IR 05000062/1998201

Insp Rept 50-062/98-201 on 980126-28.Violations Noted.Major Areas Inspected:Review of Emergency Preparedness Program of This Class 1 Non Power Reactor Including Organization, Facilities & Equipment & Safety Committee Actions & Audits

ML20197B807
Person / Time
Site:	University of Virginia
Issue date:	03/04/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20197B794	List: ML20197B788 ML20197B796 ML20197B801 ML20197B807
References
50-062-98-201, 50-62-98-201, NUDOCS 9803120064
Download: ML20197B807 (15)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION . Docket No.: 50-62 1-l

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Report No.: 50-62/98 201

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i l Licensee: University of Virginia

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Facility: University of Virginia Reactor (UVAR)

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f Location: Charlottesville, VA 22901 i

inspection Conducted: Januury 26-28,'1998 Inspector: C. Bassett, Senior Non Power Reactor Inspector Approved by: Marvin M. Mendonca, Acting Director Non-Power Reactors and Decommissioning Project Directorate

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EXECUTIVE SUMMARY University of Virginia Reactor (UVAR)

NRC Inspection Report No. 50-02/98 201 The primary focus of this routine, announced inspection was the on-site review of the emergency preparedness program of this Class I non-power reactor including organization, f acilities and equipment, safety committee actions and audits, procedures and training, offsite agency support, and drills and exercise Chanaes. Oroanization. and Staffina e

The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specification Chances to the Emeroency Plan and imolementina Procedures

• Changes made to the Emergency Plan and implementing procedures were made in accordcnce with 10 CFR 50.54(q) and revisions were distributed in a timely manner.

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Emeroencv Preoaredness Proaram imolementation/ Exercises and Drills

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• Tl o most recent annual on-site emergency exercise was conducted in accordance with requirements outlined in the Emergency Plan.

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Licensee personnel designated as responders to the " emergency" were cognizant of I their responsibilities.

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Emergency response f acilities, equipment, instrumentation, and supplies were maintained as require Offsite Succort

The licensee maintained coitact with offsite agencies through Letters of Agreement and periodic commuriication that confirmed support for the f acility in case of an emergenc *

Of fsite agencies participated in simulated emergencies biennially as required by the Emergency Pla Emeraency Alarms and Communications Systems

• Alarms and communication systems were being maintained as require * An inspector Follow-up item was established concerning the licensee's decision to install an additional alarm in the reactor roo *

An apparent violation was noted for failure to test the evacuation alarm every six months as required by the Emergency Pla . _

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Tralnina e The training provided to emergency responders by the licensee was acceptable and complied with the requirements in the Emergency Pla Follow un on Previous Onen items

• One Inspector Follow-up item and an Exercise Weakness were close * One Inspector Follow up item remains open following a review of the issu * An apparent deviation was noted following a review of the licensee's actions in response to the Exercise Weakness.

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REPORT DETAILS l

Summary of Plant Str.tus The licensee's two megawatt (2 MW) research reactor continues to be operated !n support of graduate instruction end laboratory experiments, reactor operator training, and various types of research. During the inspection, the reactor was being started up, operated, and shutdown as required to support training and researc . Organization and Staffing (82745)

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a. insoection Scone The inspector reviewed the following regarding the licensee's organization and -

staffing to ensure that the requirements of TS Sections 6.1.1, 6,1.2, and 6.1.3 were met:

e the organizational structure, e management responsibilities, and-e staffing requirements for safe operation of the UVAR facilit b. Observations and Findinas Through discussions with licensee representatives the inspector determinec: that management responsibilities and the organization at the facility had not changed since the previous NRC inspection of emergency preparedness in November 1996 (Inspection Report No. 50-62/96-03). The inspector determined that the MANE Department Chairman retained overall responsibility for management of the facility and emergency preparedness as specified in the T Through observation of operations and discussions with licensee personnel, the inspector determined that the staff;ng at the facility was adequate to support the

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work and any emergencics that might develop. Although staffing met the requirements of the Technical Specifications and the Emergency Plan, the inspecter noted that additional personnel would be required to support any increase in the workloa c. Conclusions The licensee's organization and staffing remain in compliance with the requirements specified in the Technical Specifications and Emergency Pla ... .

