ML20035E948
| ML20035E948 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 04/01/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035E947 | List: |
| References | |
| 50-128-93-01, 50-128-93-1, NUDOCS 9304200104 | |
| Download: ML20035E948 (9) | |
See also: IR 05000128/1993001
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Inspection Report:
50-128/93-01
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Operating License: R-83
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Licensee: Texas A&M University System
Texas Engineering Experiment Station
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301-WERC
College Station, Texas 77843
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Facility Name: Nuclear Science Center
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Inspection At: College Station, Texas
Inspection Conducted: March 15-16, 1993
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Inspectors:
L. T. Ricketson, P.E., Senior Radiation Specialist
Facilities Inspection Programs Section
T. W. Dexter, Senior Physical Security Specialist
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Facilities Inspection Programs Section
D. B. Spitzberg, Ph.D., Emergency Preparedness Analyst
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Facilities Inspection Programs Section
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10b # N k t f/A
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Approved:
B. Murra~y, Chibf, Facil'ities Inspection
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Programs Section f
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Inspection Summary
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Areas Inspected: Routine, announced inspection of emergency planning and
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preparedness, (security) plans, procedures and reviews, reports of safeguards
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events, fixed site protection of special nuclear material, and protection of
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safeguards information.
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Results:
Differences were noted between elements of the Emergency Plan and the
corresponding elements of the emergency implementing procedures
(Section1.1.1).
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Dedicated emergency kits had been maintained (Section 1.1.2).
An exercise weakness was identified regarding the failure to establish
radiological emergency classification action levels related to facility
parameters which could be promptly assessed (Section 1.1.3).
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9304200104 930409
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An exercise weakness was identified involving the lack of clear guidance
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for emergency notifications to the NRC (Section 1.1.3).
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Functional tests demonstrated that remate pool level and intrusion
emergency alarms were operable. However, the fire alarms were only
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received within the facility (Section 1.1.4).
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The licensee's staff had been trained in emergency preparedness and had
participated in exercises and drills (Section 1.1.5).
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The NRC-approved Physical Security Plan was adequately implemented and
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implementing procedures reflected current plan changes.
Licensee
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personnel were effectively complying with requirements (Section 2.1).
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The licensee was correctly reporting security events, and licensee
personnel were knowledgeable of reporting requirements (Section 3.1).
The security system was installed and operated as committed to in the
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Physical Security Plan. Alarm response personnel were properly trained,
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and testing of the system was ceing conducted as required (Section 4.1).
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Safeguards information was properly protected (Section 5.1).
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Summary of Inspection Findinos
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Emergency Preparedness Weakness 128/9301-01 was opened (Section 1.1.3).
Emergency Preparedness Weakness 128/9301-02 was opened (Section 1.1.3).
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Violation 128/9202-02 was closed (Section 6.1).
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Violation 128/9202-04 was closed (Section 6.2).
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Attachment:
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Attachment - Persons Contacted and Exit Meeting
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DETAILS
1 EMERGENCY PLANNING AND PREPAREDNESS (40750)
The inspectors reviewed emergency equipment and supplies, changes to the
emergency plan, and documentation related to emergency preparedness to
determine if the licensee's emergency preparedness program had been maintained
in a state of operational readiness. The inspectors met with licensee staff
and representatives of offsite response organizations to determine whether the
licensee's staff was trained and prepared to respond to emergency conditions
and understood the responsibilities of the offsite response organizations.
1.1 Discussion
1.1.1
Changes to the Emergency Plan and Implementing Procedures
The inspectors reviewed the emergency plan and determined that no changes had
been made to the plan since it became effective in November 1982. The
inspectors also reviewed the emergency implementing procedures contained in
Standard Operating Procedures IX, A through F dated February 1, 1985.
It was
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noted that several specific elements of the plan were in conflict with
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corresponding elements of the emergency implementing procedures.
For example,
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the offsite medical facility which would receive contaminated injury victims
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had changed from that reflected in the emergency plan.
Licensee
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representatives acknowledged that elements of the plan were out of date and
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were in need of revision. The representatives stated that a revision of the
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plan had been initiated but that no time frame for completing the revision had
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been set. The licensee had chosen not to exercise the provisions of
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10 CFR 50.54(q) which permit changes to the emergency plan without NRC
approval provided that the changes are determined not to decrease the
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effectiveness bf the emergency plan.
