ML20033B749
| ML20033B749 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/09/1981 |
| From: | GILBERT/COMMONWEALTH, INC. (FORMERLY GILBERT ASSOCIAT |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| Shared Package | |
| ML16341B739 | List:
|
| References | |
| CON-044549-000, CON-44549 B-208-176, NUDOCS 8112010771 | |
| Download: ML20033B749 (1) | |
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Docket No. 40-3392 oV V
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, nmu ATTN: Mr. A. J. Cipolla u,,,,,C#"'8 7l E
Metropolis, Illinois 62960 s
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Dear Mr. Cipolla:
We have completed our pre-acceptance review of the radiological contingency plan that you submitted on June 9,1981. Our review has revealed several deficiencies in content and format in the infomation submitted. Those are described in the enclosure.
You are requested to send us additional infonnation concerning these matters by November 28, 1981. Please submit the indicated infomation as properly numbered replacement cr additional pages suitable for in-sortion into your plan. The infomation should be prepared in accordance with the " Standard Format and Content for Radiological Contingency Plans for Fuel Cycle and Materials Facilities", which was enclosed with our February 11, 1981 Order.
Sincerely, if%ned) R. G. Page R. G. Page, Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMS$
Enclosure:
As stated DISTRIBUTION:
Docket 40-3392-RG Page
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P. O. Box 430
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ATTN: Mr. A. J. Cipolla
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Metropolis, Illinois 62960
Dear Mr. Cipolla:
We have completed our pre-acceptance review of the radiological contingency plan that you submitted on June 9,1981. Our review has revealed several deficiencies in content and format in the infomation submitted. Those are described in'the enclosure.
You are requested to. send us additional information concerning these matters by November 28, 1981. Please submit the indicated infomation as properly numbered replacement or additional pages suitable for in-scrtion into your plan. NThe information should be prepared in accordance with the " Standard Format and Content for Radiological Contingency Plans for Fcel Cycle and Materials Facilities", which was enclosed with our February 11, 1981 Order.
xSincerely, R. G. Page Chief Uranium Fuel 1.icensing Branch Division ofs Fuel Cycle and Material Safety, HMSS
Enclosure:
As stated s
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Staff Comments From Pre-Acceptance Review of Allied Chemical (Metropolis Works)
' Radiological Contingency Plan Submittal Section 1.2
- ^..; c A more thorough description of the distillation and cylinder filling process is needed.
Include information concerning the means used to assure that containment and protective systems are functioning as in-tended.
Information on alarms, if any, provided on waste confinement and effluent control systems to detect releases should be presented.
Shut-off systems to limit releases in the event.of an accident should be included.
Sections 2.1.1-2.1.2 These sections should describe effective means for assuring that an inadvertent release of radioactive material will be rapidly detected, alarms sounded and appropriate measures taken to prevent further releases.
Casual observations by operating personnel could very well not provide for detection of a release until after considerabic process material has escaped from the building. Describe the frequency and extent of inspections by process operators and demonstrate their adequacy as a primary control measure.
This section should also discuss engineered provisions to detect, contain and end an accidental release of HF which could adversely affect the safety of licensed operations and the associated control of radioactive materials.
Section 2.1.4 The infonnation in this section is inadequate in that it does not specify goals for assuring continued proper performance of plant engineered systems important to safety through monitoring, auditing, and appropriate maintenance operations.
Performance goals should be specified for plant engineered systems important to safety.
Section 2.2 All of Section 2.2 is too general in describing the engineered provisions for abnormal operations.
Especially, in Section 2.2, the engineered systems that limit release of radioactive material following an abnormal occurrence -
should be addressed and Section 2.2.3 should be expanded to include more detail on inspection and maintenance procedures used for maintaining plant support systems.
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Section 3.1
- o The discussion of "UF6 Release Control Procedure" in Section 3.1 and Appendix A does not indicate whether or not there are automatic mechanisms for shutting down leaking equipment. More detailed discussion is needed on leak prevention, leak detection and equipment shutdorm procedures and mechanisms Section 3.2 The staff position maintains that each plan must contain at least the four categories of the classification scheme described in the Standard Format.
It is recommended that the numerical classification be deleted and the first class changed to read " Notification of Unusual Event."
For the " Site Area Emergency" classification, tha NRC, as well as state and local agencies, should be notified in the event of an uncontrolled UF6 release which is large enough to be visible outside the building.
Notification procedures should include identification by title of individuals who have the responsibility for making the notification as well as indication of how soon after the detection of an incident the notification will be made.
Reliance solely on visual observation of UF6 hydrolysis products at the site boundary for requiring notification of nearby residents is inadequate.
Discuss means for detection during night time and other times of low visibility.
The discussion of accident consequences does not have sufficient supporting information to allow an independent analysis of the accident scenarios.
The presentation should include models, aisumptions and other information sufficient for an independent review.
For the entire chapter, numerical class designations should be changed to reflect the categories of Chapter 3.
Section 4.3 This section should prescnt letters of agreement describing the arrangements reached with each support group offering off-site assistance to the facility.
Section 4.4 Reporting procedures to state and local agencies should be expanded to include accidents classified as Site Area Emergencies.
Section 5 For the chapter, numerical class designations should be changed to reflect the changed categories of Chapter 3.
Section 6 Comment same as for Chapter 5.
Section 7 Comment same as for Chapter 5.
sf Section 8
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Comment same as for Chapter 5.
' Section 9 Coninent same as for Chapter 5.
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