ML20080H927
| ML20080H927 | |
| Person / Time | |
|---|---|
| Site: | Reed College |
| Issue date: | 02/16/1995 |
| From: | Frantz S REED COLLEGE, PORTLAND, OR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9502240157 | |
| Download: ML20080H927 (11) | |
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- . , , a REED COLLEGE '
Portland, Oregon 97202 I
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Reply to a Notice of Violation February 16,1995
. U.S. Nuclear Regulatory Commission ATTN: Document Control Desk J Washington, DC 20555 Docket: 50-288 License: R-112
Subject:
Reply to a Notice of Violation NRC Inspection Report 50-288/94-01 Dated 1/25/95 Pursuant to the subject NRC inspection of the Reed Reactor Facility, a Notice of Violation was issued to the facility. The Notice of Violation stated that the facility did not conduct or document the required annual training of Reed College Community Safety, Portland Police Bureau, Portland Fire Bureau, and Good Samaritan Hospital emergency room personnel. The Notice of Violation is not contested. The facility's response is as follows:
- 1) Reason for the violation There is no acceptable excuse for the violation. The required training was not documented (and sometimes not conducted) due to staffing shoitages. The available staff had to allocate its time between all the various necessary tasks, and documentation of training was sometimes neglected.
The f acility staff conducted training for personnel when the need was evident, but it w'as not consistently documented.
All Reed College Community Safety personnel received emergency and security training in 1992 (as documented) and replacement Community Safety personnel received individual traim,ng as they were himd. Training only the replacement personnel was considered adequate at the time, but it was not documented. A Portland Police Bureau and Portland Fire Bureau personnel were trained on an irregular basis .
(e.g., when they were at the college for some reason), but it was not documented.
Good Samaritan Hospital emergency room personnel were not trained because their own training program exceeded any additional useful training that the facility could provide. There was no documentation of this decision.
- 2) Corrective actions that have been taken and the results achieved ,
During the fall semester of the 1994-95 academic year (prior to the inspection), the training l program was re-established and documented. All Reed College Community Safety personnel, and selected Portland Police Bureau and Portland Fire Bureau personnel were trained on the facility's emergency and security procedures. The director met with the Portland Police Bureau's training officer, provided a tour of the facility, and supplied him with the requisite security and emergency ;
information so that the bureau could determine where it fit best into their overall training program. i Members of the local fire bureau were given a tour of the facility and provided with the appropriate :
security and emergency training. All of this training was documented. The directorof the Good l l
23C043 1 3203 SE Woodstock Blwl.. Portland. OR 97202-8199 Tel:(503) 777-7222 Fax:(503) 777 7274 email:sgf@ reed.edu f NO22g gg[ Eoo$2es k- M M6 I/
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' ReedReactor, Docket 30-288 Reply to a Notice of Violation 2/16l95 :
Sarnaritan Hos pital emergency room was contacted and it was determined that their penonnel had adequate radio; ogical traming to handle injured personnel from the facility. This conversation was documented.
A draft standard operating procedure (SOP-12, Security) was written which, among other things,
- specified the required traimng croff-site penonnel for security and emergency response. The draft SOP was presented to the facility's Radiation Safety Committee in October 1994 and they were reviewing it individually prior to full committee discussion.
Subsequent to the NRC inspection in December 1994, the draft SOP-12 was approved (with revisions) by the Radiation Safety Committee and the procedure became effective February 1995.
A copy of SOP-12, Security, is included as an enclosure to this letter. Training of Community Safety, Portland Police Bureau, and Portland Fire Bureau is required under section 12.7.5.
Upon the recommendation of the NRC inspector, a facility planning calendar was created to indicate when periodic events should be conducted. This includes training off-site persc,nnel. A copy of the planning calendar is included as an enclosum to this letter.
