ML20116C896

Responds to NRC Re Deficiencies Noted in Insp Rept 50-186/85-02.Corrective Actions:Health Svcs Will Complete Training of Medical Support Personnel at Facility Hosp & Clinics by 850731

ML20116C896
Person / Time
Site:	University of Missouri-Columbia
Issue date:	04/12/1985
From:	Alger D, Mckibben J MISSOURI, UNIV. OF, COLUMBIA, MO
To:	Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20116C875	List: ML20116C896
References
NUDOCS 8504290205
Download: ML20116C896 (7)

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Research Reactor Facility UNIVERSITY OF MISSOURI Research Park April 12, 1985 coturnbia, Missouri 6521 Telephone (314) 882-4211 FrilC?lTY rruill,G qu' d m:

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?YY' u qq-U. S. Iluclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 .

Attention: C. J. Paperiello, Chief Emergency Preparedness and Radiological Protection Branch

Subject:

Emergency Preparedness DOCKET NO. 50-186 - University of Missouri

Reference:

Letter with enclosures fron C. J. Paperiello, to University of Itissouri, dated February 28, 1985.

Dear Sirs:

In response to your referenced letter which reports the results of an on-site appraisal of the !!URR emergency preparedness program by liessrs, ll. Snell, W. IIerrington and G. Martin, we are submitting our planned actions to correct the deficiency items identified in Appendix A of your letter. First your identified deficiency will be given, followed by our planned actions to correct the problem.

1. The following EALs need to be added to the Emergency Procedures:

Unusual Event - threats to or breaches of facility security prolonged fire or minor explosion within the facility but nonspecific to the reactor or its control system.

- other plant conditions exist that warrant assuring energency personnel are availabic to respond and assuring information will bo provided to of fsite authorities.

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a COLUMBIA KANSAS CITY ROLLA ST. LOUIS an equal opportuniti institution APR 171985

l[. S. Nuclear Regulatory Commission April 12, 1985 Page 2 Alert - fire or explosion which might adversely affect the reactor or its safety systems.

- loss of physical control of the facility.

- other plant conditions exist that warrant notification of the emergency staf f and activation of the Facility Emergency Organization.

Site Area Emergency - fire compromising the functions of safety systems.

- other plant conditions exist that warrant activation of the Facility Emergency Organization and assistance from offsite support organizations.

(Section 2.2.1)

Response

We realize that the potertial exists for emergencies of the types identi-ficd by your suggested EALs and we have procedures for handling these emergen-cies. Therefore, we can and would activate our emergency organization to deal appropriately with the events; however, we would consider the emergencies not necessarily fitting into one of the four general classifications. We can call on both onsite and offsite support organizations at any time without first having to declare an emergency of one of the four general classifications.

We have identified many emergency conditions for which prior planning, training, and procedures are important to mitigate the consequences but which by themselves do not pose a reasonable threat of radiological consequences to the staff or members of the general public. We feel it is important to prepare for these emergency events and we can do this without adopting the proposed action levels into our procedures.

liost of the proposed action levels do not have any direct correlation to a plant parameter or condition that would constitute a threat or potential threat of radiological consequences to the public or staff, which is supposed to be the basis for the standardized emergency classifications. Our understanding is that an event is classified by the radiological hazard associated with it so that the risk to the general public at the site boundary is the same for all licensees for a given classification. This means that an emergency such as total loss of electrical power might be a site area emergency at some facilities while not even be a radiological emergency at other facilities. It is an important factor to be considered when determining emergency classifications and deriving appro-priate EALs. Federal, state, and local emergency personnel and the public are developing an understanding of the significance of the standard classifications, but they rarely have the plant specific knowledge to understand the significance of a problem for a given facility. There is a threat to the health and safety of the public by over-alarming them by using an inappropriate classification.

i

U. S. Nuclear Regulatory Commission April 12, 1985 Page 3 To support the requested EALs, you stated in section 2.2.1 of your assess-ment report that "almost all EALs addressed in the procedures are the result of a radiological release. The Emergency Plan provides the bases for classifying an emergency as an Unusual Event or greater based on nonradiological events."

Then you give your eight requested EALs.and conclude, "To assure the adequate implementation of the Emergency Plan, the above EALs need to be added to the procedures." This line of reasoning is not consistent with nor supported by the guidance given to research and test reactors by the NRC. In Federal Register /Vol. 47, No. 88/ Thursday, May 6, 1982/page 19512, the NRC requested research and test reactor ifcensees to use Revision I to Regulatory Guide 2.6 (for comment) and ANSI /ANS-15.16 to meet the requirements of 10 CFR 50.54(r) .

