ML20248C285

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/98-07 on 980408

ML20248C285
Person / Time
Site:	07007001
Issue date:	05/28/1998
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	John Miller UNITED STATES ENRICHMENT CORP. (USEC)
References
70-7001-98-07, 70-7001-98-7, NUDOCS 9806020107
Download: ML20248C285 (1)

Text

May 28, 1998 Mr. J. H. Miller Vice President - Production United States Enrichment Corporation Two Democracy Center 6903 Rockledge Drive Bethesca, MD 20817

SUBJECT:

RESPONSE TO PADUCAH INSPECTION REPORT 70-7001/98007

Dear Mr. Miller:

This refers to your May 8,1998, response to the Unresolved item (URI) transmitted to you by our letter dated April 8,1998, with Inspection Report 70-7001/98007. We have reviewed your >

response and proposed actions and have no further questions at this time. Your corrective I actions will be examined during future inspections.

If you have any questions, please contact me at (630) 829-9603. i i

Sincerely, 1

Original Signed by )

9806020107 980528 PDR ADOCK 07007001 Patrick L. Hiland, Chief C PDR Fuel Cycle Branch i

l Docket No. 70-7001 l

cc: S. A. Polston, Paducah General Manager L. L. Jackson, Paducah Regulatory Affairs Manager J. M. Brown, Portsmouth General Manager S. A. Toelle, Manager, Nuclear Regulatory i Assurance and Policy, USEC l Paducah Resident inspector Office Portsmouth Resident inspec.or Office R. M. DeVault, Regulatory Oversight Manager, DOE J. C. Hodges, Paducah Site Manager, DOE bec w/itr dtd 05/08/98: Docket File PUBLIC IE-07 R. Pierson, NMSS P. Ting, NMSS W. Schwink, NMSS {

P. Harich, NMSS }

M. L. Horn, NMSS R. Bellamy, RI EJM, Ril (e-mail)

' rn- F. Wenslawski, RIV/WFCO

.110 u s i Greens DOCUMENT NAME: G:\SEC\ PAD 98007.RES To rceive a copy of this document. indicate in the box:"C" = Copy without enclosure "E". Copy with enclosure"N" = No copy OFFICE Rlli l C, Rlli l& l l NAME Blanchard:ib Ch8 Hiland f.t.9 DATE 05/a/98 05/>8'/98 OFFICIAL RECORD COPY L____________.________________________._

1 USEC A Clobal Energy Company May 8,1998 GDP 98-1031 U. S. Nuclear Regulatory Commission Attention: Document Control Desk l Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)

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 c'over letter transmitting this IR l (reference NRC letter dated April 18,1998, P.L. Hiland to J.H. Miller), NRC requested that USEC l I

provide a written response to this URI. Specifically, NRC requested that USEC 's response should

" Identify the c-iteria 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 Control Room activities, including the safety basis for necent changes to the first-line manager training ::quirements."

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,

[. .

1 Steve Polston I

General Manager )

Paducah Gaseous Diffusion Plant i

Enclosures:

As Stated cc: NRC Region III Office i NRC Resident Inspector - PGDP P.O. Box 1410, Paducah, KY 42001 Telephone 502-441-5803 Fax 502-441-5801 http://www.usec.com OfBces in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC M4(12 M l Ci DTS

g l ', *

.~4 Enclosure 1 May 8,1998 Page1of4 UNITED STATES ENRICHMENT CORPORATION (USEC)

REPLY TO UNRESOLVED ITEM (URI) 70-7001/98007-01 Restatement ofInformation Reauested bv NRC in Reolv to URI 98007-01 l . In the cover letter transmitting IR 70-7001/98007, NRC requested that USEC's response to URI 98007-01 should:

l l " Identify the criteria used to determine which staffare covered by the requirements of10 CFR 76.95 and the adequacy ofyour current training programfor cascade i 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 NR.C request is provided below:

USEC Response A. Identify the criteria used to determine which staff are coveted by the requirements of 10 CFR 76.95 10 CFR 76.95 states:

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 analy:m of thejobs to be performed; (b) Learning objectives derived from the analysis which describe desired performance after training; (c) Training design and implementation based on the leaming 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  !

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 l

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Enclosure 1 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).

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 program for casca' d e first-line managers that sunervise Area Control Room activities 1

PGDP SAR Section 6.6.14 " Manager Training" states:

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" Manager training is provided for those persons who manage the operations and maintenance personnel relied upon to operate, maintain, or modify Q l

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 Managem; 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 l l skills,just knomedge 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 KY/T-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 l

I Enclosure 1 May 8.1998 Page 3 of 4 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 KYfr-31, Rev.1, " Administrative Guide For The Cascade Operator Training Program." This course consists of approximately six weeks of classroom training providing a general overview of the operation of cascade systems. Several of these 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" (SAR 6.6.14).

I 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 l other regulatory requirements. Training on " Facility-specific TSRs, Stage Instrumentation, Seal Instrumentation, UF6 Detectors, High Pressure Operations, and Hi-Side Pressure Control" provides the necessary knowledge for the FLM to direct operations in that area.

Training on " Overview ofCascade Flows, Process Power Systems, Emergency Diesel Power Systems, Line Recorder Operation, Assay Machine Operation, Freezer Sublimer Operation, i 480 Volt Auxihary Power, Cascade Splits, Conduct of Operations Overview, etc." provides l 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.

1 The cascade FLM training program for supervising ACR activities is adequate. All 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 the operator. Certain FLMs may be designated to supplement minimum staffing, if needed.

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 chances to the first-line manacer trainine requirements.

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Enclosure 1 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 -

L clanfy training requirements for FLMs. No changes were 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/r-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.

n Enclosure 2 May 8,1998 Page1of1 l.

l 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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