ML20126E319

Insp Rept 50-160/92-04 on 921109-10.Violation Noted.Major Areas Inspected:Operational Readiness of Licensees Emergency Preparedness Program & Annual Emergency Preparedness Drill Conducted on 921109

ML20126E319
Person / Time
Site:	Neely Research Reactor
Issue date:	12/08/1992
From:	Barr K, Kren J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20126E308	List: ML20126E305 ML20126E313 ML20126E319
References
50-160-92-04, 50-160-92-4, NUDOCS 9212290095
Download: ML20126E319 (7)

See also: IR 05000160/1992004

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DEC 101932

Report No.:

50-160/92-04

Licensee: Georgia Institute of Technology

225 North Avenue

Atlanta, GA

Docket No.:

50-160

License No.: R-97

facility Name:

Neely Nuclear Research Center

inspection Conducted-

November 9-10, 1992

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Inspector:

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LJ. L. Kre T1Fadiation Specialist

Signed

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Accompanying Personnel:

C. H. Bassett, NRC Region 11

H. M. Mendonca, NRC Headquarters

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Approved by:

CI Barr,'Cli

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Date Signed

Emergency Preparedness Section

Radiological Protection and Emergency Preparedness Branch

Division of Radiation Safety and Safeguards

SUMMARY

Scope:

This routine, announced inspection was conducted to assess the operational

readiness of the licensee's emergency preparedness program and to evaluate the

annual emergency preparedness drill conducted on November 9, 1992.

Results:

In the areas inspected, one repeat violation was identified for failure to

have certain emergency plan notification requirements in written procedures

(Paragraph 2).

No deviations were identified. The licensee's emergency

response capability was maintained in an overall adequate state of readiness.

Emergency response personnel performed well during the drill.

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REPORT DETAILS

1.

Licensee Employees Contacted

W. Downs, Senior Reactor Operator

• R. Ice, Manager, Office of Radiation Safety

• R. Karam, Director, Neely Nuclear Research Center

B. Statham, Manager of Operations

Other licensee employees contacted during this inspection included

operators, technicians, and-administrative personnel.

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• Attended exit interview

2.

Emergency Preparedness Plan and Implementing Procedures (82745)

The Emergency Preparedness Plan (EPP) and associated implementing

procedures (known as the-Emergency Procedures) were reviewed to note

changes made since the last inspection in this area (September 1991)

and to assess the 11. act of any such changes on the overall state of

emergency preparedness.

No changes were made to the EPP (currently

Revision No. 2, approved by the NRC on June 8, 1989), since the last

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inspection.

One of the licensee's ten Emergency Procedures was new Procedure 6080,.

" Accidental Release of High Levels of Gaseous Activity to the

Atmosphere," Revision 00, approved August 13

1992. Two of the

licensee's Emergency Procedures had been revised since the

September 1991 inspection.

The changes in these revisions, which

involved Procedures 6090 and 6100, were reviewed to determine their

consistency with the EPP. Of particular interest were the changes

made in Procedure 6100, " Emergency Notification" (Revision 03,

approved September 26,1991), in response to a previous noncited

violation (50-160/91 04 02) for an inadequate notification procedure.

The referenced violation was based upon the licensee's failure to

specify. in the Emergency Procedures that the State of Georgia and the

Atlanta /fulton County Emergency Management Agency (EMA) will be

notified for all incidents classified as Notification of Unusual Event

(NOVE) through General Emergency, in accordance with the explicit

requirement- in Section 3.2 of the EPP.

At-the time of this finding

(September 1991), the violation was not cited because the licensee's

proposed corrective actions and the minor nature of'the violation

appeared to satisfy the applicable criteria in the NRC Enforcement

Policy. However, the. inspector's; review of Revision 03 to

Procedure 6100 disclosed that the licensee's corrective actions did

not completely address the subject violation.

Procedure 6100

specified notification of the State of Georgia (specifically, the

Department of Natural Resources) for most initiating events classified

as NOVE and for.all events classified as Alert or higher, but the

subject procedure did not specify notification of the Atlanta /Fulton

County EMA for any of the classifiable events listed in Sections 5.9,

5.10, and 5.11.

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Discussions with the Director of the facility disclosed that

corrective actions for the violation were undertaken immediately after

the September 17-19, 1991 inspection (as indicated by the revision

approval date of September 26,1991), but were based upon the

licensee's apparent misunderstanding of the issue as discussed during

the exit interview for that inspection. The facility Director stated

that he had not perused the details of this matter in NRC Inspection

Report 50-160/91-04, which was issued on November 5, 1991.

