ML20209D482

Discusses Licensee 990702 Request That NRC Exercise Discretion Not to Enforce Compliance with Actions Required by Tsrs 2.2.3.2,2.4.3.1,2.5.3.1 & 2.7.3.2.NRC Concluded That NOED Warranted

ML20209D482
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	07/07/1999
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Adkins J UNITED STATES ENRICHMENT CORP. (USEC)
References
EA-99-176, TAC-L32125, NUDOCS 9907130144
Download: ML20209D482 (4)

Text

July 7, 1999 i

EA 99176 Mr. James N. Adkins Vice President - Production l United States Enrichment Corporation

. Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

NOTICE OF ENFORCEMENT DISCRETION FOR UNITED STATES ENRICHMENT CORPORATION REGARDING PORTSMOUTH GASEOUS DIFFUSION PLANT (TAC NO. L32125, GDP NOED 99-02)

Dear Mr. Adkins:

By letter dated July 2,1999 (enclosed), your staff requested that the NRC exercise discretion not to enforce compliance with the actions required in Technical Safety Requirements (TSRs) 2.2.3.2,2.4.3.1, 2.5.3.1, and 2.7.3.2. That letter documented information initially discussed with the NRC in a telephone conversation on July 2,1999, at approximately 11:00 a.m. (CDT). The NRC staff members who participated in that telephone conference and a second telephone conference at about 4:30 p.m. (CDT) the same day,

! included Roy Canlano, Deputy Director, Division of Nuclear Materials Safety, Region Ill; Brent

! Clayton, Enforcement / Investigations Officer, Region lil: Pat Hiland, Chief, Fuel Cycle Branch, Region Ill; David Hartland, Portsmouth Senior Resident inspector; Ken O'Brien, Paducah l Senior Resident inspector; Bob Pierson, Chief, Special Projects Branch, NRC Office of Nuclear l Material Safety and Safeguards (NMSS); and in the first call only Melanie Galloway, Chief, Special Projects Branch-Enrichment Section, NMSS; Charlie Cox, Mechanical Systems k l_ Engineer, Special Projects Branch-Enrichment Section, NMSS; Chris Tripp, Nuclear Criticality l Engineer, Special Projects Branch, NMSS; and Joseph Giitter, Chief, incident Response Operations, Operations Section.

Your staff stated that various TSR Limiting Conditions for Operation (LCOs) associated with the Portsmouth Criticality Accident Alarm System (CAAS) had been entered at 12:40 a.m. (EDT) on July 2,1999, due to the discovery of a calibration error in the facilities' CAAS alarm clusters.

The need for enforcement discretion was to allow plant operations beyond the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time limit associated with the CAAS alarm cluster LCOs. Your staff requested that a Notice of Enforcement Discretion (NOED) be issued pursuant to the NRC's policy regarding exercise of discretion for an operating facility, set out in Section Vll.C of the General Statement of Policy and Procedures for NRC Enforcement Actions"(Enforcement Policy), NUREG-1600, and be effective for a period of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. This letter documents our telephone conversation on July 2, 1999, at approximately 4:30 p.m. (CDT), when we orally issued this NOED. We understand that the affected CAAS alarm clusters were successfully calibrated to the correct alarm setpoints and declared operable at 4:09 p.m. (CDT) on July 3,1999, removing the need for this NOED and allowing you to exit the LCOs.

9907130144 9907o7 PDR C ADOCK 07007002 PDR y

J. Adkins At 12:40 a.m. (EDT) on July 2,1999, your staff identified that a calibration error existed in the methodology used to calibrate all of the Portsmouth site's CAAS cluster alarms. The existing calibration error resulted in the need for you to declare all Portsmouth CAAS alarms inoperable and enter into the appropriate LCOs allowed by the TSRs. Also, in accordance with Portsmouth emergency plan implementing instructions, you classified the total loss of the criticality accident alarm system as an ALERT.

