ML20199B430

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7002/97-11

ML20199B430
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	01/20/1998
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7002-97-11, NUDOCS 9801280277
Download: ML20199B430 (1)

Text

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January 20, 1998  ;

i Mr. J. H. MWer Vice President Production Unl6ed States Enrichment Corpors, tion Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20617  ;

SUBJECT:

RESPONSE TO PORT 8 MOUTH INSPECilON REPORT 70 7002/97011 Dear Mr. Miller.

This refers to your January 5,1998, response to Notice of Violation (NOV) transmitted to you by .

our letter dated December 5,1997, with inspection Report 70 7002/97011. In your renponse, you ackred:f-;+d the violation. We hr.va reviewed your corrective actions for the violation and have no further questions at this time. We Mrcd:f-;= your commitment to a suppiemental response by June 15,1996, regarding additional corrective actions for this violation. Your corrective actions will be examined during future inspections. i if you have any questions, please contact me at (630) 829 9603.  ;

Sincerely Original Signed by l Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70 7002 oc: S. A. Polston, Paducah Generai Manager J. B. Mor9an, Portsmouth Acting General Manager R, W. Gaston, Portsmouth Nuclear Regulatory ,

Affairs Manager S. Toolle, Manager, Nucioar Regulatory Assurance and Policy, L'SEC E. W. Gillespie, Portsmouth Site Manager, DOE Paducah Resident inspector Off6ce Portsmouth Resident inspector Office bec w/itt dtd 01/05/98: R. Pierson, NMSS l P. Ting, NMSS W. Schwink, NMSS {

P. Harich, NMSS Y. Faraz, Project Manager Portsmouth, NMSS R. Bellamy, RI E. McAlpine, Ril o 8~ 001a3 F. w.nsiawski, Riv/wCFo PUBLIC (IE 07)

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United States Nuclear Regulatory Commission ODP 98 2001 Attention: Document Control Desk Washington, D.C. 20555 Portsmouth Gaseous Diffusion Plant (PORTS) .

Dockei No. 70 7002  ;

Reply to Notlee of Violation (NOV) 70 7002/9701141 Nuclear Regulatory Commission (NRC) letter dated December 5,1997, transmitted the ,

subject inspection Report (IR) that contained a violation involving three First Line Managers (FLMs) who performed 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. Enclosure 2 lists the "

conunitments made in this report. Unless specifically noted, the corrective actions specified in each 4 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 being taken to address reducing these training deficiencies. As indicated in Enclosure 1. USEC will submit a supplemental response to this NOV by June 15,1998, if you have any questions regarding this submittal, please contact Ron Gaston at (614) 897 2710.

Sincerely, Mo Acting General Manager Portsmouth Oaseous Diffusion Plant Enclosures (2) ec: NRC Region III, Regional Administrator '

NRC Resident inspector, PORTS f3 3AH 09 WE

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Enclosure i United States Enrichment Corporation (USEC)

Reply ao a Notice of Violation (NOV) 70 7002/9701101 Technical Safety Requirement 3.4 requires, in part, that the training program shall be established, implemented, and maintained as described in Section 6.6 of 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 whleh delineate continuing training for employees.

Procedure XP24WTR1030," Conduct of Training " requires in part, that personnel who work under procedures containing nuclear criticality safety approval requirements receive nuclear criticality safety refreuher training every two years.

- Contrary to the above, between November I 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 training since October 1995 as required by Procedure XP2 TR TR1030.

USEC Response

1. Reason for Violation The root cause for this violation is that Line Managers have not enforced the requirement for .

personnel to complete their required training nor at: personnel accountable for meeting the training requirements. Additionally, work restrictions were not issued until after the individual's training qualifications had expired.

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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 Trairing, Technical Safety Requirement / Operational Safety Requirement training, etc. Non. nuclear safety related trainirig primarily includesjob-specific training, OSH A training, etc.

A review of the training records and qualification histories of the three First Line Managers (FLMs) identified in the subject NOV was perfonned. Two of the FLMs became delinquent 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 activhies. Both individuals successfully completed NCS supervisory training on November 7,1997. A computerized review of work packages in use between November 1 -

7 identified patential instances where work undur procedures containing NCSA requirements  ;

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i could have occurred, liowever, a review of each individual work package showed these two l

FLhis did not supervise NCSA work, r The third individual sl.ould have received initial NCS training when appointed to the _

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position of relief FLh1 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 FLhi did not recall receiving this letter. Another work restriction was issued to this FLhi oa i November 4,1997, and this individual successfully completed NCS supervisory training on  :

November 7,1997. A computerized review of work packages in use between July 28,1997, and November 7,1997, identified potential instances where work under procedures containing NCS A requirements could have occurred. Further review of each individual work package revealed this FLhi did supervise a crew performing an AQ NCS work activity between October 17 20,1997.

During interviews this FLM stated this particular work assignment was to support Planned Expeditious llandling (PEll) activities. Further, the FLM did not correlate the relationship between being delinquent in NCS training and the work being performed. The work i involved the modification of a seal on a non contaminated always safe vacuum cleaner in the shop.

PORTS personnel did not have sufficient time to thoroughly evaluate 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 97011. As a result of the training deficiencies identified during this inspections, a more comprehensive review of these training deficiencies (both "

nuclear safety related and non nuclear safety related) and their current status was initiated.

'!his review determined that a number of additional training deficiencies exist. However, no nuclear safety related training deficiencies currently exist. Work restrictions have been issued to individuals with deficient non nuclear safety related training requirements.

11. Corrective Actions Taken and Results Achieved

l. The three FLhis identified in the violation successfully completed NCS supervisory training on November 7,1997. Their NCS work activities no longer require work restrictions.

2. A site wide review of NCS training delinquencies was performed, and all individuals on site are current with their NCS training requirements. There have been no nuclear safety related training requirement deficiencies since IWovember 19,1997.

3. Work restrictions have been issued to individuals with deficient non nuclear safety related training requirements.

4. The monthly training summary deficiency report was modified to provide status of training deficiencies by organization. This will provide the line managers a ,

comprehensive assessment of their organization's total current and potential future .

training deficiencies.

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5. -The individual training status reports were modified to include a work restriction statement for the line manager's signature. 'Ihis will ensure that any individual with i an upcoming delinquent training requirement will have a pre printed work restriction. i e

111. Corrective Steps to be Taken A management team has been appointed to address issues which lead to or contribute to i

l 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. - Date of Full Compliance Full compliance with the cited violation was achieved on November 7,1997, when all three  :

FLMs successfully completed NCS supervisory training. The corrective actions that are being taken to prevent recurrence will be provided in the supplemental response.

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Enclosure 2 [

United States Enrichment Corporation (USEC) l IJat of Commitments A management team has been appointed to address issues which lead to or contribute to training

• requirement denciencies. 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 l by June 15,1998, discussing additional corrective actions that are being taken.

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