPZ is dellned as the reactor room (I sh S t A of 1602 Hullding).

Emenency Proctdures. Emergency procedures are documented instructions that detail the implementation actions and methods required to achieve the objectives of the emergency plan.

Encility Director. A manager or senior technical leader within the organization of the Analytical Sciences Departrnent who has responsibility for members of the reactor staff.

Offsite. The geographical area that is beyond the site boundary.

Omite. The geographical area that is within the site boundary.

Doerations Boundary. The area within the site boundary such as the reactor building (or the nearest phpical personnel barrier in cases where the reactor building is not a principal physical personnel barrier) where the reacier ed.TJrdarmer Facility Director has direct authority over all normal activities. The area within this boundary shall have prearranged evacuation procedures known to personnel frequenting the area.

2

4 IMettive Action Guides (1%G). Projected radiological dose or dose conunitment values to individuals that warrant protective action following a release of radioactive material.

Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety its taking the protective action. The projected dose does not include the dose that has unavoid$ly occuned prior to the assessment.

11adiation Safety Comndttee (RSC). The RSC is responsible for the administratlou of all Dow Midland location activities involving the use of radioactive materials and radiation sources including assurance of compilance with United States Nuclear Regulatory Conunission (NRC) regulations, n gmttp-of-knowledgenble personefrommeveral-nrens tf The Dow-Ehemient-Emnpany-which-determmet-the polietennd,nfety-standards an-all-mntters mnccining-radiologient-safety-nt-the-Midland-leention-tmd-everwc; the-fneilitierwhielrtitilire rndintion-nndmidionetive-mnterinit: The reactor license requires semi-annual operational repons to the RSC.

licaduLOpciations Committee (ROC). A group of persons including a representative of management with-tank-ttf-Rcscnich Ennger, the Radiological Safety Officer, the Reactor Supervisor, and other qualified persons. The ROC meets at least quarterly ond as necessary to review operation of the reactor, special experiments, unexplained automatic shutdowns of the reactor, proposed changes in operating proc. re, and to act as a resource team in the event of emergencies.

Research Readur. A device designed to support a self-sustaining neutron chain reaction for research, developmental, educational, training, or experimental purposes, and which may have provisions for production of nonfissile radioisotopes.

Shall. Should and May. The word "shall" is used to denote a requirement: the word "should" to denote a reconunendation; and the word "may" to denote pennission, neither u requirement nor a reconunendation.

SirenEnitch, Wall mounted switches, whlch activate the building evacuation signal.

Site lloundmy. The site boundary is that boundary, not necessarily having restrictive barriers, surrounding the operations boundary wherein the reactor administrator supervisor may directly initiate emergency activities. The area within the site boundary may be frequented by people unacquainted with the reactor operations.

TRIGA. An acronym from the words Iraining,llesearch, and Isotope Production, General Atomics. TRIGA refers to a generic reactor featuring a unique fuel design which reduces significantly the possibility of a nuclear accident.

3

1

, . t 2 11. Oreanitations and Responsibilitics aA. Governmental Agencies with Responsibilities

1) Midland County Emergency Services Department. This depanment, established under Michigan P.A. 390 (1976), the " Emergency Preparedness Act" and the Midland County

Emergency Services Resolution (Nov. 25,1980), serves to coordinate emergency services within the county. These services /organitations include the American Red Cross, Midland County

lleath Depanment, Social Services Department, Midland Public Schools, and law enforcement agencies.