The inspectors reviewed the last audit of the emergency plan which was dated
September 17, 1992. This audit satisfied the audit requirements of the
technical specifications, but it did not idestify the need to make changes to
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the emergency plan as noted above to reflect current planning information.
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1.1.2
Facilities and Equipment
The inspectors toured the Nuclear Science Center and inspected equipment
maintained for emergency use. Four emergency kits had been maintained at
strategic locations which included monitoring equipment and contamination
control supplies,
These kits had been inventoried but were not sealed to
prevent tampering. Tte facility was equipped with a decontamination room
which appeared to be ull maintained. The inspectors noted that both portable
air samplers kept in the facility had not been calibrated in years.
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addition, no procedures had been written for their use. The inspectors were
informed that calibrated air sampling equipment was available from the
university's radiation safety office located on the main campus.
Fire
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extinguishers were located throughout the facility. While the extinguishers
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had been inspected at regular intervals, the seal on the unit located at the
lower level stair well had been broken.
1.1.3
Emergency Preparedness Program Implementation
The inspectors conducted a tabletop discussion with licensee representatives
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who would be expected to implement- the emergency plan to determine if
personnel were trained on the emergency plan and could demonstrate this
knowledge and the capability to implement it properly. The tabletop
discussion included representatives from local police departments. The
inspectors had arranged for the invitation of other offsite response
organizations to the tabletop discussion, but representatives from these
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organizations were unable to attend. Those participating in the tabletop
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discussion are noted in the attachment to this report.
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The tabletop discussion included an evaluation of the licensee's understanding
of organizational responsibilities for emergency response at.tivities, the
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classification and notification of emergencies, and the implementation of
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emergency procedures. Several facility-specific accident scenarios were
discussed to evaluate the licensee's anticipated responses.
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During the tabletop discussion, licensee representatives demonstrated good
knowledge of emergency management and the responsibilities of onsite and
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offsite responders. The law enforcement representatives understood their
primary response and support roles in responding to emergencies at the Nuclear
Science Center.
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The inspectors presented hypothetical accident conditions to licensee
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representatives to evaluate their ability to assess action levels and classify
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emergencies. The licensee's classification guide was contained in the
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emergency plan and Emergency Implementing Procedure S0P IX-A.
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classification scheme consisted of three emergency classes:
operational
events, the Notice of Unusual Event (NOVE) class, and the Alert class.
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The reactor operators interviewed during'the discussions demonstrated the
ability to classify operational events appropriately. The operators were
unable to classify radiological events, however, at either the Notice of
Unusual Event or Alert class in accordance with the classification guide.
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According to the classification guide, the principal radiological emergency
action levels are indicated by stack particulate (Channel 1) and stack gas
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monitor (Channel 3) readings above a specified level. The inspectors
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determined that these monitor readouts in the control room were not calibrated
to provide indications as high as the emergency action levels. The fullscale
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monitor readings were at least an order of magnitude less than the action
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levels for a Notification of Unusual Event classification, and at least two
orders of magnitude less than the Alert action levels. As a result, the
operators conceded that radiological events associated with these. action
levels could not be assessed without input from the health physics staff.
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Even if a health physics representative were onsite to assess an event
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involving a radiological release, the specific classification action levels
associated with the stack monitors could not be assessed.
NRC Regulatory
Guide 2.6, " Emergency Planning for Research and Test Reactors" specifies that
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licensees should develop emergency action levels that relate directly to
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facility parameters. The licensee's failure to establish radiological
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emergency classification action levels related to facility parameters which
could be promptly assessed was identified as a weakness (128/93-01).
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Through the discussions, the inspectors confirmed that licensee procedures do
not direct the licensee to make notifications to the NRC except as required by
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10 CFR Part 20 and the technical specifications.
In order to expound on this
observation, the inspectors inquired into when the licensee would notify the
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NRC of emergencies. The responses from licensee representatives were varied
within the group questioned. One representative stated that a report to the
NRC would only be made as required by the technical specifications.
For such
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an event, the representative indicated that they would have at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
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before notification would be required.
