ML20216C208
| ML20216C208 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 03/10/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-98-02, 70-7002-98-2, NUDOCS 9803130331 | |
| Download: ML20216C208 (1) | |
Text
v March 10, 1998 Mr. J. H. Miller Vice President - Production United States Enrichr"at Corporation Two Democracy Cente 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
RESPONSE TO PORTSMOUTH INSPECTION REPORT 70-7002/98002
Dear Mr. Miller:
This refers to your March 4,1998, response to Notice of Violation (NOV) transmitted to you by our letter dated February 6,1098, with inspection Report 70-7002/98002. We have reviewed your corrective actions and have no further questions at this time. Your corrective actions will be examined during future inspections, if you have any questions, please contact me at (630) 829-9603.
Sincerely, 9003130331 980310 l
PDR ADOCK 07007002 Patrick L. Hiland, Ch.ie C
PL'R Fuel Cycle Branch Docket No. 70-7002 l
cc:
J. Morgan, Portsmouth Acting General Manager R. W. Gaston, Portsmouth Regulatory Affairs Manager E. W. Gillespie, Portsmouth Site Manager, DOE S. A. Polston, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory i
Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office bec w/ltr did 03/04/98:
R. Pierson, NMSS l
P. Ting, NMSS j
W. Schwink, NMSS
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P. Harich, NMSS Y. H. Faraz, NMSS 1
R. Bellamy, RI j
EJM, Ril w/o enct (e-mail)
Ing3 F. Wenslawksi, RIV/WCFO
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CATE 03/\\0/98 03/p /98't OFFICIAL RECORD COPY
USEC A Clobal Energy Company March 4,1998 GDP 98-2008 United States Nu: lear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket 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 where lifted and re-landed leads on a "Q" item were not independently verified or recorded on the 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, riease contact Ron Gaston at (740) 897-2710.
Sin,:erely, es B. M r Acting General Manager Portsmouth Gaseous Diffusion Plant l
Enclosures:
As Stated cc:
NRC ReaJonIIIOffici NRC Resident Inspector-PORTS P.O. Box 800, Portsmouth, OH 45661
' Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com Omces in Livermore. CA Paducah, KY Portsmouth, OH Washington, DC FAR e 9 199' Q20?/G&HV-STf'
GDP 98-2008 Page1of3 United States Enrichment Corporation Reply to Notice of Violation (NOV),70-7002/98002-01 Restatement of Violation-Technical Santy Requirement 3.9.1 requires, in part, that procedures shall be implemented for activities described 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-GPIG30," Work Antrol Process," Revision 3, requires, in part, that troubleshooting work packages implement Procedure XP2-GP-GP 1033, "Lifled Leaa i and Jumpers,"
when leads are lifted during maintenance activities.
Section 7 of Procedure XP2-GP-GP1033, " Lifted Leads and Jumpers," requires, in part, an independent verification for the restoration ofleads on safety systems categorized as "Q" items and that these maintenance activities be recorded on an Appendix A, Lifted 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, Lifled Lv.d and Jumper Log Sheet.
USEC Response Backoround The January 1998 work order was developed to repair / replace a thermocouple. The precautions 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 was not adequaHy performed. A LL&J log form was included within the work package but was not completed.
The October 1997 work order was developed to assist Engineering with troubleshooting a pressure loop. The prerequisites section of the work instmetions contained a step which specifically required the workers to review the LL&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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4 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 closeout of both the January 1998 and October 1997 work orders.
The September 1997 work order was developed to replace a pressure transducer. The work instructions did not contain a step to require the workers to review the LL&J procedure. There was no pre-job briefing record in the work package to require the FLM to review the use of the LL&J L
log. A LL&J log form was not included within the work package. Therefore, a LL&J form was not completed.
L A review of the three work orders 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 were held. This investigation revealed l
training on the LL&J program was only given to Group Managers and FLMs. Training was not j
given to craft personnel on the LL&J program.
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Reason for Violation f
The reasons for this violation are discussed.below:
In the case of the January 1998 and October 1998 work orders, the reasons for this violation l
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 XP2-GP-GP1033. Additionally, the FLMs did not discuss the LL&J procedural requirements for using the LL&J log during the pre-job briefing and 1
did not ensure that maintenance personnel completed the LL&J log that was in the work package.
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l In the case of the September 1997 work order, planning personnel did not adhere to the requirements of the LL&J program when devcloping the work order. Therefore, an effective work package was not prepared for this activity.
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i A contibuting 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 wem 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 electronic cards and plugs. Also, some personnel believed that when working under the direct supervision of an engbeer while performing troubleshooting the use of the LL&J log was not required.
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GDP 98-2008 Page 3 of 3
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H.
Corrective Actions Taken and Results Achieved 1.
The affected leads and electronic cards were independently verified to be installed
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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 thi 'nspection 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.
3.
A sampling of ten wntly completed work orders involving the use of the LL&J program was reviewed to ensure the interim training given to FLMs' and Planners above has been succes:ful in preventing similar occurmnces. No additional problems were noted.
Ill.
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 pm-job briefchecklist. This will be completed by April 30,1998.
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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 j
i Full compliance was achieved on February 18,1998, when an independent verification for the mstoration of the leads in the cited work orders was documented on an Appendix A, Lifted Lead and Jumperlog sheet.
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'd GDP 98-2008 Page l'of 1 Reply to Notice of Violation (NOV) 70-7002/98002-01 List of Commitments 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 requimments of the Lifted -
Leads and Jumper program. This will be completed by May 30,1998.
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