Your staff presented the basis for its conclusion that granting the NOED would not result in a safety concern. Their conclusion was based on the results of their evaluation of existing instrument calibration error, and where enforcement discretion was needed, the CAAS clusters would detect the minimum accident of concern and provide the required alarm function. While the alarm settings did not match the TSR surveillance level of 5 millirad /hr, the current alarm settings (about 8.5 millirad /hr) were evaluated against the analyses of anticipated radiation fields from the minimum accident of concern and the clusters would detect and provide the alarm as required in the TSR basis. The TSR basis for the CAAS alarms is that " Clusters are designed and calibrated to detect and alarm on a minimum credible criticality accident of concern, defined as producing an integrated total dose of 20 Rads in one minute at two meters from the reacting material." In accordance with the TSR LCOs, access to the affected facilities was limited and all personnel entering the affected facilities were required to have Electronic Personnel Dosimetry (EPD) with alarming capability. Your staff did not identify any additional compensatory actions.

The NRC accepted your safety rationale combined with the compensatory actions in place as required by the TSRs. The staff also accepted the proposed duration of the NOED based on i the time needed to adjust the alarm setpoints of 54 clusters involved in the TSRs where enforcement discretion was requested. Based on the above, the staff concluded that Criterion 1(a) of Section B.2 to NRC Manual Chapter 9900," Operations - Notice of Enforcement Discretion for Gaseous Diffusion Plants," was met. This criteria states that for ongoing operations at a gaseous diffusion plant, the NOED is intended to avoid undesirable transients as a result of forcing compliance with the TSR/ certificate condition and, thus, minimize potential safety, environmental, safeguards, or security consequences and operational risks.

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-On the basis of the staff's evaluation of your request, we concluded that a NOED was  :

warranted because we were satisfied that this action involved minimal or no safety impact, was j consistent with the Enforcement Policy and staff guidance, and had no adverse impact on  ;

public health and safety. Therefore, it was our intention to exercise discretion not to enforce {

compliance with TSRs 2.2.3.2,2.4.3.1,2.5.3.1, and 2.7.3.2 as they relate to restoration of an

" operable" criticality accident alarm for the period from 12:40 a.m. on July 2,1999, through j 12:40 a.m. on July 6,1999, a period of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. 1 i

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i J. Adkins ' . As stated in the Enforcement Policy, action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this NOED was necessary.

Sincerely,

/s/ J.L. Caldwell for J. E. Dyer Regional Administrator 4 I

Docket No. 70-7002 Certificate No. GDP-2

Enclosure:

' As stated '

cc w/ encl: J.' M. Brown, Portsmouth General Manager l P, J. Miner, Manager, Nuclear Regulatory Affairs, Portsmouth  !

H. Pulley, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE E. W. Gillespie, Portsmouth Site Manager, DOE DOCUMENT NAME: G:\SEC\SEC\NEOD.POR i To receive a copy of this document, Indicate in the box: C = Copy without enclosure E = Copy with enclosure N = No copy j

. lE OFFICE Rlli lE Rll! _h E NMSS Rlli lf Rlll0 Al , l NAME Hiland:ib [#-lP Pederson@W Pierson f1W Clayton & MF DATE 07/(,/99 07/V99 6" 07/7/99 VA **U 07/7/99 07/1/99 OFFICIAL RECORD COPY

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l J. Adkins -4 Distribution:

Docket File w/enci PUBLIC IE-07 w/enci J. Lieberman, OE w/ encl N. Mamish, OE w/enci D. Dambly, OGC w/enci J. Giitter, OEDO w/enci F. Miraglia, DEDR w/enci C. Paperiello, NMSS w/enci E. Ten Eyck, NMSS w/enct 4 R. Pierson, NMSS w/enct P.' Ting, NMSS w/enct W. Troskoski, NMSS w/enct 1 P. Harich, NMSS w/enci  !

Y. H. Faraz, NMSS w/enci j J. Dyer, Rill w/enci j J. L. Caldwell, Rlli w/enci j C. D. Pederson, Rlli w/enci l Riti Enf. Coordinator w/enci D. Hartland, SRI (Portsmouth) w/ enc!

