ML20195C900

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Notifies of Changes & Additions in Emergency Plan for Univ of Az Nuclear Reactor Lab.Arising from Annual Review of Emergency Plan Pursuant to NUREG-0849,listed Changes/ Additions Have Been Made.Rev 8 to Emergency Plan,Encl
ML20195C900
Person / Time
Site: 05000113
Issue date: 11/06/1998
From: Williams J
ARIZONA, UNIV. OF, TUCSON, AZ
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195C905 List:
References
RTR-NUREG-0849, RTR-NUREG-849 NUDOCS 9811170236
Download: ML20195C900 (14)


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Nuclear Reactor Laboratory 1}ir.UNIVERSTTY OF Engineering Building (20) John G. Williams, Director P. O. Box 210020 Tucson, Arizona 857210020 IZONA e - it:is a6is aes.e sr.rize .ea-voice (5 )621 9729 l

NovemberI,1998 l

U. S. Nuclear Regulatory Commission  ;

Document Control Desk  !

Mail Stop P1-37 One White Flint North 11555 Rockville Pike 10CFR50.54(q)

Rockville, MD 20852 10CFR50.4

Subject:

Facility License No. R-52, Docket 50-113 Change in the Emergency Plan for the University of Arizona Nuclear Reactor Laboratory Notification is hereby made of changes and additions in the emergency plan for the University of Arizona Nuclear Reactor Laboratory.

Arising from the annual review of the emergency plan pursuant to NUREG-0849, the following changes / additions have been made:

a. First page of Table of Contents - added section 3.2.5
b. Page 2, section 1.4 - changed "100 kilowatts" to "110 kilowatts"
c. Page 10, section 3.2 - added section 3.2.5
d. Page 20, section 8.2 - added locations of personnel monitoring equipment, fire alarm annunciator panel and earthquake sensor,
e. Page 20, section 8.4 - changed " Room 118" to " Room 120"
f. Page 21, section 9.0 - added means for establishing additional recovery procedures as needed.
g. Page 22, section 10.4 - added " Tucson Fire Department and the ambulance service" These changes / additions have been reviewed by the Reactor Committee pursuant to 10CFR50.54(q) and the Committee has determined that the changes / additions do not

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' decrease the effectiveness of the Emergency Plan. The changes / additions appear on five l pages of the Emergency Plan and differences in pagination required reprinting of the ,

entire document. OgV Two copies of the change pages are submitted: one showing editorial marks (deletions struck through/ additions in italic print) and one clean version as revised. Also, one 9811170236 PDR ADOCK 0500011 981106W'3

_ PDR;

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l l November 4,1998 2 l

complete copy of revision 8 of the Emergency Plan for the University of Arizona Nuclear Reactor Laboratory.

These change pages respectfully submitted on behalf of the University of Arizona, by r ,

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JohdG. Williams, Director n/t/gs(

Date Nuclear Reactor Laboratory cc: Non-Power Reacton :nd Decommissioning Project Directorate, USNRC (2) l Mr. Marvin Mendonca, Project Manager, USNRC Dr. M. Cusanovich, Vice President for Research, University of Arizona CWPFKRWPWIN\WPDOC5\11UGA\BMEltG8CIDEP111 l

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' C4m p N Eorrog g i Wot s.s TABLE OF CONTENTS L

1.0 I ntroduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.1 Application ............................................... 1

1. 2 O bjective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.3 Site Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 J

1.4 Reactor Facility Descriptions ................................. 2 1.5 Reactor Utilization and Operating Frequency . . . . . . . . .. . . . . . . . . . . . . 3

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2.0 Defi niti ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . . . . 3 1

1 3.0 . Organization and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3.1 Emergency Organization .................................... l 5

3.1.1 Emergency Director ................................. 6 3.1.2 Emergency Coordinator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1.3 Reactor Operator ............ ...... ............... 7 3.1.4 N RL Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

.. 3.1.5 University News Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1.6 Radiation Control Office .............................. 7 S

3.1.7 Nuclear Reactor Laboratory Personnel . . . . . . . . . . . . . . . . . . . 7 3.1.8 University Police . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4

3.1.9 Police Dispatcher . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 l 3.1.10 Fire Emergency Services ............................ 8 l 3.1.11 University Hospital ................................. 9 3.1.12 Off-Site Law Enforcement Agencies . . . . . . . . . . . . . . . . . . . . 9 3.2 Coordination with and Notification of Other Agencies .............. 9 3.2.1 U.S. Nuclear Regulatory Commission . . . . . . . . . . . . . . . . . . . . 9 I 3.2.2 Arizona Radiation Regulatory Agency ......... .. ..... 9  !

