IR 05000160/1988003

Insp Rept 50-160/88-03 on 880908-09.Violations Noted.Major Areas Inspected:Operational Readiness of Emergency Preparedness Program & to Determine If Key Personnel Assigned to Emergency Organization Trained

ML20205J467
Person / Time
Site:	Neely Research Reactor
Issue date:	10/14/1988
From:	Decker T, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205J408	List: IR 05000160/1988003 ML20205J404 ML20205J443
References
50-160-88-03, 50-160-88-3, NUDOCS 8810310404
Download: ML20205J467 (8)

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p OA*u e O' t% UNITED STATES 3* E NUCLEAR REGULATORY COMMISSION

~E REGION 11 jM 101 MARIFTTA ST., ATLANTA, GEORGIA 30323

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OCT 1919 Report No.: 50-160/88-03 Licensee: Georgia Institute of Technology 225 North Avenue Atlanta, GA 30332 Docket No.: 50-160 License No.: C-97

- Facility Name: Georgia Institute of Technology Neely Nuclear Research Center Inspection Conducted: September 8-9, 1988 Inspector: O, A. Gooden e+ b /d - /f- 88 Date Signed Accompanying Personnel: W. Sartor Approved by:[rt b mO T. Decker, Secition UbigV'

/O-/V -68 Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, announced inspection was to assess the operational readiness of the Neely Nuclear Research Center emergency preparedness program, and to determine if key personnel assigned to the emergency organization were trained and prepared to respond to emergencies at the research reacto Results: Within the areas inspected, one violation was identified for failure to provide training to a member of the emergency organization in

! accordance with the Emergency Plan (Paragraph 4). There were no programatic problems identifie However, a major weakness was noted in the licensee's procedural development and fonnalization progra The licensee agreed to conduct a comprehensive review of the Emergency Plan Implementing Procedures (EPIPs) to ensure that the EPIPs provide implementing details in accordance with the Emergency Plan requirement O

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REPORT DETAILS

, Licensee Employees Contacted'

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W. Downs, Reactor Operator-B. Kahn, Radiation Safety Officer  ;

1. R. Karam, Director, Neely Nuclear Research Center -

L. McDowell, Reactor Operator Supervisor

• B. Revsin, Manager, Office of Radiation Safety

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Other ' licensee employees contacted included technicians, and office personne Nuclear Regulatory Commission  ;

1. T. Decker -

'#D. Verrelli c

• Attended exit interview

1. Participated in conference call on October 7, 1988 Licensee Action On Previous Enforcement Matters

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(Closed) Deviation (50-160/87-04-01): The licensee committed to I

developing within 6 months of the response (dated January 22,1986),to  :

j Inspection Report No. 50-160/85-04, a procedure for describing notification method Fifteen months later, the procedure had not been develope The

inspector reviewed the licensee's response to the Notice of Deviation

, (dated May 26, 1987), and noted that actions to develop a procedure had ,

l been taken in accordance with the response. Although a notification .

i procedure had been developed, the inspector noted that the procedure as

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written was inadequate. Under the event classification, no definitive ,

time period was given for making the offsite notification Ambiguous ,

terms such as immediately, after assessment has been made, or if needed p were used. The licensee agreed to revise the procedure by March 1, 1989 to include the specific time period af ter the event declaration for making

the offsite notification i d

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Inspector Folinwup Item (50-160/88-03-01): Revise the notification procedure to include the specific time period after the event declaration ,

for making offsite notificatinn i Emergency Response Drill (32745)

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, The licensee's Emergency Plan requires that annual onsite emergency drills j i be conducted to test the adequacy of emergency procedures and to ensure l

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that emergency organization personnel are familiar with their duties. In i j addition, at least biennially, drills must contain provisions for j l

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coordination with offsite emergency personnel for testing comunications and notification procedures with offsite support group On September 6,1988, the ' :ensee conducted the annual emergency dril The scenario involved a i ;onse to a storage facility fire with the potential for radioactive material being involved. A staff member was simulated as being injured, overcome by smoke, and requiring imediate medical attention. The inspector observed the response by onsite emergency response personnel (Health Physics and Security) and offsite support personnel (fire and medical) in performing rescue and fire fighting functions. Personnel accountability was conducted immediately after building evacuation at the designated assembly area. An inspector observed the 6ctivation and limited operation of the Emergency Command Center (cCC). An inspector also observed the response to the simulated fire and injured victim. All emergency response personnel were prompt in responding to the simulated emergency. Periodically, licensee personnel contamination survey techniques were not in accordance with good practic The rate at which frisking was conducted was too fast for detecting the presence of contaminatio This unacceptable technique of surveying may be attributed to the artificiality of the dril However, the licensee was informed that the corrective actions would be tracked as an inspector followup item (IFI).