R. Bellamy, RI w/enci i EJM, Rll (e-mail)

D. B. Spitzberg, RIV w/ enc!

NRCWEB (e-mail)

Greens w/o enci k\ t I

130030

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USEC A ci.6. s. ,sy come.ar -

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l July 2,1959 GDP 99-0 i23 U.S. Nuca:ar Regulatory Commission Mr. James E. Dyer Regional Administrator RegionIII 801 Waru nyille Road Lisle,IL @532-4351 Portsmo ith Gaseous Dinsion Plant (PORTS)

Docket M . 70-7002 Request br Temporary Enforcement Discretion

Dear Mr. )yer:

The purp se of this letter is to request temporary enforcement discretion to allow continued plant operationn. while completing corrections to the Critiality Accident Alarm System (CAAS) cluster i alarm se: points to be in compliance with the Technical Safety Requirements (TSR) Surveillance Requiretr a nts. We anticipate that we will regain compliance within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from the discovery of the even: (Monday evening at midnight). The enforcement discretion is necessary to allow plant operatio:n to continue in those facilities that have a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time limit for remaining in the TSR Limiting Conditions for Operation (LCOs) associated with a CAAS outage. Within these facilities, the CAA3 with its current settings is still capable of detecting the minimum accident of concern, as required 3y the TSR Basis Statement. In addition, the TSR LCO Actions will still be met and personne' tecess will be restricted to personnel with Electronic Personal Dosimeters (EPDs' ,

ohich provide tuIditional capability fo'r detection of a criticality.

Thereforn USEC is seeking enforcement discretion to continue plant operations in accordance with the TSR L CO actions and with the existing CAAS alarm settings until the setpoint adjustments can be comp oted to provide compliance with the TSR Surveillance. Specifically, USEC is requesting discretict to continue operation in this mode for a period of up to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from the date of discovery. The Enclosure provides the technical justification and safety basis for this request in accordar e with NRC Inspection Manual Chapter 9900.

UWred States Enrichment Corporation Portsmouth Gaseous Diffusion Plant P.O. Box 628, Piketon. OH 45661 A9 o=tr3 uv 7 l- 7p,,.

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Should yin have any questions regarding this matter, please contact Mr. Pete Miner at (740) 89'r .2710. There are no new commitments contained in this submittal.

Sincerely, J .,/ax)n f f JM.bsun)

J.M.Bron n General hlanager Enclosute: Justification for Request for Enforcement Discretion cc: Mr. l'atrick L. Hiland - NRC Region III Office NRC Resident Inspector- PORTS I Mr. Itobert C. Pierson, NRC HQ Mr. Ilandall M. DeVault, DOE U.S. Nuclear Regulatory Commission Attention: Document Control Desk Wa:hington, D.C. 20555-0001 O

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ENCLOSURE j GDP 99-0123  !

1 Justification for Request for Temporary Enforcement Discretion J

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p- 1 Enclosure to GDP 99-0123 Page1of5 JUSTIFJ "ATION FOR REQUEST FOR TEMPORARY ENFORCEMENT DISCRETION

1. THE CERTIFICATE CONDITION THAT WILL BE VIOLATED. 1 1

The fSRs governing operation of the CAAS specify that the CAAS must be operable while

. peric rming 6:sile material operations in various facilities. The CAAS units do not meet the

. surveillance requirement in these TSRs in that they are not currently set to alarm at 5 mrad /hr. ,

USID desires to continue plant operations within the TSR LCOs with the existing CAAS alarm I settir gs until the alarm setpoints adjustments can be completed for a period of up to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from the date of discovery. Several facility TSRs limit the time that the facility can remain in the TSF; LCO Actions to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The TSRs are as follows: 2.2.3.2, 2.4.3.1, 2.5.3.1, and 2.7.3.2.

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2. TH]! CIRCUMSTANCES SURROUNDING THE SITUATION, INCLUDING ROOT  !

