ML20203G423

Insp Rept 70-7001/99-02 on 990125-29.No Violations Noted. Major Areas Inspected:Plant Support

ML20203G423
Person / Time
Site:	07007001
Issue date:	02/09/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203G406	List: ML20203G401 ML20203G423
References
70-7001-99-02, 70-7001-99-2, NUDOCS 9902190301
Download: ML20203G423 (11)

Text

- --

i- l L ,v l'

l U.S. NUCLEAR REGULATORY COMMISSION REGION lil  ;

i I

l I I

Docket No: 70-7001

' Certificate No: GDP-1  !

Report No: ' 70-7001/99002(DNMS) j i

Facility Operator: United States Enrichment Corporation f Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Roac i P. O. Box 1410 Paducah, KY 42001 Dates: January 25 through January 29,1999  ;

i inspector: T. D. Reidinger, Senior Fual Cycle inspector Approved By: Patrick L. Hiland, Chief -  :

Fuel Cycle Brance; .i Divisim of Nuclear Materials Safety ,

I i

k i

I i

l EXECUTIVE

SUMMARY

l United States Enrichment Corporation l Paducah Gaseous Diffusion Plant j l NRC Inspection Report 70-7001/99002(DNMS) j Plant Support Emeraency Preparedness

• The plant's Emergency Plan (PEP) and implementing procedures provided sufficient l guidance for responding to plant emergencies, and the emergency response j organization training was effective for responding to emergencies. Emergency '

response personnel were adequately trained and were knowledgeable of emergency . i response procedures and equipment. (Section P1.1)  ;

• The emergency management staff maintained adequate support with offsite agencies for responding to or assisting during an emergency event. (Section P1.2)

• . Emergency exercises and drills were very effective in exercising the plant's emergency  ;

response organization. The plant's emergency management staff maintained an effective tracking system for deficiencies identified during drills or exercises.

(Section P1.3) e The emergency preparedness staff maintained an effective inventory of well-maintained emergency response equipment and supplies in a state of  !

operational readiness. (Section P1.4) l e The overall organization and management structure of the PEP function was consistent ,

with the PEP and implementing procedures. (Section P1.5) '

• Based on the PEP review of records and interviews, the inspector determined those ,

changes to PEP and implementing procedures met commitments, the certificate, NRC requirements and the changes were distributed in a timely manner. (Section P1.6) e The inspector identified an Unresolved item related to the implementation and adequacy of the United States Enrichment Corporation emergency management organization  ;

located in Bethesda, Maryland. (Section P1.7) 2

s

< Report Details IV. Plant Suonort P1.1 Emeroency Plan and imolementina Procedures l.

. a. Inspection Scope (88050) 3-The inspector reviewed the plant's Emergency Plan (PEP) and implementing procedures, and organization and staffing to determine whether the emergency program was being maintained in a state of operational readiness. The inspector also reviewed training records and interviewed selected emergency response members to evaluate

[ their awareness of emergency procedures.

I b.~ Observations and Findinos The emergency response organization (ERO) and emergency response members' l 3

responsibilities were consistent with that described in the PEP. The PEP and implementing procedures provided effective guidance on the assessment of any potential releases of radioactive materials and hazardous chemicals. In addition, the implementing procedures were effective in providing guidance for site evacuation and assembly, internal and offsite notification of emergencies and personnel accountability with one exception. Section 5.4.1.2 of the PEP stated, in part, that transients on the Department of Energy (DOE) reservation, i.e., hunters, fishermen, hikers, etc., wili be directed to exit the reservation (usually upon declaration of a site area emergency). In support of that commitment, the PEP staff developed an emergency planning information pamphlet which was made available to the Westem Kentucky Wildlife Management area check-in station. The commitment for making this emergency planning information available was implemented in Procedure CP2-EP-EP5032, " Plant Emergency Management Program," Revision 2, dated April 10,1997. The inspector visited the check-in station early on January 27 and observed that the check-in station was closed. The inspector was unable to determine whether the emergency planning information pamphlets were available for visitors frequenting the reservation. In the absence of any available emergency planning pamphlets for public use, the plant's public waming and address system was available and designed to alert and provide guidance to visitors on the DOE reservation for any emwgencies occurring at the plant. I Resolution of the availability of emergency planning pamphlets for reservation visitors or attemate methods for providing guidance to reservation visitors will be tracked as an j i

inspection Followup item (IFl 70-7001/99002-01).

