ML20137E087

Forwards Response to Items Noted in Emergency Preparedness Insp Rept 50-062/85-02 on 850819-23.Corrective Actions:Ltrs of Commitment & Emergency Plans Requested from Offsite Support Organizations & Rescue Squad Tour Scheduled

ML20137E087
Person / Time
Site:	University of Virginia
Issue date:	11/07/1985
From:	Mulder R VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To:	Verrelli D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8511270199
Download: ML20137E087 (7)

Text

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UNIVERSITY OF VIRGINIA r Am 1 DEPARTMENT OF NUCLEAR ENGINEERING AND ENGINEERING PIlYSICS NU :LEAIL K CTOR FACILITY k 1I1 j SCIIONN . dINElR b AND APPLIED SCIENCE 1 & 2 F CIIARLOTTESVILLE, VA 22901 November 7, 1985 Telephone: 804-924-7136 Mr. David M. Verrelli, Chief Reactor Projects Branch 1 Division of Reactor Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Atlanta, GA 30323

SUBJECT:

Licensee reply to Report No. 50-062/85-02 of the August 19-23, 1985 NRC Emergency Preparedness Inspection

Dear Mr. Verrelli,

Please find in attachment our written statement describing the results of our consideration of the NRC suggested emergency preparedness improvement items listed in the inspection report. This response was While we always will honor an prepared at the request of the NRC. requests, we are surprised that of 10the NRC has c CFR as the basis for its request. The Commission should not need to

" determine whether or not the license should be modified, suspended or revoked" in view of statements made in your letter that "Within the scope of the inspection, no violations or deviations were identified,"

and that "We recognize that an explicit regulatory require-ment pertaining to each (suggested improvement) item identified in Appendix A (to the inspection report) may not currently exist."

The NRC appraisal of our emergency plan and procedures was very useful. Many suggestions were made and we have taken positive action on most of them. In making our evaluation on whether or not to act on each suggested emergency preparedness improvement, we considered regulatory requirements, our Facility's physical characteristics (size, lay-out, numberofpersonnel,etc.) practicality, relevance,costfactors, logic and so on. We expect that our response will meet with your approval.

Should any questions concerning these matters arise, please contact us.

Cor h you s, Sworn to and seb:n!bd bafee me thh /

tayof V 19 MA "

Wass my M ' '

!. Robert Udo Mulder, Director U.Va. Reactor Facility

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Enclosures:

Licensee Reply Clarification of Topics Raised in the Inspection Report My C;manion Epfc3 qO g 1 I

8511270199 851107 i PDR O ADOCK 05000062 ((8 i PDR

Licensee Reply to NRC Suggested Emergency Preparedness Improvement Items Item 50-062/85-02-01 All off-site emergency support organizations included in our Etergency Plan have been contacted and asked to send us current letters of commitment and their own emergency response plans. Where appropriate, their personnel have been asked to tour our Reactor Facility and to discuss expected emergency functions with our staff. So far, 8 out of 10 organizations have replied. The response plans have been reviewed for conformity with our own, in each case. Until now 37 members of the UVA Police, and 44 members of the Charlottesville Fire Department have recently toured our facility in 15 tours, consuming an estimated 45 total man-hours of our staff time. Members of the rescue squad and other local police forces will still be trained / retrained and given a facility tour.

The UVA Environmental Fealth and Safety Office is formalizing its part of the training and retraining program for dispatchers and Charlottesville and Albemarle County Police departments. This effort should be completed in the near future.

Items 50-062/85-02-02 and /85-02-03 As already stated, refamiliarization facility tours for current rescue squad members have been scheduled. On a biannual frequency and in coordination with UVA EH&S, all squad members will be asked to come to the facility for refamiliarization and retraining. New squad members may be sent by their organizations to take these tours on an informal basis, at any time between these periods, however this facility's management can not make a commitment to the effect that this will occur.

During the recent tours, expected response functions were discussed with the offsite personnel. As suggested, the UVA reactor emergency organization was described. This will continue to be done in the future.

Item 50-062/85-02-04 Appropriate corrections have been made to the Emergency Plan Implementing Procedures (EPIPs-6,-7, and -8) to ensure agreement with the Emergency Plan regarding responsibility for notification. The total review of EP and EPIP's was completed on 8/30/85 and the changes that were made met with the approval of the Reactor Safety Committee.

Corrected replacement sheets were sent to all holders of official copies of the EP and EPIP's on 9/30/85. We have received the NRC acknowledgment of receipt.

