ML20197J826
| ML20197J826 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/19/1997 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 70-7002-97-09, 70-7002-97-9, GDP-97-2033, NUDOCS 9801050105 | |
| Download: ML20197J826 (7) | |
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[nrit hment Citporation N vimber 19,1997 United States Nuclear Regulatory Commission GDP-97-2033 Attention: Chief Fuel Cycles Branch Region ill 801 Warrenville Road Lisle, Illinois 60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS) Docket No. 70-7002 Report of Action Taken on NRC Emergency Exercise Inspection Report 70-7602/97009 (DNMS)
Nuclear Regulatory Commission (NRC) letter dated October 20,1997, transmitted the subject inspection Report (IR) 70-7002/97009 (DNMS) that contained identified weaknesses in emergency plan knowledge and training. Enclosure 2 to this response provides a summary of actions taken to resolve those concern. Tim enclosed response addresses the following:
Completion of the accountability report in a timely manner.
Notification of tha NRC operation center in a timely manner.
Command and contrcl of the Command Post and delegation of responsibilities.
Evaluation of the ALOllA plume release model for adequacy.
Delayed implementation of search and rescue by the emergency responders.
Physical safety of a " simulated" victim.
Lack of effective contamination control practices at the scene.
USEC agrees that overall skills improvement is needed within the Emergency Response Organization and our actions should target both core competencies and individual responders.
Consequently, we have identified the core competencies required for improvement and are i
developing a structured training and drill program to target identified weaknesses and to improve the effectiveness of emergency response personnel. We believe that this action, in conjunction (l
9901050105 971119' hhh[lhh PDR ADOCK 07007002 PDR NOV 2 0 ud Offices in Paducah, Kentucky Portsmouth. Ohio WasNngton, DC
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l United States Nuclear Regulatory Commission November 19,1997 -
Page Two with those contained in the attached response demonstrate that we understand the basic issues and that we are being responsive to the needs of the facility, management expectations, and NRC concerns. lists the commitments contained this submittal. If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, r-hs James B. Morgan Acting General Manager Portsmouth Gaseous Diffusion Plant Enclosures (2) cc:
Regional Administrator, Regien til NRC Residentinspector, PORTS Document Control Desk, Washington, D.C.
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5 STATUS OF ACTIONS TO ADDRESS NRC EMERGENCY EXERCISE INSPECTION REPORT 70-7C32/97009 (11NMS) 1)
Issue: Failure to complete the accountobility report in a timely manner. (70-7002/97009 01)-
Background
During the Emergency Teamwork '97 Full Participation Exercise, accountability reporting was delayed because die plata population was confused about participation requirements for accountability reporting during the drill activity. Specifically, plant personnel did not respond because many did not know or thought they were exempt from accountability reporting because it was "only an exercise" and they were not exercise pa ticipants. Others were involved in the exercises as observers, controllers, or evaluators and belies ed the." were also exempt from the plant wide accountability request.
Resnonse To communicate management's expectations related to accountability reporting requirements, PORTS Emergency Management will disseminate guidance to plant empleyees via publication of a Lessons Learned Summary Newsletter related to accountability requirements during drill and exercises. To reinforce managements's expectation, mandatory crew briefings will be conducted to communiente and stress the importance of reporting during an accountability request. In addition, the PORTS General Employee Training (GET) module will be revised to clearly identify.
accountability reporting protocol. To test the effectiveness of these actions, an accountability drill will be conducted in concert with a plant exercise by July _1998.
2)
Issue: Failure to rotify the NRC opera. tion center in a timely manner. (70-7002/97009-02)
Background
- During Emergency Teamwork '97 Full Participation Exercise, NRC noted that the NRC individual listed in the emergency notification form was the State Liaison Ofticer in Region Ill rather than the NRC IIcadquarters Operations Officer (1100).
. Response Appro;.'mately 41 minutes following the declaration of the emergency event, the Assistant Plant Shift Superintendent (PSS) notified the NRC Headquarters Operations Officer (HOO) in El-1
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Rockville, Maryland, of the emergency classification at PORTS. Ilowever, when documenting tiiis call, the Assistant PSS noted a Region til rather than an NRC Headquarters contact had been madec While a documentation error was the cause of the confusion, the NRC licadquarters was notified within the required time frame.
3)
Issue: The Incident Commander did not take control of the Command Post and did not timely delegate responsibilities to the sectional commanders. (70-7002/97009 03)
Background
During the Emergency Teamwork '97 Full Participation Exercise, the incident Commander failed to estr.blish an elTective command and control structure at the Cornmand Post. As a result,' Sector Commandera were not held accountable or responsible for their affected areas, in addition, the incident Commander did not provide tetical objectives to Sector Commandeis and Sector Commanders did not adequately support the lucident Commander. The fundamental reason for this weakness is attributed to a lack of a field training and practice propa at the individual level which focuses on core fundamental concepts (i.e., Core Competencies) and the basics of emergency actic response, in addition, the current program does not ensure adequate feedback of j;
lessons learned, developed from diill and exercise critiques, is disseminated to field response organizations.
