ML20236G650
| ML20236G650 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/29/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-08, 70-7002-98-8, GDP-98-2030, NUDOCS 9807060320 | |
| Download: ML20236G650 (8) | |
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.h USEC A Global Energy Company June 29,1998
' GDP-98-2030 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Response to Inspection Report (IR) 70-7002/98008 Notice of Violation (NOV)
The subject Inspection Report (IR) contained a violation involving a failure to update the training requirements matrices and identify mandatory training needs for newly appointed managers.
USEC's response to this violation is provided in Enclosure 1.
As indicated in USEC letter dated June 10,1998 (reference 1) and aflirmed in NRC letter dated June 16,1998 (reference 2), USEC had planned to include in this submittal those actions that USEC is taking to reduce the present number of training delinquencies at PORTS while ensuring compliance with the Safety Analysis Report and the Technical Safety ftegturements. However, because of the programmatic nature of the training deficiencies identified in the NOVs in irs97-011,98-05,98-08, and 98-10, USEC requires additional time to ensure our response to this issue is fully adequate.
Therefore, per discussion between Dave Waters of USEC and Rob Krsek of NRC on June 29,1998,
//f USEC will provide NRC with a supplemental response to this NOV by July 24,1998. This supplemental response will address the additional actions that USEC is taking to improve the plant
/i training program.
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Furthermore, in order to determine the effectiveness of our corrective actions, the PORTS Safety, i
Safeguards, and Quality (SS&Q) organization will conduct a follow-up assessment of the training program to begin in November 1998. This assessment will examine the training deficiencies that led to the NOVs in irs97-011,98-05,98-08, and 98-10 and the corrective actions taken in response to these violations to determine if they are being effective in preventing recurrence. lists the commitments made in this report. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
I' 9907060320 990629' PDR ADOCK 07007002 C
.: r-o (,, V U U of P.O. Box 800, Portsmouth, OH 45661 l
Telephone 614-897-2255 Fax 611897-2644 http://www.usec.com Ofkes in Livermore, CA Paducah, KY Portsmouth, OH Washinpon, DC h
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.' United States Nuclear Regulatory Commission Jun'e 29,1998 -
.GDP 98-2030 Page Two If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely,
. 'iorris Br n eneral Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc:
. NRC Region III OITice NRC Resident inspector-PORTS
-United States Nuclear Regulatory Commission
. Jun'e 29,1998 -
GDP 98-2030, Page Three.
Ref'erences 1.
USEC letter GDP 98-2023 dated June 10,1998, " Change to a Regulatory Commitment, Notice of Violation (NOV) 70-7002/97011-01."
2.
.NRC letter dated June 16,1998, "NRC Inspection Report 70-7002/980010 (DNMS) and Notice of Violation."
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GDP 98-2030 Page1of4 1
UNITED STATES ENRICIIMENT CORPORATION (USEC)
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REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98008-01 q
Restatement of Violation i
Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented for activities described in *.ppendix A of the Safety Analysis Report Section 6.11," Procedures."
Appendix A of Section 6.11 describes training as activities that shall be implemented in accordance with written procedures.
Procedure UE2-TR-TR1030, " Conduct of Training," Revision 0, Change B, dated July 31,1997, requires, in part, that organization / group managers: 1) develop and maintain training requiremem matrices for organizations; 2) identify personnel requiring indoctrination training; and 3) place work
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restriction on or remov employees from duty where training is deficient, j
Contrary to the above, as of May 5,1998, the organization / group managers failed to: 1) update j
(maintain) the training requirement matrices for the Production Support and Nuclear Safety J
Managers te include required initial and continuing nuclear criticality safety training as specified in
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the Safety Analysis Report; 2) identify the newly appointed Operations Manager as an individual requiring indoctrination (initial) mandatory training in the areas of technical safets requirements and nuclear safety upon appointment to the position on April 10,1998; and,3) place work restrictions on or remove the newly appointed Operations Manager and the temporary Maintenance Manager from duties on April 23,1998, where training was deficient.
USEC Response I.
Reasons for Violation The reason for the violation was due to an inadequate control process for ensuring that required training is correctly identified and appropriate work limitations issued for deficient training caused byjob transfers or reassignments. Specifically,1) guidance for developing and maintaining Training Requirements Matrices (TRM) was not provided to management to ensure required training was identified for a given job code,2) instructions were not provided to ensure a person's training status for a new position is reported and appropriate
. work limitations issued for incomplete initial or refresher training, and 3) adequate guidance was not provided to ensure that the appropriate level of management reviews the training status reports. Additional details for each of the specific causes are discussed in the L
following paragraphs:
GDP 98-2030 Page 2 of 4 l
1)
Guidance for develoning and maintaining TRMs was not provided to manacement.
i TRMs were developed during the spring of 1996 as a tool to provide line managers timely and accurate status of an individual's training against an approved set of requirements. Additionally, TRMs were designed to assist management with tracking required training and implementing the requirement of SAR section 6.6.1 which states, "Line Management is responsible for placing work restrictions or removing employees from duty where training is deficient." Over the past two years a majority of the TRMs have been modified or revised and, in some cases, a regulatory required training topic for coded positions had been erroneously removed (e.g., NCS for Managers training requirement for the Production Support Organization Manager TRM).