1

2) State of Michigan. Under P.A. 390 (1976) the Radiological llealth Services Division of the Department of Public Ilealth and Emergency Services Division of the State Police can be mobilized by the Governor to respond to emergencies. The Madiological llcalth Services Division is equipped to provide offsite radiation monitoring; the State Police are prepared to handle evacuation and protective actions as required.

b)ll. Dow Emergency Organization The reactor's emergency organization is headed by the Reactor Supervisor and consists of the Reactor Staff oflicensed Senior Reactor Operators. This organization is augmented by the:

(1) Safety-Coordlnster end the Re-Entry-Team-of-the Persons responsible for the normal Analytical sciences Laboratory safety program inorganie- AnalyhGronp,which is homed in 1602 Iluilding; (2) The Reactor Operations Committee, which includes the Radiological Safety Officer

. and a line manager from the Michigan Division Analytical Laboratory; (3) The Dow Security Department, which provides communications and interfaces with response organizations; (4) The DowCorix,rnic nnd-Michignn Division-indmtrinHiygiene-Departments Dow '

industrial flygelne Expertisc Center, which provide the people and equipment to measure and evaluate radiological hazards during the state of emergency and the recovery period. One person from thc Michigan-Divmon industrinHiygicnc Dcperiment Environmental,IIcalth and Safety organir.ation will be on call at all times to respond to emergencies. This person is trained in making measurements and surveys and will have portable equipment for taking air samples. The Radiological Safety Of0cer will be notified by the Dow Security Department at any emergency -

involving the TRIGA, will evaluate the smveys and assist the Reactor Supervisor to make j decisions concerning protective and ameliorative actions. The reactor staff and the Industrial

ilygiene Depanment, through the Radiation Safety Officer, share the responsibilities of l maintaining the emergency preparedness pmgram.

i l

l 4

The Dow Fire Depanment, Ambulance Team, Medical Department, and Security personnel respond ar necessary upon call from the Reactor Supervisor and the Security Department.

The Dow Radiation Safety Committee is responsible for noti 0 cation of the NRC and the hiichigan Department of Public ifcalth of events classified " Notification of Unusual Event"-err highcr c!m of cmcigciicy, as required by the pertinent licenses and regulations.

e) C. Offsite Support Organizations The hildland City Police and Fire Departments, the hiidland County Sheriffs Department, and the hiidland llospital Center will provide law enforcement, fire protection, ambulance and medical services, as appropriate, upon call from Dow Security. The h11dland llospital Association has an agreement with the University of hiichigan llospital, which is a resource for information concerning nuclear medicine, and is also equipped for back up assistance in cases of extended emergencies involving the reactor, d) D. Person in Charge of Directing Emergency Operations The Reactor Supervisor is responsible for the safe performance of the reactor operations and the maintenance of proper security of the facility, in cases of emergency involving the reactor the Reactor Supervisor is the first individual who needs to be notified about the existence ef the emergency. lie has the authority to conduct the handling of the emergency situation within the facility itself, it is his duty to remain informed of the immediate conditions of the reactor facility and conduct any actions or operations related to the proper handling of the emergency situation. Personnel operating in the facility during the emergency act under his authority with his pennission and are to abide by his decisions concerning the facility itself.

Tne Reactor Supervisor will assess the extent of the emergency, as far as the facility is concerned, and select the proper procedures to follow in handling the emergency at hand. He is to notify any other groups which need to be brought in to handle the emergency situation. lie is to notify the Plant Protection Dispatcher and ascertain that the dispatcher is suf0ciently supplied with information with regard to the handling of the emergency.

The Reactor Supervisor will decide when the emergency is over and institute the proper reporing of the incident to the Reactor Operations Committee and subsequently to the Radiation Safety Committee.

5

t The line of succession for the Reactor Supervisor as emergency director stans with those Senior Reactor Operators who are at any time designated as Assistant Reactor Supervisor with full authority and training to act in place of the Reactor Supervisor, and thcn passes to any salariet! Senior Reactor Operator. In the absence of any of these persons Dow Management may appoint responsible persons to act as emergency director with the assistance of the reactor emergency organization and outside support groups. The emergency director shall not delegate the responsibilities for notifications or protective action decisions.

The Reactor Supervisor is in charge of coordinating emergency preparedness, including responsibility and authority for emergency preparedness, planning, updating emergency plans and procedures and coordinatin lans with othen o.3 aizations.

e) E. Information to the Puo.

An Information Ofncer, oesignated by the management of the Michigan Division of Dow Chemical USA, will communicate to the public through the Emergency Operations Center of the Midland County Emergency Services Depanment in the event of activation of this emergency plan ai the Alert level or higher.