It was determined by the Radiation Safety Committee that the facility does not need to train hospital emergency room personnel in radiation safety or facility emergency procedures: we must ensure that t se hospital's training program is adequate for our purposes, ne Radiation Safety Committec also determmed that there was no compelling reason to take contaminated injured personnel to Good Samaritan Hospital rather than other hospitals in the Portland area. These changes will require a revision to the facility's Emergency Plan.
- 3) Corrective steps that will be taken to avoid further violations He new procedure (SOP-12, Security) and the planning calendar should ensure that the required training is conducted and documented annually.
A revision to the Emergency Plan will be submitted to the NRC. This revision will remove the requirement to train hospital emergency room personnel in radiation safety or facility emergency !
3rocedures. De agreement letter with the hospital required by the Emergency Plan will ensure that lospital emergency room penonnel are adequately trained. Requiring that their pesonnel be !
trained by our facility staff would not only be redundant with their own requirements, it would be a burden on their busy schedule. Reed Reactor Facility will, of course, offer to provide any training .
they desire. l l
The Emergency Plan will also be revised to provide a choice of hospitals. Them is no longer any compelling reason for using Good Samaritan Hospital. When the Emergency Plan was written the Trojan Nuclear Power Plant was operating and had an agreement with Good Samaritan Hospital. ,
For that reason, Good Samaritan Hospital had special facilities and training for radiological l injuries. Now that the Trojan Nuclear Power Plant is permanently shutdown, Good Samaritan Hospital has similar facilities and training for radiological injuries as other hospitals in the area.
Also, Good Samaritan Hospital is not a trauma center, so it may not be the optimal destination for an injured person. The Emergency Plan will therefore be revised to include a choice of hospitals, with agreement letters for any hospital the facility plans to use.
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- Reed Reactor, Docket 50-288 Reply to a Notice of Violation 2/16/95
- 4) 'Date when full compliance will be achieved The facility is in compliance with the exception that Good Samaritan Hospital emergency room personnel are not trained by facility staff in radiation safety or facility emergency procedures.
Emergency room personnel receive adequate training by their own program, and we verify that they have adequate training by the agreement letter and discussion with their administrator. When the proposed revision to the Emergency Plan is approved, the facility will be in full compliance.
The facility plans to submit the revision to the Emergency Plan by June 30,1995.
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Stephen G. Frantz Director, Reed Reactor Facility
Enclosures:
SOP-12, Security Reed Reactor Facility Planning Calendar Copy with Enclosun:s:
U.S. Nuclear Regulatory Commission Regional Admimstrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Oregon Department of Energy ATIN: David Stewart-Smith, Director Division of Radiation Control 625 Marion Street, N.E.
Salem, OR 97310 Steven S. Koblik, President e Reed College Linda II. Mantel, Dean of the Faculty Reed College Curt Keedy Chair of Reed College Radiation Safety Committee Arthur Glasfeld Chair of Reed College Reactor Operations Committee Test, Research and Training Reactor Newsletter 202 Nuclear Sciences Center University of Florida Gainesville, FL 32611 Page3
1 I I I I I I g & E I I I I E I I i 3
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REED g g REACTORFACILITY f Security y l -
Standard Operating Procedure
- Efective: February 1995 12.1 Purpose This procedure implements the requirements of Reed College Physical Security Plan.
i Because of the nature of this procedure, portions ofit are included in appendices which am not generally distributed.
12.2 Schedule Revisions to Entry list A are made by the director as necessitated by changes in facility staff.
Entries to Entry List B are made as individuals enter and leave the facility.
Keys and Facility Access Codes shall be simultaneously changed at least once every two years (not to exceed 28 months) and at any other time the director suspects that facility security may have been compromised, including but not limited to loss of control of a facility key. This key change should take place between June and September of even numbered years.
Keys are issued, consistent with this procedure and the Security Plan, as requested by individuals requiring access to the facility.
The Physical Security System shall be tested in acewdance with the bimonthly checklist. l Each zone will be tested at least annually as detailed in Appendix D. l The Portland Police Bumau, the Portland Fire Bureau, and Community Safety will meet with the director annually to review the proper and necessary security and emergency procedures.
