ML20247E539
| ML20247E539 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 05/08/1998 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-98-07, 70-7001-98-7, GDP-98-1031, NUDOCS 9805180375 | |
| Download: ML20247E539 (6) | |
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. A Global Energy Company May 8,1998 GDP 98-1031 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant IGDP) l Docket No. 70-7001 Reply to Inspection Report (IR) 70-7001/98007 Unresolved Item (URI)
The subject IR contained one URI involving inconsistencies between procedural and regulatory requirements for training and actual training provided. In the cover letter transmitting this IR (reference NRC letter dated April 18,1998, P.L.1-liland to J.II. Miller), NRC requested that USEC provide a written response to this URI. Specifically, NRC requested that USEC 's response should
" Identify the criteria used to determine which staff are covered by the requirements of 10 CFR 76.95 and the adequacy ofyour current training program for cascade first-line managers that supervise Area l
Control Room activities, including the safety basis for recent changes to the first-line manager training requirements."
Per NRC's request, USEC's response to the URI is contained in Enclosure 1. Commitments for this response are included in Enclosure 2. The corrective actions in this submittal apply solely to PGDP.
Any questions regarding this submittal should be directed to Larry Jackson at (502) 441-6796.
' cerely, L
Steve Polston General Manager Paducah Gaseous Diffusion Plant
Enclosures:
As Stated cc:
NRC Region III Office 1
l NRC Resident Inspector - PGDP 9805180375 900500
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!!O. Ilox 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com
- "'dA Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC L
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May 8,1998 Page1of4 UNITED STATES ENRICHMENT CORPORATION (USEC)
REPLY TO UNRESOLVED ITEM (URI) 70-7001/98007-01 Restatement ofInformation Reauested by NRC in Renly to URI 98007-01 In the cover letter transmitting IR 70-7001/98007, NRC requested that USEC's response to URI 98007-01 should:
" Identify the criteria used to determine which staffare covered by the requirements of10 CFR 76.95 and the adequacy ofyour current training programfbr cascade first-line managers that supervise Area Control Room activities, including the safety basisfor recent changes to thefirst-line manager training requirements. "
USEC's response to the above NRC request is provided below:
USEC Response A.
Identify the criteria used to determine which stafTare covered by the requirements of 10 CFR 76.95 10 CFR 76.95 states:
i A training program must be established, implemented, and maintained for individuals relied upon to operate, maintain, or modify the GDPs in a safe manner. The training program shall be based on a systems approach to training (SAT) that includes the following:
(a)
Systematic analysis of thejobs to be performed; (b)
Leaming objectives derived from the analysis which describe desired performance after training; (c)
Training design and implementation based on the learning objectives; (d)
Evaluation of trainee mastery of the objectives during training; (e)
Evaluation and revision of the training based on the performance of trained personnelin thejob setting.
Section 6.6, " Training," of the PGDP Safety Analysis Report (SAR) defines the training program for personnel who are covered by 10 CFR 76.95 (i.e., those personnel who are
" relied upon to operate, maintain, or modify the GDPs in a safe manner"). The SAR explains the training program and organization, trainee selection, initial training, continuing training, etc. The criteria for determining which staff are trained is delineated in the same section of l
the SAR (e.g., sections 6.6.2, " Trainee Selection," and 6.6.3.1, " Conduct of Needs/ Jobs Analysis and Identification of Tasks for Training"). Examples of personnel that meet the
May 8,1998 Page 2 of 4 criteria of 10 CFR 76.95 include, but are not limited to, Cascade Operators, Chemical Operators, and Maintenance Mechanics.
The SAR further states that it is the responsibility of Organization Managers to determine which training their personnel need to meet the criteria of 10 CFR 76.95. This is done by definingjob specific qualification requirements and putting these requirements in Training Development and Administrative Guides (TDAGs).
i Section 6.6.3 defines the SAT approach and describes the needs/ jobs analysis done to determine the various job positions / worker classifications. A facility-specific task list is developed from thejob classifications. This analysis identifies the training programs needed, from which learning objectives, lesson plans, and training guides can be developed. The task list represents the primary source for determining which staff are covered by the requirements of 10 CFR 76.
B.
Describe the adequacy of your current training nrogram for cascade first-line managers that sunervise Area Control Room activities PGDP SAR Section 6.6.14 " Manager Training" states:
" Manager training is provided for those persons who manage the operations and maintenance personnel relied upon to operate, maintain, or modify Q items or SSCs identified in NCSAs required to meet double contingency.
