ML20133F878
| ML20133F878 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 12/20/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133F871 | List: |
| References | |
| 50-062-96-03, 50-62-96-3, NUDOCS 9701150055 | |
| Download: ML20133F878 (12) | |
See also: IR 05000062/1996003
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U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50 62
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License No.: R 66 :
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Report No.: 50 62/96 03 '
Licensee: University of Virginia l
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Facility: University of Virginia Reactor Facility (UVAR)
Charlottesville. VA 22901
Inspection Conducted: November 18 21, 1996
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Inspector: A. Gooden, Radiation Specialist
Approved by: E. McAlpine,' Chief
Fuel Facilities Branch
Division of Nuclear Materials Safety
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Enclosure
9701150055 961220
PDR ADOCK 05000062
G PDR
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EXECUTIVE SUMMARY
University of Virginia Reactor Facility (UVAR)
50 62/96 03
This routine, announced inspection involved a review of the operational
readiness status of the licensee's emergency preparedness program, and the ,
observation and evaluation of the licensee's annual emergency response drill. j
e The emergency preparedness program elements were adequately maintained
to ensure a state of readiness for responding to emergencies
(Section F3.06).
e The exercise was considered a successful demonstration of the emergency
organization's capability to protect the health and safety of facility
staff, and students, following a security event (Section F3.06).
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e Communication delays and/or the lack of communication contributed to an
Exercise Weakness for failure to correctly upgrade the emergency
classification based on the loss of physical control of the facility
(Section F3.06). ;
e The licensee's capability for obtaining key reactor data via remote
interrogation was an effective tool in accident assessment
(Section F3.06).
Attachment:
Persons Contacted .
List of Items Opened, Closed, and Discussed '
List of Acronyms ;
Scenario and Exercise Objectives
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Report Details
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IV. Facility Support
F3 Emergency Preparedness (82745)
F3.01 Changes to the Emergency Plan
a. Inspection Scope
The review, approval, and distribution of Emergency Plan (EP)
changes were examined to determine if changes were made since the
last inspection (November 1995), to assess the impact of changes
on the overall state of emergency preparedness at the facility,
and to determine if the changes were made in accordance with
10 CFR 50.54(q) and Section 10.4 of the EP.
b. Observations and Findinas
According to the licensee and a review of the EP, the last changes I
were made during March 1995 and were incorporated as Revision
(Rev.) 3, dated March 6,1995. The beforementioned changes were ,
submitted for NRC review and approval on March 10, 1995. During l
the November 1995 routine inspection, the inspector reviewed the
changes and discussed the results of the review (see Inspection
Report (IR) No. 50 62/95 02). The inspector indicated that
although the review did not identify any decrease in the
effectiveness of the Plan, the formal NRC review and approval i
would be via separate correspondence. By letter dated June 11,
1996, the NRC approved changes incorporated " Rev. 3.
The inspector reviewed the administrative program governing the
review, approval, and distribution of changes to the Plan.
According to documentation changes were approved and distributed
to onsite and offsite copy holders in a timely manner. Copies
number 6 (Control Room), and 18 (first floor emergency locker) of
the Plan were examined and found to be current revisions.
The inspector discussed with a member of the licensee's staff the
last audit performed by the Radiation Safety Committee (RSC).
According to documentation (memo dated September 1994), the last
audit of the Plan and Emergency Plan Implementing Procedures
(EPIPs) by the RSC was conducted during the period September 1993
and September 1994. Section 10.4 of the Plan requires the RSC to
perform a review every two years. The inspector interviewed the
licensee contact with responsibility for performing the audit. The
inspector was informed that although the audit had not been
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, conducted at the time of the inspection, the audit would be
conducted during December 1996. In response to the licensee's
comments, the inspector indicated that the performance of the
biennial audit in December 1996 would be considered an Inpsection
Followup Item (IFI).