The inspector noted that the guidance contained in Procedure CP2-EP-EP5055,  ;

• Emergency Classification," Revision 2, dated May 15,1998, on classification,  ;

specifically relating to uranium hexafluoride (UF6) events was currently being revised to address at a minimum, event initiators such as fire or equipment failure. In response to ,

i the fire that occurred at the Portsmouth Gaseous Diffusion Plant (PORTS) on December 9,1998, several initial compensatory measures were immediately implemented for the plant shift superintendent (PSS) including a " Shift Operations Long Term Order," Number 98-12, Revision O, dated December 17,1998, and training. The order provided additional guidance to the PSS in classifying an actual or potential threat or consequences of an incident initiated by a fire or equipment failure. Training was i

3 4 _ _ _

_ ~_ _ _ _ - _ _ . _ _ _ _ .. _,

l

'. . i also conducted to address nuclear criticality safety concems that involved the l application of water or foam to breached UF6 process piping systems. j in addition, the inspector noted that the PEP staff had several other emergency ~

preparedness initiatives underway or planned that addressed the PORTS event. The initiatives included several planned emergency drills involving destructive chemical ,

reaction type events; control room habitability drills; and lubrication and hydraulic fluid i fire drills. In addition, the PEP staff were revising several emergency plan implementing l procedures to incorporate " lessons leamed" from the PORTS event. The inspector  :

noted that draft procedure,

• Fire Emergencies," CP2-EP-EP5062, Revision O, developed to provide additional guidance for responding to fires which have spread beyond the incipient stage, was currently in the review and approval process. The fire i protection pre-fire plans were expected to be revised in the near future following training l I

that was previously conducted to address nuclear criticality safety concems associated with fire fighting strategies using water and foam. ]

The PEP staff maintained a current roster of qualified plant EROS in the Emergency Operations Center (EOC). The inspector interviewed two Crisis Managers (cms) in the q ERO and noted a weakness in that the cms were unaware of the requirements in j Section 6.1.1 of the PEP to notify the United States Enrichment Corporation (USEC) i 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duty officer about events that may require an emergency response. Interviews ' ]

were also conducted with other ERO members in different capacities. The inspector ,

determined that the ERO members were knowledgeable of the applicable emergency  :

preparedness responsibilities, procedures, respective ERO assignments in the i emergency organization and were satisfactorily trained to maintain an overall  !

emergency management oversight during an emergency event. The inspector outlined several different accident scenarios with the EOC member responsible for plume modeling for the plant's chemical and dose assessment program and determined that the EOC member was proficient in plume modeling activities.

The inspector noted that selected EOC training records were up to date. In addition, training lesson plans for the plant EOC Director, CM, Incident Commander, Public Information Manager and Offsite Communicator were of high quality and adequately covered subject matter relative to the staffs respective assignments. As part of emergency response capabilities, an onsite state-certified emergency medical technician rescue staff (usually firefighters), was trained to handle emergencies. The rescue staff's training included emergency response in the areas of industrial hygiene, radiological response procedures, hazardous materials (HAZMAT) decontamination and '

spill control procedures, and first-sid procedures. The inspector attended a HAZMAT re-certification class conducted by the fire services and emergency management staff for emergency responders. The instructors were effective in_ discussing HAZMAT responsibilities and personnel protective equipment (PPE) used during emergency response with the emergency responders. The associated HAZMAT lesson plans and evaluation checklists were very detailed and consistent with PEP requirements. The instructor's performance evaluations of the emergency responders (donning PPE and Level A suit) were also observed.

' The staff also maintained an onsite fire department w'nich was equipped with ladder and pumper trucks to respond to fires and emergencies. The inspector noted that the fire e protection pre-fire plans were currently being updated to reflect additional nuclear 4

e

1 criticality safety concems identified at PORTS along with current facility configurations and conditions as required in the Compliance Plan.  ;

c. Conclusion l

The PEP and implementing emergency procedures provided sufficient guidance for responding to plant emergencies. The PSS

• Shift Operations Standing Order" was i adequate to classify fire scenarios similar to the recent PORTS event. The ERO l members were adequately trained and knowledgeable of emergency response procedures and equipment.