The Security Plan shall be reviewed and updated (as necessary) at least once every two years by the director with the help of the Radiation Safety Committee.
The security re.;ponse procedures shall be tested in cooperation with the Portland Police l
Bureau annually. Details are given in the Security Plan.
12.3 Personnel Requirements Only the director may make mvisions to Entry List A.
Any member of Entry List A may authorize students and visitors who wish to enter the facility, consistent with these procedures.
Initiation oflock and access code changes shall be the responsibility of the director. The locksmith from the Reed Physical Plant replaces locks. Issuance of access codes by
- Iloneywell shall be by specific written instruction from the director.
Keys are issued by Reed College Physical Plant upon the written direction of the director.
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SOP 12, Security (2/95) 1
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Te' sting of the Physical Security System is the res sibility of the director who may be accompanied and assisted by selected facility s and/or. Radiation Safety Committee members.
Everyone on Entry List A shares a responsibility to maintain the security of the facility.
'12.4 Prerequisites Not Applicable.
12.5 Precautions Do not put yourself in physical danger to maintain the security of the facility.
12.6 Order Not Applicable.
12.7 Procedure 12.7.1 Contmiled Access Area ,
De permanent Controlled Access Area (CAA) is the reactor room and the mechanical room. 1 A person entering the CAA enters via one of two major categories: They have been placed on Entry List A by the Director, or they enter via Entry List B.
12.7.2 Temsrily Estahlinhed Contmiled Access Area De temporary and larger CAA may be designated by any licensed operator when all of the following conditions are met:
a) The entryway outside door is locked, and b) The Psychology Building stairway door is locked, and c) There is at least one licensed operator in the permanent CAA or control room.
The temporary CAA is designated as such by opening the control room main entrance door and making an entry in the Main Img. A sign is placed on the Psychology Building stairway door should state that the door is to remain locked. ;
12.7.3 Entry List A Individuals are > laced on Entry List A by the director. Individuals on this list do not need to be accomraniec in the Reactor Facility. Any individual on Entry List A may accompany
- others who have specific business in the facility as described under Entry List B. -
The dirxtor may name to Entry List A any member of the Reed College staff, Reactor Facility staff, or trainees who, m the opinion of the director, meet the following criteria:
a) Rey have sufficient training in facility procedures including emergency pmcedures to be able to recognize and respond appmpriately to emergency situations which may arise, and
- b) Hey have a need to work in the CAA.
5 L SOP 12, Security (2/95) 2
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+ 12.7.4 Entry List B -
This list includes all visitors to the CAA who are not on Entry List A. Anyone on Entry List A may escort individuals into the CA A after the visitor has signed onto Entry List B.
The person authorizing access to the CAA will be responsible to assure the following:
a) The individuals entering via Entry List B have a legitimate purpose in the CAA.
b) The person granting authorization must accompany all such individuals into the CAA q and maintain visual contact with them at all times. i 12.7.5 Training The Portland Police Bureau, the Portland Fire Bureau, and Community Safety will meet with the Director annually to review the proper and necessary security and emergency procedures. As a minimum, training on the mformation in Appendix C will be documented.
12.7.6 General Security Guidance Personnel who are issued keys or passcards must ensure they are not lost or stolen, If they are lost or stolen, notify the director immediately.
Do not leave visitors unattended in the reactor bay or mechanical room.
Avoid working in the facility alone at night.
Set all facility alarms when work at the facility is done for the day. .
Avoid opening the entryway door to strangers. Encourage visitors to call from the chemistry loading dock or use the intercom (if installed). Do not give anyone access to the
, facility until you have identified them.
If there is a break-in at the facility notify Community Safety, the Portland Police, and the facility management in any possible way under the circumstances. Do not put yourselfin danger to do this.
