ML20197B092
| ML20197B092 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 03/04/1998 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-02, 70-7002-98-2, GDP-98-2008, NUDOCS 9803100118 | |
| Download: ML20197B092 (5) | |
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March 4,1998 GDP 98-2008 United States Nuclear Regulatory Commission
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Attention: Document Control Desk Washington, D.C. 20555 0001 Portsu outh Gaseous Diffusion Pisnt (PORTS)
Dockat No. 70-7002 Reply to Notice of Violation (NOV) 70-7002/98002 01 The subject Inspection Report (IR) contained a violation involving three maintenance activities i
where lifted and re-landed leads on a "Q" item were not independently verified or recorded on the I
appropriate form.
USEC's response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, pleas: contact Ron Gaston at (740) 897-2710.
Sincerely, hr Acting General Manager Pertsmouth Gaseous Diffusion Plant i
Enclosures:
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NRC Region Ill Office NRC Resident Inspector-PORTS 9803100118 980304 PDR ADOCK 07007002 h
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P.O. Box 800, Portsmouth, OH 45661 Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com Offices in livermore, CA Paducah, KY Portsmouth, OH Washington, DC
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GDP 98-2008 Page 1 of 3 United States Enrichment Corporation Reply to Notice of Violation (NOV),70-7002/98002-01 Restatement of Violation.
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Technical Safety Requirement 3.9.1 requires, in paat, that procedures shall be implemented for activities des:ribed in Safety Analysis Report. Section 6.11, Appendix A of the Safety Analysis Report requires maintenance to be performed in accordance with approved procedures.
Approved Procedure XP2-GP-GP1030,"Wock Control Process," Revision 3, requires, in part, that troubleshooting work paciages implement Procedure XP2-GP GP1033," Lifted Leads and Jumpers,"
when leads aie lined during maintenance activities.
Section 7 of Procedure XP2-GP-GP1033, " Lined Leads and Jumpers," requires, in part, an independent verification for the restoration ofleads on safety systems categorized as "Q" items and j
that these maintenance activities be recorded on an Appendix A, Lined Lead and Jumper Log Sheet.
Contrary to the above, on September 10, 1997, October 28,1997, and January 1,1998, the certificatee did not perform independent verifications for the restoration ofleads on a safety system categorized as a "Q" item nor were these maintenance activities recorded on an Appendix A, Lined Lead and Jumper Log Sheet.
USEC Response Backcround The January 1998 work order was develeped to repair / replace a thermocouple. The precautiom section of the work instructions contained a step which specifically required the workers to review procedure XP2-GP-GP1033," Lifted Leads and Jumpers"(LL&J). This review was not performed.
Also, the pre-job briefing record which is part of the work package contained a step which required the FLM to review the work instructions precautions containing the use of the LL&J log during the pre-job briefing. This review wm not adequately performed. A LL&J log form was i.1cluded within the work package but was not completed.
The October 1997 work, ider was developed to assist Engineering with troubleshooting a pressure loop. The r requisites section of the work instructions contained a step which specifically required the work:4,o review the LL6.J procedure. This review was not performed. Also, there was no pre-job briefing record in the work package to require the FLM to review the use of the LL&J log during the pre-job briefing. As a result, while a pre-job briefing was conducted, use of the LL&J log was not discussed. A LL&J log form was included within the work package, but was not completed.
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GDP 98-2008 Page 2 of 3 It should also be noted that the same FLM was involved in the initial work order review, performed the pre-job briefing and review closcout of both the January 1998 and October 1997 work orders.
The September 1997 work order was developed to replace a pressure trai.sducer. The work instructions did not contain a step to require the workers to review the LL&J procedure. There was no pre-job briefmg record in the work package to require the FLM to review the use of the LL&J log. A LL&J u Orm was not included within the work package. Therefore - i.L&J form was not completec A review of the three work ciders discussed above and maintenance training records relating to the Lifted Lead and Jumper (LL&J) Program was conducted. Also, interviews with the maintenance First Line Managers (FLM) and craft personnel involved w e held. This investigation revealed training on the LL&J program was only given to Group Managers and FLMs. Training was not given to craft personnel on the LL&J program.
I.
Reason for Violation The reasons for this violation are discussed below:
l In the case of the January 1998 and October 1998 work orders, the reasons for this violation were failure to follow procedure requirements and lack of accountability. Specifically, maintenance personnel did not perform steps required by the approved work instructions which stated to review procedure XF2-GP-GP1033. Additionally, the FLMs did not discuss the LL&J procedural requirements for using the LL&J log during the pre-job brief'mg and did not ensure that maintenance personnel completed the LL&J log that was in the work package.
In the case of the September 1997 work order, p anning personnel did not adhere to the 1
requirements of the LL&J program when developing the work order. Therefore, an effective work package was not prepared for this activity.
A contributing cause for this violation is that maintenance personnel lacked an understanding of the procedural requirements involved with the LL&J program. Training on these requirements were only given to Group Managers, Front Line Managers, and Planners, not to craft personnel. For example, not all personnel were aware the program applied to electrcnic cards and plugs. Also, some personnel believed that when working under the dire;;t supervision of an engineer while performing troubleshooting the use of the LL&J log was not required.
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'a GDP 98-2008 Page 3 of 3 II, Corrective Actions Taken and Results Achieved 1.
The affected leads and electronic cards were independently verified to be installed correctly and properly documented.- This was confirmed by post maintenance testing that was originally included in each work package to ensure proper restoration of the system and verify proper system operation.
2.
Lessons learned from this inspection were developed which outlined the-key elements of the LL&J program. This information was provided through crew briefings to FLMs and Planners to ensure they are aware of the LL&J program requirements.
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A sampling of ten recently completed work orders involving the use of the LL&J j_
program was reviewed to ensure the interim training given to FLMs and Planners above has been successful in preventing similar occurrences. No additional problems -
were noted.-
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Corrective Steps to be Taken 1.
First Line Managers will be retrained to ensure pre-job briefs include a thorough discussion of all items on the pre-job briefchecklist. This will be completed by April 30,1998.
2.
Planners will be retrained to ensure LL&J logs are used in work packages in which -
circuit boards are being changed out or removed. This will be completed by May 30, 1998.-
3.
All maintenance craft personnel will be trained to the requirements of the Lifted Leads and Jumper program. This will be completed by May 30,1998.
IV.
Date of Full Compliance Full compliance wcs achieved on February 18,1998, when an independent verification for the restoration of the leads in the cited work orders w: s documented on an Appendix A, Lifted Lead and Jumper log sheet.
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Encl'osure 2 I
GDP 98-2008 Pagc1of1 Reply to Notice of Violation (NOV) 70-7002/98002-01 List of Contmitments
-1.
First Line Managers will be retrained to ensure pre-job briefs include a thorough discussion of all items on the pre-job brief checklist. This will be completed by April 30.1998.
2.
Planners will be retrained to ensure LL&J logs at: ased in work packages in which circuit boards are being changed out or removed. This will be completed by May 30,
- 1998, 3.
All maintenance craft personnel will be trained to the requirements of the Lilled Leads and Jumper program. Th:s will be completed by May 30,1998.
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