OF, Radiological Assessments The Radiological Safety Officer, assisted by the staff of the Dow industrial liygiene Departments, is in charge of radiological assessments. The Radiological Safety Orncer reports his-any findings to the Reactor Supervisor and advises th: Reactor Supervisor on matters of exposures, regulations, and protective actions, g)G. Recovery The Reactor Supervisor is in charge of recovery operations.-He and is assisted by the reactor staff, the industrial flygiene Department, and the Reactor Operations Committee.

h)ll. Tennination of Emergency The Reactor Supervisor is authorized to terminate the emergency and institute recovery opeintions.

ill. Radiation Exposures in Excess of Normal Occupational Limits The Reactor Supervisor, in consultation with the Radiation Safety Officer, may authorire emergency workers to incur radiation exposure: .. excess of nonnal occupational limits.

6

l .

j)J. F.e entry into a previously evacuated area The Reactor Supervisor may authorize re-entry into a previously evacuated aru.

ikill. Emercency Classifications a)A. Unclassified At the Dow TRIGA Research Reactor there is poten'ial for emergency situations which do not have consequences .evere enough to activate the lowest standard classification but which would require activation 3f some portion of the emergency response team to deal with injuries and property damage v. nile preventing escalation. Examples of such situations include chemical exposure of worke. ,, small Gres in the building, severe weather watches, and injury or sudden illness of personnel. The 102 Building Emergency Plan and safety organization exist to cope with these situations. W. ten procedures corresponding to these emergencies are provided to employees and regular training exercises are establistico us part of the overall Dow safety program.

The reactor operation may be affected by these emergencies and the reactor staff may be involved but within this classification there is only minimal threat to the reactor and only minor releases of radioactive materials.

b)D. Notification of Unusual Events This class includes those man made events or natural occurrences which create a radiological hazard or a potential radiological hazard. er cessc damegcs to thc fecility or thc steff v,hich in general de not incindc rclceses of significent qcantitics of redioective meicriel nor significant risk to the gencret public. Tiscsc cincrgencies will hevc cffccis which tend to bc confmetHerthefneility end which cen bc coriccicd with1he-availshic pciscancl end cquipment-Emergency situations within this classification would include breaches of security, tornado warnings, prolonged fires in the reactor facility, fuel damage, or release of airborne radioactive materials which would be in excess of 10 times the effluent concentration, averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, at the sitc boundery Dow fenceline, as defined in 10CFR20.2203 c)C. Alcn Thc Alcn cless incIndcs thosc cVcnis which ceUld, tiiiengh e cesib!netien of feiinics of foci cledding end expcrinicnts, iced to e rcicesc of red!0ectivc matcrirl which could cxcccd 50 biPC ei IIic sNc boundeif, eVciegcd eVci 24 IioUis,75 iiiiciii Whe$C body-desc nCCUiiiU$eicd iii 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 20 micni'hr for i heni wholc body dosc retc, or 100 iniciii iodinc dosc. This cless incindcs cetestropliic netnrel end men-medc cycnh, snch es tomede or uncontre!!cd scicasc of ioxic gesCs, WIi!CIi WedI scVcic$y liijnic i}ic lii$ishiisiiis.

7

1. .

d)C. liigher levels of Classification There are no reasonable combinations of circumstances which could lead to emergencies classified as Alert, Site Area or General emergencies.

4-iV. bergency Action Levels Introduction. The release of radioactive materials from TRIGA fuel elements has been the subject of some experimental study and analysis. The Dow TRIGA Safety Analysis Report (1966) addresses the iesults of a fuel cladding failure based on data in ORNL 2127, (1957), while experimental data on the release fraction of radioactive fission products from TRIGA fuel are presented and reconciled in a report from Gulf Energy and Environmental Systems (F. C.

