IR 05000160/1993003
| ML20058P631 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 12/01/1993 |
| From: | Barr K, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P627 | List: |
| References | |
| 50-160-93-03, 50-160-93-3, NUDOCS 9312270208 | |
| Download: ML20058P631 (10) | |
Text
l UNITED STATES
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NUCLEAR REGULATORY COMMISSION l
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E 101 MAR!ETTA STREET, N.W., SUITE 2930 p
ATLANTA, GEORGIA 3032341199 7.
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Report No.:
50-160/93-03 Licensee: Georgia Institute of Technology 225 North Avenue Atlanta, GA 30332
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Docket No.:
50-160 License No.
R-97 Facility Name: Neely Nuclear Research Center
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Inspection Conducted: N vember 2-5, 1993
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Inspector:
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/ Z-o/- 73 A. Gooden Date Signed Accompanying Pery,ryne :
J. Kreh 2-/!f3 Approved By:
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K. BcrP M hieT~
Date Signed Emerger cy Preparedness Section Radiolagical Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection involved a review of the operational readiness status of the licensee's emergency preparedness program, and evaluation of the licensee's annual emergency response drill.
Program readiness areas reviewed included: emergency response training; maintenance of emergency cabinets / equipment; and distribution of changes to the notification roster.
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Results:
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Within the areas reviewed, a non-cited violation was identified for failure to
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perform periodic testing of the criticality alarm system in accordance with procedure (Paragraph 3). No deviations or exercise weaknesses were identifi.a The licensee appeared to be maintaining an adequate level of operatianal readiness for responding to emergencies.
The exercise was considered minimally successful, because the scenario-lacked details to ensure
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a realistic and challenging event, for an effective test of the Emergency Plan
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(Paragraph 5). The response by campus police was timely and effective in the establishment of access control; accountability was completed in a timely manner; and the Emergency Director uomonstrated good command and control during the implementation of the Phn and procedures.
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9312270208 931202 PDR ADOCK 05000160
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REPORT DETAILS
1.
Persons Contacted Licensee Employees
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- R. Ice, Manager, Office of Radiation Safety
- E. Jawdeh, Health Physicist
- R. Karam, Director,. Neely Nuclear Research Center
- B. Statham, Manager, Reactor Operations
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J. Taylor, Health Physicist Other licensee employees contacted during this inspection included operators, campus police, and administrative personnel.
Nuclear Regulatory Commission y
- K. Barr, Chief, Emergency Preparedness Section i
- C. Bassett, Project Engineer, Region II
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- W. Cline, Chief, Radiological Protection and Emergency Preparedness Branch
- J. Kreh, Radiation Specialist, Region II
- M. Mendonca, Project Manager, NRC Headquarters
- Attended Exit Interview
- Participated in teleconference exit on November 8,1993 An index of abbreviations used throughout this report will be found in the last paragraph.
2.
Emergency Plan and Implementing Procedures (82745)
The review, approval, and distribution of Plan changes was. examined to determine whether significant changes were made since the last inspection (November 1992), to assess the impact of any program changes on the overall state of emergency preparedness at the facility, and determine if the Plan and procedures were revised to reflect those changes. Requirements applicable to this area are found in 10 CFR 50.54(q) and Section 10.4 of the Emergency Plan.
The inspector determined by both review and discussion with a licensee representative that no revisions were made to the Plan (Revision No. 2, approved by NRC.on June 8, 1989). According to_Section 10.4 of the Emergency Plan, "the Emergency Plan shall be reviewed biennially by the NSC to ensure that the Plan is adequate and up to date." A review of licensee documentation disclosed that the last' Plan review by the NSC was conducted during September 1991. The inspector was provided additional documentation which disclosed a recent distribution (September 23,1993) to NSC members requesting review and comments / approval. According to the licensee contact, Plan changes reflecting the revised Part 20 requirements will be submitted to the NSC for review and approval prior to the January 1994 implementation dat a
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Since the November 1992 inspection, one emergency procedure was revised.
