ML20318A035
| ML20318A035 | |
| Person / Time | |
|---|---|
| Site: | Oregon State University |
| Issue date: | 11/03/2020 |
| From: | Reese S, Schickler R Oregon State University |
| To: | Michael Balazik Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML20318A035 (5) | |
Text
Radiation Center Oregon State University, 100 Radiation, Corvallis, Oregon 97331-5903 T 541-737-2341 I F 541-737-0480 I https://radiationcenter.oregonstate.edu/
November 3, 2020 U.S. Nuclear Regulatory Commission .5o- 213 Washington, D.C. 20555 Attn: NRC Licensing Project Manager_Michael Balazik/Document Control Desk
Subject:
Extension ofTimeframe required to Complete Biennial Emergency Exercise per Oregon State TRIGA Reactor Emergency Response Plan, Facility Operating License No. R-106 On January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid in the nation's healthcare community_in responding tq the Coronavirus Disease 2019 (COVID-19). Because of the COVID-19 public health emergency (PHE), the Oregon State TRIGA Reactor (OSTR) hereby submits an exemption request for its Facility Operating License No. R-106 from certain biennial emergency plan exercise requirements that are specified in the OSTR Emergency Plan Section 10.2. The requested exemption is for a temporary deviation from the listed :frequency of required biennial emergency exercise performance; specifically, OSTR is requesting a on~-time deviation from the 30-month time interval between biennial emergency exercises, as described in the OSTR emergency response plan, to a 35-month interval between exercises (not to exceed 8/1/2021), as allowed per Regulatory Issue Summary (RIS) 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements" dated February 24, 2006. The reason for this deviation, as discussed in the following analysis, is to ensure that OSTJl engages in activities that do not conflict with practices recommended by the Centers for Disease Control and Prevention to limit the spread of COVID-19.
As a result of the COVID-19 pandemic, the social distancing mandate that has been established by the Center for Disease Control (CDC) and the State of Oregon prevents the ability to conduct an emergency exercise with offsite authorities by the required date of03/20/2021. The specific portion of the Emergency Plan that requires a deviation is Section 10.2.c Emergency Drills:
Biennially; these drills will contain provisions for coordination with offsite emergency personnel and will test, as a. minimum, the communication links and notification procedures with these offsite agencies and support organizations." Additionally, for clarification, section 2.0 of the Emergency Plan lists a definition for biennially that reads, Every 24 months, with an interval not exceeding 30 months".
The last biennial emergency drill involving offsite organizations was conducted on September 20, 2018. The scenario for this emergency drill was a simulation of a contaminated employee falling from the reactor top, which involved the Corvallis Fire Department and the Emergency Department from Good Samaritan Regional Medical Center. There were no significant gaps or areas for improvement identified during this drill. The last annual emergency exercise was conducted on October 11, 2019. The scenario for this exercise was response to a continuously rising CAM alarm due to a simulated fuel leak, in conjunction with a contaminated SRO on the reactor top. There were no significant deficiencies identified.
By submitting this exemption request, the OSTR is proactively.taking steps to imp1ement interim actions during the deviation period that supports the health and safety of both worker and_
medical personnel to l:itµit the spread of the COVID-19 virus. The intepm actions (in accordance with the May 14, 2020 COVID EP NRC Letter sent from H. Nieh to NEI, U.S. NUCLEAR
- REGULATORY COMMISSION PLANNED ACTIONS RELATED TO EMERGENCY PREPARDNESS BIENNIAL EXERCISE REQUIREMENTS FOR ALL LICENSEES DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH-EMERGENCY" are as follows:
- 1. -Follow the re_commendation of scheduling an exercise within the 35-month window as described in the Regulatory Issue Summary (RIS) 2006-03, "guidance on
, Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements" dated February 24, 2005. This-exercise will be coordinated with
-offsite response organizations, as appropriate. Future exercises will be held as scheduled.
- 2. C01:1.duct a tabletop emergency exercise with internal OSTR personnel via a videoconference platform prior to 12/1/2020 -
This request is being made to support OSTR efforts to maintain CDQ recommendations related to social distancing, worker screening, and limiting close-proximity work. OSTR staff understands that if this proposed exemption requ~st is approved, J:b.e biennial emergency exercise must be performed as soon as practical and within-the 35-month window from the last performed exercise, as specified in RIS' 006-03 (the next exercise 'is to be performed prior to 8/1/2021).
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, Robert Schickler Dr. Steven Reese
- Assistant Director/Reactor Administrator Director Oregon State University Radiation Center Oregon State University Radiation Center 100 Radiation Center (Room D200) 100 Radiation Center (Room C102)
Corva~s, OR 97331-5903 _Corvallis, OR 97331-5903 (541) 737-7046 (541) 737-2341 Executed on:_ 11/3/2020 cc: Michael Balazik, USNRC Dr. Ire,m Turner, OSU Kevin Roche, USNRC M~ell Woods, Of?OE Dan Harlan, ROC Chair
Enclosure:
OSTR Emergency Plan section 2.0 "Definitions", page 2-1, and secti<?n 10.2
Emergency Drills", page 10-1.