(Note: technical specification
reporting requirements are generally for nonemergency conditions.) One
management representative indicated that notification to the NRC would be made
as conditions escalated to an Alert classification. None of the management
representatives interviewed were aware of a time frame in which NRC should be
notified of a declared emergency. Further, neither the emergency plan nor the
emergency implementing procedures specified when, or how soon the NRC should
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be notified of emergencies declared in accordance with the licensee's
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emergency classification guide.
Finally, the two reactor operators
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interviewed were not sure whether NRC notifications should be made to the NRC
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Operations Center in Bethesda, Maryland, or to the Region IV office.
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reviewing the Emergency Notification Roster posted in the control room, the
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inspectors noted that the telephone numbers for both NRC Region IV and the
Operations Center were listed.
This list indicated that Region IV should be
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contacted in an emergency or, if no one is available at Region IV, the
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Operations Center should be notified. The NRC position on this issue is that
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notifications of declared emergencies at nonpower reactors should be made to
the Operations Center in Bethesda, Maryland. The licensee's failure to
establish clear guidance for emergency notifications to the NRC was identified
as a weakness (128/9301-02).
1.1.4 Offsite Support and Emergency Alarms
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The inspectors visited the university communications center where certain
emergency alarms from the Nuclear Science Center are monitored. An Emergency
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call list was contained in the dispatch response procedures. Dispatch
personnel in the communications center were aware of the proper alarm response
procedures.
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The Nuclear Science Center had maintained a separate alarm panel in the
dispatch office which provided visual and audible alarms from the pool level
indicator and facility intrusion detectors. The alarm system in the dispatch
center had been tested weekly. The inspectors observed a demonstration of the
weekly tests and noted that the pool level alarm and an intrusion alarm
responded properly upon activation from the Nuclear Science Center. The alarm
panel included an annunciator tile for a fire alarm, but the inspectors
determined that the remote fire alarm system had never been installed.
Although the Nuclear Science Center was equipped with fire detectors which
gave local alarms, these alarms did not alert outside responders.
Because of
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this, local fire response personnel would not be alerted to a fire occurring
at the facility when it was unoccupied.
The inspectors reviewed letters of agreement in effect between the Nuclear
Science Center, the local fire department, and hospital and found that they
were current.
1.1.5 Emergency Preparedness Exercises and Drills
The inspectors reviewed documentation related to the last biennial exercise
conducted on May 15, 1991.
The scenario involved a contaminated injury victim
and included participation by the local treatment hospital with which the
Nuclear Science Center had entered into a letter of agreement.
Evacuation
drills conducted April 30, 1991, and November 24, 1992, were also reviewed.
Neither of the evacuation drills were preceded by a declared emergency so they
did not technically require the implementation of the emergency plan. The
drills and the exercise reviewed involved the performance of critiques by the
licensee.
1.1.6 Training
Reactor operators had been trained in the emergency plan and emergency
procedures during the course of initial operator training and annual
requalification training. The inspectors reviewed documentation that showed
that the local fire department had received facility specific training
annually. Nine individuals from the designated treatment hospital for
contaminated injuries had also received training. A lesson plan used for
training of the Nuclear Science Center staff was on file.
Records of annual
refresher training of the facility staff had been maintained.
1.2 Conclusions
The licensee's staff had been trained in emergency preparedness and had
participated in exercises and drills. Dedicated emergency kits had been
maintained. Functional tests demonstrated that remote pool level and
intrusion emergency alarms were operable. However, the remote system did not
include activation of the fire alarm system when the facility is not occupied.
Two emergency preparedness weaknesses were identified. A weakness was
identified for failure to establish radiological emergency classification
action levels related to facility parameters which could be promptly assessed.
Another weakness was identified for failure to establish clear guidance for
emergency notifications to the NRC.
2 PLANS, PROCEDURES AND REVIEWS (81401)
The security plan and implementing procedures were reviewed to determine
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compliance with 10 CFR 50-54(p) and 10 CFR 73.67(a) through (d).
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2.1 Discussion
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The inspectors verified that changes to the NRC-approved Physical Security
Plan, as implemented, did not decrease the effectiveness of the plan and that
implementing procedures were changed to adequately reflect plan changes.
Licensee personnel interviewed were knowledgeable of plan and procedure
requirements and were effectively complying with all requirements.
2.2 Conclusion
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The NRC-approved Physical Security Plan was adequately implemented and
implementing procedures reflected current plan changes.
Licensee personnel
were effectively complying with all requirements.
