ML20210F211
| ML20210F211 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/27/1999 |
| From: | Adkins J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 70-7002-99-06, GDP-99-0124, NUDOCS 9907290190 | |
| Download: ML20210F211 (8) | |
Text
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. A Global Energy Company 1
JAMES N. ADKINS,JR.
Dir: (301) 564-3417 VICE PRESIDENT, PRODUCTION Fax: (301) 571-8279 i
July 27,1999 GDP 99-0124 Mr. James Liebennan Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 j
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 i
Reply to a Notice of Violation (NOV) 70-7002/99006 (EA 99-080)
Dear Mr. Lieberman:
Nuclear Regulatory Commission letter dated June 29,1999, transmitted one Severity Level 111 NOV.
The events that led to this NOV were the subject of a predecisional enforcement conference held on June 10,1999. USEC's reply to the Severity LevelIll NOV is provided in Enclosure 1. Enclosure 2 lists the commitment contained in this submittal. Unless otherwise specified, the corrective actions j
specified in the enclosure apply solely to PORTS.
USEC does not contest this violation. Therefore, as directed by your June 29,1999, letter, Enclosure 3 is a check in the amount of $55,000 in payment of the civil penalty associated with the Severity Level III NOV.
If you have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.
Sincerely, WN ames N. Adkins, Jr.
I Vice President, Production L
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9907290190 990727 PDR ADOCK 07007002 C
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6903 Rockledge Drive. Bethesda, MD 20817-1818 i'
Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com I
Offices in Livermore, CA Paducah, KY lbrismouth, OH Washington, DC
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Director, Office of Enforcement July 27,1999 GDP 99-0124, Page 2
Enclosures:
- 2) List of Commitments
- 3) USEC Check No.101421 cc:
Patrick Hiland, NRC Region III Administrator
. David Hartland, NRC Resident Inspector - PORTS Robert Pierson, NRC Special Projects Branch Document Control Desk l
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GDP 99-0124 I
Page1of4 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO A NOTICE OF VIOLATION (NOV) 70-7002/99006 (EA 99-080)
Restatement of Violation 10 CFR 76.91 requires, in part, that the Corporation shall establish, maintain, and be prepared to follow a written emergency plan.
Section 3 of the Emergency Plan, Revision 26, dated November 6,1998, states, in part, that significant emergencies are classified as either Alerts or Site Area Emergencies. Section 3 of the Plan further defined an Alert, in part, as an emergency situation that has led or could lead to a release to the environment of radioactive or other hazardous material, or could have a direct effect on the health and safety of plant personnel.
Contrary to the above, on the morning of December 9,1998, the Corporation failed to classify, as an Alert, an emergency situation which could have led to a release to the environment of radioactive or hazardous material, or could have had a direct effect on the health and safety of plant personnel.
Specifically, on that date, the corporation failed to classify, as an Alert, a substantial ongoing fire in Building X-326, which: (1) involved the process gas cascade; (2) had the potential to release uranium hexafluoride or other hazardous materials to the environment; and (3) could have had a direct effect on the health and safety of plant personnel, j
USEC Response 1.
Reasons for Violation As discussed at the predecisional enforcement conference, the root causes of this violation were:
The Emergency Action Levels (EALs) that were in the PORTS Emergency Classification procedure (XP2-EP-EP1050), which was initially issued on November 3,1995, only addressed llazardous Chemical and Radiological Releases. This procedure did not specifically address all emergencies, or all potential emergencies that are discussed in Regulatory Guide (RG) 3.67. Emergencies and potential emergencies not addressed in the EALs included fires, natural phenomena (e.g.,
l earthquakes, high winds), and security related events.
The Emergency Plan (EP) states that a fire which threatens plant operations may warrant declaration of an Alert. Ilowever, the Emergency Classification procedure (i.e., XP2-EP-EP1050) contained a note that stated " Events or conditions that do not L
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GDP 99-0124 Page 2 of 4 meet the criteria for Alert or Site Area Emergency (SAE) such as fire, bomb threat, natural phenomena, and others are considered to be Operatioual Emergencies and may be reportable to NRC and DOE." Thus, the procedure had guidance which contradicted the EP concerning the declaration of an Alert for a fire.
Without clear guidance for a situation with potential consequences, the Incident Commander (IC) concluded that an Operational Emergency was in progress.
Management personnel assembled in the control building during the fire supported this decision.
II.