CA1'SES, NEED FOR PROMPT ACTION AND IDENTIFICATION OF ANY RELEVANT l HIS"ORICAL EVENTS.

On .hly I,1999, while investigating a new radiation calibration neutron source in the Radiation Calit ration Facility (Rad Cal), an engineer pulled up the basis spreadsheet calculations for the calib ation of the CAAS clusters on the Rad Cal Computer. This was part of an evaluation of I diser spancies between the calibration calculations and his calculations for the new source. While l peril.rming this evaluadon, he discovered the following:

The nethod of calibration for the CAAS clusters by procedme set the cluster at a point on the best range where the neutron field strength is calculated to be 5 mrad /hr in air. The procedure calls for adjusting the cluster to 35,000 counts / minute (cpm) at this field strength. The proc xiure then calls for the alarm setpoint to be set to a value between 35,000 and 60,000 cpm.

Typi : ally the clusters are set mid-range but could be as high as 60,000 cpm. Since the 35,000 I

cpm is equivalent to the TSRlimit c,f 5 mrad /hr in air, the procedure results in the cluster alarms bein; set at a value exceeding the TSR surveillance limit. The value could be as high as 5x6C K/35K or 8.57 mrad /hr in air. The lab set up dose rate has been checked with independent inst,unents calibrated by offsite facilities and the field strength is accurate. The apparent cause of th problem was an error in the spreadsheet calculations used in the calibration of the CAAS j cim.iers. ,

i Tlx xublem was reported and the entire CAAS system was declared inoperable. The EOC was acti& stod and an " Alert" was declared at 0040 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> on July 2,1999, based on the declaring of the system inoperable. i

3. THE; SAFETY BASIS FOR THE REQUEST, INCLUDING AN EVALUATION OF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSEQUENCES OF THE PROPOSED COURSE OF ACTION, INCLUDING ANY QUALITATIVE RISK ASSESSMENT.

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I The i ccident of concern associated with this request is a criticality accident. The CAAS does not p ovide any preventive function for a criticality accident; rather it provides for mitigation of

- effeos to onsite workers by sounding an evacuation signal based on detecting the elevated radiid ion levels accompanying such an accident. The SAR identifies a criticality as having only pote: tial onsite impacts with no effect on the public.  ;

The r afety basis for the CAAS is that " clusters are designed and calibrated to detect and alarm on a minimum credible criticality accident of concern, defined as producing an integrated total '

dose of 20 Rads in one minute at two meters from the reacting material. This system will prov de an audible signalin the event of a criticality that will alert personnel to evacuate the imrr a diate work areas...". In the facilities where enforcement discretion is needed, the CAAS clusus, as currently ' set (including calibration uncertainties), will detect the minimum credibic critio dity accident ofconcern and provide the required alarm. While the coverage ofindividual clust ers is reduced, the dusters still provide detection coverage for the buildings in question.

The ilegree of cluster coverage overlap is reduced. While the alarm settings do not match the TSE surveillance level of 5 mrad /hr, the current alarm settings have been evaluated against the analy ses of anticipated radiation levels from the minimum accident of concern and the clusters will c elect and pmvide the alarm as required by the TSRBasis. As such, plant personnel are still proided with the requisite protection from the minimum credible accident of concern. For those criti:ility eyesits analyzed in the SAR, which are larger than the minimum credible accident used for C AAS design and calibration, muhiple clusters would alarm. In addition, in compliance with TSit LCOs, access to these facihties is limited and all personnel entering these facilities are required to have an EPD to provide personal alarming capability. With these measures in place, the:c is no undue risk to plant personnel.

4. THE BASIS FOR THE CERTIFICATE HOLDERS CONCLUSION THAT THE l NOllCOMPLIANCE WILL NOT BE OF POTENTIAL DETRIMENT TO THE PUBLIC HE8 LTH AND SAFETY, THE ENVIRONMENT, S AFEGUARDS, OR SECURITY, AND TH/.T NEITHER AN USQ NOR A SIGNIFICANT HAZARD CONSIDERATION IS INV3LVED.

