ML20236V936
| ML20236V936 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 07/28/1998 |
| From: | Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| 70-7002-98-08, 70-7002-98-8, NUDOCS 9808040295 | |
| Download: ML20236V936 (3) | |
Text
July 28, 1998 Mr. J. H. Miller Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
RESPONSE TO PORTSMOUTH INSPECTION REPORT 70-7002/98008
Dear Mr. Miller:
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This refers to your June 29 and July 24,1998, responses to the Notice of Violatlan (NOV) transmitted to you by our letter dated May 29,1998, with inspection Report 70-7002/98008. We have reviewed your corrective actions and have no further qt.cstions at this time. Your corrective actions will be examined during future inspections.
If you have any questions, p; ease contact me at (630) 829-9603.
Sincerely, Original Signed by D. Hartland for Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 70-7002 cc:
J. M. Brown, Portsmouth General Manager D. B. Waters, Acting Manager, Portsmouth Regulatory Affairs H. Pulley, Paducah General Manager S. A. Toelle, Manager, Nuclear Regulatory Assurance and Policy, USEC Portsmouth Resident inspector Office Paducah Resident inspector Office R. M. DeVault, Regulatory Oversight Manager, DOE j
E. W. Gillespie, Portsmouth Site Manager, DOE bec w/itrs did 06/29/98 & 07/24/98: Docket File l
PUBLIC IE-07 I
R. Pierson, NMSS P. Ting, NMSS W. Troskoski, NMSS P. Harich, NMSS araz, WSS 9808040295 980728 PDR ADOCK 07007002 R. Bellamy, RI C
PDR EJM, Ril w/o encls (e-mail)
D. B. Spitzberg, RIV/WCFO l
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Greens w/o encls DOCUMENT NAME: G:\\SEC\\POR98008.RES Te receive a copy of this document. Indicate in the box:"C" = Copy without enclosure "E* = Copy with enclosure *N'= No copy OFFICE Rlli lC Rlli lc NAME Kniceley:ib 550 Hiland 9tN 5 <-
DATE 07 @ 98
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07/t1/98 OFFIC/AL RECORD COPY l
i 06430/98 TUE 07:50 FAI 740 897 4541 PORTS NRA
@002 USEC A Global Energy Company June 29,1998 GDP-98-2030 i
United States Nuclear Regulatory Commission i
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 4
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 affirmed in NRC letter dated June 16,1998 (reference 2), USEC had planned to include in this submittal those actions that QSEC is taking to reduce the present number of training delinquencies at PORTS while ensuring compliance with the Safety Analysis Report and the Technical Safety Requirements. 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.
Thettfore, per discussion between Dave Waters of USEC and Rob Krsek ofNRC on June 29,1998, 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 impiove the plant training program.
Furthermore, in order to determine the effectiveness of our corrective actions, the PORTS Safety, 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.
P.O. Box 800, Portsmouth, OH 45661 Telephone 614-897-2255 Fax 614-897 2644 http://wwwusec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
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cawwe United States Nuclear Regulatory Commission June 29,1998 j
ODP 98-2030 Page Two If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely, I
t orris B eneral Manager Portsmouth Gaseous Diffusion Plant
Enclosures:
As Stated cc:
NRC RegionIII Office NRC ResidentInspector - PORTS l
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United States Nuclear Regulatory Commission June 29,1998 ODP 98-2030, Page Three References 1.
USEC letter ODP 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 ofViolation."
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United States NucIcar Regulatory Commission June 29,1998 l
ODP 98-2030, Page Four l
Distribution i
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J. Adkins, HQ D. Couser, PORTS I
J. Dietrich, LMUS I
L. Fink, PORTS L. Jackson, PODP J. Labarraque, PODP j
P. Musser, PORTS l
.H. Pulley, PGDP A. Rebuck, HQ D. Scott, HQ S. Toelle, HQ D. Waters, PORTS R. Wells, HQ I
File:h\\nra\\ letter.nrc\\ ports \\gdp98-2.030 REF:/CB l
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i GDP 98-2030 Page1of4 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98008-01 Restatement of Violation Technical Safety Requirement 3.9.1 requires, in part, that written procedures shell be implemented for activities described in Appendix A of the bafety Analysis Report Section 6.11. "Procedur:. "
Appena A of Section 6.11 deu ;bes 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 requirement matrices for organizations; 2) idecify personnel requiring indoctrination training; and 3) place work restriction on or remove employses from duty where training is deficient.