12.8 Logging. Requirements All problems and testing of the security system is to be logged only in the Security legbook which is maintained by the director. ,
12.9 Special Not Applicable.
12.10 Acceptance Criteria Not Applicable.
APPENDICES Appendix A: Key Request Petition: A-Keys Appendix B: Key Request Petition: B Keys Appendix C: Instructions to Community Safety Personnel Appendix D: Testing of the Physical Security System (Confidential - Not Distributed)
SOP 12, Security (2/95) 3
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.. REED REACTOR FACILITY KEY REOUEST PETITION: B-Key I, (print your tuune), hereby petition the Director of the l Reed Reactor Facility for a copy of the Radiochemistry Lab, "B" key ( ).
I understand that, to be issued this key, I must need access on more than an occasional basis, and that if I cease to need the key as described below, I shall surrender it to the Director immediately.
- 1) Anticipated projects for which access to the Radiochemistry Lab is necessary willinclude:
- 2) Anticipated rate of use (e.g., weekly):
- 3) Termination date: (ifbefore September of the next schoolyear).
I understand that I have been briefed on the mquirements of the Reed Reactor Facility Security procedures as they apply to the Radiochemistry Lab, and that if I fail to follow them I may be asked to suriender my key immediately. I also understand that, notwithstanding the Termination Date above, this " Key Rec uest Petition" becomes void on the September following issue and that I will retum the key issucc to me or execute a new Petition at that time. If this key is lost or stolen, I will notify the Director immediately.
Requested by: Date:
Authorized by Director: Date:
SOP 12, Appendix B: Request for B Key (2/95) i
REED REACTOR FACILITY Instructions for holders of Radiochemistry Laboratory "B-keys" The Radiochemistry Laboratory is covered in the Reed Reactor Facility Security Plan. As a holder of a key to that lab, it is important that you understand that this plan is approved by the
. Nuclear Regulatory Commission and must be followed at all times. Following the procedure which follows will ensure that we remain in compliance with that plan.
- 1) The reactor room must be isolated by two locked doors. Do not block open the stairway door OR the entryway outside door, unless you are certain that the door between the control room and the reactor room is locked. Thus, if you need to block open either door (even for a few minutes), you must determine if anyone is in the reactor:
a) If the light in the control room is OFF, that means that no one is in the facility and the reactor room door is locked.
b) If there is someone in the facility, knock on the door, notify them that you need to block the door, and obtain their permission. If they are engaged in certain operations, you may have to wait until they finish to block either door.
- 2) The entryway outside door is NOT to be left blocked and unattended at any time.
- 3) If the reactor is running and the pneumatic transfer system (rabbit) is in use, there is the potential for sudden high radiation areas to develop in the radiochemistry lab. In these .
cases, the doors should remain locked and you should be prepared to respond as instructed by someone operating the system.
- 4) Upon completing your work, ensure that the stairway door and the entryway doors are closed and locked.
- 5) If students or others working with you need to use the Radiochemistry Lab, you are :
responsible for their understanding of and compliance with these procedures. l
- 6) If you notice any unusual situations including alarms or red lights in the reactor room use I the Emergency Notification Call list on the control room door to notify the first available person on the list.
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SOP 12, Appendix B: Request for B Key (2/95) 2
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INSTRUCTIONS FOR' RESPONSE TO
. REED . REACTOR FACILITY ALARMS OR EMERGENCIES
-1) ~ Under normal situations, Community Safety, Portland Police, Portland Fire Bureau, and custodial :ersonnel may not enter the reactor room unless accompanied by an authorized individual . The names of authorized individuals appear on Entry List A which is posted on the Reactor Control Room door.
- 2) If any of the alarms listed on the next page is activated or if evidence is found ofillegal entry:
a) DO NOT ENTER THE FACILITY - them is a risk of radiation exposure or contamination.
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b) - Use the Emergency Notification Call List (ENCL) posted on the Control Room door to penonally contact a member of the Reactor Staff. Briefly explain the situation as best you can over the phone.