3.2.3 Local Government Agencies . . . . . . . . . . . . . . .......... 10

3.2.4 University Department of Risk Management Safety . . . . . . . 10 3.2.5 AuthenticNotification. ...................................10

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EMERGENCY PLAN page 2 I

the University of Arizona Main Campus. A map cf the main campus is attached as Fig.1. The campus is centrally located in the city of Tucson, Arizona, and is bounded roughly by East Speedway Boulevard, North l Campbell Avenue, East Sixth Street, and North Park Avenue, which are h shown in Fig.1.

I l Three adjacent rooms in the Engineering Building are permanently established us the Reactor Laboratory and are designated a controlled

[ access area. These are: Room 122, the Control Room: Room 124, the Reactor Room; and Room 124A, an equipment storage and experiment l setup room which also houses a natural uranium / water subcritical assembly. Figure 2 is a plan of the north wing of the building, showing

! these rooms.

13 Reactor Facility Descriotions L

The UARR is a TRIGA Mark I licensed to operate at a maximum l steady-state thermal power of 400110 kilowatts and in the pulse mode I with reactivity insertions up to $2.50.

The reactor core is located in a swimming pool type tank which is 21 feet deep and 6.5 feet in diameter, located below grade in Room 124.

!' The tank contains approximately 5000 gallons of demineralized water.

The reactor fuel consists of standard stainless-stee! clad TRIGA fuel l elements, instrumented elements, and fuel followers for the control rods.

The U-235 enrichment of the fuelis less than 20 percent. Irradiated fuel is located either in the reactor core or in safe geometry storage racks in j the reactor pool.

The reactor pool water provides shielding of the gamma radiation

produced during operation and from the irradiated fuel. During operation, the water is cooled by refrigeration coils submerged in the pool. A pump, ,

I l~ filter, and demineralizer unit are used to maintain water purity. Inlet and outlet pipes extend from the reactor pool to the demineralizer system.  ;

Vent holes have been drilled in the intake and outlet pipes approximately two feet below normal pool-water level to assure that any siphoning action l

[ would be broken at this level of pool water. This depth of water is j sufficient to provide shielding for the irradiated fuel.

aanmoo. .a University of Arl20no Research Reccfor uo , ,, .

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l EMERGENCY PLAN page 10 l shall relay the information as specified in the Police Dispatcher

! procedures.

l 3.2.3 Local Government Aaencies The City of Tucson and Pima County offices will be notified after l

identification of Emergency Action Levels corresponding to the emergency class " Notification of Unusual Event" or greater, and of any incidents which may have caused or threaten to cause an uncontrolled l

release of radioactive materials that results in a projected off-site dose of 1 Rem whole body or 5 Rem thyroid.

3.2.4 University Deoartment of Risk Manaaement Safety The Universty of Arizona Department of Risk Management and Safety shall be notified of any emergency involving fire, explosion, or injury of personnel. This notification will be done through the University Police Dispatcher.

3.2.5 AuthenticNotifications The Emergency Director, or his designee, shall confirm that authentic i notifications have actually been received by support agencies as specified in 3.2.1, 3.2.2, 3.2.3 and 3.2.4.

3.3 Termination of an Emeraencv The Emergency Director is responsible for declaring the termination of an emergency. Prior to termination of an emergency the Emergency director shall conclude that no foreseeable subsequent events could cause the action limits of the emergency to be exceeded. He will verify that all areas to be reopened to personnel or the general public meet the requirements of 10CFR20 for occupancy. He will also confirm that areas to be restricts

  • entry or which require controlled access are clearly posted.

