ML20216B433
| ML20216B433 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 04/07/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7001-98-02, 70-7001-98-2, NUDOCS 9804130464 | |
| Download: ML20216B433 (1) | |
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April 7, 1998
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Mr. J. H. Miller Vice President - Production United States Enrichment Corporation i
Two Democracy Center 6903 Rockledge Drive l
Bethesda, MD 20817 SU3 JECT:
RESPONSE TO PADUCAH INSPECTION REPORT 70-7001/98002
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Dear Mr. Miller:
This refers to your March 30,1998, response to Notice of Violation (NOV) transmitted to you by our letter dated February 26,1998, with inspection Report 70-7001/98002. _We have reviewed your corrective actions and have no further questions at this time. Your corrective actions will be i
examined during future inspections.
If you have any questions, please contact me at (630) 829-9603.
j Sincerely,
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Patrick L. Hiland, Chief Fuel Cycle Branch i
Docket No. 70-7001 cc:
S. A. Polston, Paducah _ General Manager L. L. Jackson, Paducah Regulatory Affairs Manager J. M. Brovm, Portsmouth General Manager l
S. A. Toelle, Manager, Nuclear Re0ulatory Assurance and Policy, USEC Paducah Resident inspector Office Portsmouth Resident Inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE J. C. Hodges, Paducah Site Manager, DOE bec w/ltr dtd 03/30/98:
Docket File w/enci PUBLIC IE-07 w/ encl R. Pierson, NMSS w/enci P. Ting, NMSS w/enci l
W. Schwink, NMSS w/enci P. Harich, NMSS w/enci
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M. L. Horn, NMSS w/enci R. Bellamy, RI w/enci 12.OObn'e EJM, Ril w/enci (e-mail)
F. Wenslawski, RIV/WFCO w/enci Greens w/o encl DOCUMENT NAME: G:\\SEC\\ PAD 98002.RES.
' Ta receive a copy of this document, Indicate in the box:"C" = Copy without enclosure *E"= Copy with enclosure *N" = No copy OFFICE Rill l ce Rlli lP l
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NAME Kniceley:ib QA6 Hiland DATE-04A/98 04/'T /98 98041304b4 980407 OFFICIAL RECORD COPY PDR ADOCK 07007001 C
i y USEC
!o A Global Energy Company March 30,1998 GDP 98-1022 i
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U. S. Nuclear Regulatory Commission Attention: Document ControlDesk l
Washington, D.C. 20555-0001 i
Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 Reply to Notice of Violation (NOV) 70-7001/98002 l
l The subject Inspection Report (IR) contained one violation involving a " Procedure Hold," that was issued for certain plant training procedures, but the tasks governed by the procedures continued to be performed.
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USEC's response to this violation is provided in Enclosure 1. There are no new regulatory j
l (q commitments associated with this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PGDP, i
Also, please note that the training and procedures organization change described in Section T1.1.b (Page 7) ofthe subject IR has not yet been implemented. On March 12,1998, USEC submitted, for.
NRC review and approval, a revision to the Radioactive Material Packaging and Transportation l
Quality Assurance Plan to address the change to the training and procedures organization (see USEC j
Letter GDP 98-0042). NRC approval of the proposed revision is required before USEC can implement the organizational change.
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Ifthere are any questions regarding this submittal, please contact Larry Jackson at (502) 441-6796.
Sincerely, L9AAJP Steve Polston General Manager Paducah Gaseous Diffusion Plant
Enclosure:
As Stated O.b P.O. Box 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com OfIices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC W LIO D h Q pp
e' U. S. Nuclear Regulaton Commission March 30,1998 GDP 98-1022, Page 2 cc:
NRC Regional Administrator, Region III NRC Resident Inspector, PGDP l
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GDP 98-1022 Page1of2 UNITED STATES ENRICHMENT CORPORATION (USEC) j REPLY TO NOTICE OF VIOLATION (NOV) 70-7001/98002-01 I
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Restatement of Violation i
Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be prepared, I
reviewed, approved, implemented, and maintained for activities described in Safety Analysis Report, Section 6.11.4.1, and listed in Appendix A, to Safety Analysis Report, Section 6.11.
I Appendix A, to Safety Analysis Report, Section 6.11, requires, in part, that procedure management l
activities shall be covered by written procedures.
l Procedure UE2-PS-PS1031, "UE Policy and Procedure Control Process," Section 6.22.3, " Procedure Holds," requires, in part, that when a " Procedure Hold" is issued, the tasks within the procedure are no longer performed p1 Contrary to the above, a " Procedure Hold," was issued for certain plant training program procedures, (O
and the tasks within procedures continued to be performed. Speci6cally, from January 21, through January 27,- 1998, Procedure CP2-TR-QP-1039, "On 'Ihe-Job-Training," was placed on a Procedure Hold, and the tasks within the procedure continued to be performed. In addition, from August 29, 1997 through January 30, 1998, Procedure CP2-TR-QP1041, " Training Records and Training Program Configuration Management," was placed on a Procedure Ho!d, and the tasks within the -
procedure continued to be performed.
USEC Response I.
' Reason for the Violation The reason for this violation was less than adequate understanding and management oversight of the procedure process. The training organization did not fully understand that, when a
" Procedure Hold" is issued, the requirement to stop all work covered by an affected
. procedure applied to administrative procedures such as the ones referenced in the cited violation. ' Consequently, the training orgardzation placed several procedures into a
" Procedure Hold" status, for eventual revision and/or deletion, without being aware that work covered by the affected procedure had to be stopped.
II.
Corrective Actions Taken and Results Achieved 1.
Following identification of the above violation all affected work was stopped, in d
accordance with the provisions of UE2-PS-PS1031. This action was completed by January 30,1998.
GDP 98-1022 y
Page 2 of 2 2.
A crew briefing was conducted to ensure that training organization personnel understand the requirement to stop work whenever a procedure is placed into a
" Procedure Hold" status. Additionally, the criteria for when a " Procedure Hold" should be used was reviewed by training organization management.
3.
A training procedures recovery plan was implemented to identify procedures which might be affected by a " Procedure Hold." It was determined that the subject deficiency was applicable to the following training-related procedures:
UE2-TR-QP1002 - OralEraminations CP2-TR-QP1033 - Quahfications, Test-Out, Exemption, andRemediation CP2-TR-QP1035 - Needs, Job and Task Analysis CP2-TR-QP1039 - On the Job Training CP2-TR-QP1041 - TrainingRecords and Training Program Configuration Management CP2-TR-QP1042 -Instructor Training and Quahfication CP2-TR-TRI032 - Conduct of Training 4.
Procedure UE2-TR-QP1002 remains in a " Procedure Hold" status and, accordingly, m
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is not being used. Procedures CP2-TR-QP1033, CP2-TR-QP1035, CP2-TR-QP1041, and CP2-TR-QP1042 have been revised and reissued, with new numbers, permitting the resumption ofcovered work activities. Procedure CP2-TR-QP1039 was removed from a " Procedure Hold" status on January 27,1998, permitting the resumption of covered work activities. Procedure CP2-TR-TR1032 was only affected because ofa reference therein to Procedure CP2-TR-QP1041, which was in a " Procedure Hold" status. Consequently, once Procedure CP2-TR-QP1041 was revised and reissued work activities covered by Procedure CP2-TR-TR1032 were permitted to resume.
III.
Corrective Action to Be Taken None.
IV.
Date of Full Comoliance USEC achieved full compliance by January 30,1998, when training activities covered by procedures in a " Procedure Hold" status were stopped.
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