IR 05000223/1988005

Insp Rept 50-223/88-05 on 880829.No Violations Noted. Major Areas Inspected:Emergency Preparedness

ML20205P592
Person / Time
Site:	University of Lowell
Issue date:	10/29/1988
From:	Amato C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205P584	List: IR 05000223/1988005 ML20205P581
References
50-223-88-05, 50-223-88-5, NUDOCS 8811080230
Download: ML20205P592 (5)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-05 Docket N License No. R-125 Licensee: University of Lowell 1 University Avenue Lowell, Massachutetts 01854 Facility Name: The University of Lowell Nuclear Reactor Facility Inspection Conducted: August 29, 1988 Inspector: _O dc6 #/yy C. G. Amato, mergency Preparedness date '

Specialist, PS, FRSSB, DRSS

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Approved By: ,

. [ft< <f/u W. J/).ararW Chief. Emergency h [d'

date PreffrednessSection,FRSSB,DRSS Inspection Summary: Inspection on August 29,1988(ReportNo. 50-223/88-05)

Areas Inspected: Routine, announced, safety inspection in the area of emergency preparednes Results: No violations were identifie POR ADOCK 05000223 O FDC

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DETAILS 1.0 Persons Contacte The following personnel attended the exit meetin L. Beghian, Ph.0, Associate Vice President for Research  ;

W. Church, Radiation Safety Officer K. Skrable, Ph.D Chairman, Radiation Safety Committee

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The inspector also observed the actions of, and interviewed, other licensee ,

personne j 2.0 Follow-up on Previous Inspection Findings P

(CLOSED) (50-223/88-03-06) Notice of Violation. The licensee failed to i conduct periodic surveillance of emergency equipment in accordance with Emergency Plan requirements. A check of current surveillance records indicates the licensee has resumed this surveillance and is maintaining records in accoid with plan requirement '

3.0 Organization 3.1 To determine if an Emergency Response Organization (ERO) staff has '

been established and each member assigned clearly defined functions and responsibilities, the operating and ERO Tables of Organization were reviewe .2 The Lowell University Nuclear Reactor Facility (NRF) is a component of the Lowell Radiation Laboratory (LRL), the staff of which includes the reactor staff. These staffs provide the members of the ERO. This organization also includes other campus and off-site entitie Section 3.0 of the Lowell Emergency Preparedness Plan describes the ERO, defines positions and assigns responsibilities. An ERO Table of ;

Organization and a schematic showing the interrelationship among ERO i components are included in this section of the Plan which also '

includes off campus organization Based on this review, this area of the licensee's program is acceptabl .0 Emergency Classification System Emergency _ Response and Protective Action 4.1 The plan was reviewed to determine the extent and adequacy of the Emergency Classification System. In addition, provisions for medical support and alerting of the ERO were also reviewe .

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4.2 Section 4.0 of the plan describes the Emergency Classification System which is based on a conclusion stated in the NRC Safety Evaluation Report (NUREG-1139) that 10 CFR 20 limits would not be exceeded following the largest core damage and experiment failure. Therefore, only two Emergency Action Levels (EALs) have been established. They are the Unusual Event (UE) and Alert. Table I of the Plan lists these with associated events and symptoms, while Table II expands on these and shows specific corrective actions and steps to be taken to ensure requirements are met. The EAls cover the spectrum of credible accidents, consist of mutually exclusive groupings, and are associated with immediate actions to be taken to cope with the situation. Provisions for alerting the ERO and for decontamination, medical support and transport are spelled out. Emergency dose limits are also specified. Section 7.0 of the emergency plan provides material amplifying these provistors, including assessment, corrective and protective actions. Table 7-1 delineates actions associated with each EAL and outlines support expected from other on-campus and off-campus entities, such as hospitals and the fire departmen Based on the above review, this portion of the licensee's plan is acceptabl .0 Emergency Response Facilities (ERFs)