Procedure 6100, entitled " Emergency Notification," was revised to
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reflect enanges _ prompted by an NRC inspection' finding. The referenced change was reviewed by the inspector and determined to be consistent with the licensee's commitment _in response to the-inspection finding.
According to Section 8.5 of the Plan, a. quarterly update and verification is performed of the Emergency Notification Roster'(phone numbers and point of contacts). Documentation covering the period November 1992 to September 1993 disclosed that-the roster was reviewed.
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each quarter, and updated rosters transmitted-to various onsite (NNRC-bulletin board, ECC, etc.) and offsite, locations (e.g. AEMA,'GEMA, DNR).
With one exception, current rosters were found at each. location. The-one exception involved the roster reviewed in the GTPD procedure book.
The copy provided to the inspector for review was Rev. 31 dated June 18, 1993; however, according to the control distribution information, the current roster was Rev. 32, dated September 16, 1993. According to Notification Roster distribution documentation, the roster was distributed to the GTP during September 1993. The licensee was_ informed that periodic followup with various copy holders may be necessary to ensure that current information is available.
Regarding offsite support agreements, Section 8.3 of the Plan requires'
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agreement letters with offsite support agencies be updated on a biennial basis. The licensee currently maintains an agreement with Grady Memorial Hospital for medical emergencies involving radioactive materials. The referenced agreement was updated during September 1992.
No violations or deviations were identified.
3.
Emergency Facilities and Equipment (82745)
Facilities and equipment were inspected to_ determine whether the licensee's ECC, emergency response equipment, instrumentation, ' and supplies were maintained in a state of operational readiness, and to assess the impact of any changes on the emergency preparedness program.
Requirements applicable to this area are found in Section 10.5 of the Emergency Plan and various implementing procedures.
The licensee maintained two kits for emergency use. One kit, located in the vestibule of the Reactor Building, contained primarily. protective.
clothing, decontamination supplies, barrier ropes, etc. A second kit, located in the ECC, contained portable survey instruments, protective i
clothing, sampling material, dosimetry, etc. In addition, two air packs-
were available in the ECC. Selective examination of the emergency kit
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The inspector's review of. document 4 fen for the emergency.-kit inventory
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Additional records reviewed by-.the inspector included test documentation l
for CAS and the emergency power generator. With the. exception of CAS, l
equipment testing was performed at the required interval-in accordance i
with procedure, and equipment problems or discrepancies were corrected j
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in a timely and effective manner Regarding CAS testing, Section 3.0 of Procedure 0005 (Criticality Alarm Testing), requires monthly testing to ensure audibility of alarms and warning light indications. During the review of documentation covering the period October 1992 thru October 1993, the inspector noted that monthly test documentation was not available for May, June, and July 1993. As a result, the inspector
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interviewed a member of the licensee's staff with responsibility for the referenced testing, and confirmed that. tests were missed during the aforementioned period. Consequently, based on the interview and lack of documentation, the inspector informed the licensee that failure to perform the monthly test in accordance with Procedure 0005 was a violation of TS 6.4.b.(7): " Written procedures shall be provided and utilized for the surveillance and testing requirements." According to the licensee contact, the noted finding resulted from lack of management oversight in reviewing the status of work orders. The licensee's program maintenance activity was based on computer generated work orders-.
containing the date last done, date to be completed, and date actually completed. The work order status was tracked by administrative personnel assigned other functions. As corrective actions to prevent a. recurrence-of missed surveillances, the licensee modified the program maintenance activity to include the Manager Of Radiation Safety in reviewing the status of work orders.
In light of the aforementioned actions, this NRC identified violation is not bei g cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied. The licensee was informed that this finding was considered a NCV.
NCV 50-160/93-03-01: Failure to conduct monthly test of CAS in accordance with requirements of Procedure 0005.
