ML20198H350
| ML20198H350 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 01/05/1998 |
| From: | Morgan J UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-97-11, GDP-98-2001, NUDOCS 9801130260 | |
| Download: ML20198H350 (5) | |
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United St%s l
Enrichment Corpor; tion
~7 2 Democracy Center -
6903 Rockledge Dnve Bethesda, MD 20817 j
Tel: (304 564-3200
'* * ' " 66#U' Uniteil %tes l:nricheneni Girporaiiiin January 5,1998 United States Nuclear Regulatory Commission GDP 98 2001 Attention: Document Control Desk Washington, D.C. 205$5 Portsmouth Gaseous Diffusion Plant (PORTS)
Doeket No. 70-7002
- Reply to Notlee of Violation (NOV) 70-7002/97011-01 Nuclear Regulata Commission (NRC) letter dated December 5,1997, transmitted the subject Inspection Report (IR) that contained a violation imolving three First Line Managers (FLMs) who perfcrmed work under procedures containing nuclear criticality safety approval requirements and had not received nuclear criticality safety (NCS) refresher training as required by procedure.
USEC's response to this violation is provided in Enclosure 1. lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
USEC believes that the examples that led to this violation are symptomatic of other training deficiencies. The response to this violation addresses the corrective action that is baing taken to address reducing these training deficiencies. As indicated in Enclosure 1, USEC will submit a supplemental response to this NOV by June 15,1993.
If you have any questions regarding this submittal, please contact Ron Gaston at (614) 897-2710.
Sincerely, I
WY
,Wgp ll ames R Morg y
9801130260 990105 PDR ADOCK 07007002.
Acting General Manager C
PDR Portsmouth Gaseous DitTusion Plant Enclosures (2) cc.
NRC Region III, Regional Administrator jL.,,6 J
NRC Resident inspector, PORTS Grt'ces in Paducah, Kentucky ' Portsmouth. Ohio Washington, DC i
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United States Enrichment Corporation (USEC)
Heply to a Notlee of Violation (NOV) 70-7002/97011-01
- Technical Safety Requirement 3.4 requires, in part, that the training program shall be established, implemented, and maintained'as described in Section 6.6 ot'the Safety Analysis Report.
Section 6.6.1.2 of the Safety Analysis Report requires, in part, that plant procedures, organization
. training development, and administrative guides contain training requirements which delineate continuing training for employees.
Procedure XP2-TR-TR1030," Conduct of Training," requires in part, that personnel who work under.
_ procedures containing nuclear criticality safety approval requirements receive nuclear criticality safety refresher training every two years.
Contrary to the above, between November 1 and November 6,1997, three first line managers performed work under procedures containing nuclear criticality safety approval requirements and had not received nuclear criticality refresher trainir'g since October 1995 as required by Procedure XP2-TR-TR1030.
USEC Response a
I.
Reason for Violation i
The root cause for this violation is that I.ine Managers have not enforced the requirement for personnel to complete their required training nor are personnel accountable for meeting the training requirements. Additionally, work restrictions were not issued until aller the individual's training qualifications had expired.
I}micround Training at PORTS is classified into two categories (i.e., nuclear safety related and non-nuclear safety related). Nuclear safety related training includes Nuclear Criticality Safety -
(NCS) training, Radiation Worker Training, Technical Safety Requirement / Operational Safety Requirement training, etc. Non-nuclear safety related training primarily includesjob-specific training, OSilA training, etc.
' A review of the training records and qualification histories of the three First Line Managers (FLMs) ident fied in the subject NOV was performed. Two of the FLMs became delinquent i
on NCS refresher training on November 1,1997 Work restriction letters were issued to both individuals on November 4,1997, to identify to them that they were not to perform NCS related activities. Both individuals successfully completed NCS supervisory training on November 7,1997. A computerized review of work packages in use between November 1 -
7 identified potential instances where work under procedures containing NCS A requirements s
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I cohki have occurred.' However, a review of each individual work package showed these two a
u FLMs did not supervise NCSA work.
The third individual should have received initial NCS training when appointed to th'e position of relicf FLM on July 28,1997.- A work restriction letter was issued on September 23,1997, to identify to the individual to not perform NCS related activities. The FLM did a
not recall receiving this letter. - Another work restriction was issued to'this FLM on -
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~ November 4,1997, and this individual successfully completed NCS supervisory training on 1
- November 7,1997. 'A computenzed review of work packages in use between July 28,1997, and November 7,1997, identified potential instances where work under_ procedures
' containing NCSA requirements could have occurred.' Fur.her review'ofeach individual work
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package revealed this FLM did superdse a crew performing an AQ-NCS work activity letween October 17 20,1997, l
During interviews this FLM stated this particular work assignment was to support Planned i~
4 Expeditious liandling (PEll) activities. Further, the FLM did not correlate the relationship '
between being delinquent in NCS training and the work being performed. -The work
- involved the modification of a seal on a non contaminated always-safe vacuum cleaner in the shop.
- PORTS personnel did r.ot have suflicient time to thoioughly evakiate the circumstances and data of this issue. Therefore, we were unable to provide this information to the Inspector
- prior to the exit meeting for IR 91011. As a result of the training deficiencies identified --
during this inspection, a more comprehensive review of these training deficiencies (both nuclear safety related and non nuclear safety related) and their current status was initiated.
l This review determined that a number of additional training deficiencies exist. Ilowever, no nuclear safety related training deficiencies currently exist. Work restrictions have been issued to individuals with deficient non-nuclear safety related training requirements.
II.
Corrective Actions Taken and Results Achieved
'l.
De three FLMs identified in the violation st.ccessfully completed NCS supervisory -
training on November 7,1997. Their NCS work activities no longer require work restrictions,
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2.
A site wide review of NCS training delinquencies was perfctmed, and all individuals on-site are current with their NCS training requirements. There have been no nuclear.
safety related training req'uirement deficiencies since November 19,1997.
3.
Work restrictions have been issued to individuals with deficient non-nuclear safet, related training requirements.
4, ne monthly training summary deficiency report was modified to provide status of-a training delicienciesl by organization. -This will provide the line_ managers a
. comprehensive assessment of their organization's total current and potential future 0
- training' deficiencies.
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JThe individual training status reports were modified to include a work restriction--
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statement for the line manager's signature.1This will ensure that any individual with 1
- an upcoming delinquent training requirement will have a pre-printed work _ restriction..
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. Corrective Steps to be Taken LA~ management team has been appointed to address issues which lead to or contribute to training requirement deficiencies. This team will develop corrective actions to reduce the -
! present number of training delinquencies while ensuring compliance with the SAR and TSR is' maintained. Subsequent to this team's report,' a supplemental response to this NOV will be submitted to NRC by June 15,1998, discussing additional corrective actions that are >
being taken.-
IV.c ' Date of Full Compliance Full compliance with the cited violation was achieved on November 7,1997, when all three
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. FLMs successfully completed NCS supervisory training. The corrective actions that are=
~ being taken to prevent recurrence will be provided in the supplemental response, 1
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..i United States Enrichment Corporation (USEC)1 List of Commitments A management team has _bcen' appointed to address issues which lead to or contribute to training -
a requirement defici ncies. This team will develop corrective actions to reduce the present number
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of training'delinquencia while ensuring compliance with the SAR and TSR is maintained.
Subsequent to this team's report, a supplemental response to this NOV will be submitted to NRC
-by June 15,1998, discussing additional corrective actions that are being taken.
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