Contrary to the above, as of May 5,1998, the organization / group managers failed to: 1) update (maintain) the trairing requirement matrices for the Production Support and Nuclear Safety Managers to include required initial and continuing nuclear criticality safety training as specified in the Safety Analysis Report; 2) identify the newly appointed Operations Manager as an individual req'Aing indoctrination (initial)f randatory training in the areas of technical safety 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 I
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 l
and maintaining Training Requirements Matrices (TRM) was not provided to management l
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 ',evel of management reviews the training status reports. Additional details for each of the specific causes are discussed in the following paragraphs:
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1 GDP 98-2030 Page 2 of 4 1)
Guidance for develoning and maintaining TRMs was not provided to manazement.
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
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(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 oforganization/ group managers to definejob-specific training needs and to develop, maintain, and approve a description of the organization's training requirement as identified in TRMs. 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 ofTraining" does not contain clear action steps or criteria for evaluating 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)
Reassismment of nersonnel made without consideration of traininc stuus for new
- position, 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 aspects of the newjob and an associated work limitation was not issued to adminktratively restrict werk in those areas where the manager had not been trained.
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 l
training, the procedure does not contain specific instructions to describe how the management responsibility is to be implemented (i e., criteria by which personnel are identified or action steps to notify Training of personnel reassignments),
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ODP 98-2030 Page 3 of4 Furthermore, this procedure does not establish criteria for line management's role and responsibility in notifying Plant Training of personnel movements.
3)
Annronriate level of mannaement was not nrovided the trainin stanm reoorts Section 5.4 ofprocedure UE2-TR-TR1030, " Conduct ofTraining," requires Section Training Managers to notify line management of personnel who have not successfbily completed initiel 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 Orgaruzation 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 t< the organization managers identified with defident 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 nanager to affect the issuance of individual work limitations for identifNi training deficiencies.
3)
On May 20,1998, the Training Manager issued a manorandum to all organization managers and OTRs directing the plam 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 1)
A Plant Training Advisory Board is being established. Once established, this board will review the TRMs for the General Plant Manager, Enrichment Plant Manager, and organization managen and revise the TRMs as required to ensure that regulatory i
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L GDP 98-2030 Page 4 of 4 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 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 ensum that regulatory training requirements are implemented and the necessary skills training have been correctly identified. The myiew of the TRMs will be completed as a plant by November 30,1998.
4)
Procedure XP2-TR-TR1030, " Conduct ofTraining," will be updated to include the responsibilities and appropriate action steps to correct those weaknesses identified with the training program. This action will be cumpleted 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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eww ODP 98-2030 Page1of1 List of Commitments Cover Letter 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 conduct an assessment of the effectiveness of our corrective actions. This assessment has bee scheduled to begin in November 1998 and will examine the trair*ng deficiencies that led to the NOVs in irs97-011,98 05,98-08, and 98-10 and the corrective acions taken in response to these violations to determine if they are being effective in preventing recurrence.
hiosure 1 1)
A Plant Training Advi90ry Board is being established. Once attblished, this board will review the TRMs for the General Plant Manager, Enrichment Plant Manager, and organization managers and revise the TRMs as required to ensure that regulatory training requirements are implemented. This action will be ccmpleted by August 17,1998.
2)
Roles and responsibilities for the PJant Training Advisory Board will be incorporated into the Conduct of Training Procedure, XP2-TR-TR1030 by Sept. mber 24,1998.
3)
Organization Managers will review and revise as necessary, their organizational TRMs to ensum that regulctory training requirements are implemented and the necessary skills training have been cornetly identified. The review of the TRMs will be completed 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.
