ML20204G303
| ML20204G303 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 03/19/1999 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 70-7002-98-19, GDP-99-0047, GDP-99-47, NUDOCS 9903260125 | |
| Download: ML20204G303 (6) | |
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USEC l_
A Global Energy Company March 19,1999 GDP 99-0047 Ms. Cynthia D. Pederson Director, Division of Nuclear Materials Safety U. S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, Illinois 60532,351 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to the Augmented Inspection Team Finding Concerning not Properly Classifying an Emergency Situation (Inspection Report 070-7002/98019)
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Dear Ms. Pederson:
On February 16,1999, the United States Nuclear Regulatory Commission (NRC) issued the subject Inspection Report (IR) which presented the results of the NRC's Augmented Inspection Team review of the December 9,1998, fire at PORTS. Sections 4 and 11 of this report identified a deficiency that the Incident Commander (IC) did not declare an Alert due to an inconsistency between the Emergency Plan (EP) and the Emergency Plan Implementing Procedure (EPIP). This letter addresses the United States Enrichment Corporation's (USEC's) response to the identified deficiencies in the EPIP.
USEC concurs with the NRC's findt igs conceming the failure to declare an Alert. We believe this was due to shortcomings in the EPIP and the training of our ICs. Accc Hingly, USEC is informing NRC of the results of our investigation into the failure to declare an /
' uhe December 9,1998, event at PORTS. Enclosure 1 describes the results of the root cause ~.m..., USEC has performed on this issue, the corrective actions taken, and the corrective actions to be taken.
USEC requests that the NRC consider the enclor.ed information, as well as the information below, in any deliberation regarding this issue.
There have been no previous NRC violations or findings concerning the PORTS Emergency Classification program l
'50002 As discussed in the enclosure, actions have been taken to correct this deficiency in a l
reasonable timeframe. The ICs at both the PORTS and Paducah (PGDP) Gaseous Diffusion A' \\
Plants have been made aware of this event and specifically the need to declare an Alert in the 9903260125 990319 PDR ADOCK 07007002-'
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C PDR,
) rive, Bethesda, MD 20817-1818 s
Tefe~ phone 301-564 3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
Ms. Cynthia D. Pederson March 19,'1999 GDP 99-0047, Page 2 l
event that a fire occurs that affects safety related systems which may result in a radiological or hazardous material release. The PORTS EPIP has been revised to add a new Emergency
- Action Level (EAL) which requires,in part, that an Alert be declared for a " Fire potentially, or actually, compromising the functions of safety systems which may result in a radiological or hazardous material release." Training on this revised procedure is currently in progress.
Similar corrective actions are also being taken at the PGDP facility.
The failure to declare an Alert was not caused by any willful actions. Rather, it was due to personnel error by the IC and an inconsistency between the EP and the EPIP. Additionally, the EALs in the EPIP were too narrowly focused on hazardous and chemical releases and did not consider other natural or man-made phenomena (e.g., fires, seismic events) contained in Appendix A to Regulatory Guide 3.67, " Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities."
USEC has communicated with NRC at a Senior Management Meeting on February 18,1999, regarding some of the corrective actions being taken to address this issue. lists the commitme s contained in this submittal. Ifyou have any questions concerning this submittal, please contact l'eter J. Miner at (740) 897-2710.
Sincerely,-
n S. B.
l Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager
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Enclosures cc:
NRC Document Control Desk NRC Resident Inspector - PGDP & PORTS l
NRC Special Projects Branch e
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GDP 99-0047 Page1of3 Results of USEC's Investigation Concerning the Failure to Declare an Alert during the December 9,1998, Fire at PORTS I.
Roct Cause(s)
J USEC's investigation has determined that the failure to declare an Alert during the December 9,1998, fire at PORTS was due to the following:
1 A.
Failure to Procerly Incoroorate EP Requirements into implementing Procedures PORTS Emergency personnel believed that the ICs would declare an Alert if a fire occurred that could result in chemical ofaazardous material release. This belief was based on information contained in the EP and guidance provided to the ICs.
Specifically, Section 2.1.9, " Natural Phenomena and Fire," states: " Natural phenomena, such as earthquakes, tornadoes, severe storms, and fires may cause varying degrees of damage to the plant. In themselves, these types of events may disrupt or threaten plant operations sufficiently to warrant the declaration of an emergency."