The tsponsein Question 3 shows that the cunent condition of the CAAS does not provide an incnased risk of a criticality accident. There is no offsite impact predicted from a criticality accllent and the CAAS provides no protective function for the public health and safety. As not.:1 above; while the CAAS alarm setpoints do not meet the TSR surveillance requirements, the.'i are adequate to detect a minimum accident of concern in the buildings where enforcement digo etion is required and to provide an alarm to evacuate the area of concem for mitigating expc sure ofpersonnel In addition, the TSR LCO actions implemented restrict personnel access to *;he facility and require any personnel entering the facility to be equipped with an EPD.

Thu efore, there is no potential detriment to the public health and safety.

Enclosure to GDP 99-0123 Page 3 of 5 Baseil on the following conclusions, there is no Unreviewed Safety Questjon:

1. *'he proposed operation will not increase the probability of occurrence of an accident previously evaluated in the SAR.

2. The proposed operation will not increase the consequences of an accident previously ovaluated in the SAR. The CAAS in its current condition remains capable of meeting the initigative function by detecting a minimum accident of concern and providing the alarm to ilirect evacuation of plant workers from the area of concern. In addition, the TSR LCO i actions limit personnel access to these facilities and require EPDs for entry. Continued operation during the period required for resetting of the CAAS alarm setpoint to comply vith the TSR surveillance will not increase the consequences of a criticality.

3. The proposed operation will not increase the probability of occurrence of a malfunction of l xtuipment important to safety previously evaluated in the SAR.

4. The proposed operation will not increase the consequences of a malfunction of equipment mportant to safety previously evaluated in the SAR. The current CAAS settings are ulequate to detect the minimum credible accident and provide the alarm so evacuation of 3ersonnel from the affected area will occur. In addition, the TSR LCO action restrict

)ersonnel access ami require EPDs for entry into these areas. Continued operation during

his period cannot impact the consequences of a malfunction.of equipment important to afety.

5. The proposed operation will not create the possibility of an accident of a different type than my previously evaluated in the SAR. Continued operation during this period will not result n any new activities, therefore there is no possibility of an accident of a different type than my previously evaluated in the SAR.

6. The proposed operation will not create the possibility of a different type of malfunction of

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equipment important to safety than any previously evaluated in the SAR. Continued operation during this period will not result in any new activities, therefore there is no possibility of a different type of malfunction of equipment impoltant to safety.

7. The proposed operation does not reduce the margin of safety as defined in the supporting bases documents for any TSR because the TSR LCOs are still being met and the CAAS provides adequate detection coverage for the facilities covered by the LCOs where enforcement discretion is being requested.

Bau d on the following conclusions, there is no Significant Hazard Consideration:

1. "he proposed operation has no impact on any efBuents released offsite. As discussed above, the consequences of a criticality accident will remain within those analyzed in the SAR.

2. "he proposed operation will not result in an increase in individual or cumulative occupational indiation exposure. Continued operation during this period has no effect on the probability ofoccurrence of a cdticality accident at PORTS. As discussed above, the consequences of 4

Enclosure to GDP 99-0123 Page 4 of 5

s. criticality accident will not be affected by this operation. Therefore, there will be no ir. crease in individual or cumulative occupational radiation exposure.

3. 71is request involves continuing existing operations within the TSR LCOs and adjusting the ad ann setpoint on the existing CAAS clusters. 'Iherefore, there is no significant constmetion impact as a result of this enforcement discretion request.

4. .)s diammaM above, neither the probability nor the consequences of a criticality accident will In affected by continued operation during this period. Therefore, there is no increase in the intential for, or radiological or chemical consequences from, previously analyzed accidents.

5. C ontinued operation during this period will not result in pny new activities, therefore there is no possibility of an accident of a different type than any previously evaluated in the SAR

6. 'Ihe margins of safety associated with the CAAS TSRs remain within what is described in i de Basis. The alarm setpoint is above the TSR surveillance requirements but the CAAS will r19 detect the minimum credible accident and provide the alarm. In addition, the TSR LCO dions will be met by restricting personnel access to these areas and by requiring an EPD Sir entry. Therefore, the margin of safety is not impacted by continued operation as

. squested.

