ML20198N595

Ack Receipt of 971119 Response to Weakness in Emergency Plan Knowledge & Training Transmitted on 971020.Corrective Actions Will Be Examined During Future Insp

ML20198N595
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	01/15/1998
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-97-09, 70-7002-97-9, NUDOCS 9801210134
Download: ML20198N595 (1)

Text

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e i January 15, 1998 i

Mr. J. H. Miller  ;

Vice President Production United States Entkhment Corporation Two Demoorecy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

RESPONSE TO PORTSMOUTH INSPECTION REPORT 70-7002/97009 i

Dear Mr. Miller:

This refers to your November 19,1997, response to weaknesses in emergency plan knowledge and training transtrJtted to you by our letter dated October 20,1997, with inspection Report 70 7002/97009. We have reviewed your corrective actions and have no further questions at this tim 6. Your corrective actions will be examined during future inspections, t

if you have any questions, please contact me at (630) 829-9603.

Sincerely, Original Signed by J, Kniceley for Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70-7002 cc: S. A. Polston, Paducah General Manager J. B. Morgan, Portsmouth Acting General Manager R. W. Gaston, Portsmouth Nuclear Regulatory Affairs Manager S. Toolle, Manager, Nuclear Regulatory Assurance and Policy, USEC Paducah Resident inspector Office Portsmouth Resident inspector office E. W. Gillespie, Portsmouth Site Manager, DOE 1 bec w/Itr did 11/19/97: R. Pierson, NMSS P. Ting, NMSS W. Scheink, NMSS P. Harich, NMSS Y. Faraz, Project Manager Portsmouth, NMSS R. Bellamy, RI )

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fairhtnent thspiratiern November 19,1997 United States Nuclear Regulatory Commission GDP-97-2033 Attention: Chief Fuel Cycles Branch Region til 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 7002/97009 (DNMS)

Nuclear Regulatoiy 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. The enclosed response addresses the following:

• Completion of the accountability report in a timely manner.

= Notification of the NRC operation center in a timely manner.

. Command and control of the Command Post and delegation of responsibilities.

• Evaluation of the ALOllA plume release model for adequacy, a Delayed implementation of search and rescue by the emergency responders.

• Physical safety of a " simulated" victim.

• I ack of effective contamination control practices at the scene.

USEC agrees ' hat overall skills improvement is needed within the Emergency Response >

Organization and our actions should target both core competencies and individual responders.

i Consequently, we have identified the core competencies required for improvement and are 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 I.I 1,10lllll llll.11ll Ottices in Patiucah, Kentucky Portsmouth. Ohio Washington,DC

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- United States Nuclear Regulatory Commission-November 19,1997 Page Two with those containcd 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.

Enclosure 2 lists the commitments contained this submittal, if you have any questions regarding this stibmittal, please contact Ron Gaston at (614) 897-2710.

Sincerely, h

James B. Morgan Acting General Manager Portsmouth Gaseous Diffusion Plant Enclosures (2) cc: ' Regional Administrator, Region til NRC Resident inspector, PORTS Document Control Desk, Washington, D.C.

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Enclosure I STATUS OF ACTIONS TO ADDRESS NRC EMERGENCY EXERCISE INSPECTION REPORT 70-7002/97009 (DNMS)

1) Issue: Failure to complete the accountability report in a timely manner. (70 7002/97009-01)

Background

During the Emergency Teamwork '97 Full Participation Exercise, accountability reporting was

. delayed because the plant 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 participants. Others were involved in the exercises as observers, controllers, or eva!urors and believed they 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 employees 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 communicate 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 notify the NRC operation 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 Officer in Region ill rather than the NRC lleadquarters Operations Oflicer (1100).