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IFI 50 62/96 03 01: Perform the biennial audit of the Plan and
EPIPs during December 1996.
c. Conclusions
Based on an interview and documentation reviews, it appears that
the changes were made in accordance with 10 CFR 50.54(q),
Section 10.4 of the EP. and distributed in a timely manner.
F3.02 Implementing Procedures
a. Insoection Scope
EPIPs were examined to determine if any changes were made since
the last inspection (November 1995) for verification that the 1
revised procedures continue to implement the EP requirements, and '
determine if the changes were made in accordance with l
10 CFR 50.54(q) and Section 10.4 of the EP. l
b. Observations and Findinas
The inspector noted several changes were made to the licensee's
implementing 3rocedures involving notification since the last
inspection. C1anges were strictly administrative involving
personnel listing and/or phone numbers. The affected procedures
were EPIP 6 " Notification cf Emergency Response Personnel and
Support Organizations:" EPIP 7 " Notification of Offsite Agencies;"
and EPIP 14 " Evacuation of On site Areas." The aforementioned
changes provided updates to ensure EPIPs included a current
notification list for mobilizing the emergency organization and
the appropriate offsite support organizations in accordance with
the Plan requirements. A small sample of licensee implementing
procedures were reviewed for adequacy in implementing the Plan.
The inspector noted during the review that two EPIPs previously
associated with training (EPIP 21). and test and drills (EPIP-22)
were deleted during January 1994. When questioned regarding the
basis for the deletions, the inspector was informed that the
details were incorporated elsewhere (e.g. requal check-list).
The inspector examined copies of the EPIPs available to response
personnel in the Control Room, the first floor emergency locker,
and a co)y used by the Emergency Director (ED) at the command post
during tie emergency exercise (discussed in Section F3.06), and
determined that each was a current revision. During a facility
tour, the inspector also noted that posted at numerous locations
within the UVAR was the current notification roster.
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c. Conclusions
Procedures that were selected for review were adequate in the
areas of emergency classification, accident notification and
coordination, evacuation, and accountability. It appears that the
changes were made in accordance with 10 CFR 50.54(q), Section 10.4
of the EP, and distributed in a timely manner. The impact from the
deletion of EPIP 21 and EPIP-22 on training, tests and drills,
requires followup during a subsequent inspection.
F3.03 Emergency Preparedness Program Implementation
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a. Inspection Scope
The inspector observed the implementation of the Plan and EPIPs in
response to a postulated accident involving a breach of security.
Facilities and equipment were inspected to determine whether the
licensee's Emergency Support Center (ESC), emergency response
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equipment, instrumentation, and supplies were maintained in a
state of operational readiness
b. Observations and Findinas
The Emergency Response Organization (ER0) performance was adequate
in the implementation of the Plan and EPIPs in response to the
simulated emergency. However, an Exercise Weakness (EW) was
identified for the failure to upgrade the event from a
Notification of Unusual Event (NOUE) to a General Emergency (GE)
in a timely manner (see details in Section F3.06). Key members of
the ER0 appared to be familiar with their roles and
responsibilities. Procedures for activation, notification,
classification, and accountability were promptly initiated. The
exercise was considered a successful demonstration of the
emergency organization's capability to implement the Plan and
EPIPs for coping with an emergency.
The operational readiness status of equipment and facilities were
examined via documentation (in support of maintenance, periodic
tests and/or surveillances), facility walk-down, inventory, and
operability checks. The inspector examined the readiness of the
ESC and the first floor emergency locker, Selected inventory
items were located and available for use. Radiation survey
instruments were calibrated and responded pro >erly to both battery
and radioactive source checks. la addition, t1e operability of the
facility PA System used for making announcements (emergency and
non emergency) was checked and no problems were noted. During the i
Control Room tour, the inspector requested and observed a source j
check on the area monitoring system to verify the operability of l
select monitors (reactor bridge, reactor face, and the
demineralizer room). As further assessment of program readiness,
the inspector verified via records documentation that the ,
aforementioned area monitoring equipment, the ESC emergency
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lighting, and the facility's continuous air monitor (CAM) were ,
checked and/or calibrated in accordance with procedures or i
technical specification requirements; the emergency lockers were
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being inventoried at the frequency required in the Plan; and the
documentation indicated that the criticality monitoring alarm
system was being tested on a seriodic basis. The referenced
warning system consisted of t1ree audible horns and an indicator
light in the wood shop. The most recent tests performed since the l
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last inspection of this area was conducted on August 30, 1996,
February 19, 1996, and as part of an annual evacuation drill on
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April 24, 1996.