P1.2 Offsite Support Agencies i

a. Inspection Scope (88050) l r

The inspector evaluated the PEP staff's involvement with offsite support ' agencies as described in the PEP and implementing procedures. ,

1

b. Observations and Findinas Current agreement letters with offsite agencies for response or assistance during emergency events were maintained in accordance with the PEP and implementing procedures. The PEP staff had formally notified all applicable local, county, state, and federal support agencies regarding the full scale biennial participation emergency exercise that occurred on April 1,1998, as required. The PEP staff had contacted offsite support agencies on a quarterly basis, as required, to verify telephone numbers and points of contact.

c. Conclusions ,

The PEP staff maintained adequate support from offsite agencies for responding to or assisting during an emergency event.

P1.3 Drills. Exercises. and Audits

a. Inspection Scope (88050)

Records of drills, exercises, and audits were reviewed and discussed with cogreant -

emergency preparedness staff.

b. Observations and Findinas in accordance with the PEP and implementing procedures, periodic drills or table-top exercises were scheduled and conduded by the plant's ERO each year. Periodic drills

' included any of the following: a plant accountability drill, a chlorine release drill, a UF6 release drill, a fire drill, or a confined space drill. The inspector noted that the plant wide  !

accountability during drills and exercises was consistent with requirements stated in the i implementing procedures. Criticality evacuation drills were performed quarterly. The PEP staff conducted effective fire evacuation drills from several site buildings. In addition, the PEP staff satisfactorily conducted an emergency management exercise in i November 1998 with the ERO members. The scheduled biennial exercise, consisting of  !

5 l

- _ r

an accident scenario, activation of the ERO, and activation of emergency response l facilities, was satisfactorily conducted on April 1,1998. The next biennial field exercise with the NRC and other support agencies participating was to be scheduled in 2000.  :

Critiques of the fire and criticality evacuation drills, the full participation exercise, and the .;

emergency management exercise were detailed and comprehensive to identify and correct deficiencies. The inspector noted that the PEP staff had established an effective  !

system to track corrective actions for identified deficiencies from exercise, and drills.

The completion due dates for correcting the deficiencies were consistent with PEP priorities. The emergency management staff had effectively addressed a previous

. backlog of overdue deficiencies with dedicated resources. The NRC reviews of several open corrective action deficiencies were identified as having minimal safety significance in the PEP content or implementation. The PEP staff indicated that emergency management resources were committed to resolving open corrective action deficiencies in a timely manner.

The inspector reviewed two emergency preparedness audit reports that were issued in l 1998. The audits were performed either by members of the Independent Assessments Group or technical specialists within the plant staff The audits evaluated performance ,

relative to the requirements of the PEP and procedures, with special emphasis on

- training, emergency equipment, and memorandums of understanding from offsite agencies. In addition, the audit addressed emergency preparedness activities pertaining to the full participation exercise conducted in early 1998. There were no audit  :

findings that required a written response and no significant weaknesses were identified. l Comments from the audits were being addressed by the PEP staff via the corrective action program.  !

c. Conclusions Emergency exercises and drills were consistent with the commitments in the PEP and implementing procedures and adequately exercised the ERO. Recommendations and deficiencies identified in annual exercises and drills were effectively tracked and managed in a timely manner. <

I P1.4 Emeroency Eauipment and Facilities

a. Inscection Scope (88050) -

The inspector toured the EOC, other facilities and equipment, and observed related surveillances to determine whether the emergency response equipment,

- instrumentation, and supplies located in emergency repositories were maintained in a state of operational readiness.

b. Observations and Findinos E

The inspector noted that emergency equipment repositories contained the quantities and equipment identified in the PEP and implementing procedures. Cabinets containing emergency equipment and field kits were clearly identifiable, contents were orderly, and well maintained. Survey meters examined were calibrated and operational, and seif-contained breathing apparatus air tanks were full. In addition, the inspector verified i

via documentation (in support of maintenance, periodic tests or surveillances) that t l

6

L

l. .

