ML20211L898
| ML20211L898 | |
| Person / Time | |
|---|---|
| Site: | 07007001 |
| Issue date: | 09/02/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211L651 | List: |
| References | |
| 70-7001-99-11, NUDOCS 9909080287 | |
| Download: ML20211L898 (14) | |
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L l U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 70-7001 Certificate No: GDP 1 Report No: 70-7001/99011(DNMS)
Facility Operator: United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road P.O. Box 1410 Paducah,KY 42001 Dates: August 2 - 6,1999 Inspector: T. D. Reidinger, Senior Fuel Facilities inspector Approved By: Patrick L. Hiland, Chief, Fuel Cycle Branch j Division of Nuclear Materials Safety D DOK000 bot r
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EXECUTIVE
SUMMARY
United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70-7001/99011(DNMS)
Plant Sucoort e The inspector concluded that the certificatee's training organizational structure was sufficient to facilitate the proper training of plant staff responsible for the safe operation, maintenance, and modification of the gaseous diffusion plant. (Section T1.1) e The initial and continuing training programs required by the Safety Analysis Fteport were satisfactorily translated into applicable training and development guidelines.
(Section T1.2) e The training staff properly implemented various aspects of the plant training program regarding documentation of training requirements and adequate control of plant staff l with deficient training qualifications. (Section T1.3)
- The nuclear criticality safety training program for supervisors was adequately implemented at the plant. (Section T1.4) e Training review group meeting minutes adequately described the issues discussed and were appropriately annotated as required by the procedure. In addition, the review of the meeting minutes indicated that a discussion of those items specified by the goveming procedure was also appropriately conducted. (Section T1.5)
- Training class subject matter experts and instructors appeared knowledgeable. Class handouts contained qualitative and quantitative information related to the topics discussed in class. A weakness was identified regarding instructor evaluation techniques and evaluation documents related to donniiig and doffing personnel protective equipment. (Section T1.6) e The inspector concluded that the training instructors were current with required training instructor qualification training. (Section T1.7) 2
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Report Details IV. Plant Suncort T1' Conduct of Trainina Activities T1.1. Trainina Oraanization
- a. Inspection Scooe (88010)
The inspector reviewed the plant training organization. The review consisted of interviews with the training manager and selected staff regarding applicable training oversight responsibilities,
- b. Observations and Findinos Safety Analysis Report (SAR) Section 6.1.1.27 stated, in part, that the training manager was responsible for the technical and qualification training programs' development and implementation. In addition, the SAR stated that the training manager reported to the general manager.- The inspector reviewed the plant's organization chart and confirmed that the training manager reported directly to the general manager. Discussions with the '
training manager and staff indicated that one of the responsibilities of the training staff was to provide an oversight and integration of all the various training program elements from an administrative and technical perspective. The training staff explained that the oversight would ensure that all the associated training elements provided the appropriate mechanism for evaluating and improving the training program for current and future plant design changes. The inspector determined that the training manager was aware of the applicable training requirements as specified in the SAR and plant training procedures. In addition, the inspector confirmed that the training staffs' understanding of their respective responsibilities was consistent with the requirements prescribed in the SAR.
Safety Analysis Report Section 6.6.1 stated, in part, that the plant training organization consisted of a centralized staff which reported directly to the plant training manager.
The training staff consisted of technical trainers, instructors, administrative personnel
- and mid-level managers who were directly responsible for assisting the plant in the design, development, implementation, and auditing of training programs in the following functional areas:
e general employee training; e operations and maintenance technical training; e- radiological protection training; e- environmental, safety and health training; e subcontractor training; and, e training instructor qualification.
The inspector reviewed the training organization chart and determined that the training staff of approximately 28 training instructors and six administrative support staff I members was consistent with SAR requirements. The organization chart outlined the
- training staff and that the training specialities associated with related functional areas were consistent with SAR requirements. The training staff also interfaced with different 3
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( functional line managers in the plant to coordinate training development and implementation of various functional areas as required by procedure.