Section 6.4.b(8) of the licensee's Technical Specifications-stated

that written procedures shall be provided and utilized for a site

emergency plan.

Licensee management was informed that Procedure 6100

governing emergency notifications did not adequately' implement

Section 3.2 of the EPP.

Violation 50 160/92-04-01:

Failure to have certain EPP notification

requirements in written procedures.

Section 8.5 of the EpP required a quarterly update and verification of

the Emergency Notification Roster, a one-page call list / organizational.

chart posted at various locations throughout the facility. The

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current version of this roster was Revision 28, dated September 18,

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1992.

The inspector reviewed documentation showing that the Emergency

Notification Roster was updated during each calendar quarter since the

last inspection, and that copies of each revision were distributed to

specified campus and of fsite locations.

The ins 3ector noted that the

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roster included a 24-hour telephone number for 11e Atlanta /fulton

County EMA, although, as discussed above, Procedure 6100 did not

specify notification of this agency in the event of an emergency

declaration.

One violation and no deviations were identified.

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3.

Emergency Response Training (82745)

Pursuant to Section 10.1 of the EPP, this area was inspected to

determine whether the licensee had provided training to the onsite

emergency organization.

Licensee records documented 1992 emergency response training of seven

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facility personnel listed on the Emergency Notification Roster.

In

addition, training for the role of Emergency Director (ED) was

provided to the individual serving as Manager, Office of Radiation

Safety. This individual, who began his employment at the facility. on

October 1, 1992,

functioned as ED.during the current drill,.and will

be designated in the near future as an alternate for-the.ED position.

. Although no written lesson plans or training outlines were used and_ no

examinations were given, interviews with facility staff and

performance of licensee personnel .during the drill indicated that

emergency response training was effective.

No violations or deviations were identified.

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4.

Emergency facilities, Equipment, and Supplies (82745)

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This area was reviewed to determine whether the licensee's Emergency

Command Center (ECC) and other equipment, instruments, and supplies

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were maintained in a state of operational readiness as required by

Section 10.5 of the EPP.

The license had designated two kits for emergency use. One was

located in the vestibule of the Reactor Building and contained.

anticontamination clothing, decontamination supplies, barrier ropes,

etc.

The second kit, located in the ECC, contained portable survey

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instruments, anticontamination clothing, sampling material, dosimetry

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devices, etc.

In addition, two self contained breathing apparatus

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(SCBA) units were available in the ECC.

Selective inspection of these

emergency kits disclosed no inventorial discrepancies or inoperable

equipment. The inspector reviewed documentation which showed that

quarterly inventories of these kits were performed as required during

the period July 1991 through October 1992. These records indicated

that identified problems were corrected expeditiously.

The inspector reviewed records of the monthly test of the facility's

fire detection / alarm system for the period October 1991 through

- October 1992. Also reviewed were records of the monthly test of the

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criticality alarm system for the period January - October 1992.

According to the records, no problems or discrepancies were noted

during these tests.

No violations or deviations were identified.

5.

Coordination with Offsite Support Organizations (82745)

Section 8.3 of the EPP required biennial updating of agreement letters

with respect to arrangements for hospital, medical, and other

emergency services. The only such agreement currently being

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maintained was with Grady Memorial Hospital,- and.had been-renewed on

September 15, 1992.

Section 10.1 of the EPP specified biennial-training of the Georgia

Tech. Police and the Atlanta Fire Department in radiation safety and

the licensee's Emergency Procedures. As documented _in NRC Inspection

Report No. 50-160/91-04 (Paragraph 5), such training was provided

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during 1991 and will therefore be due again in 1993.

No violations or deviations were identified,

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6.

Emergency Response Drill (82745)

The EPP required the conduct of an onsite emergency drill annually to

test the adequacy of Emergency Procedures and to ensure that emergency

organization personnel-are familiar with their duties; also, at least

biennially,-a drill must contain provisions for testing communications

and notification procedures with offsite support groups.

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On November 9, 1992, the licensee conducted the annual emergency

drill, which included participation by the Georgia Tech. Police, the

Atlanta Fire Department, and Grady Memorial Hospital.

The scope,

objectives, and scenario for the drill are delineated in the

attachment to this report.

The drill commenced at 1:58 p.m. and

terminated at 2:55 p.m.