IFl (50-160/88-03-02): Improve drillsmanship regarding frisking techniqu The inspector noted that following the termination of the onsite portion of the drill, a critique to identify weaknesses in the response program was not conducted with players, observers, and controllers. A licensee contact stated that imediately after the drill was terminated, comments were obtained from all onsite players and observers, and the observers for the offsite groups. However, coments from the offsite players (fire and ambulance personnel) would be provided later. The inspector discussed the benefits of holding a critique involving all players, controllers, and observers immediately after the drill to avoid the possible loss of ideas and/or items for program improvement. The licensee was informed that this matter was considered an IFl. The licensee agreed to hold such critiques in the futur IFl (50-160/88-03-03): Conduct post-drill critique with all players, controllers, and observers imediately af ter drill is termit.ate The inspector noted the following items for consideration by the licensee for improvement:

Enhance communications capability (between the Emergency Director and incident scene) by locating Georgia Tech Police with two-way radios at the location of the incident and the EC *

Consider conducting a drill with a scenario developed by a non-drill participan .. _ - . _ - - -

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As a training ' tool, consider using an individual designated as an Alternate Emergency Director in the role Emergency Director during a future dril No violations or deviations were identifie ~ Emergency Organization (82745) l

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Pursuant to 10 CFR Part 50, Appendix E, Sections IV.A and IV.F. this area i was inspected to determine if the licensee had defined the key functional

areas of the onsite and offsite emergency organization; and assigned trained personnel to all functional areas of the onsite organization. The inspector reviewed Section 3.0 of the Emergency Plan for a description of

, the emergency organizatio In addition, personnel interviews were conducted with individuals assigned to the emergency organization. Based on the review and interviews, the inspector determined that the licensee i had defined the key functional areas for the onsite emergency t organization, and that personnel assigned to these key functional areas f were aware of their responsibilities and authorities during an emergenc i

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An emergency organization chart was available which depicted the various  ;

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onsite and offsite interfaces. The inspector noted that the organization '

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chart had not been updated to reflect recent personnel changes in the area of onsite Health Physics (effective August 1988). This matter was resolved by the licensee shortly after identification. Training records for personnel assigned as the Emergency Director (including the line of succession as discussed in the Emergency Plan) were reviewed. With one ,

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exception, all personnel designated as Emergency Director had received training on the Emergency Plan and Emergency Plan Implementing Procedure The one exception involved a person assigned as the Radiological Safety Officer (RS0). Sections 3.1.1 and 3.1.5 of the licensee's Emergency Plan identified the RS0 as an Alternate Emergency Director. However, no ,

documentation was available to show that training had been attended by the I

person currently assigned as RSO. Further, the RSO when interviewed by the inspector, acknowledged that the aforementioned training had not been  ;

attended and that the interviewee was not aware of his role and/or responsibilities as the Alternate Emergency Director. The licensee was  ;

l informed that failure to provide training to personnel in accordance with l the Emergency Plan is a violatio !

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Violation (50-160/88-03-04)

Failure to provide emergency response l

training in accordance with Section 10.1 of the Emergency Pla l

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In addition to reviewing training for the Emargency Directors, the '

inspector reviewed training for other components of the emergency t organization (Georgia Tech Police, Atlanta Fire Department, and offsite  !