In addition, SAR Section 6.6.1 stated, in part, that additional staff who worked directly for different plant organizations were matrixed (temporarily assigned) to the plant training staff. The organization chart indicated that approximately four staff members
- were matrixed to the plant training staff. The "matrixed" staff received instructional and training guidance from the training staff that ensured that their respective organizational training programs were consistent with plant training policies and procedures.
Discussions with several "matrixed" staff indicated that the staff was cognizant of l applicable plant training policies and procedures.
- c. Conclusions The inspector concluded that the certificatee's training organizational structure was sufficient to facilitate the proper training of plant staff responsible for the safe operation, maintenance, and modification of the gaseous diffusion plant.
T1.2 Trainina Development and Administrative Guides (TDAGs) l
- a. inspection Scope (88010) -
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1 The inspector reviewed the development and implementation of TDAGs of various plant )
training organizations. In addition, the inspector conducted interviews with the training j manager and selected staff. j
- b. Observations and Findinas i Safety Analysis Report (SAR) Section 6.6.1.1 stated, in part, that TDAGs shall contain ,
initial training requirements. The training manager and staff informed the inspector that the " initial training" program consisted of classroom and on-the-job training necessary to I
_ provide an understanding of the fundamentals, basic principles, systems, procedures, and emergency responses involved in work to which an employee was assigned. In addition, the training staff explained that initial task or duty area qualification was granted by line management based on successful evaluation of the plant staff's mastery of the leaming objectives presented during the training. New employees or employees transferred from other duty areas within the facility were evaluated to determine whether the employee was partially qualified by reason of previous applicable training or .
experience.
Safety Analysis Report Section 6.6.1.2 required that TDAGs contain training requirements which delineated " continuing training" for employees. Discussions with the training staff indicated that " continuing training" was provided to plant staff in the interest of promoting safety, safeguards, security, and environmental protection awareness. In addition, continuing training was explained as a method for plant staff to maintain and improve job-related knowledge and skills. The training staff indicated that annual training hours listed in the TDAGs were based on some of the following factors: (1) periodicity required by regulatory agencies and national standards; (2) tasks related to j
system approach to training (SAT); and, (3) training needs as determined by line management. These training needs included some of the following elements: (1) nuclear criticality; (2) safety assessments; (3) facility system changes; (4) component 4
. I changes; (5) procedure changes; (6) " lessons learned
- which included industry, in-house operating experience and event reports; (7) emergency response procedures; and, (8)
Technical Safety Requirements. Review of selected TDAGs indicated that applicable training hours were commensurate with the complexity of the technical areas involved and appeared appropriately weighted to address regulatory requirements.
i in addition, the inspector reviewed plant Procedure CP2-TR-TR1032, " Conduct of Training" and confirmed that the SAR organization training requirements were appropriately incorporated into the specific TDAG actions necessary to perform the required training tasks.
The inspector reviewed the following TDAGs used by the plant training organization to determine whether required initial and continuing training requirements were incorporated as required by the SAR: !
- Cascade Operator I e Instructor Training !
e- Cascade Coordinator j e Electrical Maintenance '
e Mechanical Maintenance e Calibration and Electronics e Assistant Plant Shift Superintendent
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e Plant Shift Superintendent (PSS) e Uranium Handlers e
j Fire Services i Based upon a sampling review of the TDAGs, the inspector determined that the TDAGs appeared to incorporate all the required initial training and continuing training requirements specified in the SAR. Specifically, the review of the initial and continuing training matrices for the TDAGs provided an outline by module numbers of training courses that were required to have been satisfactorily completed by the applicable plant employee at the prescribed training frequency. The inspector noted that the fire services TDAG contained a redundant self-contained-breathing apparatus training requirement. Discussions with the fire services management indicated that the fire service TDAG will be revised to eliminate the duplicate training requirements.
In addition, the SAR required the TDAGs that describe programs developed for specific jobs and positions to include the following elements:
e Organization and Administration Responsibilities; e Trainee Selection Criteria; e Course Loading and Scheduling Requirements;
- Initial and Continuing Training Program Requirements;
- Training Resource and Facility Guidelines; e Test / Evaluation Guidelines; j e Training and Evaluation Documentation Guidelines; and, I e Courses / Modules for Specific Qualification Areas. !