As further assessment of the operational status of the program,. the inspector observed the following' equipment during a facility; tour:
criticality alarm indications at the ECC and GTPD, Reactor Building ARMS, Kanne Gas monitor, and other alarm indicators at the Control Room panel (e.g. ARMS, reactor tank level, fuel element temperature, etc.).
Based on meter face readings and light indications, the select 0d equipment appeared to be operational.
One NCV was identified.
4.
Emergency Response Training (82745)
Emergency response training was reviewed to determine if the licensee was providing training in accordance with the Emergency Plan.. The requirements for training are found in Section 10.1 of the Plan.
According to licensee training records, all personnel assigned to the Emergency Notification Roster were trained. The inspector interviewed the licensee representative with responsibility for emergency response training to review material discussed during the annual training sessions. The inspector was informed that one-hour sessions were conducted on three separate dates: October 4, 1993, October 6, 1993, and November 2, 1993. According to the documentation, the subject matter
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included a discussion of the Emergency Plan, a review of all current emergency procedures, and a review of the revised emergency procedures (6010-6100). When questioned by the inspector regarding lesson' plans or i
course outline, the licensee contact indicated that no lesson plans or i
outline were used. The inspector discussed with the licensee for consideration as an ' improvement item, the formalization of training i
presentation to include written lesson plans or training outlines.
Regarding emergency response support training, Section 10.1 of the Plan I
required biennial training in radiation safety and NNRC emergency i
I procedures for the GTP and AFD. According to training records, the AFD was provided training during September 1993, and GTP received training on October 14, 1993.
No violations or deviations were identified.
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Emergency Response Drill (82745)
i Section 10.2 of the licensee's Emergency Plan required that drills be conducted annually to test the adequacy of emergency procedures and to ensure that emergency organization personnel are familiar with their duties.
Further, the Emergency Plan required that at least biennially, drills contain provisions for coordination with offsite emergency
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organizations for testing communications and notification procedures i
with offsite support agencies.
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On November 4,1993, the licensee conducted the annual emergency drill.
This small-scale exercise was limited to the.onsite emergency organization (GTP and NNRC staff). The scenario details simulated two ARMS in an alarmed state. A Cobalt-60 source was located near-the i
detectors to increase the level of radioactivi.ty above the detectors
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setpoint level. This resulted in an audible local alarm and visual indication in the Control Room (approximately 2:18 p.m.). In response to i
the high radiation alarm, Control Room personnel implemented alarm response procedure (Procedure 2602), and notified the facility ED. In accordance with procedures, immediate notification was made to the campus police and a building evacuation announced..The GTP was notified
and promptly (2:23 p.m.) responded to establish access control to the NNRC. Accountability was completed within six minutes of the I
announcement to evacuate the facility.
The inspector observed good interface between the alternate ED, GTP, and HP personnel in the implementation of Plan and procedures. However, the.
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limited scope and scenario details did not provide conditions to fully test the adequacy of the Plan, procedures, and personnel training. The scenario and conduct of the exercise were considered minimally adequate j
in light of the following
l The scenario developer had anticipated that the event would be
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classified as a NOVE based on " Failure of an experiment with minor releases of radioactivity as determined by observing the levels on facility air monitors" (EAL 5.9.4 of Procedure 6100 and Emergency
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Plan Table I, Emergency Classification Guide). However, the Exercise Controller was not provided data to simulate stack readings or an incident involving the rabbit system failure.
Ineffective scenario development and planning, as evidenced by
the understanding of the scenario developer and controller regarding event classification.
In advance of the exercise, the inspector interviewed the aforementioned individuals regarding various scenario details (e.g. accident being postulated, event classification, exercise simulations, etc.). As previously.noted, the scenario developer anticipated a NOVE, whereas the controller anticipated the event would result in an Operational Event.
Adequacy of procedures (e.g. offsite communications) was not fully
tested in that the event classification (Operational Event) did not require offsite notifications. Offsite notifications are only required for NOVE and higher events.