7. /.s discussed above, neither the probability nor the consequences of a criticality will be a Tected by continued operation during this period. Therefore, continued operation during t tis period will not result in an overall decrease in the effectiveness of the plant's safety, 1

nfeguards or security programs.

S. THE. BASIS OF THE CONCLUSION THAT THE NONCOMPLIANCE WILL NOT INY 3LVE ADVERSE CONSEQUENCES TO THE ENVIRONMENT.

The )roposed operation has no impact on any effluents released offsite.

6. ANY PROPOSED COMPENSATORY MEASURES.

~~ As :n.viously stated, this request proposes to continue operation within the TSR LCOs until the cad S alarm setpoints am adjusted to meet the TSR surveillance requirement. Since the CAAS will nietect a minumum credible accident and provide the alarm required for personnel protection and ihe TSR LCO actions restrict personnel access and require EPDs for entry, no compensatory memures are necessary.

7. TH E. JUSTIFICATION FOR THE DURATION OF NONCONFORMANCE.

USE.C is preparing a procedure to adjust the alarm setpoints in the field for the 54 clusters invo ved in the TSRs where enforcement discretion is requimd. V a will begin these adjustments imrixliately and we intend to complete this effort within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from time of discovery. The clu:d ers adjustments will be prioritized in the recovery plan. Since the CAAS provides adequate

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Enclosure to GDP 99-0123 l Page 5 of 5 alant. coverage and we are continuing to restrict access and use EPDs, we believe that the 1 i

addit onal time presents no risk to plant personnel or to the public. ,

8. A P:ATEMENT THAT THE REQUEST HAS BEEN APPROVED BY THE PLANT I OPIRATIONS REVIEW COMMITTEE (PORC).

The PORTS PORC approved this request for t+rrey enforcement discretion on July 2,1999. l l

9. TKi REQUEST MUST ADDRESS HOW ONE OF THE NOED CRITERIA FOR APP IOPRIATE PLANT CONDITIONS SPECIFIED IN SECTION B IS SATISFIED.

I Crili:ria B.2.1.a. in NRC Inspection Manual 9900, NOEDs for GDPs states: "For ongoing oper itions at the GDP, the NOED is intended to: (a) avoid undesirable transients as a result of forcing compliance with the TSR/ certificate condition and, thus, nunimize potential safety, enVJ onmental, safeguards, or security consequences and operational risks:" The exceedance of the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limitation on remaining in LCOs could result in potential shutdown of the major i

entdunent process, withdrawal and feed facilities; this could introduce potential severe

. tran iients to the GDP which could present additional safety and operational risks. Since the plan: will remain within the TSR LCOs and the CAAS is capable of detecting a criticality ,

acc.tlent, the lowest risk is to conthue plant operations within the TSR LCOs until the setpoint j adju tments are completed. Therefore, the granting of temporary enforcement discretion would l I

pres ont a safety and operational risk without corresponding safety, safeguards, security or emi onmental benefits. .

10. IF .L FOLLOW-UP TSR/ CERTIFICATE AMENDMENT IS REQUIRED, THE NOED RIiQUEST MUST INCLUDE MARKED-UP TSR PAGES. THE ACTUAL TSUCERTIFICATE AMENDMENT REQUEST MUST FOLLOW WITH" 4 COURS.

Nc fSR/ Certificate Amendment is required.

11. AM( OTHERINFORMATION THE STAFF DEEMS NECESSARY BEFORE MAKING A DD:ISION TO EXERCISE ENFORCEMENT DISCRETION.

PORTS plans to downgrade the " Alert" upon identification of a success path to completing the clus ter setpoint adjustment coincident with receiving enforcement discretion. The success path wil be identified as in place when the procedure has been completed and at least one cluster has ben returned to service. The Crisis Manager will authorize the downgrade of the " Alert". No oth r information has been requested by the Staff at this time.

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