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. l The TDAGs were comprehensive and administratively organized as specified by the SAR. Based upon a selected review of courses and modules, the inspector determined !
that TDAGs incorporated the required administrative elements specified by the SAR with one exception. The TDAG for the PSS stated that the training program was structured into five distinct courses of training designed to ensure that the PSS staff had the necessary knowledge and skills to satisfy the mission statement. The inspector noted that although the TDAG had approximately 60 training modules (training courses), the training courses were not delineated to reflect the five distinct required courses of training as specified by the PSS TDAG requirements. Plant management informed the inspector that the PSS TDAG will be revised to partition the applicable training modules into the five required training courses.
- c. Conclusions The required initial and continuing training programs required by the SAR were satisfactorily incorporated into the applicable TDAGs. The inspector noted that the SAR administrative training requirements were also incorporated into the TDAGs with one exception related to the PSS staff.
T1.3 Trainina Reauirements and implementation
- a. Inspection Scoce (88010)
The inspector reviewed the incorporation and implementation of training requirements specified in the SAR into plant procedures and practices.
- b. Observations and Findinos Safety Analysis Report, Section 6.6, ' Training," describes training activities associated I with the safe operation and management of the plant. Plant Procedure !
UE2-TR-TR1030, " Conduct of Traini g," required, in part, that the organization managers: (1) develop and maintain training requirement matrices; (2) identify plant staff requiring indoctrination and training who perform activities affecting quality; and, (3) ,
place work restrictions on or remove plant staff from duty where training was deficient. l The inspector reviewed the system and records used by the plant training organization l to document training requirements and completed training. The system included a matrix of training requirements, by position, and the current training status of individuals assigned to the respective positions. The system appeared well organized and comprehensive.
i The inspector also reviewed a monthly report, issued by the training organization to plant managers, which documented the training status of all plant staff. Plant procedures c;irected plant managers to use the report information to ensure that plant staff did not perform work following the expiration of required training. The report was distributed approximately ten days prior to the end of the month and indicated training qualifications that expired at the end of the month, in 30 days, and in 60 days. During discussions with the training staff, the inspector was informed that plant managers were expected to review the training status of their staff and to issue work restriction memorandums for individuals with expired training requirements. This expectation was consistent with documented SAR and procedural requirements.
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The inspector reviewed approximately 60 plant staff training records to determine the g training status for the applicable training requirements. Based upon a detailed review of the training records and the most recent plant staff monthly training status report, the
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inspector determined that the qualifications outlined for the minimum requirements for j the position has been met. The inspector noted that when deficient training was listed on the monthly training status report, th9 responsibilities and duties of the affected plant L staff were subsequently delegated to other plant staff pending the completion of the '
required training. The inspector noted that the work restrictions memoranda were issued immediately following the training organization transmittal of the most recent monthly training status report to plant managers in accordance with plant procedural requirements.
During discussions with the training manager and staff, the inspector determined that work restrictions, placed on workers as a result of expired training qualifications, were promptly communicated back to the training organization following issuance of the monthly training status report. The inspector reviewed selected training records and observed that the letters of restriction were appropriately placed into plant staff training files as required by written procedures.
- c. Conclusions The training staff properly implemented various aspects of the plant training program regarding documentation of training requirements and adequate control of plant staff with deficient training qualifications.
T1.4 Supervisorv Nuclear Criticality Trainina 1
- a. Insoection Scoce (88010) l The inspector reviewed applicable plant staff training records to determine whether the requirement for nuclear criticality safety (NCS) training and refresher training was implemented for applicable plant supervisors and managers.
- b. Observations and Fin.dj_nas n
Safety Analysis Report, Section 6.6.5.2, Nuclear Criticality Safety, stated, in part, that initial NCS training shall be provided to plant staff who supervise and manage the handling of fissile material and work within fissile control areas. In discussions with the training staff regarding nuclear criticality training the inspector determined that applicable plant supervisory staff, selected byjob position and responsibilities and who directed work that contained NCS requirements, received special supervisory NCS training. The training manager explained that NCS training required initial classroom training followed by refresher training every two years.
