# Presentation: 280344

## Combining DOE and NRC Regulations In The PORTS Emergency Management Program
Steven D. Arnold
Tetra Tech, Inc.
and 
Marty Redden
United States Enrichment Corporation 

- Steven D. Arnold
- Tetra Tech, Inc.
- and
- Marty Redden
- United States Enrichment Corporation

## Purpose

- To describe the challenges associated with conducting a “seamless” emergency management program between multiple entities who are regulated by different federal agencies.

## PORTS Site Description

- The PORTS Site is a 3714 acre DOE-owned reservation located in rural Pike County, in south central Ohio.
- The plant is located between Chillicothe and Portsmouth, Ohio, approximately 70 miles south of Columbus, Ohio.

## Assumptions

- For the purpose of Emergency Management, the entire DOE reservation is assumed to be controlled by the United States Enrichment Corporation (USEC).
- Lease and contractual agreements exist between USEC and DOE or between their respective contractors that govern site responsibilities and services to be provided.

## Regulatory Interfaces

- Department of Energy
- Established requirements applicable to the site to protect the public health and safety from radiological hazards, to provide for the common defense and security and to ensure adequate safeguards.
- Provides nuclear safety oversight for those activities involving DOE environmental management and enrichment facilities and operations.
- Events are reported to DOE/Oak Ridge Operations Office.
- DOE Portsmouth Paducah Project Office provides oversight on site.

- Nuclear Regulatory Commission
- Established certification requirements applicable to the GDPs to protect the public health and safety from radiological hazards, to provide for the common defense and security and to ensure adequate safeguards.
- Provides oversight over USEC uranium enrichment activities. (Paducah Plant only)
- Events are reported to NRC Operations Center

## Regulatory References

- DOE Order 151.1A
- ORO Order 150
- 29 CFR 1910
- OSHA
- RCRA
- CERCLA
- SARA

- 10 CFR 76.91
- Reg. Guide 3.67
- 10 CFR 70
- OSHA
- RCRA
- CERCLA
- SARA

## Emergency Plans

- The PORTS Site Emergency Plan is the USEC-02 Emergency Plan.
- USEC-02 was written to comply with the requirements of 10 CFR 76.91and formatted to Regulatory Guide 3.67.
- USEC-02 is maintained by USEC EM Group.
- BJC has been issued controlled copies of the USEC-02 Plan.

## Emergency Plans

- BJC developed and maintains an annex to the USEC-02 Plan (BJC-329).
- BJC-329:
- Is formatted to comply with the requirements of DOE Order 151.1A.
- Refers the user to the USEC-02 Plan for information that covers most actions.
- Explains in detail how the differences between the USEC-02 Plan and DOE Order are handled.

## Emergency Plan Implementing Procedures

- USEC EPIPs are used to guide all emergency responses on site.
- USEC EPIPs are developed and maintained by USEC EM Group.
- BJC is involved in review and comment of EPIPs.

## Emergency Plan Implementing Procedures

- BJC has developed a stand alone Emergency Protective Action procedure for all BJC/DOE personnel and subcontractors to describe actions to be taken in emergency situations.
- This procedure covers:
- accountability       evacuation      shelter-in-place
- severe weather    earthquake      bomb threat
- fire response 	     criticality alarm evacuations

## Emergency Classification Levels

- Since USEC, regulated by the NRC, provides site-wide emergency response services to DOE at PORTS, the emergency classification levels used at PORTS are different than those used at other DOE sites.
- The classification levels are a composite of both NRC and DOE classification systems.

## Emergency Classification Levels

- This classification system is used in an effort to be consistent with NRC regulations, as well as to maintain compliance with DOE requirements.
- DOE granted PORTS authorization to use this system in 1995. (RI 70-7001/95-003).

## Emergency Classification Levels

- The PORTS Classification System does not use the General Emergency classification.
- An *ALERT* signifies an event with on-site consequences.
- A *SITE AREA EMERGENCY* signifies an event with offsite consequences.

## Emergency Notifications

- In the event of an emergency at PORTS, the following offsite notifications are made:
- Within 15 minutes:
- Pike County Emergency Management Agency/LEPC
- State of Ohio
- DOE-Oak Ridge Operations Office
- As soon as possible, after offsite agencies have been notified:
- USEC Headquarters
- As soon as possible, after offsite agencies have been notified not to exceed 1 hour:
- NRC

## Hazards Analysis Consequence Assessment

- BJC develops Emergency Management Hazards Surveys (EMHS) and Emergency Management Hazards Assessments (EMHA) for the DOE non-leased facilities on site.
- EMHS/EMHAs are reviewed by USEC.

