ML20198H538

Responds to Insp Rept 50-160/85-04 on 851028-1101.Corrective Actions:Emergency Preparedness Plan Revised to Include Site Area Emergency Action Levels in Table 1.Rev 1 to Plan Encl

ML20198H538
Person / Time
Site:	Neely Research Reactor
Issue date:	01/22/1986
From:	Karam R Neely Research Reactor, ATLANTA, GA
To:	Walker R NRC
Shared Package
ML20198H543	List: ML20198H538
References
NUDOCS 8601310050
Download: ML20198H538 (5)

Text

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- Georgia institute of Technology Neely Nuclear Research Center Atlanta, Georgia 30332 e (404) 894-3600 esomeIATECil 1806 1946

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January 22, 1986 Mr. Roger D. Walker, Directot Division of Reactor Projects U.S. Nuclear Regulatory Commission 101 Marietta Street Atlanta, Georgia 30303

SUBJECT:

INSPECTION REPORT NO. 50-160/85-4 This letter is our response to the referenced inspection of the Emergency Preparednons Plan conducted October 28-November 1, 1985. The deadline for our response was to have been January 18, 1986; however Mr. Paul Fredrickson of your staff agreed by telephone to extend the deadline to February 14, 1986.

All items in Appendix A and Appendix B are answered below.

Item Appendix A.1 "The Emergency Plan was inconsistent in that a classification of Site Area Emergency was defined in Section 4.0; however, respective Emergency Action Levoln were not identificd in Table I, and response to thiu clasuitication was not discussed in Section 7.0 (2.2.1.1)."

The Emergency Preparedness Plan has been revised to include Sito Area Emergency Action Levolu in Table I and a responne to thin clansification is now discussed in Section 7.8. The rovined Plan is appended.

Item Appendix A.2 "No emergency traplementinj procedure was in place describing personnel monitoring at the assembly area and cogregation and decontamination of contauinated personnel."

Emergency Proceduren Part IX (appended) lu our response to the inuuo rained in Appendix A.2.

Item Appendix A.3

" Emergency response training should be given to all likely onsite and of f at to oraergency responac personnel."

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Mr. Walker Page 2 January 22, 1986 Our intent is to indeed train all personnel, onsite and offsite, in emergency response. A significant amount of this has already been done and much more needs to be done. We plan further training for all groups.

The philosophy behind our Emergency Preparednenn Plan, however, is that the Emergency Director along with help from supporting groups such as Realth Physics, reactor operating staff, state Environmental Protection Division, and others will direct police and/or firemen in combatting the specific emergency. It is our experience that both police and tiremen are atraid of radiation.

Consequently we have to chow them the way and be with them.

Item Appendix A.4

" Emergency Plan, Section 10.2 required that drills be conducted biennially rather than annually as specified in 10 CPR 50, Appendix E, Section IV.F."

We prefer biennial drilla not because we only have to do it once every two years, but an emergency drill unneccesarily disturbs our neighborn despite efforts to inform them that it is only a drill. No doubt that drills are needed and are beneficial to emergency personnel but how do you balance that need against creating concern in the public mind?

Ilcretofore annual emergency drills will be held at the NNRC starting in July 1986. The Emergency Preparedneca plan in revised accordingly.

Item Appendix B.1

" Developing a procedure deacribing notification methodu including: the titlo of the person rouponsible, the agencion which muut be notified for each claus of emergency, the time period during which notification muut take place and the information to be provided ( 2.1.1 ) . "

We appreciate thin comment and agree with the NRC with regard to its usefulnean. A proceduto will be developed during the next six months period. The procedure will be cubmittud to the Nuclear Safeguarda Committee for approval.

Item Appendix U.2

" Performing quarterly updaten of the emergency organization rontor and the renulto documented (2.1.1)."

Mr. Walker Page 3 January 22, 1986 1

Itather than updating the emergency organization router quarterly we proposed to update it at least annually or when personnel changes occur.

Item Appendix B.3 "Providing backup means for internal communication at the ECC (2.1.2)."

We are studying this problem. Walkie talkies do not perform adequately; one possibility is locating one speaker of the P.A.

system in the ECC.

Item Appendix B.4

" Placing copies of the Emergency Plan and Procedures in the ECC (2.3.1.1)."

This was done immediately after NRC inspection.

Item Appendix B.5 J " Posting evacuation routes with mapc showing the location of the assembly area throughout the facility. Old evacuation routes should be removed (2.3.2.1)."

This was also done immediately after the inspection.

1 Item Appendix B.6 l

.i " Including a description of accountability methods and the title of the responsible person in the procedurou (2.3.2.3)."

j It is not clear what this recommendation is all about!

5 Item Appendix 11.7

"Itemoving outdated emergency procedurou from doors, bulletin boardo, and fire alarms. Posting current directionu with emergency notification routers in appropriate locations (2.3.2)."

This han been done.

Item Appendix 11.8

" Developing methodu and plans for keeping track of personnel dono during emergencies and making them available in the ECC

.l (2.3.3)."

Mr. Walker Page 4 January 22, 1986 A procedure for this purpose will be developed.

Item Appendix B.9

" Establishing a formal documentation system for emergency organization training and retraining (3.1)."

We feel that our training and retraining program for Emergency Procedures is adequate. We will continue to hold training sessions with onsite and offsite personnel. We will also keep records of these sessions including attendance rosters and

.aaterial discussed.

Item Appendix B.10

" Documenting drill critiques and providing for incorporation of lessons learned into plan or procedures (3.2) ."

This was done in the past and will be continued in the future (see 10.3 Emergency Plan).

I tam Appendix B.11

" Developing a procedure for update and revision of the Emergency Plan (3.3)."

See Emergency Plan Sections 10.3 and 10.4.

Item Appendix B.12

" Developing a document control and distribution uystem for the Emergency Plan which includes dating and plan and Procedures, and providing copies to applicable personnel and agencies (3.3)."

The distribution list for the Emergency Plan and Procedures 19 appended. Any revision to the Emergency Plan and/or Procedures will heretofore be designated on the cover page and revised copieu will be distributed to those on the distribution list.

I hope that you will find our response natiofactory. If you have any questions please let me know.

Sincerely,

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1.A. Karar

?lrector RAK jlr

Enclosures:

As stated

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O DISTRIBUTION LIST EMERGENCY PLAN AND PROCEDURES

1. Dr. James R. Stevenson

2. Dr. Thomas E. Stelson All Alternate Emergency Directors

3. Dean McDowell

4. Robert Boyd

5. Steve Millspaugh

6. Bill Downs

7. Paul Sharpe

8. R.A. Karam

9. Georgia Tech Polico, Mr. Jack Vickery

10. Atlanta Fire Department, Mr. Gene Sparks

11. Department of Natural Resources, Environmental Protection Division, Mr. Jim liardeman

12. Grady Hospital, Dr. J.W. Pinkston

13. Nuclear Regulatory Commission, Mr. Paul Frederickcon

14. Les Potherick, Environmental Safety, Georgia Tech

15. Emergency Command Center