This training is not SAT-based but is designed, developed, and implemented to assist facility managers in gaining an understanding of the applicable procedures and practices specific to the gaseous diffusion process and facility... This training includes:
Management Skills Training; Initial and Continuing Process Safety Training for Managers; and Applicable elements of the Operations and Maintenance Initial and Continuing training."
First-Line Managers (FLMs) are not required to operate equipment as part of their normal responsibilities. Rather, FLMs are responsible for managing those individuals who are tasked with operating the equipment. Consequently, they do not need the specific operating skills,just knowledge and understanding of the operating systems. Operators, in addition to the initial Cascade Operations Basic Course, receive SAT-based technical skills training as required by section 6.6 of the SAR. This is specifically outlined in KYff-31, Rev.1. The FLMs also need and receive leadership training. This is provided in the form of a specific course just for FLMs. The FLMs also receive NCS training designed specifically for
May 8,1998 l
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1 managers. This gives them a knowledge perspective different from the operators and aids them in their management function.
FLMs supervising personnel who operate and maintain the ACR receive management and process safety training (e.g., training on Technical Safety Requirements, Nuclear Criticality Safety Requirements). Additionally, they receive the Cascade Operations Basic Course (Initial) training outlined in KY/f-31, Rev.1, " Administrative Guide For The Cascade Operator Training Program." This course consists of approximately six weeks of classroom I
training providing a general overview of the operation of cascade systems. Several of these
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system overviews are associated with the ACR. This combined training gives the manager the necessary "...tmderstanding ofthe applicable procedures andpractices specific to the gaseous diffusion process andfacility" (S AR 6.6.14).
l For those facilities for which they are assigned, FLMs are expected to provide direction, I
when necessary, for operators to stay within the boundaries of applicable TSR, NCSA, and other regulatory requirements. Training on " Facility-specific TSRs, Stage Instrumentation, i
Seal Instrumentation, UF6 Detectors, High Pressure Operations, and lii-Side Pressure Control" provides the necessary knowledge for the FLM to direct operations in that area.
Training on " Overview of Cascade Flows, Process Power Systems, Emergency Diesel Power Systems, Line Recorder Operation, Assay Machine Operation, Freezer Sublimer Operation, 480 Volt Auxiliary Power, Cascade Splits, Conduct of Operations Overview, etc." provides the necessary knowledge for the FLM to provide oversight on ACR activities. The training described above is provided in the six-week basic classroom course discussed previously.
The cascade FLM training program for supervising ACR activities is adequate. All l
applicable regulatory requirements are being met by the existing program elements. This is explained in detail by the discussion provided above. More importantly, we have no operational history which indicates a deficiency or inadequacy in the technical supervision of operators. Years of safe operation indicate the training program is on target.
There are some situations where an FLM would be required to receive the same training as i
the operator. Certain FLMs may be designated to supplement minimum staffing, if needed.
l Many managers are currently trained to that level, not as a requirement, but as a best management practice. This allows for supplementing minimum staffing and assisting in the training and evaluation of personnel (personnel who perform OJT training / evaluation, must first be trained on the task). USEC plans to continue this practice for FLMs who may be needed to supplement minimum staffing. This action is not a regulatory requirement but may be included in future revisions to the TDAG.
C.
Describe the safety basis for recent changes to the first-line manager training requirements.
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May 8,1998 Page 4 of 4 Revision 1 of KY/T-31, " Administrative Guide For The Cascade Operator Training Program," became effective on February 10, 1998. The concern raised in the NRC Inspection Report was that KY/T-31, Rev. O, contained apparent requirements for FLMs which were deleted from Rev.1. The purpose of the revision was to reformat the TDAG and clanfy training requirements for FLMs. No changes svere made to the requirements or intent of the TDAG. Therefore, no safety basis is needed for an administrative or editorial change.
However, USEC recognizes that further clarification is needed for FLM training requirements in KY/T-31. Therefore, by August 31,1998, USEC will either revise KY/T-31,
" Administrative Guide For The Cascade Operator Training Program (TDAG)," or a new Administrative Training Guide will be developed, which more clearly defines the training requirements for Cascade Operations FLMs.
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l May 8,1998 Page1of1 UNITED STATES ENRICHMENT CORPORATION (USEC)
LIST OF COMMITMENTS By August 31,1998, USEC will either revise KY/T-31," Administrative Guide For The Cascade Operator Training Program (TDAG)," or a new Administrative Training Guide will be developed, which more clearly defines the training requirements for Cascade Operations FLMs.
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