ML20126E319
| ML20126E319 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 12/08/1992 |
| From: | Barr K, Kren J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20126E308 | List: |
| References | |
| 50-160-92-04, 50-160-92-4, NUDOCS 9212290095 | |
| Download: ML20126E319 (7) | |
See also: IR 05000160/1992004
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DEC 101932
Report No.:
50-160/92-04
Licensee: Georgia Institute of Technology
225 North Avenue
Atlanta, GA
Docket No.:
50-160
License No.: R-97
facility Name:
Neely Nuclear Research Center
inspection Conducted-
November 9-10, 1992
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Inspector:
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LJ. L. Kre T1Fadiation Specialist
Signed
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Accompanying Personnel:
C. H. Bassett, NRC Region 11
H. M. Mendonca, NRC Headquarters
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Approved by:
CI Barr,'Cli
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Date Signed
Emergency Preparedness Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted to assess the operational
readiness of the licensee's emergency preparedness program and to evaluate the
annual emergency preparedness drill conducted on November 9, 1992.
Results:
In the areas inspected, one repeat violation was identified for failure to
have certain emergency plan notification requirements in written procedures
(Paragraph 2).
No deviations were identified. The licensee's emergency
response capability was maintained in an overall adequate state of readiness.
Emergency response personnel performed well during the drill.
9212290095 921210
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REPORT DETAILS
1.
Licensee Employees Contacted
W. Downs, Senior Reactor Operator
- R. Ice, Manager, Office of Radiation Safety
- R. Karam, Director, Neely Nuclear Research Center
B. Statham, Manager of Operations
Other licensee employees contacted during this inspection included
operators, technicians, and-administrative personnel.
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- Attended exit interview
2.
Emergency Preparedness Plan and Implementing Procedures (82745)
The Emergency Preparedness Plan (EPP) and associated implementing
procedures (known as the-Emergency Procedures) were reviewed to note
changes made since the last inspection in this area (September 1991)
and to assess the 11. act of any such changes on the overall state of
No changes were made to the EPP (currently
Revision No. 2, approved by the NRC on June 8, 1989), since the last
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inspection.
One of the licensee's ten Emergency Procedures was new Procedure 6080,.
" Accidental Release of High Levels of Gaseous Activity to the
Atmosphere," Revision 00, approved August 13
1992. Two of the
licensee's Emergency Procedures had been revised since the
September 1991 inspection.
The changes in these revisions, which
involved Procedures 6090 and 6100, were reviewed to determine their
consistency with the EPP. Of particular interest were the changes
made in Procedure 6100, " Emergency Notification" (Revision 03,
approved September 26,1991), in response to a previous noncited
violation (50-160/91 04 02) for an inadequate notification procedure.
The referenced violation was based upon the licensee's failure to
specify. in the Emergency Procedures that the State of Georgia and the
Atlanta /fulton County Emergency Management Agency (EMA) will be
notified for all incidents classified as Notification of Unusual Event
(NOVE) through General Emergency, in accordance with the explicit
requirement- in Section 3.2 of the EPP.
At-the time of this finding
(September 1991), the violation was not cited because the licensee's
proposed corrective actions and the minor nature of'the violation
appeared to satisfy the applicable criteria in the NRC Enforcement
Policy. However, the. inspector's; review of Revision 03 to
Procedure 6100 disclosed that the licensee's corrective actions did
not completely address the subject violation.
Procedure 6100
specified notification of the State of Georgia (specifically, the
Department of Natural Resources) for most initiating events classified
as NOVE and for.all events classified as Alert or higher, but the
subject procedure did not specify notification of the Atlanta /Fulton
County EMA for any of the classifiable events listed in Sections 5.9,
5.10, and 5.11.
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Discussions with the Director of the facility disclosed that
corrective actions for the violation were undertaken immediately after
the September 17-19, 1991 inspection (as indicated by the revision
approval date of September 26,1991), but were based upon the
licensee's apparent misunderstanding of the issue as discussed during
the exit interview for that inspection. The facility Director stated
that he had not perused the details of this matter in NRC Inspection
Report 50-160/91-04, which was issued on November 5, 1991.
Section 6.4.b(8) of the licensee's Technical Specifications-stated
that written procedures shall be provided and utilized for a site
Licensee management was informed that Procedure 6100
governing emergency notifications did not adequately' implement
Section 3.2 of the EPP.