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j UNITED STATES ENRICHMENT CORPORATION l
PoRTsMouTH GAsteus DirruSION PLANT NucLIAR RcoutAroRY AFFAIRS Orrict
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Tus TRANSMITRAL consists or rAoes FACSIMILE: (740)897-454i VERIFICATION: (740)697-2575 O
LISA dAMMIEL (30 l } 504-321 O O
MARK LOMsARD i
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ANY MAIN D
STEVE ROUTH l
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MARK SMITH O
STEVE TOELLE D
Russ WELLS D
D DON SsLVERMAN (202)407-7170 l
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. JOHN DIETRICH (3011571-8278 l
D LARRY dACKsON (502) 44 l *0796 O
TY MILLER D
RANDALL DEVAULT (423)241 4708 j
ORGANt%ATION MANAGEMs O GCNERAL MANAGER 2909 r D OPERATIONS 37I9 l
D ENetictiMENT PLANT 2705 O PLANT SHIFT SUPERINTENDENTS 3793 D ADMINISTRATIVE SUPPORT 4790 D PMODUCTION SUPPORT 41Ol D CUSTOMER GERVicE 4785 OSS&Q 2644 l
D ENGINEEMINo 3785 O SITE & FActLmEs SUPPORT 4640 l
D ES&H 3422 O TRAININo & PROCEDURES 3788 J
O MA NTENANCE 4540 0 WORK CONTROL 3720 O MATERLALs 2517 OTHER VRob ErnK D
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FROM:
MESSAGE:
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j USEC A Global Energy Company July 24,1998 1
GDP-98-2037 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Portsmouth Gaseous Diffusion Plant (PORTS)
Docket No. 70-7002 Supplemental 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 (GDP-98-2030 dated June 29,1998) included a commitment to provide a supplemental response to address additional corrective actions that USEC is taking to improve the plant training program. provides corrective actions previously communicated in earlier responses and additional actions being taken to improve our training program. Enclosure 2 lists only the commitments not previously communicated in USEC response to NOVs cited in irs97-011,98-005, and 98-008. Unless specifically noted, the corrective actions specified in each enclosure apply solely to PORTS.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
l Sincerely,
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J. Morris Brown l
General Manager Portsmouth Gaseous Diffusion Plant I
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Enclosures:
As Stated cc:
NRC Region Ill Office NRC Resident Inspector - PORTS l
l P.O. Box 800, Portsmouth, OH 45661 Telephone 740 897-2255 Fax 740-897-2644 http://www.usec com Offices in Livermore. LA Paducah, KY Portsmouth, OH Washington, DC g 8 7, g) c_ _ _ - _ - _.._
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GDP 98-2037 Page1 of4 UNITED STATES ENRICIIMENT CORPORATION (USEC)
SUPPLEMENTAL REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98008-01 l
Issue Summarv i
On December 5,1998, NRC issued IR 70-7002/97011 which contained a violation involving three front line managers who performed work under procedures containing ne.: lear criticality safety
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approvals and had not received nuclear criticality safety (NCS) refresher training as required by procedure.
On May 17,1998, NRC issued a violation (IR 70-7002/9800Q, regarding the failure to revise on-the-job training modules when procedure changes necessitated thct training modules also be revised.
On May 29,1998, NRC issued a violation (IR 70-7002/98008), conceming the failure to update the f
training requirements matrices and identify mandatory training needs for newly appointed managers.
j On June 16,1998, NRC issued a violation (IR 70-7002/98010), concerning the failure to place work restrictions on several emergency squad members whose training was deficient in that they did not pass self-contained breathing apparatus training.
USEC has determined the root causes for each of the above violations and has developed corrective actions to correct the deficiencies which caused the violations. However due to the complexities associated with the training program as a whole, USEC required additional time to understand the dynamics associated with the overall training program which has limited the overall training effectiveness. The following response details the actions PORTS has taken and those actions to be taken to correct the backlog of training deficiencies and to improve the overall training performance.
I.
Reasons for Training Deficitacies Tne weaknesses identified with the PORTS training program were caused by managers not fully understanding and enforcing training requirements. Additionally, these weaknesses l
were due to an inadequate control process for ensuring that required training is correctly i
i identified and appropriate work limitations issued for deficient training. Specifically, managers did not enforce the requirements for personnel to complete their required training in a timely manner and did not issue work restrictions for personnel with deficient training.
In addition, the Training Department's guidance for implementing training program requirements was inadequate.
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j GDP 98-2037 Page 2 cf 4 II.