Section 5.4 of UE2-TR-TR1030, " Conduct of Training" procedure, identifies the responsibilities of organization / group managers to delimejob specific training needs and to develop, maiatain, and appmve a description of the organization's training requirements as identified in TRMr. The procedure further directs an Organization Training Representative (OTR) to assist organization managers in determining training / qualification requirements for personnel. However, the implementing plant procedure XP2-TR-TR1030, " Conduct of Training" does not contain clear action steps or criteria for evaluatmg such training needs and requirements nor does the
- procedure establish specific responsibilities or actions for line management to ensure training needs are being correctly identified.-
2)
Reassignment of nersonnel made without consideration of training status for new l
positiort In the case cited in the violation, where an organization manager was reassigned and assumed the duties as Operations Manager, the reassignment occurred without verifying current training status which created a condition where the manager was not trained in all aspece of the newjob and an associated work limitation was not 1
I issued to administratively restrict work in those areas where the manager had not been treined, i
.This is symptomatic of a deficiency in the plant training program whereby employees are moved to newjob positions without verifying current training status for the new position. While procedure UE2-TR-TR1030 identifies organization and group managers as responsible for identifying personnel requiring indoctrination training, the procedure does not contain specific instructions to describe how the l
management responsibility is to be implemented (i.e., criteria by which personnel are l
identified or action steps 'to notify Training of personnel reassignments).
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GDP 98-2030 Page 3 of 4 Furthermore, this procedure does not establish criteria for line management's role and responsibility in notifying Plant Training of personnel movements.
3)
Appropriate level of manacement was not nrovided the trainine status renorts Section 5.4 of procedure UE2-TR-TR1030, " Conduct ofTraining," requires Section Training Managers to notify line management of personnel who have not successfully completed initial training or who are past due for continuing training.
In this specific citation, the individual training status reports which identified training deficiencies, were provided directly to the individuals for review as opposed to their immediate manager. In effect, the Organization Training Representatives (OTR) and respective organization managers were pursuing resolution of the training deficiencies, rather than informing the Enrichment Plant Manager of the training status and issuing a work limitation while the training deficiencies were being resolved. Contributing to this oversight was a lack of rigor in the application of issuing work restrictions in that neither the training representative nor the incumbent Organization Managers took the required action for issuance of a work limitation by the Enrichment Plant Manager for the identified training deficiencies.
II.
Corrective Actions Taken and Results Achieved 1)
On May 7,1998, work restrictions were issued to the organization managers identified with deficient training.
2)
On May 8,1998, the Training Manager issued a directive to all OTRs and training database administrators, to ensure that an individual training requirements status report is generated whenever a change is made to a TRM or if a person is assigned to a new position or duty area. OTRs were directed to ensure that these reports were delivered to the cognizant manager to affect the issuance of individual work limitations for identified training deficiencies.
3)
On May 20,1998, the Training Manager issued a men orandum to all organization managers and OTRs directing the plant training group to confirm that all required work limitations were in place and to notify the organization managers of any discrepancies. This action was fully implemented on June 1,1998.
III.
Corrective Steps to be Taken l
1)
A Plant Training Advisory Board is being established. Once established, this board l
will review the TRMs for the General Plant Manager, Enrichment Plant Manager, l
and organization managers and revise the TRMs as required to ensure '. hat regulatory I
i GDP 98-2030 Page 4 of 4 training requirements are implemented. This action will be completed by August 17, 1998.
I 2)'
Roles and responsibilities for the Plant Training Advisory Board will be incorporated
- into the Conduct of Training Procedure, XP2-TR-TR1030 by September 24,1998.
3).
Organization Managers will review and revise as necessary, their organizational
' TRMs to ensure that regulatory training requirements are implemented and the necessary skills training have been correctly identified. The review of the TRMs will be com[deted as a plant by November 30,1998.
4)
Procedure XP2-TR-TR1030, " Conduct of Training," will be updated to include the responsibilities and appropriate action steps to correct those weaknesses identified with the training program. This action will be completed by September 24,1998.
- IV.
Date of Full Compliance USEC achieved full compliance on May 7,1998, when work restrictions were issued to the organization managers identified with deficient training.
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, f GDP 98-2030 Page1of1 List of Commitments Cover Letter l
To determine the effective of our corrective actions in improving the implementation of the PORTS plant training program, the PORTS Safety,. Safeguards, and Quality (SS&Q) organization will
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conduct an assessment of the effectiveness of our corrective actions. This assessment has been scheduled to begin in November 1998 and will examine the training deficiencies that led to the i
NOVs in irs97-011,98-05,98-08, and 98-10 and the corrective actions taken in response to these i
violations to determine if they are being effective in preventing recurrence.
' Enclosure 1 -
1)
A Plant Training Advisory Board is being established. Once established, this board will.
reviewLthe TRMs for the General Plant Manager, Enrichment Plant Manager, and I
I organization managers and revise the TRMs as required to ensure that regulatory training requirements are implemented. This action will be completed by August 17,1998,
-2)-
- Roles and responsibilities for the Plant Training-Advisory Board will be incorp*ated into the Conduct of Training Procedure, XP2-TR-TR1030 by September 24,1998.
q 3)
Organization Managers will review and revise as necessary, theli organizational TRMs to ensure that regulatory. training requiremen's are implemented.d the necessary skills t
training have been correctly identified. The review of the TRMs w' 1 be completed as a plant J
by November 30,1998.
4)
Phocedure XP2-TR-TR1030,' " Conduct of Training," will be updated to in.:lude the responsibilities and appropriate action steps to correct those weaknesses identified with the training program. This action will be completed by September 24,1998.
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