3.4 Authorization for Reentry The Emergency Director shall authorize any reentry into the reactor l laboratory or portions thereof previously evacuated during an emergency.

l It shall be the responsibility of the Director of Radiation Control to establish reentry requirements, provide additional personnel monitoring, 1

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l EMERGENCY PLAN page 20 radioisotope identification. A portable high volume air sampint ter collection of airbome particulate radioactivity is available in the emergency kit. Self-reading dosimetersfor use by emergencypersonnel are available in the emergency kit and also in the control room. A pool level alarm

indicator and fuel temperature indicator in the control room can provide l system or status information for emergency assessment. The Engineering

' Building is equipped with smoke detectors, sprinkler heads andfire alarm pull l stations. An annunciatorpanelindicating the source of alarm signals is located in the main entrance. lobby of the Engineering Building. An earthquake sensor, l which initiates a reactor SCRAM, is located on the north null of the reactor room. Earthquake information may be obtainedfrom the University ofArizona Geosciences Department, which operates earthquake monitoring systems.

8.3 First Aid and Medical Facilities Accidents resulting in personal injury without contamination will be j handled by administering first aid and summoning an ambulance if l needed. In the event of injury requiring medical treatment with contamination, the individual will be transported to the University Hospital, j which is located about 0.4 miles from the Engineering Building. Either I NRL or RCO personnel will accompany the contaminated injured victim to j the hospital, which has emergency procedures for this situation.

Requests for ambulance transport shall be made through the University Police Dispatcher, who will contact the ambulance service with which a

[ support agreement has been made.

8.4 Decontamination Facilities I

Decontamination of personnel at the NRL can normally be handled in the NRL or in the Radiochemistry Laboratory, Room 164, which is across the hall from the NRL. Both laboratories have sinks with soap, paper towels, and contaminated waste containers at hand. In an emergency when the facilities of these laboratories are not available, Room 448120, located between the NRL and the ESC, may be used for segregation of contaminated personnel and for decontamination.

Radiation Control Office personnel shall be responsible for decontamination of individuals involved in an emergency.

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EMERGENCY PLAN page 21 8.5 Communications Systems Telephones are located in the NRL Control Room, at the ESC, and elsewhere in the Engineering Building, and may be utilized during emergencies. Word-of-mouth communications will provide a backup for intemal communications. The University Police can also be summoned by activation of the intrusion alarm system by pressing a button in the

' NRL Control Room. University Police maintain a radio system for communication between police officers, the dispatcher, and patrol cars.

9.0 Recoverv Ooerations Restoring the NRL to a safe operating condition after an emergency shall be the rt,sponsibility of the Emergency Director. Operations necessary to restore the facility will be under his direction. Radiation Control Office staff shall survey, supervise decontamination, and ascertain that contamination and radiation levels

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within 'the affected areas are within acceptable limits. The' Reactor Laboratory Director shall assess resultant damages, direct repairs and review the emergency. Termination of the Emergency shallrequire completion of the actions specified in section 3.3. Completion of recovery operations shall include all measures specified in this section and execution of additional written procedures as may be needed, after approval by the Reactor Committee. With advice from the Reactor Laboratory Director, the University Reactor Committee will authorize continued operation of the reactor.

10.0 Maintainino Emeroencv Preoaredness 10.1 Trainina NRL operators and staff, and members of the Radiation Control Office with emergency response responsibilities will complete an initial training program and an annual review program. For NRL Operators, this may be a part of the Reactor Operator Requalification Program. Specific training in protective action decision making will be included in the initial and periodic training for those individuals who may serve as Emergency Director during an emergency. Support groups will receive training commensurate with their degree of potential involvement.

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EMERGENCY PLAN page 22 10.2 Conduct of Drills and Exercises On-site emergency drills will be conducted annually to test the adequacy of emergency procedures and to ensure that emergency organization personnel are familiar with their duties. These drills will include the use of appropriate emergency equipment, and will include, as a minimum, testing of the communications links with the University Police Department and the Radiation Control Office.