The scenario involved a fire in the Storage Barn, a building separate

from the main facility structure. A smoke generator was used to

simulate combustion products, although this unit had ceased

functioning by the time the inspector arrived at the Storage Barn just

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prior to the start of the drill, and only a slight trace of smoke was

present. A licensee staff member used a source of heat to actuate the

fire detector in the Barn at 1:58 p.m.

The fire alarm sounded

throughout the facility, resulting in an evacuation of personnel to

the parking lot, where an accountability was conducted and quickly _

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identified one person as missing.

The Georgia Tech. Police arrived .

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promptly (by 2:00 p.m.), since their headcuarters was located near the

Neely Nuclear Research Center and receivec direct indication of any

fire alarm occurring at the licensee's facility.

The activation and operation of the ECC by the ED and staff were

evaluated by the inspector and determined to be effective in accident

investigation and mitigation. The inspector also observed the

response by Health Physics personnel in surveying the incident area

for abnormal radiation levels and/or contamination.

Their response

was prompt, and they demonstrated good survey techniques in accordance

with standard Health Physics practices.

The ED declared an Operational Event at-2:21 p.m. based upo_n the

criterion, " Minor fire or explosion non specific to the reactor or its

control systems" (EPP Table I, " Emergency Classification Guide").

The

licensee and the inspector had anticipated that the event would

probably be classified as a NOVE based upon the classification

criterion, " Prolonged fire or minor explosion within facility but non-

specific to the reactor or its control systems." However, because of

the failure of the smoke generator, the players had no indication that

a " prolonged fire" was occurring as intended by the scenario.

Since

the drill was being allowed by the licensee to simply run its course

without anyone actually serving to control the scenario events, there-

was no established mechanism for informing 31ayers-that the fire was

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supposed to be continuing and generating su)stantial quantities of

smoke. After the drill, the inspector discussed with licensee

management the desirability of instituting the standard practice of

using at least one person as drill controller.

The function of a

controller is to insure that the scenario stays "on track" in the

event of equipment failures or other unforseen circumstances.

In this

drill, a designated controller could have informed licensee staff

arriving at the Storage Barn that the building was filled with smoke

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and that the visibility inside was poor in order to communicate the

continuing " existence" of a fire.

Licensee management agreed during

the exit interview to consider the use of a controller for future

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drills.

This issue will be tracked as an Inspector follow-up Item

(IFI).

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IFI 50-160/92 04 02:

Consideration of the use of a drill controller.

As required by the EPP, a critique was conducted after the drill and

was observed by the inspector.

The critique was determined to be

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thorough, with pertinent input from drill participants as well as

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evaluators. The licensee's follow up of critique findings will be

reviewed during a future inspection.

No violations or deviations were identified.

7.

Action on Previous NRC Inspection findings

a.

(Closed) Exercise Weakness 50 160/91-04 01:

Excessive

prompting prevented a true demonstration of the alternate ED's

capabilities.

No prompting of player responses was observed during the

current drill.

b.

(Closed) IFI 50 160/91-04-03:

Review and identify a backup

ECC.

The licensee had tentatively identified the nearby Georgia

Tech. Police Department headquarters as a backup ECC, although

this arrangement was not yet formalized or incorporated into

the EPP.

The licensee planned to pursue this development to an

appropriate conclusion,

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c.

(0 pen) IFI 50-160/91-04-05: Review the_ notification procedure

for NRC notification time limits to ensure consistency with

10 CFR 50.72.

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Licensee management stated that they had planned to review'this

matter but had not yet done so.

They agreed to give near-term

consideration to this item.

8..

_ Exit Interview

The inspection scope and results were summarized on November 10, 1992

with those persons indicated in Paragraph I'

The inspector described

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the areas inspected and discussed in detail the inspection results

listed below.

Proprietary information is not contained.in this

report.

The-facility Director. expressed disagreement with the

characterization of the-violation as a repeat violation, although he

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stated that he had taken corrective action for the previous (noncited)

violation strictly on the basis of the exit interview rather than the

discussion in the inspection report.

Item Number

Cateaory. Description, and Reference

50-160/92-04-01

Repcht Violation - Failure to have an

adequate procedure for implementing

certain EPP notification requirements

(Paragraph 2).

50-160/92-04-02

IFl - Consideration of the use of a drill

controller (Paragraph 6).

Attachment (1 page):

Scope, Objectives, and

Scenario for l'.2 Drill

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