Response

Approximately 41 minutes following the declaration of the emergency event, the Assistant plant Shift Superintendent (PSS) notified the NRC licadquarters Operations Oflicer (1100) in El.1

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4 Rockville, Maryland, of the emergency classification at PORTS. Ilowever, when documenting this call, the Assistant PSS noted a Region !!! rather than an NRC lleadquarters contact had been made. While a documentation error we.s the cause of the confusion, the NRC lleadquarters was t 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)

Backcround During the Emergency Teamwork '97 Full Participation Exercise, the incident Commander failed to establish an effective command and control structure at the Command Post. As a result, Sector Commanders were not held accountable or respont.ible for their affected areas. In addition, the incident Commander did not provide tactical objectives to Sector Commanders and Sector Commanders did not adequately support the incident Commander. The fundamental reason for this weakness is attributed to a lack of a field training and practice program at the individual level which focuses on core fundamental concepts (i.e., Core Competencies) and the basics of emergency action response. In addition, the current program does not ensure adequate feedback of lessons learned, developed from drill and exercise critiques, is disseminated to field response ,

organizations.

Response

PORTS Emergency Management staff, Fires Services, Plant Shift Superintendent, and licalth Physics fermed a team to identify core competencies necessary for effective implementation of the PORTS Emergency Plan and EPIPs. "lucident Command" was identified as one of those core competencies. Selected drills and exercises are being developed 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 learned feedback process is being developed and will be proceduralized by February 28,1998. This formal process will ensure that lessons leamed from drills and exercises will be disseminated to field response organizations and used to improve field performance.

4) Issue: The ALOllA plume release model does not compensate for changes in meteorological conditions or extrapolate plume migration as related to changes in wind direction. (70-7002/97009 04)

Backcround l

Following the termination of the UF6release from the dropped cylinder the ALOllA plume release L model anchors the plume at the point of the release and is unable to model a detached plume after the release has been terminated. The NRC is concerned that the plume model does not compensate for changes in meteorological conditions.

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Resonnse The ALOllA plume mouel 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 4

A LOllA plume release model to determine the adequacy of the ALOHA model. This review will e completed by June 30,1998.

5) Issue: Removal of the two material handlers and a HP technician by the emergency responders was delayed. (70-7002/97009-05)

Background

During the Emergency Teamwork '97 Full Participation Exercise, search and rescue activities were not carried out in a timely manner. Due to a lack of command and control by the incident Commander, tacticel 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 discussed in example 3 of this response.

Resnonse The " search and rescue" function has also been identified as one of the core competencies required to demonstrate an effective emergency response. Corrective actions to address the fundamental weakness associated with search and rescue discussed in example 3 of this response will be r applied to the search and rescue issue as well.

6) Issue: Two are department tean' 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)

Background

During the Emergency Teamwork '97 Full Participation Exercise, two members of the Fire Services Department, wearing Class-A personal protective equipment, attempted to carry a victim approximately 500 yards to afety. 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 their 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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EcssonAc Recognliion of the safety ofindividuals during drills is addressed in the "on-scene safety" and the

" search and rescue" functions which have been identified as core competencies required to demonstrate an effective Emergency Management program. Corrective actions to address the fundamental weaxness associated with search and rescue are included in the core competency corrective action plan discussed in example 3. ,

7) Issue: The Isek of effective contsr'ation control during decontamination of

- responders. (70-7002/970W w) 7

Background

During Emergency Teamwork '97 Full Participation Exercise, decontaminatica of returning responders was Ic.; than adequate. In some instances responders in the dccontamination area cross-contaminated other pieces of equipment. The fundamental reason for this weakness is discussed in example 3 of this response. Contributing to the weakness was the IIP technician's insensitivity toward proper implementation of proper llealth Physics practices during the exercise.

Response

'lhe Ilealth ics Group administered disciplinary action to the subject 11P technician for not implementing poper licalth Physics practices during the exercise. In addition, the licalth Physics department lesued an information notice (via the required reading program) to the 11ealth Physics group concerning 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 licalth Physics have identified " decontamination" and "11AZMAT" functions as core competencies. The overall corrective actions to address the fundamental weaknesses ide:tified in the report are discussed in example 3 of this response.

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Enclosure 2

, UNITED STATES ENRICllMENT CORPORATION (USEC)

List of Commitments

1) To communicate management's expectations related to accountability reporting requirements, PORTS Emergency Management wi!! issemi.iate guidance to plant employees via publication of a Lessons Leamed Sununary 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 repotting during an accountability request.

3) PORTS General Employee Training (GET) module will be revised to clearly identify 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 competencies 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 wd other users of the ALOHA plume release model to determine the adequacy of the ALOHA model. This review will be completed by June 30,1998, and recommendations presented to management for approval.

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