The inspector reviewed the initial NCS training records for approximately 25 plant supervisory staff. Training records indicated that the selected supervisory staff received initial NCS training. In addition, the inspector reviewed the refresher NCS training requirements and selected plant staff training records. Procedure CP2-EG-NS1030,
- Nuclear Criticality Safety Training," stated, in part, that the two-year cycle for NCS 7
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required refresher training begins after the plant staff completed initial NCS training. In addition, Procedure CP2-EG-NS1030, allowed substitution of the dedicated NCS refresher training with another NCS training urse, if the substitution NCS course included a review of general NCS procedural changes and past plant NCS issues. The -
inspector reviewed additional training records and determined that the selected supervisory staff had refresher training or equivalent training at the required two year interval.
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! c. Conclusions The inspector determined that the NCS supervisory training program was adequately implemented at the plant.
T1.6 Trainina Review Grouc
! a. Insoection Scope (88010)
The inspector reviewed selected training review group (TRG) meeting minutes and evaluated the meeting frequency. These activities were then compared with the requirements stated in Procedure CP2-TR-TR1032, " Conduct of Training."
l l b. ' Observation and Findinas i
Procedure CP2-TR-TR1032, " Conduct of Training," Section 6.13, stated, in part, that the '
TRG shall meet and review training and qualification issues as needed but was not limited to the following:
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e Requalification Training Schedules
'e - Training Audit Findings l e TDAG Revisions e- Training for New Plant Design Changes l e Continuing Training issues The inspector reviewed documentation from the following TRGs to determine the adequacy, frequency of meeting dates, and staff composition of the meetings:
! o - 3de Operator i e L %1e Coordinator i e Eles .ical Maintenance o Uranium Handlers e Fire Services The inspector reviewed selected TRG meeting minutes from November 10,1997, to April 7,1999, and determined that the meeting minutes adequately described the issues discussed and were appropriately annotated as required by the procedure, in addition, the review of the meeting minutes indicated that a discussion of those items specified by the goveming procedure was appropriately conducted. The inspector identified that the selected meeting minutes specified actions to be taken for specific areas, responsible plant staff for the actions identified, or final decisions for previously-identified actions.
The inspector also determined that the selected TRG meetings were appropriately attended, with one exception, by the plant staff; (1) chairman, (2) group manager 8
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Discussions with the fire services training coordinator indicated that in the recent past, fire services TRG meetings with the Fire Chief (chairman) were conducted without the
, presence of the training coordinator due to oversight. Discussion with plant l management indicated that future fire cervices TRG meetings will appropriately include the fire services training coordinator, c.' Conclusions Training review group meeting minutes adequately described the issues discussed and were appropriately annotated as required by the procedure. In addition, the review of the meeting minutes indicated that a discussion of those items specified by the goveming procedure was appropriately conducted. The TRG meetings were appropriately attended by the plant staff with one exception, the fire services training coordinator had missed meeting in the recent past.
T1.6 Trainina Classes
- a. Insoection Scope (88010)
The inspector attended selected training classes, reviewed training documentation, and compared the activities observed with the requirements stated in the SAR and Procedure CP2-TR-TR1032, " Conduct of Training."
- b. Observation and Findinas Safety Analysis Report, Section 6.6.3.3, " Development of Lesson Plans and Training Guides Nuclear Criticality Safety," stated, in part, that lesson plans and other training guides shall provide the guidance and structure necessary to ensure consistent delivery of training material from trainer (instructor) to class. Discussions with training staff indicated that classroom lessons were used primarily to provide cognitive leaming on fundamentals, theory, basic operating and maintenance principles, and overviews of plant processes. The training staff indicated other forms of instructional materials such as video were used to supplement classroom instruction.