During a previous inspection, an IFI was opened associated with
the modification and testing of the facility evacuation alarm
system to demonstrate facility wide audibility coverage. In
response to the open item (50 62/95-02 01), the ins >ector reviewed
documentation dated November 13, 1995, which descri>ed the
modifications and~ testing involving the connection of the
criticality alarm to the evacuation alarm system. According to the
test result (dated November 13, 1995) the alarm was audible via
the evacuation system. However, during the annual evacuation drill
(conducted on April 24, 1996), audibility problems were noted in a
facility laboratory. Consequently, additional system modifications
were made to include a small separate alarm for the laboratory.
The modifications were completed in August 1996, and approved for
operation on October 8,1996, following testing. The alarm system
was not tested during the inspection. The inspector interviewed
the licensee contact with the responsibility for maintenance,
testing, and installation. In addition, the inspector verified via ,
walkdown the location of the modifications for the laboratory
including the location of the alarm within the laboratory. Based
on the licensee's actions and test results, item 95 02 01 is
considered closed.
c. Cpnclusions
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The ESC and accident assessment equipment appeared to be
adequately maintained to ensure a state of readiness for
responding to emergencies.
F3.04 Offsite Support
a. Insoection Scope
Licensee activity in the areas of offsite training, agreements,
and exercises, was reviewed to determine if the licensee was
properly coordinating with offsite authorities.
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b. Observations and Findinas
Discussions were held with a member of the licensee *s staff and a
local official with Albermarle County Emergency Services regarding
the coordination of emergency planning with offsite support agen-
. cies. The offsite contact described the UVA community as a good
neighbor. The inspector reviewed the status of agreement letters
with offsite support agencies, and noted that all agreements were
current and up to date.
No training had been provided to offsite authorities since the
last inspection. However, during June 1996, by letter offsite
support contacts were offered a site familiarization tour to
review what situations or hazards resaonse personnel may encounter
in responding to an emergency at the JVAR Facility.
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Based on interviews and documentation to show periodic contact
with the offsite authorities, the inspector concluded that the
licensee did interface with offsite support agencies on matters
of mutual concern involving emergency preparedness.
F3.05 Emergency Alarms
a. Insoection Scope
The operational readiness status of several UVAR alarms were l
examined via documentation (in support of maintenance, periodic !
tests and/or surveillances), facility walk-down, and source 1
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b. Observations and Findinos l
The inspector reviewed documentation for calibration, maintenance,
and/or periodic testing of the following: criticality alarm
system, CAM, evacuation alarm, and area radiation monitors (ARMS). j
The inspector requested and observed a source check from the '
Control Room to verify the operability of the area monitors for
the reactor face, bridge, and demineralizer room.
c. Conclusions
Based on the documentation, interviews with Reactor Operators, and
operability checks, selected accident assessment equipment and
various alarm signals appeared to be adequately maintained to
p,"caide some indication of abnormal conditions. The selected
equipment was tested at the frecuency specified in the Technical
Specifications, Plan, and procecures. )
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F3.06 Emergency Preparedness Exercises and Drills
a. Inspection Scope
Section 10.2 of the licensee's EP required that periodic drills
and exercises be conducted to test the adequacy of timing and
content of implementing procedures and methods, to test emergency
equipment, and to ensure that emergency personnel are familiar
with their duties. The EP required that annually an onsite
emergency drill be conducted and, at least biennially, drills
contain provisions for coordination with local offsite emergency
organizations for testing communications and notification
procedures. The inspector observed the annual exercise conducted
on November 19, 1996.
b. Observations and Findinos
The scenario was reviewed in advance of the exercise and was
discussed with a licensee representative prior to the exercise.