Violation 50 160/92-04-01:
Failure to have certain EPP notification
requirements in written procedures.
Section 8.5 of the EpP required a quarterly update and verification of
the Emergency Notification Roster, a one-page call list / organizational.
chart posted at various locations throughout the facility. The
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current version of this roster was Revision 28, dated September 18,
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1992.
The inspector reviewed documentation showing that the Emergency
Notification Roster was updated during each calendar quarter since the
last inspection, and that copies of each revision were distributed to
specified campus and of fsite locations.
The ins 3ector noted that the
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roster included a 24-hour telephone number for 11e Atlanta /fulton
County EMA, although, as discussed above, Procedure 6100 did not
specify notification of this agency in the event of an emergency
declaration.
One violation and no deviations were identified.
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3.
Emergency Response Training (82745)
Pursuant to Section 10.1 of the EPP, this area was inspected to
determine whether the licensee had provided training to the onsite
emergency organization.
Licensee records documented 1992 emergency response training of seven
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facility personnel listed on the Emergency Notification Roster.
In
addition, training for the role of Emergency Director (ED) was
provided to the individual serving as Manager, Office of Radiation
Safety. This individual, who began his employment at the facility. on
October 1, 1992,
functioned as ED.during the current drill,.and will
be designated in the near future as an alternate for-the.ED position.
. Although no written lesson plans or training outlines were used and_ no
examinations were given, interviews with facility staff and
performance of licensee personnel .during the drill indicated that
emergency response training was effective.
No violations or deviations were identified.
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4.
Emergency facilities, Equipment, and Supplies (82745)
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This area was reviewed to determine whether the licensee's Emergency
Command Center (ECC) and other equipment, instruments, and supplies
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were maintained in a state of operational readiness as required by
Section 10.5 of the EPP.
The license had designated two kits for emergency use. One was
located in the vestibule of the Reactor Building and contained.
anticontamination clothing, decontamination supplies, barrier ropes,
etc.
The second kit, located in the ECC, contained portable survey
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instruments, anticontamination clothing, sampling material, dosimetry
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devices, etc.
In addition, two self contained breathing apparatus
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(SCBA) units were available in the ECC.
Selective inspection of these
emergency kits disclosed no inventorial discrepancies or inoperable
equipment. The inspector reviewed documentation which showed that
quarterly inventories of these kits were performed as required during
the period July 1991 through October 1992. These records indicated
that identified problems were corrected expeditiously.
The inspector reviewed records of the monthly test of the facility's
fire detection / alarm system for the period October 1991 through
- October 1992. Also reviewed were records of the monthly test of the
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criticality alarm system for the period January - October 1992.
According to the records, no problems or discrepancies were noted
during these tests.
No violations or deviations were identified.
5.
Coordination with Offsite Support Organizations (82745)
Section 8.3 of the EPP required biennial updating of agreement letters
with respect to arrangements for hospital, medical, and other
emergency services. The only such agreement currently being
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maintained was with Grady Memorial Hospital,- and.had been-renewed on
September 15, 1992.
Section 10.1 of the EPP specified biennial-training of the Georgia
Tech. Police and the Atlanta Fire Department in radiation safety and
the licensee's Emergency Procedures. As documented _in NRC Inspection
Report No. 50-160/91-04 (Paragraph 5), such training was provided
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during 1991 and will therefore be due again in 1993.
No violations or deviations were identified,
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6.
Emergency Response Drill (82745)
The EPP required the conduct of an onsite emergency drill annually to
test the adequacy of Emergency Procedures and to ensure that emergency
organization personnel-are familiar with their duties; also, at least
biennially,-a drill must contain provisions for testing communications
and notification procedures with offsite support groups.
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On November 9, 1992, the licensee conducted the annual emergency
drill, which included participation by the Georgia Tech. Police, the
Atlanta Fire Department, and Grady Memorial Hospital.
The scope,
objectives, and scenario for the drill are delineated in the
attachment to this report.
The drill commenced at 1:58 p.m. and
terminated at 2:55 p.m.