I inventory and operability checks were timely, and that equipment and instrumentation stored at selected locations (Fire Service's emergency response vehicles, PSS emergency response vehicles) were operational and properly maintained.  ;

Surveillance records for the public address system were consistent with the requirements in the implementing procedures. The PEP stated, in part, that decontamination equipment and supplies on emergency response vehicles were t I adequate for decontamination activities in the field. The inspector noted from review of l surveillance records that the decontamination trailer was declared out of service with regard to conducting radiological decontaminations of contaminated personnel (contamination greater than 1 percent uranium-235 assay) due to unsatisfactory nuclear criticality safety evaluations of the various shower drain holding tanks. The decontamination trailer was still being used for conducting HAZMAT decontaminations of affected emergency responders (entry team members).

c. Conclusions y The emergency preparedne 1 staff maintained an effective inventory of well-maintained emergency response equipment and supplies in a state of operational readiness.

P1.5 Plant and USEC Emeroency Preparedness Oraanizations

a. Inspection Scope (88050)

The inspector conducted discussions with the PEP staff regarding their respective emergency management organizations and reviewed respective emergency responder rosters

b. Observations and Findinos j 3

The overall organization and management structure of the emergency preparedness function was consistent with the PEP and implementing procedures. Two emergency management specialists, one senior emergency preparedness analyst and one emergency preparedness technical associate reported directly to the Emergency .

Management Manager (EMM). The EMM reported to the Offsite and Facility Support Manager, who reported to the Plant General Manager. An emergency management-analyst who transferred to another organization and a former PEP consultant were also available to provide emergency support assistance to PEP staff. The PEP staff involved in the emergency preparedness program had qualified the former administrative office manager (emergency preparedness technical associate) to help facilitate required

. surveillance activities in addition to maintaining various PEP databases. The inspector reviewed selected surveillances conducted by the new emergency preparedness technical associate and determined that the surveillances were consistent with the requirements in the PEP and reflected a high level of competence. Interviews with the new emergency preparedness technical associate indicated a high degree of knowledge regarding the PEP, implementing procedures, and associated PEP surveillance requirements. The emergency preparedness technical associate's training records indicated that ERO and supplemental HAZMAT training requirements were completed as required to conduct PEP surveillances and PEP training.

l 7

l

l

c. Conclusions ,

I The structure of the plant's emergency preparedness organization was consistent with the requirements in the PEP. j P1.6 Emeroency Plan Prooram Chanoes

a. Inspection Scope I Changes to the PEP, implementing procedures, facilities and equipment were reviewed - i 1

to assess the impact on the effectiveness of the program and to verify that changes were provided as required by 10 CFR 70.32(1). ,

1

. b. Observations and Findinas ,

Since the August 1997 NRC inspection several PEP and numerous implementing ,

procedure changes were made. The inspector reviewed six procedures that were i revised and had incorporated changes since the last inspection for applicability and i adequacy in implementing the PEP. The changes to the implementing procedures i appeared to be procedural enhancements or updates and continued to implement the l PEP. , Several changes resulted from the full scale exercise conducted in 1998. The l administrative system for review and approval of PEP and implementing procedure l

' changes was reviewed and determined to be an adequate system for ensuring that  :

revisions did not reduce the effectiveness of the emergency management program. l The inspector verified that the approved authorities, as required in Section 7.1, of the PEP reviewed and approved the revisions. The revisions were distributed to controlled copy holders in a timely manner. During a facility walkdown, the inspector observed that l controlled copies of the PEP and implementing procedures were current in the selected ,

locations.~ Regarding several PEP changes, the NRC had requested that additional j information be prov',ded to clarify several proposed changes to the PEP. The inspector reviewed the PEP staff actions in response to the NRC request for clarification and determined that the clarification for the proposed changes was consistent with the

- NRC's written request. Selected review of several PEP changes indicated that the changes were properly dispositioned in accordance with 10 CFR 70.32(i).

c. Conclusions Based on the review of records and interviews, the inspector determined that changes to the PEP and implementing procedures met commitments, the certificate, and NRC requirements, and the changes were distributed in a timely manner.

- P1.7 Corporate Emeroency Manaaement Prooram. Records and Administration

a. Inspection Scope (88050)

The inspector reviewed the implementation of the USEC Emergency Management Program (EMP) that addressed the emergency operations facility (EOF) to determine whether the emergency response equipment, instrumentation, and staff were maintained in a state of operational readiness. In addition, related surveillances,

, training, exercises, critiques, and records for the EOF were also inspected.