10.3 Critioues of Drills and Exercises At the conclusion of each drill a critique to identify deficiencies shall be held by the participating NRL staff and observers and may include members of other support and emergency groups. Observer and participant's comments concerning areas needing improvement shall be evaluated and consideration given to possible changes in the plan and l procedures.'

10.4 Emeroencv Plan Review and Uodate The Emergency Plan shall be revised and updated as required i based on drill results or changes in the facility and shall be audited annually by the Reactor Supervisor. This audit shall be reviewed by the

. Reactor Committee to ensure the plan is adequate and up-to-date.

Letters detailing arrangements with the Radiation Control Office, the University Police, and University Hospital, Tucson Fire Department and the L ambulance service shall be renewed annually, at intervals not to exceed 15 p months. Applicable portions of the plan, agreements, and implementing l procedures shall be distributed to the University Police, the Radiation Control Office, and the Arizona Radiation Regulatory Agency, and any revisions to implementing procedures affected by the plan shall be approved by the Reactor Committee and sent to authorized recipients within 30 days after the revised plans have been issued.

10.5 Emeroency Eauipment Maintenance and Surveillance Surveillance of emergency supplies insures availability and proper

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condition for immediate use. The Emergency Coordinator is responsible

for scheduled surveillance of emergency supplies. Contents of the j eenuaw a University of Aritono Rossorch Reoctor -, ,m

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C/fAdGC PAses I-- h l'

L TABLE OF CONTENTS i

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' 1.0 I ntrodu cti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 j 1.1 Application ............................................... 1 i I

1. 2 O bjective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-L 1.3 Site Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 1 L 1.4 ' Reactor Facility Descriptions . . . . . . . . . . . . . . . . ................. 2

.1.5 Reactor Utilization and Operating Frequency . . . . . . . . . . . . . . . . . . . . . 3

. 2.0 Defin i tic is . . . . . . . . . . . . ........................................ 3 i

3.0 _ Organit tion and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5  ;

l 3.1 L.nergency Organization .................................... 5 I 3.1.1 Emergency Director . . . . . . . . . . . . . . . . ................. 6 3.1.2 Emergency Coordinator . . . . . . . . . . . . . ................. 6 3.1.3 Reactor Operator ................................... 7 3.1.4 ' N RL Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1.5 University News Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - 7 3.1.6 Radiation Control Office . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 L

3.1.7 Nuclear Reactor Laboratory Personnel . . . . . . . . . . . . . . . . . . . 7 3.1.8 University Police . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3.1.9 Police Dispatcher . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3.1.10 Fire Emergency Services . . . . . . . . . . . ................. 8 3.1.11 University Hospital . . . . . . . . . . . . . . . . ................. 9

' 3.1.12 Off-Site Law Enforcement Agencies . . . . . . . . . . . . . . . . . . . . 9 3.2 Coordination with and Notification of Other Agencies .............. 9 g 3.2.1 U.S. Nuclear Regulatory Commission . . . . . . . . . . . . . . . . . . . . 9 l 3.2.2 Arizona Radiation Regulatory Agency . . ................. 9

[ 3.2.3 Local Government Agencies . . . . . . . . . ................ 10 L

3.2.4. University Department of Ris'< Management Safety . . . . . . . 10

, 3.2.5 Authentic Notification . . . . . . . . . . . . . . ...... ..... ... 10 t

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I EMERGENCY PLAN page 2 the University of Arizona Main Campus. A map of the main campus is attached as Fig.1. The campus is centrally located in the city of Tucson, ,

, Arizona, and is bounded roughly by East Speedway Boulevard, North Campbell Avenue, East Sixth Street, and North Park Avenue, which are shown in Fig.1.

l Three adjacent rooms in the Engineering Building are permanently established as the Reactor Laboratory and are designated a controlled access area. These are: Room 122, the Control Room; Room 124, the j Reactor Room; and Room 124A, an equipment storage and experiment j setup room which also houses a natural uranium / water subcritical A

assembly. Figure 2 is a plan of the north wing of the building, showing these rooms.