meoical support). According to Section 10.1 of the licensee's Plan, the t

aforementioned groups are trained in radiation safety and Neely Nuclear i Research Center (NNRC) emergency procedure Although the Plan contains ,

l no required frequency for this training, Georgia Tech Police personnel i j received training in calendar years 1987 and 1988. However, the last  ;

i formal classroom training for the offsite support groups was conducted j

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during June and July of 1986, and attended only by the Atlanta Fire Departmen The licensee acknowledged the absence of hospital personnel attendance at training on radiation safety because of the hospital's own established program. The inspector informed the licensee representative that possible personnel turnovers within the Atlanta Fire Department could necessitate more frequent training than biennial training. The licensee was informed that this matter would be tracked as an IF IFI (50-160/88-03-05): More frequent formalizco classroom training in radiation safety and NNRC emergency procedures to Atlanta Fire Department personne The inspector discussed with a licensee representative the absence of a formalized procedure addressing training. Training documentation did not always include a course outline or lesson plans. In fact, no Emergency Director training included a course outline or lesson plans. The licensee did not indicate a willingness to commit to formalizing the training procedure to include a course outline or lesson plans. Irrespective of its formalization, the licensee does appear to maintain an emergency training and retraining program for personnel assigned to the emergency organizatio Walk-throughs were conducted with selected members of the emergency organizatio With one exception (as noted above), all personnel interviewed were familiar with their roles and responsibilit Interviewees were prompt in analyzing the hypothesized accident scenario for event classificatio Personnel appeared to be knowledgeable on the Emergency Plan and Plan Impicmenting Procedure No problems were noted during the walk-through One violation was identifie . Emergency Plan and Implementing Procedures (82745)

This area was reviewed to determine whether changes were made to the program since the last inspection (April 1987), and to assess the impact of these changes on the overall state of emergency preparedness. The inspector reviewed Section 10.4 of the Emergency Plan which described the program for review, update, and distribution of revisions to the Plan and Implementing Procedure According to licensee documentation, on April 6,1988, a request was made to the Nuclear Safeguards Committee to conduct a review of changes incorporated as Revision No. 2. At the time of the inspection, Revision 2 had not been approved by the Nuclear Safeguards Committee. The licensee contact indicated that the only change was administrative (involving organizational change) and was dete rmined not to decrease the effectiveness of the Plan. Section 10.4 of the licensee's Emergency Plan assigns responsibility for a biennial review of the Emergency Plan to the Nuclear Safeguards Committee; further, Section 10.4 states that applicable portions of the Plan, agreements, and Implementing Procedures shall be

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distributed to authorized agencies and support organizations; and any revisions to implementing procedures affected by the Plan shall be '

approved and sent to authorized recipients within 30 days after approva However, no formalized procedure governing the review, update, and revision to Plan and procedures exist. A controlled document distribution list was maintained by the licensee; but licensee personnel did not transmit changes via a cover memo with an acknowledgement slip to serve as an accountability check on transmittals to copy holders. The inspector discussed with the licensee procedural upgrades to ensure adeq"ate implementation of Section 10.4 of the Emergency Plan. The lice <see acknowledged that the current procedure for distributing changes to the Plan and Procedures should be revised to include a transmittal and/or acknowledgement sheet to serve as a verification for document transmitta The licensee was informed that this matter would be tracked as an IF IFI(50-160/88-03-06): Revision of the procedure for distributing changes to the Emergency Plan and Implementing Procedures to include a transmittal and/or acknowledgement sheet for accountability purpose The inspector noted during procedural reviews, that in most cases, current procedures do not appear to provide Emergency Plan implementing detail For example, a formalized procedure detailing the Emergency Plan training and retraining program for each category of emergency personnel did not exist. A class attendance roster was provided to the inspector for review i with no supporting details regarding the subjects discussed, training objective, evaluation criteria, et As stated in paragraph 2, the notification implementing procedure contains ambiguous terms regarding the time requirement for cffsite notifications following the event declaratio Additionally, as stated above, a formalized written procedure governing the distribution of changes to the Plan and Procedures do not exis The licensee contact stated that a procedural upgrade program had been initiated to bring about consistency in format among the emergency procedures Health Physics Procedures, and the Operations Procedures. The licensee agreed to conduct a comprehensive review of the Emergency Plan Implementing Procedures to ensure that the EPIPs provide implementing details in accordance with the Emergency Plan requirement The inspector informed the licensee contact that the procedural upgrade '

program would be tracked as an IF IFl (50-160/88-03-07): Upgrade of Emergency Plan Implementing Procedure No violations or deviations were identifie . Emergency Equipment and Supplies (82745)

The licensee had designated two kits for emergency use. One kit, located in the Control Room, contained primarily protective clothing, decontamination supplies, barrier ropes, etc. A second kit, located in the ECC, contained hand-held survey instruments, protective clothing,

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sampling material, dosimetry, etc. In addition, two air packs were available in the ECC. The inspector examined the two instruments stored