Foushee and R.11. Peters, " Summary of TRIGA Fuel Fission Product Release Exper;ments,"

Gulf EES-A10801,1971). A detailed examination of accidents is presented by S. C. llawley and R. L. Kathren in " Credible Accident Analyses for TRIGA and TRIGA. Fueled Reactors"(NUREG/CR.2387 PNL 4028, April 1982).

Assuming the Dow TRIGA Reactor has been operated at 300 KW for a period of time sufficient to establish equilibrium of the radioactive fission products, the average inventory of noble gases and halogens in a fuel element is calculated to be almost 42 conservative estimate of tne low temperature release fraction

, the release of aboutof 1.5 x 10'p0 C 21 mci of iodines,27 mci of total halogens, and 36 mci of noble gases een be expected from a single failed fuel element.

8 The volume of the reactor room is about 1.3 x 10 cm3 and the air turnover rate, with the intake and exhaust systems operating, is 1700 cfm. Even in an unventilated room the air exchange rate is expected to be 0.5 to 2 per hour under average conditions, so that the airborne radioactive material will be expected to leak out of the room or settle on room surfaces within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, it is expected that all of the halogens will be retained in the reactor pool and all of the nobje gases will be vented. The pool water will have an average concentration of about 1.5 x 10' pCi/mL of radioactive halogens, well below the technical specifications maximum permissible level of 0.1 pCi/mL.

The use of the Dow TRIGA everthc pest 15 ycers since 1967 indicates that the reactor has not been continuously operated for a sufficient period of time to achieve saturation of the noble gas fission products and is not likely to be so operated.

8

Sperific Emergency. Mon Levee lt is expected that the Continuous Air Monitor, located in the reactor roora Limin 15 feet of the pool, will respond to the release of radioactive materials due to failure of e kel element (this did indeed occur during the initial start up of the reactor in July,1967). The Continuous Air Monitor is set to alarm at a level which is sulliciently lower than that expected from a release from a damaged fuel element that any such event would surely be detected. At the same time this alarm level is set sufficiently higher than the maximum observed natural hackground that no alarms due to natural background are expected. abottt-three-timerthe-mnximuin observed-nattern! bnckgroimd-If-n relense-of-rndionetive-mnterinis-is-smpeetedreit heehy-nn-ninrm-from-t he42tmtinuotts-AirfF.;

orthe-Arenmioniterrnir$nmpling-wilFbe-initiatedio-tietcrrninc the-magnitude-of-the relense-and thttsiherinssifiention-levelttf1hc cincinncy.

The-nirmampling-will-betendtteted-tenilt,iv nn cstimatemf-the-amotmttf-iodine 431-and otheemnterinitteleased-Thiswilltonsistmf-a-10-minute-4S-etthie-feet-ixr-rninute-samplemf trir collected-t hmugh-n-i-inch 2FEDA-ehnreont-filtertartridge-and-ttTartiettinteTreftlter-The-tot al netivity-ondhe-charennFenrtridge-irnssumed1&he-iodine 43h-A-G-MTanenke-deteetoewith-n F&tifteiency-will-be-tned-to-monitor-the-rndionetivity-tmihc chniconl-ftlter-Thc niedc!s-nnti vahtes-fotmd-in-1GilP-2;-1&tmd .W-havc ixcn used-ttrenlettlate-a cotmt-rats u,my,1,nding-itra 100-mrem-totnFthymtd-dmertnsuming-a-t-hotterxpmurc nnd n hrcething-ente-of-2(Hiters per minute-Streh-nn-expmttre cottid-tmly-be pmsible-if-the-totn! icicssc frnetion cquilibrittm inventory of- 21-mGi-total-indines-of cnch of-25-TitlGA-fttel-elements-was-released-to-the ini mphere-within$nehottriSttttonN-formtda-fortlisperstonrtaking no credit-foetmytetentionef iodine-inte pool er fortmy pinte-out:

A -jw,rtnhie-ite-chamheevilEbe-ttsed-ttrevnhtnte-the pmsible-whole-body-dme tit-the site hotmdary:

The-renets,. . , ,s , n . .u u. inonitor- n-G-M-detector) is sct-itt-ttintm--tit-2-mrem /he-Fhis correspondttertippmxitrMely4x-10-4 p (Ei/ml rthe4tttnFreletne-frnetierrinventorymf at-the-egttilibrium-of-ttne-of1he-Tit 1GA-fttel-elementsrtisstiming pcricci mixing-in-thc scncier room-Using-Sutttm%-formuin-for-tlisixi, ion this-amotmt ttf-nohic gns would gt;c n 2?hoitr nyernpconcentration-of-tipproximntely-0DMilP-ntihc ncercst site +otmdery in slightly-stable wind renditions-l 9

I Table-of-limergency Action levels (IIAL'3)

Detection sysicm (Imcation) EAL ( Alarm Level) Intuptclation Continuous Air Monitor (4(XX) cpm) Radiation level is more-well (Reactor Room) than-5-5-times above background G-Mfancake liliDA42harcoal 2(XO cpiii HXHttrem1hyroidtlose-is (Siteilmmdary) eiv,vc imckgnnmd possible:

1%rtabledonEhnmber M iiirc ni/hr 15-mrem /who c lwiy-dose /

(Sitellotmdary) 24 hottrs is possible:

3 iiircni//hr M iiirctii/whole+ody40sc! 24

-hoters is possible Aren-Monitor (2 iiircm/hr) M124419t24-hour)1tohle (RenetorRoom) pscs i; possible SN. Etucigency Planning 2unc The timergency Planning Zone for the Dow TRIGA Research Reactor shall be the operations boundary.

(tVI. Sincigengdesponse a)A. Activation of limergency Organization Any person observing a situation which has led or could lead to injuries or property damage may activate the I!mergency Response System. There are several methods of activation and the particular method is left to the judgment of the initiator, Method 1: Activate the enttualiun siren signal (any one of 5 7 switches located throughout the building) and meet with building supervisor at the designated assembly point outside the building to decide appropriate action.

Method 2: Activate the Alert siren signal and meet with building supervisor at the designated assembly point inside the building to decide appropriate actio1 Method 3: Dial 12 3 on the nearest tel: phone and describe the situation to the Dow Security dispatcher.

10

l Notification and mobilization of the support organizations requires a speciFe notification of the Dow Security Department, either by telephone (1-2 3 or 6-4400) or by radio 1 communication from the scout car which responds to emergency alarms during off hours, j l

Emergency situations whkh arise outside the building (severe weather or chemical release, for example) will result in activation of the telephone emergency alert system, whereby alert messages are transmitted to a number of telephoncs throughout the Dow plant (including the telephone at the reactor console). Personnel may then take shelter or evacuate, using the siren system as a signal, as necessary.

Current notification lists are maintained by the Dow Security dispatcher who will notify Dow and offsite support organizations as required. The Dow Security dispatcher is on duty at all times. All notincation of support groups is performed by the Dow dispatcher.

The Continuous Air Monitor automatically signals the Dow Security dispatcher whenever the response is greater than the action level or whenever i10 VAC power is lost. The dispatcher will notify persons on the notincation list for this situation.

b)ll. Assessment Actions The primary efnuent monitor is the Continuous Air Monitor, located in the reactor room.

This monitor is enHbretcd wccidy-with n known soaree tested daily and calibrated semi-annually. Portable monitoring instruments including air samplers would be used to provide quantitative data.

Actual or projected radioactivity releases would be correlated to offsite dose projections by a simple diffusion model and hand calculations. Onsite radiation doses to personnel will be determined by pocket dosimeters and film badges. Assessments of non radiological emergencies will be made by the persons on the site at the time of the emergency.

e)C. Corrective Actions in any emergency at any classification level the first action will be to secure the reactor, if the reae. 4 s in operation at the time in case of the release of radioactive materials t'a reactor room may be sealed by shutting off the ventilation system and closing the outside dampers.

In case of threatened or actual breach of security the Dow Securi.y dispatcher will be informed by telephone. Security Department personnel may call upon law enforcement agencics as necessary.