The scenario involved a fire in the Storage Barn, a building separate
from the main facility structure. A smoke generator was used to
simulate combustion products, although this unit had ceased
functioning by the time the inspector arrived at the Storage Barn just
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prior to the start of the drill, and only a slight trace of smoke was
present. A licensee staff member used a source of heat to actuate the
fire detector in the Barn at 1:58 p.m.
The fire alarm sounded
throughout the facility, resulting in an evacuation of personnel to
the parking lot, where an accountability was conducted and quickly _
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identified one person as missing.
The Georgia Tech. Police arrived .
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promptly (by 2:00 p.m.), since their headcuarters was located near the
Neely Nuclear Research Center and receivec direct indication of any
fire alarm occurring at the licensee's facility.
The activation and operation of the ECC by the ED and staff were
evaluated by the inspector and determined to be effective in accident
investigation and mitigation. The inspector also observed the
response by Health Physics personnel in surveying the incident area
for abnormal radiation levels and/or contamination.
Their response
was prompt, and they demonstrated good survey techniques in accordance
with standard Health Physics practices.
The ED declared an Operational Event at-2:21 p.m. based upo_n the
criterion, " Minor fire or explosion non specific to the reactor or its
control systems" (EPP Table I, " Emergency Classification Guide").
The
licensee and the inspector had anticipated that the event would
probably be classified as a NOVE based upon the classification
criterion, " Prolonged fire or minor explosion within facility but non-
specific to the reactor or its control systems." However, because of
the failure of the smoke generator, the players had no indication that
a " prolonged fire" was occurring as intended by the scenario.
Since
the drill was being allowed by the licensee to simply run its course
without anyone actually serving to control the scenario events, there-
was no established mechanism for informing 31ayers-that the fire was
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supposed to be continuing and generating su)stantial quantities of
smoke. After the drill, the inspector discussed with licensee
management the desirability of instituting the standard practice of
using at least one person as drill controller.
The function of a
controller is to insure that the scenario stays "on track" in the
event of equipment failures or other unforseen circumstances.
In this
drill, a designated controller could have informed licensee staff
arriving at the Storage Barn that the building was filled with smoke
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and that the visibility inside was poor in order to communicate the
continuing " existence" of a fire.
Licensee management agreed during
the exit interview to consider the use of a controller for future
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drills.
This issue will be tracked as an Inspector follow-up Item
(IFI).
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IFI 50-160/92 04 02:
Consideration of the use of a drill controller.
As required by the EPP, a critique was conducted after the drill and
was observed by the inspector.
The critique was determined to be
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thorough, with pertinent input from drill participants as well as
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evaluators. The licensee's follow up of critique findings will be
reviewed during a future inspection.
No violations or deviations were identified.
7.
Action on Previous NRC Inspection findings
a.
(Closed) Exercise Weakness 50 160/91-04 01:
Excessive
prompting prevented a true demonstration of the alternate ED's
capabilities.
No prompting of player responses was observed during the
current drill.
b.
(Closed) IFI 50 160/91-04-03:
Review and identify a backup
ECC.
The licensee had tentatively identified the nearby Georgia
Tech. Police Department headquarters as a backup ECC, although
this arrangement was not yet formalized or incorporated into
the EPP.
The licensee planned to pursue this development to an
appropriate conclusion,
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c.
(0 pen) IFI 50-160/91-04-05: Review the_ notification procedure
for NRC notification time limits to ensure consistency with
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Licensee management stated that they had planned to review'this
matter but had not yet done so.
They agreed to give near-term
consideration to this item.
8..
_ Exit Interview
The inspection scope and results were summarized on November 10, 1992
with those persons indicated in Paragraph I'
The inspector described
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the areas inspected and discussed in detail the inspection results
listed below.
Proprietary information is not contained.in this
report.
The-facility Director. expressed disagreement with the
characterization of the-violation as a repeat violation, although he
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stated that he had taken corrective action for the previous (noncited)
violation strictly on the basis of the exit interview rather than the
discussion in the inspection report.
Item Number
Cateaory. Description, and Reference
50-160/92-04-01
Repcht Violation - Failure to have an
adequate procedure for implementing
certain EPP notification requirements
(Paragraph 2).
50-160/92-04-02
IFl - Consideration of the use of a drill
controller (Paragraph 6).
Attachment (1 page):
Scope, Objectives, and
Scenario for l'.2 Drill
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