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inside the ECC emergency kit and noted that both instruments were within calibration and had a successful battery chec Additional survey equipment was available from the Radiological Safety Offic The inspector selectively examined calibration records for identical instruments as stored in the ECC emergency kit. No problems were note The inspector noted documentation for kit inventories conducted during September 198 The referenced inventory was in accordance with Section 10.5.1 of the Emergency Plan. The inspector discussed with a ,

licensee representative facility and/or equipment changes since the last inspection. The inspector was informed that communication improvements had been made since the last inspection via the installation of a telephone operated Public Address System, and a telephone was installed in the storage facilit No violations or deviations were identifie . Action On Previous Inspection Findings (92701) (Closed) IFl 50-160/85-04-02: Updcting and documenting notification roster The inspector reviewed documentation covering the period June 1987 through July 1988, and noted that quarterly updates and verification of the notification roster had been performe (Closed) IFI 50-160/85-04-10: Ensuring tracking of personnel doses in an emergency. The inspector reviewed an Emergency Procedure Part IX "Procedure for Personnel Monitoring." This procedure appears to be adequate for conducting accountability and personnel contamination surveys at the assembly area. However, this procedure did not include the special issuance of personnel dosimetry devices (TLD chips and self-reading dosimeters) for emergency personnel to ensure control of emergency personnel exposure in accordance with limits in Section 7.2 of the Emergency Plan. The licensee was informed that this matter will be revisited during a future inspection as part of the procedural upgrade review (see Paragraph 5, IFI 50-160/88-03-07). (Closed) IFI 50-160/85-04-16: Develop document control and distribution system for Plan and implementing Procedures. The

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inspector noted that a controlled document distribution list had been developed by the licensee, and that the Plan and Procedures contained revision dates. However, the licensee's system for distribution did not include a system of verification that copy holders received '

document change As discussed in Paragraph 5 (see IFl 50-160/88-03-06), this item will be reviewed during a subsequent inspection, 8. Exit Interview -

The inspection scope and results were summarized on September 9,1988, with the Manager, Office of Radiation Safety. Prior to the aforementioned

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meeting, a debriefing was held with the Director of the Neely Nuclear Research Center to discuss the scope of the inspection and the findings listed below. The Director of the Research Center advised that the violation involving training occurred as a result of personnel changes that were made during the Calendar Year 1988 (in the Office of Radiation Safety). Prior to organizational changes, the person filling the Radiation Safety Officer's Position was trained and designated in the Emergency Plan as an alternate to the Emergency Director. Following the organizational change, an administrative oversight occurred in that one of the following actions were not initiated: 1) Immediately provide emergency training to the newly assigned RSO in accordance with the Emergency Plan; or 2) Revise the Emergency Plan to delete the RSO as an Alternate Emergency Directo The Director further stated that, the Plan is being revised to delete the responsibility for the RSO to serve as an alternate Emergency Directo On October 7,1988, the licensee was contacted telephonically to obtain a committal date for completing the review and revision to EPIPs (Paragraphs 2 and 5).

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector, item Number Description 50-160/88-03-01 IFI-Revise the notification procedure to include the specific time period after the event declaration for making the offsite n0tifications (Paragraph 2).

50-160/88-03-02 IFI - Improve drillsmanship regarding frisking technique (Paragraph 3).

50-160/88-03-03 IFI - Co Auct Post-drill critique with all players, coatrollers, and observers immediately after the drill is terminated (Paragraph 3).

50-160/88-03-04 Violation - Failure to provide emergency response training in accordance with Section 10.1 of the Emergency Plan (Paragraph 4).

50-160/88-03-05 IFI - Conduct more frequent formalized classroom training in radiation safety and NNRC emergency procedures to the Atlanta Fire Department personnel (Paragraph 4).

50-160/88-03-06 IFl - Revise the procedure for distributing changes to the Emergency Plan and Implementing Procedures to include a

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transmittal and/or acknowledgement sheet for accountability purposes (Paragraph 5).

50-160/88-03-07 IFI - Verify that the procedural upgrade program includes revised Emergency Plan Implementing Procedures to adequately implement the Emergency Plan (Paragraph 5).

Licensee representatives were informed that open items discussed in Paragraphs 2 and 7, although considered closed, will be revisited during a future inspectio _

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