ML20215K399

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Discusses Insp Rept 50-062/87-01 on 870518-20.Addl Info Re Proper Distribution of Revs to Emergency Plan Implementing Procedures,Offsite Support Personnel Training & Emergency Action Level for Alert Response Provided.W/O Encls
ML20215K399
Person / Time
Site: University of Virginia
Issue date: 06/02/1987
From: Farrar J
VIRGINIA, UNIV. OF, CHARLOTTESVILLE, VA
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8706250313
Download: ML20215K399 (2)


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UNIVERSITY OF VIRGINIA r ,g, , DEPARTMENT OF NUCLEAR ENGINEERING AND ENGINEERING PHYSICS NUCLEAR REACTOR FACILITY SCHOOL OF ENGINEERING AND APPLIED SCIENCE

( J CHARL.OTTESVILLE, VA 22901

, 7 w 2 Telephone: 801 924 7136 June 2, 1987

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Dr. J. Nelson Grace, Administrator U.S.N.R.C. Region II

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101 Marietta Street, N.W. (o Atlanta, Georgia 30323 h

Dear Dr. Grace:

EI co This letter is in reference to a recent inspection at our facili g by Ms.

Anne Tabaka of your office in the area of Emergency Preparedness performed on May 18-20, 1987. (Inspection #87-01). I was out of town during the inspection but several questions arose at the exit interview that I would like to address.

This additional information should be provided to Ms. Tabaka.

Ms. Tabaka was concerned with proper distribution of revisions to our Emergency Plan Implementing Procedures (EPIP,s) to the NRC. We completed 5 revisions to our EPIP,s in the past 20 months, most of which were upgrading lists of facility personnel. No substantive change to the emergency procedures themselves were made. A cover sheet was sent along with each revision, requesting that the recipient sign, date, acknowledge receiving and filing the revision, and return the cover sheet for our files.

After sending Revision #1 to Washington, I received a phone call from our then Project Manager, Mr. Robert Carter,(please see attached memo) requesting that we do D_ot q send any more Revisions of our EPIP,s to Washington because they were concerned about personnel names and phone numbers appearing in the Public Document Room. I have not sent any Revisions to Washington since then.

After Revision #1 was sent to your office on September 30, 1985, I received an acknowledgement from Mr. A.L. Cunningham that it had been received and filed. I received no similar acknowledgement for Revision #2 (dated November 18,1985) or Revision #3 (dated July 25,1986). When Revision #4 was sent to your office I included a letter to Mr. Paul Fredrickson (see attached copy) requesting that he check on this matter and inform me of the situation. I have never received a response to my letter or an acknowledgement that the Revision had been received. After Revision #5, an update of facility personnel list, was issued on March 10,1987, I did not forward a copy to your office because of the nature of the revision and your office's apparent unconcern.

We would like to remove the personnel lists from our EPIP,s, and merely keep an informal up-to date listing of personnel in our office not to be considered officially part of the Emergency Plan and its Implementing Procedures. This request will be submitted to our Reactor Safety Committee for i

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review and approval. We request your office's concurrence with this action.

Future Revisions to the EPIP,s will be sent to both your and the Washington offices'by registered mail.

Ms. Tabaka also needed further information about the training.of some of l our off-site support personnel, in particular, the Rescue Squad. The Radiation Safety Office at the University periodically holds formal classroom training

- for off site support personnel. The Rescue Squad's last classroom training was in 1985. The Rescue Squad also participated in a full scale emergency drill at our facility on October 29, 1986 that involved a simulated accident with three individuals who.were both injured and contaminated. A fire was postulated during the drill and the Fire Department was called for assistance. The Rescue Squad administered to the three " injured" individuals and transported them to the U.VA. Hospital Emergency. Room, requiring the hospital to initiate their Radiation Emergency Plan. This drill was observed by Ms. A.R. Long, an inspector from your office, who happened to be here for a compliance inspection in another area. I might also point out that one of our staff members is a member of a local Rescue Squad unit and is fully qualified as an instructor in CPR, advanced first aid, etc. The Rescue Squad also has detailed procedures (46 pages) for incidents involving hazardous materials, including Radioactive Materials, and have in-house training on a regular basis. Since Ms. Tabaka's inspection, I have asked our Radiation Safety Office to arrange formal lectures on a more frequent basis.

Ms. Tabaka also had a question regarding the Emergency Action Level (EAL) for an Alert response. Section 5.2.2.d (page 20) of our Emergency Plan states that an Alert condition would exist if radiation dose rates increase above ambient levels by a factor of 1000 throughout the facility. EPIP-3 (Response to Alert Emergency), Section 6.1, page 4 of 8, requires a response if exposure levels increase to >0 1 REM /hr throughout the facility. Since we consider ambient exposure levels throughout the normally occupied sections of the facility to be 0.1 mr/hr, no conflict exists between these numbers.

I hope this information, which I was not able to personally provide to the Emergency Preparedness inspector, has satisfactorily answered the questions raised by Ms. Tabaka.

Very Truly Yours, dAAAA.-

J.T. Farrar, Administrator.

U.VA. Reactor Facility Sworn to and subscr: ed before me this D -

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