Additionally, Section 3.1 of the EP titled " Classification System" states: "An Alert ensures that emergency personnel are readily available to respond to a change in plant
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conditions and to provide assessment support as required. An incident classified as an Alert may require offsite emergency support organizations to respond to an onsite s
emergency, such as a fire or security-related event."
USEC, however, has determined that the PORTS EPIP (i.e., XP2-EP-EP1050,'Rev.2,
" Emergency Classification") was deficient with regard to a fire or other events daused by man-made or natural phenomena. The EALs in this procedure only addressed events caused by fluorine, chlorine, hydrogen fluoride, nitric acid, UF, and radiological releases. however, Regulatory Guide 3.67', Appendix A gives other examples of conditions that initiate an Alert (e.g., a fire onsite that might affect radioactive material or safety systems).
i The EALs in procedure XP2-EP-EP1050 did not address these other exampl6s of l
conditions that can initiate an Alert. Furthermore, the training provided to the ICs (i.e., training module EMP01.05.02, " Emergency Classification") also only addressed events caused by fluorine, chlorine, hydrogen fluoride, nitric acid, UF, and 6
radiological releases.
' The PORTS EP is generally based upon NRC Regulatory Guide 3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities (January,1992).
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t GDP 99-0047 Page 2 of 3 Thus, during the fire that occurred on December 9,1998, the IC rationalized that an Alert did not need to be declared since the EALs in procedure XP2-EP-EP1050 did no't specifically require this declaration for a fire.
B.
laconsistency Between the EP and the EPIP
'As'noted in the above section, the EP states that a fire which threatens plant operations would wammt declaration of an Alert. However, the EPIP (i.e., XP2-EP-EP1050) contained a note on page 6 that says " Events or conditions that do not meet the criteria for Alert or SAE such as fire, bomb threat, natural phenomena, and others are considered to be Operational Emergencies and may be reportable to NRC and DOE." Thus, the EPIP had guidance which contradicted the EP concerning the declaration of an Alert for a fire.
H.
Corrective Actions Taken 1.
On December 15,1998, the PORTS Operations Department issued a lessons leamed to the ICs regarding the need to activate the Emergency Operations Cemer (EOC) for conditions other than the EALs specified in XP2-EP-EP1050. Specifically, the ICs
.l were informed that the EOC is to be activated whenever a fire, explosion, or natural phenomena exists that " impacts or could potentially impact personnel or public health and safety, protection of the enviromnent, plant SSCs performing their intended safety function, and the integrity of plant systems to contain radioactive 3
material."
2.
PGDPissued a Long-Term Order clarifying actions to be taken for EALs associated.
with a fire, security-related incident, natural phenomena, or equipment failure. '
3.
Procedure XP2-EP-EP1050 was revised on March 4,1999, to add an EAL consistent with Regulatory Guide 3.67. Specifically, a new EAL titled "Other Emergency Conditions," has been added to this procedure. This new EAL requires, in part, that an Alert be declared for a " Fire potentially, or actually, compromising the functions of safety systems which may result in a radiological or hazardous material release."
Additionally this procedure revision deleted the note which caused the inconsistency between the EPIP and the EP. This procedure revision is effective on March 19, 1999.
4.
PORTS has briefed the local and state emergency agency officials on the above change to the EPIP.
j-5.
. Affected PORTS personnel were trained on the revision to XP2-EP-EP1050 on l
March 18,1999.
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GDP 99-0047
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Page 3 of 3 l
III.
Corrective Actions to Be Taken 1.
Training module EMP01.05.02, " Emergency Classification," will be revised by August 1,1999, to reflect the new EAL.
2.
PGDP is revising their EPIP similar to the actions taken at PORTS, IV.
Date of Full Compliance i
l Full compliance was achieved on December 15, 1998, when the PORTS Operations
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l Department issued a lessons learned to the ICs regarding the need to activate the EOC whenever a fire, explosion, or natural phenomena exists that " impacts or could potentially -
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impact personnel or public health and safety, protection of the environment, plant SSC, performing their intended safety function, and the integrity of plant systems to contain j
radioactive material."
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GDP 99-0047 1
Page1of1 List of Commitments **
1.
Training module EMP01.05.02, " Emergency Classification," will be revised by August 1, 1999, to reflect the new EAL.
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- Regulatory commitments contained in this document are listed here. Other corrective i,.
actions listed in this submittal are not considered regulatory commitments in that they are either statements of actions completed, or they are considered enhancements to USEC's investigation, procedures, programs, or operations.
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