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2. Changes to the Emergency Plan and implementing Procedures (82745)

a insoet.tlon Scone l'he inspector reviewed the following to ensure that changes, if any, to the Emergency P an and implementing procedures were made in accordance with 10 CFR 50.54(q):

• the review, approval, and distribution process for the Emergency Plan, e the review, approval, and distribution process for the implementing procedures, and e documentation of changes made to the Emergency Plan and implementing procedures, b. Observations and Findinos The inspector reviewed documentation and discussed changes to the Emergency Plan and implementing procedures with licensee pe sonnel. It was noted that the last major update and revision to the Emergency Plan, Revision (Rev.) 3, was approved and submitted for NRC review and approval on March 10,1995. By letter dated June 11,1996, the NRC approved the changes. Since then, no major revisions or changes have been made. The inspector also noted that changes have been made to the implementing procedures but these have been minor in nature and have involved administrative issues such as personnellistings and telephone number changes. It was also noted that the Emergency Plan and procedures had been distributed to the staff members and other agencies as require c. Conclusions Based on interviews with licensee personnel and documentation reviews, the changes were made in accordance with 10 CFR 50.54(q) and distributed in a timely manne . Emergency Preparedness Program implementation / Exercises and Drills (82745)

a. Insoection Scoce The inspector reviewed the following to ensure that the Emergency Plan and associated crocedures were t'eing implemented consistently with the TS and the requirements specified in the Emergency Plan:

• the performance of emergency response personnelin simulated emergency situations, e the condition of emergency response f acilities, equipment, instrumentation, and supplies, and

• the documentation of recent drills and exercise _ _ _ - _ _ _ _ - - _ _ _ _ - _-_

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3-b. Observations and Findinos The inspector reviewed the results of the most rr. cent annual on site emergency exercise conducted at the facility on January 13, 998. The inspector reviewed the (

scenario and a checklist of the time line of events used in the exercise. Alt > t reviewed was the detailsJ description of sne emergency responders' actions as noted by the designated observers and a summary of the critique of the exercise by the participants and observers. The exercise was conducted in accordance with, and fulfilled the requirements stipulated ir, the Emergency Plan. Key licensee emergency response personnel demonstrated that they could respond to emergencies as required. Offsite response agency communications verifications were completed as required by the Emergency Pla The inspector toured the licensee's f acility and observed the facilities, equipment, instrumentation, and supplies that would be used for response to an emergency, it was noted that they were being maintained in a state of readiness as required by the Emergency Plan. Copies of the Emergency Plan and the implementing procedures '

were noted to be available in various locations as require c. Conclusions

! The mos ent annual on-site emergency exercise was conducted according to j 'equiremei 4 outlined in the Emergency Plan. Licensee personnel designated as responders to the " emergency" were ;ognizant of their responsibilities. Emergency response f acilities, equipment, instrumentation, and supplies were maintained as required.

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4. Offsite Suooort (82745)

a. insoection Scoce The ir'spector reviewed the following to ensure that offsite support would be available to the facility as indicated in the Emergency Plan:

• Letters of Agreement signed by offsite agencies,

• training provided to the offsite agencies, and

• coordination and communication with these agencies, b Qassrvations and Findinas The inspector reviewed the Letters of Agreement and noted that all the agen-Ms specified in the Emergency Plan had signed letters indicating various types of support for the f acility in case of a problem. All the letters were current but were being reviewed and renewed during this calendar year. Although no training had been provided to offsite personnel, it was noted that such training and site f amiliarization had been offered through letters to the agen 'as issued during 199 l l

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-4-l During the most recent drill, offsite agencies had not participated directly because' !

they had participated in last year's drill and are only required to participate bienially. )

However, various groups were contacted by telephone as required by procedur '