I1

Fires, chemical spills, personnel injury or illness will result in telephone notincation of the Dow Security dispatcher who will notify the appropriate support groups.

A tornado warning would result in an Alert signal and personnel would take shelter in a designated area.

The reactor supervisor and building supervisory personnel will determine the detailed corrective and recovery actions following the initial responses noted above.

d)D. Protective Actions in case of any emergency requiring evacuation of 16 building all persons will congregate at the primary site just north oi the building or at the se cadary site just cast of the building, depending on the hazards involved and the wind direction. The evacuation procedure includes accounting for all personnel in the building by comparison with current lists of visitors, and sign out boards for regular 1602 inhabitants, andwentiendi*tvall of which are routinely carned to the designated congregation area. Typically during quarterly exercises the accounting takei place in less than Ove minutes. Potentially contaminated personnel remain segregated 11 possible, within the building with the deluge shower, and if not, in an area just cast of the building.

limergency personnel have protective clothing, monitoring equipment and respiratory protection gear available. The 1602 Building re-enty mm staff is equipped with two peith'c sclf-contained +renthing-kitennd full. face respirators, disposable paper coveralls and boots, with pencil dosimeters, film badges, survey meters, and a portable air sampler. The Dow Ambulance and Fire Department crews arrive in turnout gear and equipped with self-contained breathing equipment, respirators, and survey instruments. Industrial liygiene staff arrive with survey instruments and are prepared to record radiation survey results and keep time for personnel exposed to radiation fields. The Dow Security personnel arrive with survey meters and portable communication equipment.

During an evacuation the Dow Security personnel conirol access to the area. All entries to the building are under observation and access is controlled by the Security personnel with advice from the Reactor Supervisor. After re entry into the buildin;; the affected areas are isolated by signs and physical barriers while detailed surveys and subsequent cleanup take place.

Radiation dose rates and contamination levels are monitored by Industrial liygiene personnel and the results and data are transmitted to the Reactor Supervisor, in case of a sp.ead of radioactive material offsite the Reactor Supervisor then informs the Security Dispatcher either by radio communication gear operated by Security personnel onsite or by means of an automatic-dial telephone located some 300 feet north of the building.

12

l l

1 Tim Dow standard for radiation exposure of emergency workers is 25 rem for life-saving situations; otherwise the standard is 5 rem.

9 Nil. Emergency Facilitics n)A. Emergency Support Center The EmerEency Support Center is the conference room of the 1602 Building. For short periods of evacuation the Emergency Support Center may be the congregation area outside the building; for longer periods of evacuation or during inclement weather the Emergency Support Center will be located in 1603 Building, some 300 feet cast of the reactor facility. The Emergency Support Center will be activated by the Reactor Supervisor immediately upon recognition of an emergency situation. Response personnel will be guided to the Center by members of the facility emergency response team.

Buildings 1602 and 1603 are equipped with deluge shov/crs and eye showers for first aid treatment of chemical exposures. All major decontamination takes place at the Dow Medical Building under supervision of medical personnel. There are no first-aid supplies kept in the buildings; tirst aid is supplied by the Ambulance crew, b)B. Assessment Facilities

1) Fixed radiological monitors.

(a) Continuour air monitor in reactor room.

(b) Area monitor in reactor room.

2) Portable radiological monitors.

(a) Survey meters (ionization chambers and G.M. detectors) in contial room and adjoining laboratories.

(b) Laboratory monitors and frisking monitors in the control room and adjoining laboratories.

3) Sampling equipment.

Poa d air sampling devices hicated in 1803 Building. (Health Physics) and in 1602 Building.

4) Instrumentation for specific radionuclide identification and analysis.

(a) Gethi) and Nal(TI) detectors at the facility.

(b) Ge(Id) and Nal(TI) detectors at Leikin Lab end 1702 1803 Bldg.

5) Fire detection devices.

(a) Smoke detector in control room.