Item 50-062/85-02-05 The list of emergency personnel and their telephone numbers, which is part of the " Emergency Actions" rosters, (and only the list) has been posted diongside the "public" telephones in the facility. Copies of the list were given to all faculty, to be kept with their private U.Va.

phone directory. It is the responsibility of the faculty to keep

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their list within easy reach. . Updated or revised phone lists will be posted or distributed each semester or earlier, as needed. Emergency Action duty roster telephone numbers will continue to be posted on the numerous bulletin boards throughout the facility. These boards are within short distances of the nearest phone and the roster sheets can easily be grabbed when needed and carried to the nearest phone in the event that this were necessary.

Item 50-062/85-02-06 The schedule for ensuring that the listed Emergency Action duty roster telephone numbers are kept current will be semestral and a file for documentation of the same will be maintained.

Item 50-062/85-02-07 The need for moving the radio and walkie-talkies to the primary Emergency Support Center was assessed.

It was concluded that this action was not necessary as well as undesirable. The (non-dedicated) Emergency Support Center within the Facility may be either the " Front Office" or the "HP Office." The HP Office is small and is already filled with file cabinets and instrumen-tation. The Front Office is likewise crowded, with 3 secretaries and 1 work-study student, and is accessible to all faculty and students. The radio equipment might be subject to tampering, if stored there. The 2-way radio and 3 walkie talkies are better kept in the offices where they are at present. The 2-way radio and one walkie talkie are presently kept in the SR0 Office, across the hall from the Front Office.

Essentially no time would be lost in moving them to the Front Office, or another location, should the need arise. The size of the facility is, of course, much smaller than a power plant.

The walkie talkies have been tested on a monthly frequency since their purchase, in conjunction with the weekly 2-way radio checks. We are maintaining formal documentation to that effect.

As stated, the evacuation a' arm is scheduled for testing once every six months. Henceforth, the pool low water level alarm and radiation alarms used on-site will be tested in conjunction with the evacuation alarm.

Item 50-062/85-02-08 The EAL tables.in EPIP-1, the allowable emergency dose limit in EPIP-10 and the emergency plan values have been made consistent. The review performed by the NRC and the Reactor Facility staff's own review which was finalized on 9/30/85 ensure that reasonable consistency between the plan and EPIPs now exists.

Item 50-062/85-02-09 A copy each of the Emergency Plan, EPIP's, and Emergency Action roster list was placed in the Front Office (possible ESC). Similar documentation is available in the HP Office (second choice for ESC).

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1 Item 50-062/85-02-10 The white rope that had been stored in the emergency lockers has been replaced with magenta-yellow " radiation rope", which was available at the_ facility in a storage room, althcugh this fact was not realized at the time of the inspection.

Item 50-062/85-02-11 Additional stocks of protective clothing and dosimeters will be esttblished in the emergency lockers for use by off-siM support personnel. This stock of clothing can't be made too large since there is limited space available in the lockers. In the. case of the dosimeters, their number is limited by budgetary and calibration time expenditure considerations. We believe, given that ours is a non-power reactor facility, that we would not be required in the event of an emergency to send many offsite personnel into radiation areas. The size of the emergency off-site support organization is fairly large and we can't be expected to provide supplies for all!

The number of respiratory protection masks stored in the emergency lockers has been increased. Unused masks have aeen found throughCut the facility. These have been cleaned, their filters exchanged and checked.

However, we believe that the two available Scott air packs and spare bottle are sufficient for-our needs. We can count on the rescue squad to provide their own self-contained breathing apparatus.

It was noted during the inspection that the emergency locker instrument calibration due dates did not coincide with the quarterly locker content checks. We don't feel that this is or has been "a problem", since calibrations have been made quarterly as required. The two due dates have now been clearly posted on the externals of both lockers, and the locker check due date will be adjusted to occur soon after the instrument calibration dates.

Item 50-062/85-02-12 The contents of the decon kit have been expanded, although the orfJinal basic detergent, water and rag capabilities were felt to be adequate.

A formal agreement with U.Va. EH&S has been obtained, assuring their assistance in this and other emergency areas. This might be considered superfluous since their support was assumed in the formulation of the Emergency Plan and Implementing Procedures, but it has now been provided for completeness in record keeping.

Item 50-062/85-02-13 After considering the suggestion associated with this item, it was decided that evacuation routes and maps showing locations of assembly areas will not be posted. Please inform us if this is contrary to explicit regulatory requirement. We believe not.

. .~ .

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4 Our facility is small, with dimensions of cbout 15 m x 60 m per floor. There are three stories in the building and the hallways run in the same direction on each floor and are linked by stairways at both ends. There is a single entrance by the Front Office, which also serves as an exit. Another exit exists (for emergencies only) at the other end of the building. In short, whatever the flow pattern in the hallway, an exit is quickly reached and the primary assembly area is visible' from both.

Practice evacuations and regular emergency. training of personnel have established both the desired direction of traffic flow and the locationoftheinitial(primary)assemblyarea. An individual who nevertheless went the wrong way would be called or attracted back to this staging area. Visitors (even NRC inspectors) are escorted while in the facility by trained personnel. Finally; the building is checked for strays immediately following an evacuation call.