Controller lacked understanding regarding role and responsibility
(prompting and interaction with players) in controlling the flow of the exercise. On occasion, the controller was_ observed discussing information (e.g. location of detectors, potential reasons for alarms, etc.) with the alternate O that would reveal future conditions. As a further example in this regard, the controller at 2:31 p.m. responded to the alternate ED request for air sampling by preparing an air sampler and delivering the sampler to HP personnel.
The licensee's self-critique included as a discussion item the
need for better defined scenarios and improvement in scenario development.
Based on the above observations, the inspector discussed in detail the adequacy of the scenario in meeting the intent of Section 10.2 of the Emergency Plan. The inspector discussed past exercises which resulted in event classifications of Operational Event rather than NOUE or higher requiring offsite coordination. Additionally, the use of realistic scenarios such as design basis accidents and the program benefits associated with the use of such scenarios were discussed by the inspector. The licensee was informed that the use of unrealistic, poorly developed, and unchallenging scenarios may result in an artificial state of preparedness. The use of credible accidents was discussed as an opportunity to provide a true test and evaluation of the ERO, Plan, and procedures. In response to the inspector's comments, members of the licensee's organization indicated that although past exercises resulted in merely an Operational Event, communications with offsite authorities were executed. The licensee expressed an intent to coordinate in advance of an exercise with offsite authorities by extending an opportunity to participate either in a tabletop or actual exercise involving an event classified at the Alert level or higher. Subsequent to the inspection, the licensee was informed that based on the additional details and discussion regarding past exercise notifications to offsite authorities
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(State, local, and NRC) and the intent of calendar year.1992 exercise to satisfy the biennial requirements in Section 10.2 of the Plan, no violation or exercise weakness will be issued for scenario inadequacy.
However, the licensee was encouraged to make improvements in the area of
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scenario development and exercise planning. The licensee committed to coordinate with the Georgia Department of Natural Resources, Environmental Protection Division, to participate in a tabletop drill or i
exercise involving an event classified at the Alert level. The licensee was informed that the coordination with offsite authorities regarding
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exercise planning would be tracked as an IFI for review during a subsequent inspection.
a IFI 50-160/93-03-02: Verify offsite authorities are contacted regarding
exercise participation.
No violations or deviations were identified.
6.
NRC Information Notices
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IN No. 92-38, " Implementation Date For The Revision To The EPA
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Manual Of Protective Action Guides And Protective Actions For.
Nuclear Incidents" r
The IN was received and reviewed by the licensee. According to the licensee contact, any Plan changes reflecting the revised EPA guidance would be submitted along with revised Part:20 i
l requirements to the NSC for review and approval prior to the January 1994 implementation date.
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IN No. 92-79, "Non-Power Reactor Emergency Event Response"
The licensee contact informed the inspector that the IN was i
received and reviewed by various staff, but no additional action was considered necessary.
7.
Action on Previous NRC Inspection Findings (92701)
a.
(Closed) IFI 50-160/91-04-05: Review.the notification procedure I
for NRC notification time limits to ensure consistency with 10 CFR 50.72.
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A review of Procedure 6100, " Emergency Notification" disclosed that all notification time limits for emergency declarations _had been standardized for one hour. This item is considered closed.
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(Closed) Violation 50-160/92-04-01:
Failure to have an adequate i
procedure-for implementing certain EPP notification requirements.
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Revision 5 to Procedure 6100 (Emergency Notification) required notifications be made to State and local emergency management agencies within one hour following the event declaration.
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(Closed) IFI 50-160/92-04-02: Consideration of the use of a drill controller.
An individual was assigned as controller to insure that the scenario stayed on track and the flow of scenario details was consistent with the postulated accident conditions. Therefore, the aspect of assigning a controller is considered closed. However, a new item was opened involving training for personnel assigned as controller. During the drill, the controller was observed providing equipment and/or decisional information to exercise participants (see Paragraph 5). When questioned regarding training or a controller briefing on the role and responsibility for a controller, the interviewee indicated no briefing or training was provided. This item was discussed with the licensee for followup as an IFI.