13

e)C. First Aid and Medical Facilities initial decontamination of personnel, in case of serious contamination or of chemical exposure in addition to radioactive contamination, takes place within the 1602 Building at deluge showers and eye showers. The decontamination areas are closed off and access is controlled by the facility staff until the area can be decontaminated. If the emergency situation requires evacuation of 1602 Building then contaminated clothing is removed and secured at a designated area outside the building, personnel are clothed in disposable covers and are transported to contamination facilities at the Dow Medical building. The ambulance crew is trained to provide first-aid. The Dow Medical Department has facilities for treatment of injured personnel and has arrangements to transfer patients to the Midland llospital Center if necessary. The Midland llospital Center has an agreement ,f assistance with the University of Michigan llospital (Ann Arbor, Michigan) which is equipped for back-up assistance in cases of extended emergencies invc!ving the reactor.

d)D. Communications Equipment An emergency alert system using a special emergency telephone system will warn each building in zoned areas of the plant and laboratory locations of emergency situations in other buildings. This telephone alert system also provides notice of utility failures, low water pressure, powei, etc. Storm warnings or tornado alerts are received from this system. The telephone alert system is manned continuously by the central dispatcher's office of Plant Security.

Emergency situations due to hazardous conditions inside the building are made known by an electrically operated siren for which there are fwe seven wall-mounted switches in the main corridors of the building near each exit door. The siren can be operated by any person desiring to initiate an alert or evacuation.

Dow Security personnel are equipped for two-way radio communications with the Security dispatcher. The Dow Ambulance crews are equipped for two-way radio communications with the Dow Medical Department.

Communications systems are checked durirg practice evacuations and hypothetical emergency exercises.

l 14

thVill. Recovery in the event of an emergency involving radioactive contamination, the facility will be restored to a safe status under the direction of the Reactor Supervisor using health physics practices which are generally applicable to the particular circumstances of the situation. In the case of contamination with a short-lived isotope decontamination may be aided by waiting for the radionuclide to decay followed by cleanup of remaining low-level contamination.

In case of a contained spill, the area will be immediately roped off and posted.

Decontamination operations are planned in such a way that further uncontrolled release is avoided. The source of the release may be covered with absorbent material and polyethylene film to avoid spreading the activity.

The contaminated area is subsequently decontaminated by systematically wiping and washing with soap and water on moist paper towels, etc. The latter are subsequently disposed of as radioactive waste.

Contamination of air in the facility requires an identification of the radionuclides and decontamination procedures are based on the chemical properties of the radionuclide. Air fibering, scrubbing or alternate decontamination procedures will be employed. All decontamination of the facility will be conducted by the Reactor Supervisor and his staff with the advice of licalth Physics personnel.

Re-entry into previously evacuated portions of the building will be authorized by the Reactor Supervisor. The a wty team-staf f will be suitably clothed and equipped to monitor radioactive contamination. Decontaminatior, will follow assessment of contaminated areas and re-entry of employees into decontaminated areas will be authorized by the Reactor Supervisor upon advice of the Industrial liygiene personnel.

9-IX. Maintaining Emergency Preparedness a)A. Training Industrial liygiene conducts periodic retraining for Dow emergency response personnel likely to be involved in a radiation emergency. The Michigan Division Medical Department, Security Department and the Fire Depar: ment are annually trained by rev; ewing radiation fundamentals and specific radiation hazards likely to be encountered in an emergency.

Radiation fundamentals discussed with all emergency response personnel include the concepts of radiation types, radiation protected by time, distance and shielding properties of radiation, biological effects, background radiation sources, current exposure standards, assessment of radiological hazards and the ALARA philosophy.

l l

15

In addition, the Medical Department Staff reWews the transport, receipt and care of the contaminated or exposed patient. This includes contamination control, patient, equipment and personnel isolation, contamination monitoring, deconttunination and waste control. The Fire Departmen' and Plant Protection personnel are given training by reviewing the radiation har.rds likely to be encountered in the reactor facility, limphasis is placed on contaminatiot, monitoring and instrumentation, respiratory protection, equipment and personnel isolation, radiation warning signs, and fire control relative to the radiation hazard.