Offsite participation had been accomplished during the exercise conducted on November 19,1996. Participation of the offs!!e agencies was determined to be acceptable and communications were deemed satisfactory, c. Conclusions The licensee maintained contact with offsite agencies through Letters of Agreement and periodic communication that confirmed support for the facility in case of an emergency. Offsite agencies participated in simulated emr,rgencies biennially as required by the Emergency Pla . Emergency Alarms and Communications Systems (82745)

a. insoection Scooe The inspector reviewed the following to ensure that emergency alarms were operable and being maintained as required by TS 4.4 and 4.7 and Emergency Plan Section 7.2(2):

• periodic functional tests of emergency alarms and communications systams, e calibration of monitoring equipment, and e maintenance records of the alarms and equipment, b. Observations and Findinas Through a review of the documentation of calibration, maintenance, and/or periodic testing of the emergency alarms, the inspector determined that the alarms functioned as required. These included the criticality alarm system, the continuous air monitor (CAM), the evacuation alarm, the Argon monitors, and the area radiatbn monitors. It was noted that, during one annual facility evacuation drillin April 1997, the alarm was not sufficiently loud in the UVAR reactor room to attract one's attention immediately. To assure that the alarm was understood effectively and quickly, the licensee had decided to install an additional alarm in the reactor roo The inspector informed the licensee that the installation of the additional alarm in the reactor room will be tracked as an inspector Follow up ltem (IFI) by the NRC and will be reviewed during a subsequent inspection (IFl 50-62/98 201 01).

10 CFR 50.54(q) requires that a licensee authorized to possess and/or operate a research reactor shall follow and maintain in effect emergency plans which meet the requirements in Appendix E of Part 50. Section 8.4(2) of the licensee's Emergency Plan reouires that the evacuation alarm will be tested once every six month _-

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The inspector noted that the evacuation alarm was typically tested in the spring during the annual evacuation drill and in the fall during the annual emergency exercise. On occasion, the alarm was also tested along with the fire alarm. In 1996, the evacuation alarm had been tested on Januery 22 along with the fire alarm and on April 24 during the evacuation drill. The alarm was also tested during the annual exercise on November 19,1996. In 1997, the evc? ation alarm was tested along with the fire alarm on January 22 and again on April 11 during the annual evacuation drill. The alarm had not been tested in the fall of 1997 and was not tested during the most recent emergency exercise on January 13,1998. The licensee was informed that f ailure to test the evacuation alarm every six months was an apparent violation (VIO) of 10 CFR 50.54(q) (VIO 50-62/98-201-02).

Following the inspection, the licensee contacted the NRC by electronic mail (e-mail)

anJ informed the inspector that an evacuation drill had been conducted anC the alarm tested on Friday, January 30,1998, c. Conclusions Alarms and communication systems were being maintained as required. An Inspector Follow up Item was established concerning the licensee's decision to install an additional alarm in the reactor room. Also, an apparent violation was rnted for failure to test the evacuation alarm every six months as required by the Emergency Pla . Training (82745)

a. Insoection Scone The inspector reviewed the following to ensure that training was being completed according to the requirements in Section 10.1 of the Emergency Plan:

• Ree0 tor operator requalification training records, e annual training given UVAR personnel, and e emergency respond:r training records and documentatio b. Qbservations and Findin i F.eview of the records and documentation of the annual training given, '

wed that emergency response personnel were receiving the training outlined in Sacuon 10.1 of the Emergency Plan. The training included decision making, transmitting information, accident assessment, radiological monitoring and first aid as require The recent on-site emergency exercise showed the effectiveness of the training, c. Conclusions The training provided to emergency responders by the licensee was acceptable and complied with the requirements in the Emergency Pla .

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6-7. Follow up on items of Noncompilance (92701)

a. Insoection Scong The inspector reviewed the actions taken by the licensee following identification of previously noted Inspector Follow up Items and a Violatio b. Observations and Findinas (*) IFl - 50-62/96-03-01 - Verify that the Rear: tor Safety Committen (RSC)

completes an audit of the Emergency Plan and implementing procedures during December 199 During a provious inspection in November 1996, it was noted that the RSC was scheduled to complete an audit of the emergency preparedness program during December 1996. The inspector reviewed the results cf the audit conducted in December 1996 and rioted that the auditors identified various findings. The findings were subsequently addressed by the licensee in a response to the RSC by It;tter dated May 28,1997. The audit and actions taken in response wero l

determined to be acceptable. This IFlis considered close (2) Exercise Weakness (EW) - 50-62/96-03-02- Failure to upgrade the emergency classification from a Notification of Unusual Event (NOUE) to a General '

Emergency (GE) in accordance with Section 4.4 of Emergency Plan implementing Procedure (EPIP) 1.