No major problems were identified during the review, but
inconsistencies became apparent during the exercise. The
inconsistencies failed to detract from the overall performance of
the licensee's emergency organization. However, during an
interview with the facility ED regarding the EW discussed below,
the inspector was informed that scenario inconsistencies and
exercise simulations impacted the emergency classification
decision.
The postulated accident commenced at approximately 8:53 a.m. and
was terminated at 10:20 a.m.. The scenario details simulated a
breach of security by an intruder, who gained access to the UVAR
Facility and planted a package suspected of containing a bomb.
The inspector observed the licensee's actions in the following
areas:
o Notification and communication with offsite authorities
o Interface between the ED and on scene response personnel
o Facility evacuation and accountability
o On scene response by health physics (HP) personnel
o Event recognition and classification (prior to the ED
relocating to the backup ESC at the Materials Handling
Building).
In response to the postulated accident conditions, an immediate
building evacuation was announced. Accountability was completed
within approximately six (6) minutes of the announcement to
evacuate the facility. The initial assessment of accident
conditions and the resulting emergency classification by the ED
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was both timely and correct. A NOUE was declared by the ED at
9:10 a.m.. The following details (approximate timeline and
events) associated with activity preceding the emergency
classification upgrade were noted:
9:11 a.m. Emergency Coordinator (EC) requested that UVA Police
personnel relocate from the building
9:12 a.m. Police exit building and reported no one located
inside at this time
9:15 a.m. ED relocating to backup ESC
9:18 a.m. Medical transport vehicle arrive in response to
injured student
9:20 a.m. UVA Police discussed with the EC the lack of identity
and confirmation regarding the intruder whereabouts
and/or number of intruders
9:25 a.m. Police Commander at the incident command post informed
the EC that Police would maintain surveillance of
facility and contact (simulated) the local bomb
ordinance group for responding to bomb
9:30 a.m. ED advised the EC of location at the backup ESC and j
consideration for PARS based on wind direction and the <
location of the incident command post
9:33 a.m. The EC discussed with the ED concern for what the
intruder may be doing to the facility )
9:39 a.m. A facility staff member who responded to the incident
informed the EC that the intruder cut the lock to gain
entry to the Cavalier Room where the package was found
containing the bomb
ED contacted the EC and indicated that the emergency
classification remained a NOUE
9:40 a.m. Report received from caller (via facility cellular
ahone) that facility was lucky to get the student out j
aut the facility remains in danger l
9:43 a.m. ED upgraded the emergency classification to an Alert
based on loss of facility
The event upgrade was both delayed and incorrect based on
postulated conditions at the time of upgrade. Based on the
availability of additional information at the incident command
post as of 9:20 a.m. from the UVA Police. in addition to
information discussed at 9:33 a.m. and 9:39 a.m. combined with i
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the 9:40 a.m. phone call, postulated conditions at a minimum were
specific to Emergency Action Level (EAL) 3.4 in EPIP 1 for the
, SAE: " Imminent loss of physical control of the UVAR and/or
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CAVALIER Reactors;" or more appropriately EAL 4.3 in EPIP 1 for
the GE: " Loss of physical control of the Reactor Facility or UVAR
and/or CAVALIER Reactor control rooms." The inspector observed
Police briefing the EC at 9:20 a.m. that the building search was
, unsuccessful in determining the status of perpetrator (number
i and/or location). According to EPIP 1 (Emergency Director-
Controlling Procedure), item 5.b., "if EALs have been exceeded
declare the appropriate emergency class." At 9:43 a.m..