At this point it may be worthwhile to state that while measures such as the one suggested are appropriate at nuclear power plants (complex sites an which many large buildings with confusing lay-outs are located), they represent over-kill when applied to research facilities such as ours. A balance must be struck between reasonable steps to ensure safety and superfluous measures, some possibly associated with negative PR messages. Our facility is visited by many people over the course of a year. During our tours we attempt to convince them that, perhaps contrary to their impressions, nuclear energy as used for power and research is not uncommonly dangerous. This point is already difficult to make due to the many cautionary signs posted throughout our facility.

Item 50-062/85-02-14 EPIP-14, Evacuation, is being revised to be consistent with EPIP-19, Reentry. The removal of required dosimetry and emergency instrumentation from the emergency lockers will be addressed. After approval of these additional steps by our Reactor Safety Committee, the corrected pages will be distributed to permanent holders of official copies of the EP and EPIP. This action will very likely be completed by January 31, 1986.

Item 50-062/85-02-15 Many of the comments made by this licensee associated with the response to item 50-062/85-02-13 apply here also. It has been decided that the primary and secondary assembly areas will not be posted.

Please inform us if this is contrary to explicit regulatory requirements. We believe not. Adequate supervision of evacuees by reactor staff assuret that they will be assembled at these areas as necessary, even if they forget their training instructions.

Item 50-062/85-02-16 At the present time more than one staff member is qualified in medical first aid measures.

Item 50-062/85-02-17 This item has already received considerable staff attention.

Sub-Items d), e),_f) and h) have been completely formalized and have been executed to a large degree. Efforts on formalizing records for sub-items a), b), c) and g) are continuing. The objective of conso-lidating the training information into a training program manual, represents an effort that is time consuming and equivalent to that which was necessary to formulate the Emergency Plan itself. (Please remember, our staff is small when compared to that of power plants!). In time, a continuing strengthening of the training / retraining program will occur.

It is relevant to cite some examples of the difficulties which we have encountered in putting the training program into practice. First, many dozens of off-site personnel need to be identified for training. We estimate that we will retrain or train approximately 160 offsite personnel in total! Such training must be coordinated so as not to interrupt our facility's operation nor that of the trainee's. Hence, j only several off-site personnel are able to tour and visit the facility at any one time. Often, the visitors are called on to respond to an ,

actual emergency before their training here is finished. All this places a tremendous strain on our. limited resources.

Item 50-062/85-02-18 Off-site support groups were recently contacted and current response and assistance plans requested. So far, 7 out of 8 agencies that have such a plan responded. These plans were reviewed and found compatible with our own.

Every two years, beginning this fall, these groups will be contacted to verify this coordination of response plans.

Item 50-062/85-02-19 Letters of agreement were requested from 10 off-site support agencies identified in our Emergency Plan. We have had a positive response from 8 of these agencies.

Clarification of Topics Raised in the Inspection Report Report Section 1.2.2, Police Protection, second paragraph We would like to state that facility tours are given by the Reactor Facility Staff and not by the UVA Environmental Health and Safety Department. This department provides the Reactor Facility with HP services. Included in these services is the training of all personnel in HP related emergency topics. Tours will be coordinated with UVA EH&S to complement their training efforts.

Report Section 2.2.1.2, Equipment, third paragraph In this paragraph, equipment were referenced that have alarm set-points. Among these are area monitors located within the facility, with alarm set-points set as follows:

Monitor Location Set-Point UVAR Reactor Bridge 30 mR/h UVAR Reactor Face 2 mR/h UVAR Demineralizer Room 300 mR/h UVAR Hot Cell 2 mR/h CAVALIER T?.nk Top 15 mR/h CAVALIER Reactor Pit 25 mR/h CAVALIER Peactor Control Room 5 mR/h The information presented to the inspectors was that if these monitors reached their set points, the extrapolated (calculated) dose rate at the site boundary would be essentially undetectable. The closest point at the fence (site. boundary) is - 70 meters or - 228 feet. Multiplying the above dose rates by the inverse square distance factor alone yields very low values. Actual dose rate values at the site boundary would be measured directly with portable si my meters, needing no conversion factors.

Additionally, there are two Argon gas monitors for the UVAR reactor located inside the reactor room and the duct leading from the experimental area. Their set points are set such that the activity at the site boundary would be:

a) 1/10 MPC for unrestricted areas for the reactor room monitor b) 1/5 MPC for unrestricted areas for the duct monitor.

Report Section 3.2, Drills, first paragraph Evacuation and accountability drills at the Reactor Facility were in past years conducted up to two times each year. The last biannual emergency exercise which included off-site support was conducted last year (1984) in the fall.