Resnonse l
PORTS Emergency Management staff, Fires Services, Plant Shift Superintendent, and llealth Physics formed a team to identify core competencies necessary for effective implementat on of the i
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PORTS Emergency Plan and EPIPs. " Incident Command" was identified as one of those core L
competencies Selected drills and exercises are being deseloped to target the implementation requirements for incident command; we will be conducting scheduled drills to test each Plant Shift Superintendents' competency. These drills will begin by January 31,1998. A lessons leamed feedback process is being developed and.will be proceduralized by February 28,1998. This formal process will ensure that lessons teamed from drills and exercises will be disseminated to field response organizations and used to improve field performance.
4)
-Issue: The ALOlIA plume release model does not compensate for changes in i
meteorological conditions or extrapolate plume migration as related to changes in wind direction. (70-7002/97009-04)'
Background -
Following the termination of the UF release from the dropped cylinder the ALOHA plume release model anchors the plume at the point of Qe release and is unable to model a detached plume after
' the release has been terminated. The NRC is concemed that the plume model does not compensate for changes in meteorological conditions.
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-e Response -
'I5e' ALOIIA plume model is nationally accepted guassion model, approved by the EPA and used by the State of Ohio and the State of Kentucky. It was selected for use at Portsmouth and Paducah '
to bring the GDPs into close alignment with similar industrial facilities. PORTS Emergency Management will coordinate a review of the plume model currently in use with other users of the ALOHA plume release model to determine the adequacy of the ALOHA model. 'lhis review will-be compkted by June 30,1998.
5)
Issue: Removal of the two material handlers and a llP technician by the emergency responders was delayed. (70-7002/97003-05) 0 Dackereund During the Emergency Teamwork '97 Full Participation Ex :reise, search and reseta activities were
- not carried out in a timely manner. Due to a lack of command and control by the Incident Commander, tactical objectives were not issued to Sector Commanders in a timely manner. As a result, the removal of victims from the affected area was delayed. The fundamental reason for this weakness is dircussed in exampic 3 of this response.
Response
The "scarch and rescue" function has also been identified as one of the core competencies required to demonstrate an effective emergency response. Corrcctive actions to address the fundamental weakness associated with search and rescue discussed in example 3 of this response will be applied to the search and rescue issue as well 6)
Issue: Two fire department team members were unnecessarily subjected to a heat stress condition which potentially compromised the physical safety of an individual role playing a " simulated" victim, (70-7002/97009-06)
Backcround During the Emergency Teamwork '97 Full Panicipation Exercise, two members of the Fire Services Department wearing Class-A personal protective equipment, attempted to carry a victim approximately 500 yards to safety. The actual safety of the victim became a concern when the rescue team began to exhibit signs of heat stress and excessive fatigue. When the exercise controller recognized the condition, the controller directed the fire department team members to remove thei: personal protective equipment and suspend that portion of the exercise. The
. fundamental reason for this weakness is discussed in example 3 of the response.
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Respor.sq Recognition of the safety of mdividuals during drills is addressed in the "on scene safety" and the
" earch and rescue" functions which have been identified as core competencies required to demonstrate an ef#ective Emergency Management program. Corrective actions to address the fundamental weakness associated with search and rescue are included in the core competency corrective action plan discussed in example 3.
7)
Issue: The lack of effective contamination control during decontamir.ation of responders. (70-7002/97009-07)
Backcround During Emergency Teamwork '97 Ful! Participation Exercise, decontamination of returning responders was less than adequa'c. In some instances responders in the decontamination area cross-contaminated other pieces of equipment. The fundamental reason for this weakness is discussed in exampie 3 of this response. Contributing to the weakness was the llP technician's insensitivity toward proper implemmation of proper llealth Physics practices during the exercise.
Resnonsg The llealth Physics Grot.p admiuu,tered disciplinary action to the subject IIP technician for not implementing proper llealth Physics practices during the exercise. In addition, the 1lealth Physics department issued an infonnation notice (via the required reading program) to the llealth Physics group conceming the proper actions to take should a monitoring instrumentation be dropped in a contaminated area.
PORTS Emergency Management staff, Plant Shift Superintendent, Fire Services, and IIcalth Physica have identified "decontanJnation" and "IIAZMAT" functions as core competencies. The overall corrective actions to address the fundamental weaknesses identified in the report are discussed in example 3 of this response.
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,e UNITED STATES ENRIC'IMENT CORPORATION (USEC)
List of Commitments 1)
To communicate management's expectations related to accountability reporting requirements. PORTS Emergency Management will disseminate guidance to plant employees via publication of a Lessons Leamed Summary Newsletter related to accountability requirements during drill and exercises.
2)
To reinforce managements's expectation, mandatory crew briefings will be conducted to communicate and stress the importance of reporting during an accountability request.
3)
PORTS General Employee Training (GET) module will be revised to clearly identif, accountability reporting protocol.
4)
To test the effectiveness of these actions, an accountability drill will be conducted in concert with a plant exercise by July 1998.
5)
Selected drills and exercises will be developed to target identified core competencits and these enhanced drills will begin by January 31,1998.
6)
A lessons leamed feedback process is being developed and will be proceduralized by February 28,1998.
7)
PORTS Emergency Management will coordinate a review of the plume model currently in use with other users of the ALOllA plume release model to determine the adeq'tacy of the ALOllA model. This review will be completed by June 30,1998, and recommendations presented to management for approval.
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