- conditions indicated a loss of physical control of the Reactor
Facility. This was identified during the exit meeting on
November 21, 1996 as an EW for failure to upgrade the event in a
timely manner (more than 20 minutes from the Police update to the
EC). Subsequently, based on additional review of exercise
details, the licensee was informed telephonically that the upgrade
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in the event classification was incorrect based on conditions at
the time of upgrade and the EALs in EPIP 1. In response, the
Facility Director responded as follows:
o Classification was based on known facts and conditions
existing at that time
o Drill artificiality in.that no individual was staged inside
the building as an intruder j
o Lack of information from the scene regarding the status of
the intruder and delays in receiving information from the !
incident command post impacted the classification upgrade 1
o Confusion resulted from non exercise activity associated
with access control and exercise simulations associated with
the intruder
The inspector indicated that an EW was identified for failure to
upgrade the event from a NOUE to a GE (rather than an Alert). In ;
addition, an IFI was identified for verification that corrective
actions are taken to improve performance in the area of
communications and timely updates from the incident command post i
to the backup ESC.
EW 50 62/96 03-02: Failure to upgrade the emergency
classification from a NOUE to a GE in accordance with Section 4.4
of EPIP 1. l
IFI 50 62/96 03 03: Verify that corrective actions are taken to
improve communications and timely updates from the incident
command post to the backup ESC. ;
Additional observations that were noted and discussed with members
of the licensee's staff had to do with the untimely response by
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University Relations to activate personnel and prepare press
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release. Adequate corrective actions were developed and
implemented prior to the exit. A significant program strength
that was noted involved the licensee's capability to remotely
interrogate the status of the reactor via a system referred to as
" MAX."
At the conclusion of the exercise, the licensee conducted a
critique that included participants from onsite and offsite
organizations. The critique included critical and candid
assessments by exercise participants.
c. Conclusions
The licensee's performance to protect the health and safety of
facility staff, and students was adequate.
F3.07 Training
a. Insoection Scope
Emergency response training was reviewed to determine if training
was conducted in accordance with the requirements in Section 10.1
of the EP.
b. Observations and Findinas
Based on the review of training attendance sheets, personnel as-
signed to the Emergency Notification Roster attended Calendar Year
(CY) 96 training. One exception that was noted by the inspector
involved the lack of attendance to training during early 1996 by a
HP Technician. The inspector noted that the only CY 96 response
training for the beforementioned individual was a November 14,
1996 table top drill. As a result, the inspector interviewed the
individual regarding the role and responsibility of the HP
Technician in the ERO, and the training provided (EPIPs, types of
surveys, radio use, etc.). In response, the interviewee indicated
that guidance was provided just prior to the exercise and included
instructions that EPIP 9 be reviewed for familiarity. No
additional training or instructions were given. The inspector
reviewed the normal day to day responsibilities for the
Technician, formal education, and past work ex>erience. Based on
the interview, the ins)ector determined that t1e individual was
qualified to perform t1e required functions associated with HP
surveys, but lacked a full understanding of the ER0 and the
reporting chains and interfaces for onsite and offsite response
organizations. The inspector concluded that the licensee's
performance in assigning the individual to the organization
without additional or more detailed instructions was marginally
acce) table only in that the appropriate actions were implemented
in t1e areas of health physics surveys. The 1996 emergency
response training was conducted on the following dates:
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April 24, 1996 - evacuation drill
June 3, 1996 - lecture involving a discussion of the EPIPs, SOPS, <
recent changes to the EPIPs\ SOPS, and the emergency action levels l
October 16, 1996 - cardiopulmonary resuscitation certification
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November 14,1996 - two hour table top drill conducted using I
scenarios presented by NRC during the 1996 TRTR meeting I
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Regarding offsite support training, no training was conducted. !