Revision 1 to Regulatory Guide 2.6 for comment Emergency Planning For Research and Test Reactors states "the Commission's interest in emergency planning is focused primarily on situations that may cause or may threaten to cause radio-logical hazards affecting the health and safety of the public" (page 2). The fact that "almost all EALs addressed in the procedures are the result of a radiological release" is not a weakness in the implementation of the plan, but consistent with bases of the emergency planning for research and test reactors as defined in Regulatory Guide 2.6 and the description of our Emergency Plan contained in the Introduction.

We will incorporate in our procedures six of the requested EALs, with changes to focus on the radiological hazards. The other two EALs we feel are inappropriate for our facility. The following EALs will be added to the Emergency Procedures:

UNUSUAL EVENT - Threats to or breaches of facility security that have a significant potential for a radiological exposure of the staff or public approaching i rem whole body or 5 rem thyroid.

- Prolonged fire or explosion within the facility that can result in a release of radioactivity that would cause exposures of the public or staff ap-proaching i rem whole body or 5 ren thyroid.

- Other plant conditions exist that warrant assuring emergency personnel are available to respond to an emergency to prevent exposures of 1 rem whole body and 5 ren thyroid to the public and staff.

U. S. Nuclear Regulatory Commission April 12, 1985 Page 4-ALERT - Loss of physical control of the facility.

- Other plant conditions exist with a level of significance of a major failure of fuel cladding but primary and containment boundaries exist to reduce releases.

SITE AREA Emergency - Other plant conditions exist with a level of significance of major fuel damage and conditions that indicate actual or imminent failure of containment integrity and primary system integrity.

The requested EALs for fire under the Alert and Site Area Emergency classifications would not cause or even threaten to cause a radiological hazard affecting the health and safety of the public. As stated in the NRC approved MURR Emergency Plan 3.1 Bases for Emergency Classifications:

"MURR's EPZ is based on ANS 15.16 (Table II) and is the area bounded by a 100 meter radius from the MURR exhaust stack which lies completely within the site boundary. There are no credible accidents identified for the MURR facility that would result in radiological effluents exceeding PAG at EPZ boundary or exceeding the Notification of Unusual Events action levels listed in Table I at the site boundary. However, the emergency plan describes three standardized classes of emergency situations grouping the accidents according to the severity of offsite radiological consequences: (1) Notification of Unusual Events, (2) Alert; and (3) Site Area Emergency; and the latter two classifications are included to be conservative and to provide for consultation with offsite authorities and handling of information for the public through offsite authorities."

The requested fire EALs seemed to be based on an assumed need for active safety systems to remove core heat as found in nuclear power plants. However, at MURR, as with most research reactors, no active systems are required; the decay heat removal will be performed indefinitely by the in pool heat exchanger. The control blades are released on loss of electrical current to their electro-magnets and drop to the full inserted position by gravity. All process systems are placed in the shutdown condition due to the failsafe design of these sys-tems; i.e. the redundant (only one is required) primary in pool heat exchanger valves 546 A and B open by spring actuation, placing the convection cooling in-pool heat exchanger in service. This fatisafe design of the system permits shutdown decay heat removal with no electrical power (Appendix 0 of Addendum 4

i d.S. Nuclear Regulatory Commission April 12, 1985 P. age 5 to Hazard Summary Report). Therefore a fire threatening the safety system causes a major operational problem but does not significantly increase the possibility of fuel damage. There is no appropriate fire EAL for an alert or site area emergency classification.

The three requested ' catch all' EALs - "other plant conditions exist that warrant assuring emergency personnel are available to respond and assuring information will be provided to offsite authorities" (UNUSUAL EVENT), "other plant conditions exist that warrant notification of the emergency staff and activation of the Facility Emergency Organization" (ALERT) and "other plant conditions exist that warrant activation of the Facility Emergency Organization and assistance from offsite support organizations" (Site Area Emergency) -- are not EALs by the definitions in Revision 1 to Regulatory Guide 2.6 (for comment) and in NUREG-0849 " Standard Review Plan for the Review and Evaluation of the Emergency Plans for Research and Test Reactors."

