ML20032C021
| ML20032C021 | |
| Person / Time | |
|---|---|
| Site: | General Atomics |
| Issue date: | 11/02/1981 |
| From: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| 67-3021, NUDOCS 8111060619 | |
| Download: ML20032C021 (2) | |
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-_ nammm-e m m w unnn uove" ~ ~ ~ ~,uan=nwamwaw=vwan GENERAL ATOMIC COMPANY P.O. BOX 81608 In Reply h"3Is'3 s" Nerenber 2, 1931 Refer To: 67-3021 0
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Mr. Janos R. Miller, Chief
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Standardization and Special Projects Branch md ", i Division of Licensing Nuclear Regulatory Connission v
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Subject:
Mark F Reactor Docket 50-163: License R167;_
or Delay of Emergency Plan Submittal.
Gentlenen:
General Atomic Company has been requested to suhiit a revised energency plan pursuant to a final NRC regulation published August 19, 1980 on energency planning and preparedness.
We have also been requested to updatc our energency plans to include certain 10 CFR 50 Appendix E requirenents for our licensed fuel fabrication facili-ties within which our research reactors are 1ccated. These plans are t.s be reflected in our recently submitted SNM-696 renewal application and the Radiological Contingency Plan subnitted October 13, 1981 for our facility.
General Atonic has for sometire had approved energency plans which we be-lieve substantially meet the 10 CFR 50 Appendix E requircrents appropriate to a fuel fabrication and a non-test research reactor facility.
In various meetings with the staff we have pointed out the inappropriateness of many of the aspects of Appendix E which establishes a nyriad of details (e.g.
classification of emergencies, establishnent of EPZs, public notifications and drills, etc.), nostly appropriate to power reactors and larger test re-actors. We have repeatedly requested that vore appropriate requirenents and guidance ha developed for research and training reactors and uraniun fuel fabrication facilities.
Ue covtinue to believe that 10 CFR 50, Appendix E, IV, as written is,ri-mauy for power reactors and that it is largely inapprcpriate for facil-ities with much, much less potential hazard. Uhile new guidance has been discussed, none has been received to date for the subject or sirilar facil-ities.
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Mr. James R. Miller 67-3021 We request approval for a delay in the submittal of a new Emergency Plan for the TRIGA Mark F reactor. We agree to submit an appropriate Emergency Plan within a reasonable period of time after we receive specific guidance more appropriate to the types of accidents that may be experienced in the subject facility.
Very truly yours, h
William R. Howry Licensing Administrato Nuclear Materials Control Division URM:hr.s 4
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