The inspector attended the following " continuing training" classes that were conducted either by subject mattcr experts (SMEs) or training instructors:
- Industrial Forklift Operation
- Distributed Process Control System Operation
- NCS Overview e Radiation Worker Level 1
- Donning and Doffing Personnel Protective Equipment e Stop-Think-Act-Review Training The inspector also reviewed several training modules that were used in classroom training and subject-specific teaching aids used by SMEs and instructors which were developed from procedures or regulatory guides. The training modules were reviewed for content. The modules appeared to have sufficient detail and contained the class outline, study notes and tests that would be used to evaluate the students
! understanding of the subject material.
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The inspector observed that the training class SMEs and instructors appeared knowledgeable on the various subject matter. The inspector noted that the class j handouts contained qualitative and quantitative information related to the topics i
discussed in class. Video presentations and handouts were used as training aids and the class attendees were appropriately involved in question and answer discussions.
Safety Analysis Report, Section 6.6.3.5," Evaluation of the Effectiveness of Training,"
stated, in part, that systematic evaluations of training effectiveness as it was related to on-the-job performance shall be used to ensure training programs convey required skills and knowledge. Discussions with the training staff indicated that student feedback on the training received was used to determine effectiveness of training programs and identified areas for refinement or revision. In addition, the students were asked to evaluate the instructor and the course at the completion of training. The inspector reviewed several classroom instructor feedback evaluation forrns and noted that the classroom participants evaluated the various classroom SMEs and instructors and related courses appropriately.
Safety Analysis Report, Section 6.6.3.5, " Evaluation of the Student Mastery of Learning Objectives," stated, in part, that a trainee's progress was evaluated by SMEs, instructors, or technical trainers through a variety of performance and knowledge demonstrations, such as practical tests to ensure mastery of the job performance requirements or learning objectives contained in these modules. The inspector attended the " Donning and Doffing Personnel Protective Equipment (PPE)" class conducted by the training staff for emergency responders. The instructor's performance evaluations of the emergency responders donning and doffing PPE were also observed. The inspector observed that class participants satisfactorily donned and doffed PPEs under the guidance of the SME and instructor after viewing a video that demonstrated the proper donning and doffing techniques. After the class participants gained confidence, t
the class was then instructed that practical evaluations would be conducted under the guidance and direction of either the SME or class instructor for each of the class participants. In addition, the class was instructed that each participant was required to satisfactorily pass the practical demonstration for donning and doffing PPEs (simulated in-field demonstration). The inspector observed that the SME and instructor provided
. hints and coaching during each of the evaluations. After the evaluations were l completed, the inspector was informed that all the classroom participants satisfactorily passed the practical demonstration of donning and doffing PPEs. The inspector noted that plant Procedure "On-The-Job-Training," Section 6.2.3, stated, in part, that when the evaluation starts: "Do not coach or assist the participant." in addition, the procedure also stated that the instructor shall not in any way direct the participant on how to perform the task. The inspector discussed the observation with the training manger and was informed that practical demonstration evaluations would be repeated for all the participants and refresher training would be conducted for the instructors emphasizing proper evaluation techniques.
The procedure also required that the practical evaluations shall be conducted using a job performance measure (JPM) and performance evaluation check!!ct (PEC). The inspector reviewed the applicable documentation used by the Si,fds that were used to evaluate the practical demonstrations. The inspector delarmined that the JPM and PEC were not adequately developed to include all the critical steps to properly evaluate a participant. The training staff agreed with the inspector's observation. The training staff 10
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informed the inspector that the JPM and PEC related to donning and doffing PPEs will be revised accordingly to include the appropriate evaluation elements. The certificatee's actions to provide refresher instructor evaluation techniques and revising the JPM and PEC related to donning and doffing PPEs will be tracked as an inspection Followup Item (IFl 70-7001/9901101).
- c. Conclusions The inspector observed that in general the training class SME and instructors appeared l
knowledgeable on the various subject matter. Class handouts contained qualitative and
' quantitative information related to the topics discussed in class. Refresher instructor evaluation techniques and revisions to evaluation documents related to donning and doffing PPEs was identified as a IFl.
T1.7 Instructor Qualifications
- a. Inspection Scooe (88010)
The inspector reviewed the instructor qualification training documentation required by the SAR and Procedure CP4-TR-QP1004, " Instructor Training and Qualification."