8 o m _ ~ _

a. - .-+.--- .+.-- w

b. Observations and Findinas Chapter 6 of PEP stated, in part, that various emergency facilities, equipment, and l materials were maintained to support emergency response activities and that the facilities were activated to provide direction and control, offsite resource coordination, l and public information for emergencies. In addition to the onsite emergency facilities, Chapter 6.1.1 of the PEP described the responsibilities and function of the EOF located in Bethesda, Maryland. Discussions with the USEC EOF Safety and Health Assurance ,

^

and Policy Manager (SHAPM) revealed a training program deficiency in that the manager was unaware that the EOF was required by the PEP. The manager essentially stated that the EOF was not required by the PEP and that the EOF was a corporate organization only designed to assist the gaseous diffusion plants (GDPs) during a i declared emergency; j Section 5.2 of the EMP stated, in part, that annual training would be provided to all members of the emergency response team (ERT) and required training could be received through formal classroom activities or participation in GDPs drivs and

. exercises. Section 5.0 of the EMP stated, in part, that records and reports of activity )

conducted in response to emergency planning, response and preparedness will be maintained by the SHAPM . The inspector questioned the SHAPM on how USEC ensured that the ERT mnmbers were current with the EMP training requirements and whether training requirements and associated lesson plans were developed as required by the EMP. The SHAPM explained that training was essentially on-the-job for ERT members and was conducted after the emergency drills and exercises. The associated attendance records were generally handled in an informal manner and not documented.

Chapter 8.2 of PEP stated, in part, that emerger.cy preparedness records were to be retained to document readiness assurance. The records included the following: I emergency management training and retraining; lesson plans; drill and exercise critiques; and surveillance of emergency equipment. The SHAPM explained that official documentation (lesson plans and sign-up sheets) was not available to verify that annual I

or refresha grvining coJJrses were conducted for USEC ERT members.

Pending completion of the inspectors' review of current plant and USEC emergency management policies, training, procedures, and records; the implementation and I adequacy of the EOF will be tracked as an Unresolved item (URI 70-7001/99002-02). l

c. Conclusions Based on the review of records and interviews with USEC staff, the inspector identified 4 an URI related to the implementation and adequacy of the emergency operations  :

facility..

V. Manaaement Meetinas X Exit Meeting Summary The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspection on January 29,1999. The plant staff acknowledged the findings presented.

9

The inspector asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

l PARTIAL LIST OF PERSONS CONTACTED  !

Lockheed Martin Utility Services -

• M. A. Buckner, Operations Manager

• C. V. Hicks, Site Facility and Support Manager

• L. L. Jackson, Nuclear Regulatory Affairs Manager

• H. Pulley, General Manager l

• W. E. Sikes, Commitment Manager j United States Ennchment Corporation

• J. A. Labarraque, Safety, Safeguards and Quality Manager

• Denotes those present at the January 29,1999 exit meeting. [

Other members of the plant staff were also contacted during the inspection period or attended the exit meeting.

INSPECDON PROCEDURE USED IP 88050: Emergency Preparedness ITEMS OPENED, CLOSED AND DISCUSSED Opened l '70-7001/99002-01 IFl Resolution of the availability of emergency planning pamphlets or attemate notifications for DOE reservation visitors.

70-7001/99002-02 URI implementation and adequacy of the USEC organization.

j Closed None.  !

i Discussed None r

10 l

l ,

l~ '

-._,- . . . - ~ - . - .. - - - .. .- - - - .. - . -.. . - .

p ,

p  ;

1 i'

i-LIST OF ACRONYMS USED l l CFR Code of Federal Regulations '

CM Crisis Manager i DOE- Department of Energy EMP Emergency Management Program

-EOC Emergency Operations Center EOF Emergency Operations Facility EMM. Emergency Management Manager ERO Emergency Response Organization

. GDP : Gaseous Diffusion Plant

• HAZMAT Hazardous Material -

IFl Inspection Followup item NRC , Nuclear Re0ulatory Commission PPE Personnel Protective Equipment PORTS Portsmouth Gaseous Diffusion Plant

.PSS' Plant Shift Supervisor l- PEP Plant Emergency Plan - ,

SHAPM- Safety and Health Assurance and Policy Manager.

i UF6 Uranium Hexafluoride l URI Unresolved item USEC United States Enrichment Corporation l.

l i.

11 l

- , _ . _ . .- . .. . .