In Revision 1 to Regulatory Guide 2.6 (page 4) the guidance for preparing EALs is stated as follows:

" Emergency action levels related to facility parameters and equipment conditions should be developed to the extent feasible for each emergency class as well as emergency actic1 levels related to effluent release levels. These action levels should quantify observations or judgments of the reactor operator that certain occurrences have affected the ability to transfer energy from the core to the normal or alternative heat sink and that these occurrences might lead to a radiological hazard appro-priate to the emergency class."

In NUREG-0849 (page 11), the evaluation of Emergency Action Levels (EALs) should meet the following criteria:

" Emergency action levels based on actual or potential radiological exposures. Each facility's plan should describe specific instrument read-ings, observations or judgments that will be used to initiate emergency measures consistent with Appendix I."

The three requested EALs try to classify an emergency by what resources are required to handle it, instead of classifying the emergency based on actual or potential radiological exposures. It is inappropriate to classify an emergency based on the support organizations utilized. A scenario could be created where we would respond to a fire in our nonradioactive storage room outside contain-ment by assembling the Facility Emergency Organization and calling for assis-tance from the Fire Department. It would be inappropriate to classify this as

~

b.S.NuclearRegulatoryCommission April 12, 1985 Page 6 a Site Area Emergency as is stated by your requested EAL "other plant conditions exist that warrant activation of the Facility Emergency Organization and assistance from offsite support organizations."

Our understanding of the intent of the three requested EALs is to give guidance to the Emergency Director for classifying emergencies that do not easily fall into one of the original EALs. Therefore, we changed the three requested ' catch all' EALs to be more in line with the NRC guidance in Regulatory Guide 2.6 and NUREG-0849.

2. Provide procedures for obtaining and analyzing stack samples under accident conditions. (Section 2.2.1)

Response

A new procedure 50P HP-30 will be written to provide analysis of stack samples under accident conditions.

3. Inconsistencies in the procedures to the Emergency Coordinator, Duty Operator and surveillance team having responsibility and assigned tasks for evacuation activities need to be corrected. (Section 2.3.2)

Response

The EMERGENCY COORDINATOR will have the responsibility for verifying all evacuation activities. This responsibility is assigned to the EMERGENCY COORDINATOR for the REACTOR ISOLATION and for the FACILITY EVACUATION as stated in your letter. The Site Emergency Procedures will be revised to always assign an EffERGENCY COORDINATOR and to clarify responsibilities for evacuation activi-ties.

4. The procedures need to be revised to accurately reflect how accountability will be implemented and that people will be required to be surveyed for contamination before being allowed to leave the area. (Section 2.3.2)

Response

The procedures will be revised to reflect accurately how accountability will be implemented and that people will be required to be surveyed for con-tamination before being allowed to leave the area.

U.S. Nuclear Regulatory Commission April 12,1985 P, age 7

5. In accordance with 10 CFR Part 20.202, supply appropriate personnel monitoring equipment to personnel entering the facility under circumstances in which it is possible for them to receive a significant dose. Provisions need to be established either in the Emergency Plan or Emergency Procedures to supply the appropriate personnel dosimetry to offsite emergency response personnel.

(Section 2.3.3)

Response

Procedure SEP-10 " Monitoring Offsite Personnel" is being written to provide for issuing radiation dosimeters and recording exposures of offsite personnel who respond to i1VRR calls under the Emergency Plan.

Procedure SEP-11 "lionitoring Planned Exposures in Excess of Limits in 10 CFR 20" is being written to provide dosimetry, appropriate monitoring, and records for personnel who received planned radiation exposures in excess of 10 CFR 20 limits.

6. Provide the required biennial training to the medical support staf f in handling contaminated injured persons. (Section 3.1)

Response

The UTC Health Physics Services will complete training of the medical support personnel at the UIC Hospital and Clinics by July 31, 1985. He will ensure future training is scheduled to meet the biennial training requirement.

Records of the medical support personnel training will be maintained at liURR.

The new procedures and revisions to the existing procedures will be completed before June 30, 1985. Copies of the new/ revised procedures will be sent to you when completed.

Sincerely, 0 '

J. C. 1tcKibben Reactor Manager Reviewed and Approved:

W b.

Don I1. Alger i Associate Director xc: HRC, Director of Nuclear Reactor Regulation NRC, Division of Emergency Preparedness and Engineering Response R. ft. Brugger