Persons involved in protective action decision making, including the Reactor Supervisor and the reactor stn': receive specific training as part of the annual biennial requalification program for Senior Reactor Operators (including an annual building evacuation involving the TRIGA) and as part of the biennial annual hypothetical emergency excreises.

b)ll. Drills and lit crcises Emergency procedures are tested quarterly in the form of building and facility evacuation drills which include all personnel present in 1602 Iluilding at the time of the drill. These drills satisfy the requirements of the 1602 Ilullding emergency plan. At lease one drill [vr year is to be pre-planned with a scenario which will test the preparedness of on-site personnel in medical:-ftre-ftghting-and contamination-control procedures. At least once every two years a drill is to include a scenario which is appropriate to test serious emergency situations. This drill will include coordination with off-site emergency personnel and will test, at a minimum, the communication links and notification procedures with those off site agencies e)C. Reviewing and Updating of the Plan The emergency plan will be reviewed every two years. This review will be conducted within 3 months of the biennial emergency drill and will involve updating to incorporate changes in the facility and results of cmergency tests and drills. Written agreements pertaining to the emergency plan will be reviewed and updated, if necessary, at this time also. Critiques of the drills, comments arising during the nnnuni requalification program for Senior Reactor Operators, as well as day-to-day com ncnts and observations will be used as necessary to correct and improve the emergency plan, d)D. Maintenance and inventory of timergency liquipment and Supplies Fixed radiological monitors (Continuous Air Monitor and Area Monitor)in 160213uilding are tested each day the reactor is operated as part of the daily checklist. Portable survey meters are calibra:cd quarterly-unnually. The emergency kit and its contents are checked monthly as part of the monthly checklist. Air monitors and back-up survey instrumentation is maintained by industrialliygiene.

16

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4 APPENDIX II Letters of Agreement With Off Site Support Groups I

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. g\ 1Y O g l l Midland Fnc EXynment

• nis t:aulli :occ< Masa Mwsm tw e sti et&7t t .5I1 s3I ns12-ras 16 April 1997 Mr. Ward Rigot The Dow Chemical Company 1602 Building Midland,MI 48667 RE: Emergency Response to the Dow Chemical Research Reactor

Dear Mr. Rigot:

This letter is to confinn that the Midland Fire Department will respond to calls for assistance at your facility, within The Dow Chemical Company, which contains a research nuclear reactor. As taxpayers and corporate citizens of Midland you can be assured that this department will respond and provide all of the assistance that we are technically able to provide.

The Fire Department would like to schedule training exercises with your facility on an at least yearly basis. I will contact you so that we can arrange familiarization tours for our personnel.

Should you have any questions, please contact me.

Sincerely, [ -

a Daniel L Hargarten Fire Chief cc: Karl Tot.Nn, City Manager Patti Halm, City Attorney File 1

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or h DEPARTMENT OF EMERGENCY SERVICES MIDLAND, MICHIGAN 48640 5194 MIDLAND COUNTY SERVICES BUILDING 220 W ELLSWoRTH TELEFNONE (517) 832 6750 Roger Gamer DeRECTOR OF GMfRO1NCY SERVCES January 29, 1997 Ward L. Rigot, Research Associate Dow Chemical Company .

1602 Building _

Midland, Michigan 48667 Dear Mr. Rigott With regard to any community emergency resulting from a problem at the Dow Triga Research Reactor; the Midland County Department of Emergency Servicas will support the emergency response operations of the Dow Chemical Company and the City of Midland Fire Department, by carrying out emergency management functions as described in the County of Midland / City of Midland Emergency Operations Plan and supporting standard operating procedures.

Please do not hesitate to contact me if you have further questions or c:,ncerns .

- - Sincerely, ON J /h /7

\

% fy i^ Q C~X'r -

Roger darner Diredtor of Emergency. Services County of Midland ,

4*

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• APPENDIX III Emergency Orgenization 3

a e i ^% e e.

Dow Chemical Emergency Organization Rex * $upem l

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