ML20195G766
| ML20195G766 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 11/16/1998 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Clayton H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| GDP-98-0257, GDP-98-257, NUDOCS 9811230123 | |
| Download: ML20195G766 (4) | |
Text
Y USEC A Global Energy Company JAMES H. MILLER DIR: (301) 564-3309 VicE PRESIDENT, PRODUCTION fax: (301)571 8279 November 16,1998 GDP 98-0257 Mr. H. Brent Clayton Region III Enforcement / Investigations Officer U.S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle,IL _60532-4351 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002
Reference:
NRC Tracking Number 98-A-0145
Dear Mr. Clayton:
l The Nuclear Regulatory Commission's (NRC) letter of September 14,1998 (Reference 1), requested that the United States Enrichment Corporation (USEC) respond to information received by the NRC regarding certain activities at the Portsmouth Gaseous Diffusion Plant (PORTS). As agreed to in
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a phone conversation between yourself and Mr. Scott Scholl of USEC, the due date for this response was extended to November 16,1998.
1 USEC conducted an investigation of the subject concerns. The results of the investigation are provided in Enclosure I to this letter. As described in Enclosure 1, the persons performing this investigation were independent of the affected individuals and organizations. There are no new commitments contained in this submittal.
If you have any questions regarding this review, please contact Mr. Scott Scholl at (740) 897-2373.
9811230123 981116 m
Sincerely, PDR ADOCK 07007002 C
PDR y
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l es H. Miller ice President, Production
- Reference 1: Letter from H. Brent Clayton (NRC) to J. H. Miller (USEC), September 14,1998. : Response to NRC Concern, Tracking Number 98-A-0145 6903 Rockledge Drive, Bethesda, MD 20817-1818 Oggg77 Telephone 301-564-3200 Fax 301-564 3201 http://www.usec.com l
Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC NOV 17 W l
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l GDP 98-0257 Page 1 of 3 Response to NRC Concern, Tracking Number 98-A-0145 I.
Overview ofInvestigation l
Individuals from the Human Resource and Nuclear Regulatory Affairs organizations at Portsmouth (PORTS) conducted an investigation into the statement made by an individual that waivers are routinely being signed that authorize first line managers to exceed overtime hours as authorized by 1
the TSR. Both of these organizations report directly to the PORTS General Manager and are independent of the Section Managers who have day-to-day responsibility for ensuring overtime is not authorized on a routine basis.
Based on a review of overtime approvals covering a three month period, USEC has concluded that the statement made by the individual is not substantiated. The investigation determined that overtime approvals for first line supervisors are not being authorized in a routine manner.
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Findings ofInvestigation Details Provided by NRC "A concemed individual stated that waivers are routinely being signed that authorize first line and front line managers to exceed the overtime hours as authorized by the TSR.
What is the policy regarding first line and front line supervisors providing "hamis en" support during maintenance and surveillance activities?"
l USEC Response USEC's policy for implementing TSR administrative controls on overtime at PORTS is contained in procedure XP2-HR-LR1030, " Limitations On Hours of Work." The procedure applies to PORTS personnel that perform safety functions. The restrictions on overtime apply to first line supervisors whenever they are involved with safety-related work. The procedure does not make a distinction between supervisors who perform " hands on" support from those that are providing oversight of safety-related work. As a result, overtime limits apply to all supervisory personnel regardless of the function they are performing when safety-related work is involved.
The Section Manager is assigned responsibility for ensuring that adequate shift coverage is maintained without reliance on routine use of overtime by first line supervisors. The General Manager has overall responsibility for approving requests to exceed TSR overtime limits. The day-to-day responsibility for approving overtime requests is delegated to the Plant Shift Superintendent (PSS). The PSS must approve any deviations from the TSR required limits on overtime before the work can be performed. This approval is documented on Form A-3890. " Request For Individual To Exceed Established Hours Of Work Limitations."
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GDP 98-0257 Page 2 of 3 A review of approved A-3890 forms was conducted to determine if first line managers have routinely been granted approval to deviate from TSR established overtime limits. A three month period including August, September and October,1998, was chosen for this review. This period covers overtime approvals that were granted before and after changes were made to the program on September 30,1998. Prior to this date, procedure XP2-HR-LR1030 applied to all personnel performing safety or non-safety related work. This policy resulted in a large number of overtime approvals which made it difiicult for management to determine the number of approvals that were granted exclusively for safety-related work. The revised overtime program now in effect applies only to safety-related work which facilitates management oversight of the program The review considered the overall number of approvals granted for supervisors each month and cases where multiple approvals were granted to individual supervisors for a given month. Instances where supervisors did not actually work approved overtime were not included in the review. These instances were not considered germane to this investigation since the individual's Section Manager would have been aware that the individual had not worked the previously requested overtime and, therefore, would not have considered additional approvals routine. An attempt was made to screen the overtime approvals for August and September so that only safety-related work approvals were included in the review.
The total number of overtime approvals granted to supervisors in August, September and October was 52,31 and 20, respectively. The total number of supervisors receiving approval over the three month period was 55, indicating that some supervisors had been approved more than once in the review period. To determine if a trend exists that could indicate approval has become routine, this information was further broken down to determine if any supervisor had been granted approval in each of the three months.
Only one supervisor was identified who had received approvals in each of the three months. This individual has been assigned to perform batching of Department of Energy waste in addition to his normal job assignment. As a result of this assignment, the individual was granted overtime approval twice in August, twice in September, and once in October. Because of these findings, the evaluation was expanded for this individual to include overtime approvals for the months of June and July. None were found. The overtime approvals for this individual are expected to continue for several more months at which time this work assignment will end. Since this work is temporary in nature and outside of normal plant operations, the overtime approvals for this individual are not considered to be routine.
A review ofinstances where more than two overtime approvals were granted to an individual supervisor in a single month was also conducted. The review identified six individuals who met this criteria. In the month of August there were four occurrences as follows; one individual received six approvals, two individuals received five approvals, and one individual received three approvals. In the month of September there were two individuals that each received three approvals. There were no occurrences in October.
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i GDP 98-0257 Page 3 of 3 A review of the basis for the above approvals indicated that the multiple instances in August were i
- primarily related to outage _ work being performed to return cells or autoclaves to service, and high priority emergent work. The individuals who received five approvals in August did not have any additional approvals in'the following two months. The individuals who received six and three approvals in August, each had one additional approval in September, but no approvals in October.
The two individuals who received three ' approvals in September did not have any additional approvals in the previous and following month. The above information indicates that the multiple approvals were based on non-routine work and occurred on a temporary basis throughout the three j
month period.
USEC Conclusion-Ba' sed on the above investigation findings, USEC concludes that overtime approvals are not routinely being granted to first line supervisors. Overtime approvals are being granted to allow completion of outage or other high priority emergent work on a temporary basis.' Based upon these j
findings, there is not a requirement to perform a root cause analysis and no corrective actions are necessary.
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