3 REPORTS OF SAFEGUARDS EVENTS (81402)
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The security program records and reports were inspected to determine
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compliance with the requirements of 10 CFR 73.71(a)and (b), 10 CFR Appendix G,
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and the Physical Security Plan.
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3.1 Discussion
The inspectors determined by a review of records, reports, and discussions
with licensee personnel that the licensee was correctly reporting security
events as required by the regulations.
Personnel interviewed were
knowledgeable of reporting requirements.
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3.2 Conclusion
The licensee was correctly reporting security events, and licensee personnel
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were knowledgeable of reporting requirements.
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4 FIXED SITE PROTECTION OF SPECIAL NUCLEAR MATERIAL (81431)
The physical protection system was inspected to determine compliance with the
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requirements of 10 CFR 73.67(a) through (d), and the Physical Security Plan.
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4.1 Disecssion
The inspectors determined from discussions with licensee personnel, and by
observing the security system that the .ystem was installed and operated as
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committed to in the NRC-approved Phys. cal Security Plan.
The inspectors also
verified by observation that access was controlled to the Controlled Access
Area and alarm response personnel were properly trained.
The inspectors also
verified by a review of records that the licensee conducts testing of the
security system in accordance with their security plan. The inspectors
witnessed a satisfactory licensee conducted test of the system during the
inspection.
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During the inspection, the inspectors noted that certain aspects of the entry
ways could be strengthened to prevent ease of rapid entry. This observation
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was discussed with the licensee.
4.2 Conclusion
The security system was installed and operated as committed to in the Physical
Security Plan. Alarm response personnel were properly trained, and testing of
the system was being conducted as required. The hardware on several external
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security doors could be strengthened.
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5 PROTECTION OF SAFEGUARDS INFORMATION (81810)
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The licensee's program to protect Safeguards Information against unauthorized
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disclosure was inspected to determine compliance with the requirements of
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5.1 Discussion
The inspectors determined by observation and verified from discussion with
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licensee staff personnel that an effective program had been implemented to
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protect safeguards information and that personnel. responsible for controlling
the information were knowledgeable of the requirements for storage, marking,
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reproduction, destruction and transmitting safeguards information.
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5.2 Conclusion
An effective program was in place to protect safeguards information.
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6 FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702)
6.1
(Closed) Violation 128/9202-02:
Failure to Instruct All Personnel Havinq
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Access to the Reactor and Laboratory Buildings
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The licensee implemented the use of a different record (Form 822) which -
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iridicated more clearly whether training had been provided for an individual.
The record required the signatures of the instructor and trainee upon
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completion of instruction. The licensee will perform routine audits of the
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records to ensure that personnel receive the required instruction. To ensure
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that the audits are performed on schedule, the audits will be tracked on the
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licensee's Management Overview Program (computer) tracking system.
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6.2 (Closed) Violation 128/9202-04:
Failure of the Reactor Safety Board to
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Perform Audits of Reactor Programs at the Recuired Intervals
Activities of the Reactor Safety Board were formerly not tracked by the
licensee. As corrective action for the violation, all audits to be performed
by the board were added to the Management Overview Program tracking system
which will provide a reminder when the audits are due.
The inspector verified
that an audit of the reactor operator requalification program was performed in
October 1992.
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ATTACHMENT
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1 PERSONS CONTACTED
1.1 Licensee Personnel
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- D. Reece, Director, Nuclear Science Center
W. Asher, Reactor Operations Manager
S. Brightwell, Reactor Operator
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- M. Brown, Assistant Director, Nuclear Science Center Laboratories,
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Nuclear Science Center Health Physicist
- B. Carlisle, Assistant Director, Nuclear Science Center Reactor
F. Jennings, Chairman, Reactor Safety Board
S. O' Kelly, Reactor Supervisor
1.2 Others
A. W. Onstott, Officer, College Station Police Department
C. Walling, Officer, Bryan Police Department
W. Zikus, Lieutenant, Texas A&M Police Department
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- Denotes personnel that attended the exit meeting.
In addition to the
personnel listed, the inspectors contacted other personnel during this
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inspection period.
2 EXIT MEETING
An exit meeting was conducted on March 16, 1993. During this meeting, the
inspectors reviewed the scope and findings of the report. The licensee did
not identify as proprietary, any information provided tu, or reviewed by the
inspectors.
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