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In response to this EW, the licensee submitted a letter to the NRC dated February 17,1997. In the response the licensee committed to revise the EPIPs to correct the weakness. The revision to the EPIPs was to be completed and presented to the RSC for approval by July 1,199 During this inspection,it was noted that the EPIPs had not been updated. The inspector discussed this issue with the licensee and the licensee suggested that the EPIPs were not and probably would not be updated due to a tro.iage of staff needed for such a project. The licensee was informed that failure to update the EPIPs as initially indicated was an apparent deviation (DEV) to comply with a written commitment made to the N9C (DEV 50-62/98-201-02).

This EW is considered closed but, as noted above, an apparent deviation resulte (3) IFl - 50-62/96-03-03 - Verify that corrective actions are taken to improve performance in communications and timely updates from the incident command post to the backup Emergency Support Center CSC).

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Besides the commitment noted above concerning updatirig the EPIPs, the lics.1see also stated that an emergency drill desktop training session would be held to discuss the NRC inspection report documenting the Novomber 1996 inspection. During the desktop training session, " lessons learned " from the .

exercise and the report were to be reviewed as wel During this inspection, it was noted that this desktop training session was never hed. This item will romain open, c. Conclusions a

f IFI 50-62/96-03-01 is considered closed. EW 50-62/96-03-02 will be closed but an apparent deviation was noted. IFl 50-62/96 03-03 will remain ope . Exit Interview

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The inspection scope and results were summarized on January 28,1998, with licensee

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personnel. The inspector described the areas inspected and discussed in detail the inspection findings-No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector, a

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i PARTIAL LIST OF PERSONS CONTACTED Licensee Emolovaes P. Benneche, Reactor Supervisor C. Bly, Senior Reactor Operator B. Hosticka, Senior Reactor Operator R. Mulder, Director, University of Virginia Reactor (UVAR) Facility Other Oraanizations -

D. Steva, Reactor Health Physicist, Environmental Health and Safety Department INSPECTION PROCEDURE USED IP 82745 Class i Non Power Reactor Emergency Preparedness

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l ITEMS OPENED. CLOSED. AND DISCUSSED Ooened item Number .T.vna Descriotion and Reference 50-62/98 201-01 IFl Follow up item on the licensee's decision to install an additional alarm in the reactor room (Paragraph 5.b ).'

50 62/98 201-01 VIO Failure to test the evacuation alarm every six months as required by the Emergency Plan (Paragraph 5.b).

50 62/98 201-02 DEV Failure to update the EPIPs as initially indicated in a letter to the NRC dated February 17,1997 (Paragraph 7.b(2)).

Closed item Number Iygg Descriotion and Reference 50-62/96 03-01- lH Verify that the Reactor Safety Committee (RSC)

performs an audit of the Emergency Plan and implementing procedures during December 1996 (Paragraph 7.b(1)).

50 62/96 03-02 EW Failure to upgrade the emer0ency classification from an NOUE to a GE in accordance with Section 4.4 of EPIP 1 (Paragraph 7.b(2)).

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Discussed item Number .IYRA D.g;criotion and Reference 50-62/96-03 03 IFl Verify that corrective actions are taken to improve performance in communications and timely updates from the incident command post to the backup ESC (Paragraph 7.b(3)).

U.ST.0F ACRONYMS USED CFR Code of Federal Regulations DEV Deviation EPIP Emergency Plen Implementing Procedure ESC Emergency Support Center EW Exercise Weakness GE General Emergency IFl Mspector Follow-up Item IP inspection Procedure NOUE Notification of Unusual Event NPR Non-Power Reactor NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation PDR Public Document Room RSC Reactor Safety Committee TS Technical Specification UVAR University of Virginia Reactor VIO Violation l

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