- b. ' Observation and Findinas Safety Analysis Report, Section 6.6A, " Training Instructor Qualification," stated, in part, that the training instructors qualification was the responsibility of plant training staff.
Training was provided to designated SMEs, instructors and knowledgeable technical trainers who developed and conducted qualification training for site personnel. The training staff informed the inspector that the program consisted of several modules designed to train instructors in conducting analysis, design, development, #
implementation, and evaluation of plant training programs. In addition, the program '
included initial training and qualification and periodic re-evaluation of skills and knowledge in both material development and instructional competency.
Safety Analysis Report Section 6.6.6.1 stated, in part, that the extent of further training for plant staff was determined by regulation, performance evaluations or comprehensive examinations. In addition, the training instructor TDAG stated, in part, that instructors were evaluated in accordance with appropriate training evaluation requirements, i.e., written examination. The inspector reviewed approximately 15 training instructor records and determined that some of the instructors were not administered a written examination. Discussion with th6 training manager indicated that in lieu of a written examination, the instructors were evaluated via a practical performance evaluation, in response to the inspector's observation, the training manager wrote a problem report to
- address the non-conformance with the TDAG. The training manager indicated that the training instructor TDAG will be revised to allow the optional practical performance evaluation.
The inspector reviewed the initial qualification training records for approximately 15 training instructors. Training records indicated that the training instructors received initialinstructor qualification training. Procedure CP2-TR-QP1039, 11
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"On-The-Job-Training" stated, in part, that a biennnial evaluation shall be conducted for
, technical trainers and instructors. The inspector reviewed additional training records and determined that the selected instructors were evaluated at the required two year l interval.
- c. Conclusions -
The inspector concluded that the training instructors were current with required training instructor qualification training.
T8 Miscellaneous Plant Support issues M8.1 (Closed) IFl 70-7001/99002-01: Resolution of the availability of emergency planning pamphlets for reservation visitors or alternate methods for providing guidance to reservation visitors. The plant staff posted large waming signs at appropriate areas on the reservation which provided information and guidance to visitors regarding the plant's public warning and address system for any emergencies occurring at the plant. The inspector was also informed that emergency planning information pamphlets were also made available for visitors frequenting the reservation at the local Western Kentucky Wildlife Management area check-in station.
IV. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspections on August 6,1999. The plant staff acknowledged the findings presented.
The certificatee did not identify any of the information discussed at the meeting as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corooration (USEC)
- A. Canterbury, Maintenance Manager
- C. Hicks, Site and Facilities Support Manager
- L. Jackson, Nuclear Regulatory Affairs Manager
- J. Labarraque, Safety, Safeguards and Quality Manager
- S. Penrod, Enrichment Manager
- H. Pulley, Plant General Manager
- R. Starkey, Training Manager
- Denotes those present at the August 6,1999, exit meeting Other members of the plant staff were also contacted during the inspection period.
INSPECTION PROCEDURES USED IP 88010: Operator Training j
ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-7001/99011-01 IFl The certificatee's actions to provide refresher instructor
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evaluation techniques and revising the JPM and PEC related to donning and doffing PPEs.
Closed 70-7001/99002-01 IFl Resolution of the availability of emergency planning pamphlets for reservation visitors or attemate methods for providing guidance to reservation visitors.
Discussed None 13
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LIST'OF ACRONYMS USED CFR , Code of Federal Regulations DNMS- Division of Nuclear Materials Safety
' i GDP_ Gaseous Diffusion Plant
.lF11 Inspection Followup item <
JPM Job Pedormance Measure NCS- - Nuclear Criticality Safety !
NRC Nuclear Regulatory Commission OJT On-the-job-training PDR 1 Public Document Room PEC ~ Podormance Evaluation Checklist {
i PPE Personnel Protective Equipment PSS Plant Shift Superintendent l i
SAR Safety Analysis Report I SAT. System Approach to Training SME_ Subject Matter Expert TDAG Training Development and Administrative Guideline TRG Training Review Group TSR Technical Safety Requirements USEC.- United States Enrichment Corporation i
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