1.4 Reactor Facility Descriotions The UARR is a TRIGA Mark I licensed to operate at a maximum steady-state thermal power of 110 kilowatts and in the pulse mode with reactivity insertions up to $2.50.

The reactor core is located in a swimming pool type tank which is 21 feet deep and 6.5 feet in diameter, located below grade in Room 124.

The tank contains approximately 5000 gallons of demineralized water.

The reactor fuel consists of standard stainless-steel clad TRIGA fuel elements, instrumented elements, and fuel followers for the control rods.

The U-235 enrichment of the fuel is less than 20 percent. Irradiated fuel is located either in the reactor core or in safe geometry storage racks in the reactor pool.

The reactor pool water provides shleiding of the gamma radiation produced during operation and from the irradiated fuel. During operation,

, the water is cooled by refrigeration coils submerged in the pool. A pump, filter, and demineralizer unit are used to maintain water purity. Inlet and outlet pipes extend from the reactor pool to the demineralizer system.

l Vent holes have been drilled in the intake and outlet pipes approximately two feet below normal pool-water level to assure that any siphoning action l

j woule i broken at this level of pool water. This depth of water is suffica..it to provide shielding for the irradiated fuel.

fL eusmmm e University of Arizono Research Reactor - . , , -

EMERGENCY PLAN page 10 shall relay the information as specified in the Police Dispatcher i procedures.

)

3.2.3 Local Government Acencies j The City of Tucson and Pima County offices will be notified after i identification of Emergency Action Levels corresponding to the l

emergency class " Notification of Unusual Event" or greater, and of any incidents which may have caused or threaten to cause an uncontrolled release of radioactive materials that results in a projected off-site dose of j 1 Rem whole body or 5 Rem thyroid. l 3.2.4 University Deoartment of Risk Manaaement Safety The University of Arizona Department of Risk Management and 2

Safety shall be notified of any emergency involving fire, explosion, or injury of personnel. This notification will be done through the University Police Dispatcher.

3.2.5 Authentic Notifications The Emergency Director, or his designee, shall confirm that authentic notifications have actually been received by support agencies l as specified in 3.2.1,3.2.2,3.2.3 and 3.2.4. I 3.3 Termination of an Emeraency I The Emergency Director is responsible for declaring the l termination of an emergency. Prior to termination of an emergency the l Emergency director shall conclude that no foreseeable subsequent events could cause the action limits of the emergency to be exceeded. He will verify that all areas to be reopened to personnel or the general public meet the requirements of 10CFR20 for occupancy. He will also confirm that areas to be restricted to entry or which require controlled access are clearly posted.

1 3.4 Authorization for Reentry The Emergency Director shall authorize any reentry into the reactor laboratory or portions thereof previously evacuated during an emergency.

It shall be the responsibility of the Director of Radiation Control to establish reentry requirements, provide additional personnel monitoring, menamamu UnNsrsity of Ati2Ono Reseonch Reoctor -m

EMERGENCY PLAN page 20 l l Engineering Building. If necessary, additional counting equipment and survey instruments are available from the Radiation Control Office and i

other University facilities. Both the Nuclear Reactor Laboratory and the l Radiation Control Office maintain gamma ray spectrometers for

! radioisotope identification. A portable high volume air sampler for j

( collection of airbome particulate radioactivity is available in the emergency kit. Self-reading dosimeters for use by emergency personnel '

are available in the emergency kit and also in the control room. A pool l

, level alarm indicator and fuel temperature indicator in the control room ,

can provide system or status information for emergency assessment. The l

, Engineering Building is equipped with smoke detectors, sprinkler heads and fire alarm pull sizdons. An annunciator panel indicating the source of ]

alarm signals is located in the main entrance lobby of the Engineering

, Building. An earthquake sensor, which initiates a reactor SCRAM, is located on the north wall of the reactor room.' Earthquake information may be obtained from the University of Arizona Geosciences Department, which operates earthquake monitoring systems.