(0 pen) IFI 50-160/93-03-03: Review training for personnel assigned as drill controller.
8.
Exit Interview The inspection scope and results were summarized on November 5,.1993, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee. The inspector informed the licensee that the scenario used for the 1993 exercise was inadequate in that the scenario failed to include provisions for testing
Section 10.2 of the Plan involving offsite personnel (State and local).
i The inspector indicated that a preliminary review of this issue would H
l appear to result in a potential violation for failure to implement Section 10.2 of the Plan regarding the conduct of drills and exercises.
On November 8, 1993, discussions were held telephonically involving the licensee and NRC personnel identified in Paragraph 1. According to i
licensee representatives, the intent of the calendar year 1992 exercise scenario was to satisfy Plan requirements in Section 10.2 regarding a biennial drill containing provisions for offsite support groups. The
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licensee indicated that equipment failure (smoke generator) during the 1992 exercise resulted in a lower event classification (Operational j
Event) than the event which was intended (N0VE based on prolonged fire).
Licensee personnel assigned responsibility for offsite notifications-indicated that, irrespective of the event classification resulting in an Operational Event (no offsite notifications required), offsite
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notifications were made to State and local agencies. Based on the additional details and the licensee's commitment to coordinate with offsite authorities regarding exercise participation in advance of an exercise, a determination was made by Regional Management that a
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violation had not occurred. The Manager of Radiation Safety was contacted on November 10, 1993, and informed that based on the additional details and discussion regarding past exercise notifications to offsite authorities (State, local, and NRC) and the intent of
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calendar year 1992 exercise to satisfy the biennial requirements in-Section 10.2 of the Plan, no violation or exercise weakness will be issued for scenario adequacy. However, the licensee was encouraged to make improvements in the area of scenario development and exercise planning,
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Item Number Descriotion/ Reference 50-160/93-03-01 NCV - Failure to conduct monthly test of-
CAS in accordance with requirements in-
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Procedure 0005 (Paragraph 3).
50-160/93-03-02 IFI - Verify offsite authorities are contacted regarding exercise participation
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50-160/93-03-03 IFI - Review training for personnel assigned as drill controller (Paragraph 7).
The licensee was informed that three open items from previous inspections were reviewed and closed (Paragraph 7).
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Index of Abbreviations Used In This Report AEMA Atlanta Emergency Management Agency AFD Atlanta Fire Department ARMS Area Radiation Monitors CAS Criticality Alarm System
DNR Department of Natural Resources EAL Emergency Action Level u
ECC Emergency Command Center ED Emergency Director
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EPA Environmental Protection Agency j
EPP Emergency Plan Procedure i
ERO Emergency Response Organization i
GEMA Georgia Emergency Management Agency GTP Georgia Tech Police
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GTPD Georgia Tech Police Dispatcher l
HP Health Physics i
IFI Inspector Followup Item l
IN Information Notice
.l NCV Non-cited Violation NNRC Neely Nuclear Research Center
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NOUE Notification of Unusual Event j
NSC Nuclear Safeguards Committee Rev.
Revision l
TS Technical Specifications Attachment:
Scenario and Exercise Objectives a
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EMERGENCY DRILL 2:00 P.M.
November 4, 1993 Objective:
To demonstrate the following:
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Alternate Emergency Directors can handle emergency situations; (2)
That NNRC personnel are trained properly and can respond appropriately to emergency situations; (3)
That procedures are adequate; (4)
That procedures are followed; (5)
That emergency communications are appropriate; (6)
Emergency organization can restore emergency situation back to normal.-
Scope:
The Emergency Drill of 1993 is structured to. test how the emergency organization of the Neely Nuclear Research Center responds to unusual and unexplained events.
Scenario:
During reactor operation, two radiation ' area monitors, suddenly and for no reasons (known),
alarmed.- The response of the reactor operators and.
the emergency ' organization will be tested under this scenario.
Procedures 6010, 6020, 6090 and 6100 are activated.
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