Page 2 of 2
- 2- 1 2.0 DEFINITIONS Action Drill A drill which tests the integrated capability of the emergency plan, or a component thereof, and may include instruction periods to develop and maintain skills in a particular operation.
Annual Every 12 months, with an interval not exceeding 15 months.
Assessment Actions Those actions taken during or after an accident to obtain and process information that is necessary when deciding whether to implement specific emergency measures.
Biennial Every 24 months, with an interval not exceeding 30 months.
Corrective Actions Those measures taken to ameliorate or terminate an emergency situation at or near the source of the problem.
Emergency An emergency is a condition which calls for immediate action, beyond the scope of normal operating procedures, to avoid an accident or to mitigate the consequences of one.
Emergency Action Levels Radiological dose rates, specific concentrations of airborne, waterborne or surface-deposited radioactive materials,_speci:fic ob~rvations, or specific instrument readings that may be used as thresholds for initiating specific emergency measures (e.g., designating a particular class of emergency, initiating a notification procedure, or initiating a particular protective action).
Emergency Planning Zone (EPZ)
The EPZ for the OSTR is limited to the operations boundary and includes no offsite areas.
Emergency Support Center (ESC)
The room(s) from which effective emergency control directions will be given.
Emergency Response Implementing Procedure.
10- 1 10.0 MAINTAINING EMERGENCY PREPAREDNESS This chapter describes the elements necessary for maintaining an acceptable state of emergency preparedness.
Provisions have been made for maintaining the effectiveness of the Emergency Response Plan, including training, review and update of the Emergency Response Plan.and associated implementing procedures, and maintenance and inventory of equipment and supplies that would be used in emergencies.
10.1 Initial Training And Periodic Retraining Program a) An initial training and periodic retraining program will be conducted to maintain the ability of emergency response personnel to perform their assigned functions.
b) The personnel involved in the training program will be:
i) Facility personnel responsible for decision making and transmitting emergency information and instruction.
ii) Facility personnel responsible for accident assessment iii) Facility radiological monitoring and assessment team members.
iv) Medical support personnel at Good Samaritan Regional Medical Center. (I) v) Oregon State Police and OSU Department of Public Safety personnel Cl) vi) Police, ambulance and fire-fighting personnel. Cl) c) The content of the training program will include the overall Emergency Response Plan and the particular implementing procedures relevant to each group of personnel listed above.
10.2 Emergency Drills a) Annual onsite emergency drills will be conducted as action drills with each required emergency measure being executed as realistically as is reasonably possible, including the use of appropriate emergency equipment b) Annual action drills will employ the use of written scenarios to more effectively fulfill their function.
c) Biennially, these drills will contain prov1S1ons for coordination with offsite emergency personnel and will test, as a minimum, the communication links and notification procedures with these offsite agencies and support organizations.
(1) These personnel will receive regular training at fixed intervals, but initial training for all new employees is not considered feasible.
10- 2 d) After each drill there will be a debriefing, during which time observers will present their critiques of the exercise. These will then be evaluated by the facility emergency response personnel. Any deficiencies identified in the emergency plan, the implementing procedures, or their actual use during a drill will be corrected within six months of the exercise. Corrections will be approved by the OSTR Reactor Operation Committee prior to implementation.
10.3 Emergency Plan Review And .Update a) The Emergency Response Plan will be reviewed and updated annually, and will include modifications necessitated by changes in the facility and/or environs. 'The -
review committee will consist of the Radiation Center Director, the Reactor Administrator~ the Senior Health Physicist, and the Reactor Supervisor. The updated plan will then be approved by the OSTR Reactor Operations Committee.
b) Revised or updated copies of the Emergency Response Plan, support agreements and applicable implementing procedures will be distnlmted within 30 days of approval to all affected individuals and federal, state, county, and local organizations.
c) Changes to the Emergency Response Plan will be made in accordance with 10 CFR 50.54(q). Three copies of changes made without NRC approval which do not decrease the effectiveness of the plan, and proposed changes which may decrease the effectiveness of the plan, will be submitted to the NRC within 30 days after they are made or proposed. The signed original and one copy should be sent to the USNRC Document Control Desk, Washington, D. C. and one copy should be sent to the USNRC Project Manager.
10.4 Equipment Maintenance And Inventory The operational readiness of all emergency communications and emergency health physics equipment is assured by a routine maintenance program. Part of this is performed under the existing OSTR surveillance and maintenance program (S&Ms) covered by OSTROPs 14.0 and 16.0, and the rest is performed as part of the routine health physics program.
A check of the emergency equipment security seals shall be_performed quarterly. If this seal is broken, an inspection and inventory shall be immediately performed using the checklist for the given cabinet or room as appropriate. If the seal is not broken, the status of the seal shall be recorded in the checklist However, all emergency equipment shall be inventoried and inspected' annually regardless of the status of the security seals. The inventory and inspection checklists are given in Appendix B.