The licensee offered training during June 1996 according to i
documentation. However, at the time of the inspection, no offsite ,
group had requested that the licensee provide training as I
discussed in a June 1996 letter. I
c. Conclusions 1
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The licensee's performance in this area was considered acceptable '
in meeting the commitments of the EP. A significant amount of
training appeared to occur during the latter part of the calendar ;
year, with essentially no activity during the early part of the !
year. Additionally, the newly assigned EC had no prior knowledge
in emergency planning and comments from the exercise appears to
indicate the lack of training may have contributed to scenario
development problems.
VI. Management Heetings ,
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M1 Exit Interview l
On November 21, 1996, the inspection scope and results were summarized
with licensee representatives. The inspector discussed in detail the
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exercise observations, routine program areas inspected, and the l
findings, including the EW for failure to properly upgrade the event
classification. Dissenting comments were not received from the
licensee. The licensee did not identify any of the materials provided
during the inspection as proprietary.
M2 Teleconference Exit Interview
On December 6, 1996, the inspector informed the Reactor Director that ,
following further review of the exercise time line, and postulated
conditions that were given to members of the response organization at
the incident scene, the exercise weakness was identified for failure to
upgrade the event from a NOUE to a GE (rather than an Alert). In
response to the inspector's comments, the Director discussed in detail
the decision making basis, and the impact of scenario inconsistencies
and drill artificialities on the event classification. There were no
dissenting comments expressed by the licensee.
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ATTACHMENT
1 PERSONS CONTACTED
Licensee Personnel
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- P. Benneche, Reactor Supervisor
S. Bose, Research Specialist
- H. Crawford, Supervisor Electronics Shop
T. Doyle, Research Scientist, (Emergency Coordinator)
- J. Farrar, Reactor Administrator
- R. Flack, Chair, Mechanical Aerospace and Nuclear Engineering
- W. Johnson, Chair, Reactor Safety Committee
+*R. Mulder, Director, University of Virginia Reactor Facility
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- D. Steva, Reactor Health Physicist, UVA Environmental Health and Safety
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Other licensee employees contacted during this inspection included
administrative personnel, security, and public relations.
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Other Oraanizations
J. Abbott, Lieutenant University Police
K. Harden, Emergency Coordinator, Albermarle County
G. Urquhart, Distor, Virginia Department of Emergency Services Plans
Department
- Denotes those present at the exit meeting on November 21, 1996
+ Participated in teleconference exit on December 6,1996
2 INSPECTION PROCEDURES USED
IP 82745 Emergency Preparedness
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3 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50 62/96 03 01 IFI Verify that the RSC performs an audit of the
Plan and EPIPs during December 1996.
50 62/96 03 02 EW Failure to upgrade the emergency classification
from a NOUE to a GE in accordance with
Section 4.4 of EPIP 1.
50 62/96 03 03 IFI Verify that corrective actions are taken to
improve performance in the area of
communications and timely updates from the
incident command post to the backup ESC.
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Closed
50 62/95 02-01 IFI Perform modification and testing of the facility
evacuation alarm system to demonstrate facility
wide audibility coverage.
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j 4 LIST OF ACRONYMS
ARM Area Radiation Monitor i
CAM Continuous Air Monitor
CFR Code of Federal Regulation l
Calendar Year
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CY
EAL Emergency Action Level
, EC Emergency Coordinator
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ED Emergency Director 4
- EPIP Emergency Plan Implementing Procedure
ER0 Emergency Response Organization
- ESC Emergency Su) port Center
EW Exercise Wea(ness
GE General Emergency
- HP Health Physics
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IFI Inspector Followup Item
IP Inspection Procedure i
IR Inspection Report
NOUE Notification of Unusual Event
NRC Nuclear Regulatory Commission
PA Public Address System
PAR Protective Action Recommendation
Rev. Revision
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RSC Radiation Safety Committee
, RS0 Radiation Safety Officer
SAE Site Area Emergency
TRTR Test Research and Training Reactor
- UVA University of Virginia
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