5.1 The Control Room (CR), Emergency Support Center (ESC), emergency equipment storage room, and decontamination facility were inspected to determine if plans and procedures were in place and current, equipment was functional and within the required calibration period, and facilities were functiona .2 Plans and procedures in the CR were in place and functional, as was emergency equipment, which was also within the specified calibration period. The operators present were well trained in their use. Plans and procedures in the ESC were also in place and current. Phones were functional and adequate space is provided in this non-dedicated facility (Room 107 of the pinanski Building) for the intended functio .3 The emergency equipment storage room is Room 106 of the Pinanski Building and was not identified as such. This room, which is supposed to be dedicated to the storage of emergency equipment, contained both emergency and non emergency equipment. An inventory of emergency equipment was not posted. A compressed gas cylinder was found free standing. One air sampler was apparently missing. Face pieces were uncovered. Storage of equipment was in a state of disarray. Currency of flow calibration for air samplers could not be determined. Iodine air sampling media is CESCO 8 organic cartridge The acceptability and collection efficiency of these for the intended use coulu not be determined. Location of the keys for this facility was not eviden When these conditions were called to the attention of the licensee's staff, the licensee agreed to take prompt corrective acticn. This matter is unresolved (50-223/88-05-01).

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5.4 The decontamination facility is not identified as such. Although the facility was functional, several limitations were identified. Access was impeded by storage of miscellaneous items. The facility is a single, large shower stal) with three shower heads, with no provision for sexual segregation of decontaminees. The licensee agreed to clear the facility of the stored items and install at least one, opaque, wrap around, floor to ceiling shower curtain. This will be reviewed in a subsequent inspectio .5 The emergency phone list in the CR was undated and did not list all key emergency phone numbers. When this was called to the licensee's attention, the licensee agreed to update the list quarterly, date it, add key off-campus numbers, including place it within a transparent folder, wall mount them in the CR and ESC and distribute copies to key ERO personnel and the' Campus Police Dispatcher's offic This matter is unresolved (50-223/88-05-02).

Based on the above findings and with the exception of the unresolved items, this portion of the licensee's plan is acceptabl .0 Maintaining Emergency Preparedness 6.1 To ascertain how, and to what degree the licensee maintains the program, the training records were reviewed and operators were given scenario question .2 The plan provides for both on-campus and off-campus initial qualification of ERO personnel and biennial requalification. On site drills are conducted annually; drills with off-campus entities are conducted every two years. A check of drill records indicated they have been held. Operator response was satisf actor .3 A check of training records indicated that training documentation is not adequate, a fact also noted by the Reactor Safety Committee when they reviewed emergency preparedness activities. The training program does not provide for donning respiratory equipment, nor the use of face pieces and canisters. This matter is unresolved (50-223/83-05-03).

Based on the above, this portion of the licensee's program is acceptable with the exception of the unresolved item, 7.0 Review of the Ep 7.1 The EP and licensee records were checked to determine if EP reviews are specified, and if so, are they don _ _ _ _ _ _ _ _ _ _ - _ _ _

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7.2 The inspector verified EP reviews are conducted every two years as required by Section 10.4 of the E Based on the above, this portion of the licensee's program is acceptabl .0 Recovery 8.1 The EP was reviewed to determine if provisions for recovery are mad .2 Section 9.0 of the EP, which is not listed in the index, specifies that recovery actions shall be undertaken. Responsibility for this is assigne Based on the above, this portion of the licensee's program is acceptabl .0 Appendicies 9.1 The plan appendicies were checked to ascertain if they meet the requirements of Annex C to U. S. NRC Regulatory Guide .2 A check of the appendicies indicates the required material is present. However, Letters of Agreement (LOAs) have not been recently updated. The licensee, when advised of this fact, agreed to undertake immediate updating. Currency of LOAs will be reviewed in a subsequent inspection.

4 Based on the above, but with the exception of the LOAS, this portion of the licensee's program is acceptabl .1 Exit Meeting l

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The inspector met with licensee personnel listed in Section 1 at the

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conclusion of the inspection. The licensee was informed no violations

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were identified. The inspector also discussed some areas for improvement.

j The licensee acknowledged these findings, agreed to evaluate them, and institute corrective action as appropriate. At no time during the course of the inspection did the inspector give the licensee written materia ;

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