- USEC hazard analysis was completed as a site wide (leased facilities) document by Murray State (KY) University.

## Emergency Action Levels 

- Joint BJC/USEC EAL Development Working Group to create a workable EAL on EMHA identified hazards.
- Team consists of:
- BJC EM		USEC EM
- BJC ES&H		USEC Fire Services
- BJC NCS		USEC PSS

## Emergency Action Levels

- BJC EALs are developed in a similar format to USEC developed EALs.
- BJC EALs are incorporated into USEC Classification procedure to be used by PSS in classifying emergencies in the  non-leased buildings.

## Emergency Response Organization (ERO)

- USEC is responsible for providing the Emergency Response at the PORTS Site.
- USEC is:
- Responsible for staffing the majority of the ERO positions.
- The lead for managing the overall emergency responses, including the direction and control of emergency responses.

## Emergency Response Organization (ERO)

- USEC provides:
- 911 call center
- Plant systems, Criticality Accident Alarm System (CAAS) and fire alarms
- Plant radio systems
- Plant Shift Superintendent/Incident Commander (PSS/IC) Office
- Protective Force
- Fire Services/Emergency Medical Services
- HazMat Teams
- Field Monitoring Teams

## Emergency Response Organization (ERO)

- USEC operates and maintains the Site Emergency Operations Center (EOC).
- Provides training for EOC Cadre.
- USEC operates and maintains the Joint Public Information Center (JPIC).
- Provides training for JPIC Cadre.
- USEC maintains all Mutual Aid Agreements and  Memorandums of Understanding , etc. with outside agencies.

## Emergency Response Organization (ERO)

- BJC has personnel assigned to the EOC cadre.
- BJC Manager of Projects (MOP) assumes the role of Response Manager in events that occur in DOE spaces.
- BJC personnel staff five EOC positions (3 deep). Subject Matter Experts are called in as-needed. BJC Cadre members work along with USEC advisors in determining resolutions to all emergency events, no matter the location, during EOC activations.

## Emergency Response Organization (ERO)

- BJC has personnel assigned to the JPIC Cadre.
- BJC personnel are trained to serve as Spokesperson to the media in events that involve any DOE/BJC facilities and/or operations at PORTS.

## Emergency Response Organization Training

- EOC/JPIC Training
- All cadre members are trained by USEC trainers, using USEC training modules.
- Training records are maintained by USEC Training Organization.
- BJC EM coordinates, tracks and ensures the BJC/DOE EOC and JPIC cadre members are current on EOC/JPIC training.

## Assessments

- The EM Program at PORTS is assessed:
- On a regular basis by NRC Inspectors during program specific or as part of other program inspections.
- By DOE ROA audits and other DOE audits.
- Through both BJC and USEC Corporate and site level internal audit organizations.

## Exercises

- USEC maintains the PORTS EM Drill and Exercise (D/E) Program.
- BJC serves as a member of the D/E Committee that governs the program.
- BJC serves on D/E design teams.
- BJC personnel serve as controllers and evaluators during drills and exercises.

## Exercise Program

- USEC has a requirement for an NRC graded full participation exercise (FPE) every other year.
- The DOE requirement for a graded FPE is every three years.
- USEC extends invitation to DOE to grade all of the FPEs.

## Issues

- Even though PORTS program is similar to other DOE facilities where there is a Lead EM Contractor and Event Contractor set-up, there are some issues that are peculiar to PORTS.

## Issues

- With two regulators, change does not come easy.
- To implement a new DOE Directive or Order, any change to the USEC program must go through the NRC license change process.
- Emergency Plan Changes
- Procedural Changes

## Issues

- Conflicting regulations or methodologies create issues that sometimes provide different results for the same work.
- Until resolution, these issues are handled in accordance with NRC regulatory guidance.

## Conclusion

- Transitional Changes:
- LATA/Parralax, Theta Pro2Serve Management Company (TMPC), USEC Advanced Technologies (AT), UDS integration into EM programs
- Upcoming Site mission changes
- Future adventures?