Note: If you were alerted by Honeywell because of a fire or security alarm involving the mactor, they should have already notified someone from the list who should arrive soon. A second call can ensum that someone is on the way. ,
c) Notify Police or Fire Buman (call 911), if assistance is needed. If you think that radioactive materials may be involved, inform the Police or Fire Bureau of that fact so that they can alert their specially trained personnel.
d) Do not allow unauthorized individuals to enter the facility.
- 2) Emergency entry to the facility is permitted if BOTH of the following criteria are met:
a) NO alarms have been activated;and b) ~ It is a genuine emergency which cannot wait until authorized personnel arrive (e.g., a fire or injured person).
Emergk b b -
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Radiochemistry 0 Lab }
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r SOP 12, Appendix C: Instructions to Community Safety (2/95) 1
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REED REACTOR FACILITY l EMERGENCY SIGNALS AND ALARMS 1
Name of Alaan Location of Alarm _ Meanino of Alarm i 1 Water Level Red light outside north wall Water level more than 4" below Alarm over double doors and in or above normal.
reactor hallway. DO NOT ENTER FACILITY.
2 Evacuation Siren in reactor room; light in Manually opirated.
Alarm lab. DO NOT Jt1TER FACILITY.
3 Fire Alarm Red " FIRE" light in hallway and Fire in reactor room or labs.
lab. Sector 1 fire alarm on Honeywell panel at Psychology Building door.
Alarms throughout Psychology Building and facility.
4 Security Alarm Bell on south wall of reactor illegal entry into facility.
room.
5 Isolation Cycle Red light on panel on south Ventilation syctem not wall; small red light on center operating norms!!y; may be of the top stack monitor box in caused by loss of power, or control room (visible in mirror may indicate radioactive through Door A) materials in alt (especially if accompanied by other alarms).
6 Secondary HLgh pitched alarm in reactor Secondary water pump has Water room. failed or pressure is too low.
Pressure (NOT AN EMERGENCY) 7 Secondary Green light on south wall, Pump is on lit;off if not lit.
Water Pump Red light on east wall (NOT AN EMERGENCY)
For the followino. the vellow llaht should be on andjhe red licht should be off.
Emeroency condition is indicated by Vallow licht off: red licht on. or alarm bell.
8 Radiation Area Pole in northwest comer of High radiation in reactor room.
Monitor reactor pool DO NOT ENTER FACILITY.
9 Continuous Air Cart on floor of the east wall of Radioactive air in reactor room.
Monitor reactor room DO NOT ENTER FACILITY.
10 Stack Monitors Panel on north wall of control Radioactive air leaving reactor.
room (visible in mirror through DO NOT ENTER FACILITY.
Door A)
SOP 12, Appendix C: Instmetions to Community Safety (2/95) 2
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Reed Reactor Facility Planning Schedule
' January February March i Paideia Maintenance Bi-monthly Checklist I Annual Checklist EPA Argon-41 Report I Semi annual Checklist URR Sharing Grant Application Bi-menthly Checklist Schedule Spring Reactor Seminar NRC Exam Request May NRC Exam !
April May June DOE MBR (2 copies) Bi-monthly Checklist Letter to NRC terminating licenses Police Response to Security Requal Exam New ENCL and Entry L - A New Medicals NRC Exam Complete License Applications July August September Semi-annual Checklist Annual Report Bi monthly Checklist Di-monthly Checklist DOE Grant Closcout Community Safety Training New RRC membership PPB & PFB Training Schedule Fall Reactor Seminar New Key Requests Change keys / codes (even # years)
Agreement letters (even # years)
New ENCL and Entry List A
, October '
November December DOE MBR (2 copies) Bi monthly Checklist NRC Inspection (even # years)
, Request December NRC Exam Emergency Drill Plan Paideia New and Bi-annual Medicals Complete License Applications i
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revised 2/17/95 j l