Corrective Actions Taken and Results Achieved j
The PORTS General Manager met personally with management personnel responsible for declaring emergencies to reinforce expectations for activating the Emergency Operations Center (EOC) for emergency conditions such as fire.
On December 15,1998, the PORTS Operations Department issued a lessons leamed to the ICs regarding the need to activate the EOC for conditions other than the EALs j
specified in XP2-EP-EP1050.
l Procedure XP2-EP-EP1050 was revised on Mar..n 4,1999, to:
Add a new EAL titled "Other Emergency Conditions." This new EAL required that an Alert be declared for: 1) a fire potentially, or actually, compromising the ftmetions of safety systems which may result in a radiological or hazardous material release: 2) severe natural phenomena; and
- 3) imminent or actual loss of physical control of the plant.
Delete the note which caused the inconsistency between the Emergency Classification Procedure and the EP.
Stipulate that if there is any doubt on the activation of the EOC, then it should be activated.
During the Augmented Inspection Team (AIT) follow-up inspection, a discrepancy was identified that the revised EALs did not adequately address a security compromise. As a result, a Compensatory Action Form (which is procedurally govemed and approved by the Plant Operations Review Committee) was issued by l
the Plant Shift Superintendent's office on March 25,1999, which clarified the Alert i
and SAE classifications for a security comprmnise.
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GDP 99-0124 Page 3 of 4 A meeting was held between Paducah (PGDP) and PORTS on May 18,1999, to develop EALs consistent with the EP, RG 3.67 and other nuclear facilities, as applicable.
Based on the May 18,1999 meeting, PORTS revised procedure XP2-EP-EP1050 on June 7,1999, to:
Expand the EALs to make thsm consistent with the EP and RG 3.67 for both an Alert and SAE. This includes fires, explosions, natural phenomenon events, security events, and other adverse events (e.g., events which have the potential to cause a chemical or radiological release). This procedure revision corrected the deficiencies that were identified during the AIT follow-up.
(Note: PGDP has performed a similar action).
Add a requirement for annual retraining on emergency classifications (Note:
PGDP has performed a similar action).
Add an action step that states if conditions warrant in the judgement of the IC or Crisis Manager (CM), staff the EOC for non-classified Operational Emergencies (a similar requirement already existed for PGDP).
The ICs and cms at both sites were trained on the new EALs.
A self-assessment of the PORTS Emergency Management Program was performed (including EP training). The self-assessment was composed ofindividuals from PORTS and PGDP.
Subsequent to the predecisional enforcement conference, on June 11,1999, USEC notified the NRC Headquarters Operations Center that the December 9,1998, event met the criteria for an Alert emergency classification in accordance with the guidance contained in NUREG-1022. On July 12,1999, USEC submitted Event Report 98-17, Revision 2, which identified that an Alert had been declared.
III.
Corrective Steps to be Taken A training module will be developed and implemented for annual retraining on emergency classifications. The appropriate personnel will be trained on thi&cw module by August 31, 1999.
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b GDP 99-0124 Page 4 of 4 cIV.
Date of Full Compliance l
Full compliance was achieved on June 11,1999, when USEC notified the NRC IIeadquarters Operations Center that this event met the criteria for an Alert emergency classification.
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AdditionalInformation In reviewing the June 29,1999, letter transmitting the.NOV, USEC has identified two i
statements which require clarification. This was discussed with the PORTS Resident Inspector on July 22,1999.
On page 3 of the cover letter in the paragraph discussing Corrective Action credit, the NRC states, "(2) a Long-Term Order was issued clarifying actions to be taken for emergency action levels associated with fire,..." This statement was made in our March 19,1999 letter and was performed by Paducah. It is a similar action to the December 15,1998 lessons learned described in the " Corrective Actions Taken and Results Achieved" section of this l-response.
l Also on page 3, the NRC states,"(6) incident response teams are being established on each shift." While each shift currently has identified responders, no additional efforts to create L
incident response teams are planned. PORTS is, however, implementing a team concept for our EOC cadre.
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GDP 99-0124 Page1 of1 J
List of Commitments
- A training module will be developed and implemented for annual retraining on emergency classifications. The appropriate personnel will be trained on this new module by August 31,1999.
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- Regulatory commitments contained in this document are listed here. Other correctae actions listed in this submittal are not con.idered regulatory commitments in that they are either statements of actions completed, or they are consi Jered enhancements to USEC's investigation, procedure programs, or operations.
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