8.3 First Aid and Medical Facilities Accidents resulting in personal injury without contamination will be handled by administering first aid and summoning an ambulance if l needed. In the event of injury requiring medical treatment with contamination, the individual will be transported to the University Hospital, which is located about 0.4 miles from the Engineering Building. Either j NRL or RCO personnel will accompany the contaminated injured victim to the hospital, which has emergency procedures for this situation.

Requests for ambulance transport shall be made through the University Police Dispatcher, who will contact the ambulance serWee with which a support agreement has been made.

8.4 Decontamination Facilities Decontamination of personnel at the NRL can normally be handled in the NRL or in the Radiochemistry Laboratory, Room 164, which is i across the hall from the NRL. Both laboratories have sinks with soap, paper towels, and contaminated waste containers at hand. In an wemm m.m Universlty of Atl2ono Research Rooctor - me l

EMERGENCY PLAN page 21 emergency when the facilities of these laboratories are not available, Room 120, located between the NRL and the ESC, may be used for

! segregation of contaminated personnel and for decontamination.

Radiation Control Office personnel shall be responsible for decontamination of individuals involved in an emergency.

8.5 Communications Systems Telephones are located in the NRL Control Room, at the ESC, and i elsewhere in the Engineering Building, and may be utilized during ,

emergencies. Word-of-mouth communications will provide a backup for j l intemal communications. The University Police can also be summoned by activation of the intrusion alarm system by pressing a button in the NRL Control Room. University Police maintain a radio system for J l communication between police officers, the dispatcher, and patrol cars.

l 9.0 Recoverv Ooerations Restoring the NRL to a safe operating condition after an emergency shall l be the responsibility of the Emergency Director. Operations necessary to restore

! the facility will be under his direction. Radiation Control Office staff shall survey, i supervise decontamination, and ascertain that contamination and radiation levels  ;

within the affected areas are within acceptable limits. The Reactor Laboratory )

l Director shall assess resultant damages, direct repairs and review the l

emergency. Termination of the Emergency shall require completion of the actions specified in section 3.3. Completion of recovery operations shall include all measures specified in this section and execution of additional written procedures as may be needed, after approval by the Reactor Committee. With advice from the Reactor Laboratory Director, the University Reactor Committee will authorize continued operation of the reactor.

10.0 Maintainina Emeraency Preparedness 10.1. Trainina NRL operators and staff, and members of the Radiation Control Office with emergency response responsibilities will complete an initial training program and an annual review program. For NRL Operators, this l awmmm m Urdverslty of Arizono Research Reactor -m

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l EMERGENCY PLAN page 22 -l may be a part of the Reactor Operator Requalification Program. Specific )

l training in protective action decision making will be included in the initial l

! and periodic training for those individuals who may serve as Emergency l l Director during an emergency. Support groups will receive training commensurate with their degree of potential involvement.

l 10.2 Conduct of Drills and Exercises i

On-site emergency drills will be conducted annually to test the l adequacy of emergency procedures and to ensure that emergency organization personnel are familiar with their duties. These drills will l include the use of appropriate emergency equipment, and will include, as a minimum, testing of the communications links with the University Police Department and the Radiation Control Office.

10.'3 Critiaues of Drill's and' Exercises At the conclusion of each drill a critique to identify deficiencies shall be held by the participating NRL staff and observers and may include .

! members of other support and emergency groups. Observer and participant's comments concerning areas needing improvement shall be evaluated and consideration given to possible changes in the plan and procedures.

10.4 Emeraency Plan Review and Uodate The Emergency Plan shall be revised and updated as required based on drill results or changes in the facility and shall be audited annually by the Reactor Supervisor. This audit shall be reviewed by the Reactor Committee to ensure the plan is adequato and up-to-date.

Letters detailing arrangements with the Radiation Control Office, the University Police, University Hospital, Tucson Fire Department and the ambulance service shall be renewed annually, at intervals not to exceed 15 months. Applicable portions of the plan, agreements, and implementing procedures shall be distributed to the University Police, the Radiation Control Office, and the Arizona Radiation Regulatory Agency, and any revisions to implementing procedures affected by the plan shall e

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