Corrective Actions Taken and Results Achieved 1)
On May 8,1998, the Training Manager issued a directive to all Organizational l
Training Representatives (OTRs) and training database administrators, to ensure that individual training requirements status report is generated whenever a change is made to a Training Review Matrix (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 l
cognizant manager to affect the issuance of individual work limitations for identified training deficiencies. (70-7002/98008) 2)
On May 20,1998, the Training Manager issued a memorandum to all organization managers and OTRs directing trainers and managers 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. (70-7002/98008) 3)
On June 29,1998, the General Manager issued a memorandum directing the Organizational Managers to verify the training status of personnel prior to being I
transferred to another job and that required training should be completed prior to
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movement whenever possible. This action was designed to reinforce the Training Mangers directive stated in item 2 above.
l III.
Cnrrective Actions to be Taken 1)
A Plant Training Advisory Board is being established at PORTS to improve i
awareness and compliance with training requirements. Once established, this board will review the TRMs for the General Plant Manager, Enrichment Plant Manager, and organization managers and revise the TRMs as required to ensure that regulatory training requirements are implemented. Some of the responsibilities of this board are i
listed below:
Ensure that management provides clear direction and is effectively involved with plant training activities.
Ensure line and training staff are systematically using training to improve performance.
Evaluate the mix and application of plant wide training resources and their application.
Ensure that a systematic process is used to determine training requirements.
Ensure a systematic evaluation of training completeness and effectiveness is conducted and that evaluation results are used to modify content and conduct of training programs.
Provide programmatic reviews of problem report trends related to training.
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GDP 98-2037 Page 3 of 4 Establish, monitor and guide actions to improve performance related to Training Performance Indicators i
The Training Advisory Board will be established by August 17, 1998. (70-7002/98008) 3)
To augment the Plant Training Advisory Board, Organizational Training Review Groups will be established via a charter to pride the following services to enhance the overall training program.
Ensure that the Systems Approach to Training (SAT) process is used to review task list modifications and to determinejo' performance requirements for SAT based training programs.
Review and revise as necessary, the Training Development and Administrative C.ldes (TDAGs) for SAT based training programs.
Conduct training program evaluations measuring training completeness and effectiveness.
Ensure that evaluation results are used to modify content and conduct of training programs.
Review and approve requalification training schedules and content for upcoming continuing training.
Ensure that the training program content provides the participant with the knowledge and skills needed to perform functions associated with the position for which the training is being conducted Review Training Development / Change Requests to provide a prioritization of need to Plant Training.
The Organizational Training Review Groups will be established by September 30, 1998 I
4)
Procedure XP2-TR-TR1030, " Conduct of Training," will be updated w include the i
responsibilities and appropriate action steps to correct those weaknesses identified l
with the training prograni. This action will be completed by September 24,1998.
(70-7002/98008) 5)
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 and necessary l
revisions of the TRMs will be completed by November 30,1998. (70-7002/98008) l I
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GDP 98-2037 Page 4 of 4 To increase the number e available resources to meet training needs, Plant training 6) r will reassign technical trainers to augment the maintenance training staff. In l
addition, Line management from Maintenance and Site & Facilities Support will l
provide additional personnel from their respective organization tobe trained as OJT instructors. This action will be completed by August 15,1998.
7)
Plant Training will coordinate with line management and work control to develop l
schedules for OJT and Classroom training necessary to reduce identified training l
deficiencies. Line management from Maintenance, Site & Facilities Support, and Operations will begin implementing the training schedule by August 31,1998.
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To determine the effectiveness of our corrective actions in improving the implementation of the PORTS plant training program, the PORTS Safety, Safeguards, and Quality (SS&Q) organization will conduct a follow-up assessment to begin in November 1998. (70-7002/98008) l l
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l GDP 98-2037 l
Page1ofI List of Commitments l
1)
To augment the Plant Training Advisory Board, Organizational Training Review Groups will
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be established via a charter to provide the following services to enhance the overall training l
program. This action will be completed by September 30,1998.
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To increase the number of available resources to meet training needs, Plant training will reassign technical trainers to augment the maintenance training staff. In addition, Line management form Maintenance and Site & Facilities Support will provide additional j
personnel from their respective organization to be trained as OJT instructors. This action will be completed by August 15,1998.
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3)
Plant Training will coordinate with line management and work control to develop schedules for OJT arid Classroom training necessary to reduce identified training deficiencies. Line management from Maintenance, Site & Facilities Support, and Operations will begin j
implementing the training schedule by August 31,1998.
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