|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N7591999-10-18018 October 1999 Provides Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20217M3861999-10-15015 October 1999 Provides Addl Changes to SAR Update Certificate Amend Request,Containing Changes That Resulted from re-evaluation of Autoclave head-to-shell O-ring Leakage Analysis Provided by DOE SAR Repts ML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217F6801999-10-12012 October 1999 Forwards Updated Paducah GDP Certificate Amend Requests at NRC for Approval ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20216J8931999-10-0101 October 1999 Forwards Copy of Security Incident Log & Associated Info for Sept 1999 ML20216J9081999-09-30030 September 1999 Forwards Revised Written Event Rept 99-10,rev 3,pertaining to Corroded Fire Sprinkler Heads Affecting Operability of high-pressure Fire Water (HPFW) Sprinkler Sys.No Commitment Contained in Rept ML20217M3701999-09-29029 September 1999 Submits bi-monthly Update on Progress of Mods to Upgrade Audibility of Criticality Accident Alarm Sys (Caas).Schedule for CAAS Audibility Upgrades Attached ML20212H1251999-09-24024 September 1999 Notifies NRC of Change in Regulatory Commitments Associated with Submittal Date for Update of Application SAR Chapter 3.Specifics of Commitment Changes of Listed ML20212H3801999-09-24024 September 1999 Responds to 990723 RAI Re 1999 Annual Update to Certification Applications ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20212H3721999-09-22022 September 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth GDPs That Were Generated During Month of Aug 1999.Without Encl ML20217J1211999-09-20020 September 1999 Submits Listed Comments on NRC Proposed Rule, Reporting Requirements for Nuclear Power Reactors ML20212D4291999-09-17017 September 1999 Forwards Required 30-day Written Event Rept Re Criticality Accident Alarm Sys Response Time in Bldg C-710.Encl 2 Contains Commitments Contained in Submittal ML20212D4231999-09-16016 September 1999 Informs That Review of Event Rept Er 99-12 Revealed Listed Two Statements Inadvertently Omitted from Document ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212D2361999-09-15015 September 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20211Q9951999-09-10010 September 1999 Forwards 30-day Written Rept ER-99-12,re Loss of Power to Autoclave Position 1 North & 1 South Process Gas Leak Detection (Pgld) in Bldg C-333-A.Caused by Electrical Short Circuit.Submitted Work Request 501636 for PI SEX-4 ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20216E4891999-09-0909 September 1999 Responds to Violations Noted in Insp Rept 70-7001/99-08. Corrective Actions:On 990602 Responsible Organization Manager Met with FP Engineer Performing Bldg Reappraisal & Made Clear Expectation for Prompt Reporting of Deficiencies ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211M3551999-09-0101 September 1999 Forwards Copy of Security Incident Log & Associated Info for Month of Aug 1999,IAW 10CFR95.57(b) ML20211K4041999-08-31031 August 1999 Forwards Responses to Remaining NRC Questions/Comments from 980601 & 0709 NRC RAIs Re SAR Update ML20211M7031999-08-30030 August 1999 Forwards Proprietary Rev 0 to Arming & Arrest Authority Security Plan for Paducah & Portsmouth Gaseous Diffusion Plants, for Review & Approval.Encl Withheld ML20211G9971999-08-26026 August 1999 Forwards Rev 2 to Written Rept Er 99-10,re Corroded Fire Sprinkler Sys in Bldg C-337 & C-333.Analysis of Root Cause Has Not Been Completed.Statistically Based Sprinkler head- Sampling Plan Has Been Completed & Approved ML20211D9751999-08-20020 August 1999 Forwards Rev 1 to Final Written Event Rept Er 99-11,re Unplanned Actuation of C-333-A Autoclave 1 North Autoclave Steam Pressure Control Sys (Aspcs) on 990623 ML20211F1761999-08-20020 August 1999 Requests That Paducah GDP facility,C-709 Lab Annex Bldg Be Added to List of Facilities to Be Exempted from CAAS Detection Coverage ML20211B5021999-08-20020 August 1999 Forwards Amend 2 to Certificate of Compliances GDP-1, Revising Paducah GDP Technical Safety Requirements Re Audibility Requirements for Criticality Accident Alarm Sys at Facility & Related Sections of SAR ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20211D5811999-08-16016 August 1999 Submits Monthly Update on Progress of Installation of Seismic Upgrade Mods to Bldgs C-331 & C-335 ML20210P7421999-08-10010 August 1999 Forwards Insp Rept 70-7001/99-08 on 990529-0719 & Nov. Violations of Concern Because Late Reporting of Problems with safety-related Equipment Could Negatively Impact Continued Availability of Equipment ML20210Q6061999-08-0909 August 1999 Forwards NRC Form 790 Classification Record Documents for Paducah & Portsmouth Gdps,Per 10CFR95.57.Records Were Generated During Month of July 1999.Without Encl ML20210L6571999-08-0404 August 1999 Informs That Staff Completed Initial Review of 990720 Application to Amend Coc GDP-1.Staff Anticipates Completing Review by 990930 ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210J1331999-07-30030 July 1999 Forwards Copy of Security Incident Log & Associated Info for Month of July 1999,per Reporting Requirements of 10CFR95.57(b) ML20210H3161999-07-30030 July 1999 Forwards Rev 1 to Written Event Rept ER-99-10,re Corroded Fire Sprinkler Heads Affecting Operability of HP Fire Water Sprinkler Sys in Bldg C-337 & C-333.Testing & Analysis of Root Cause & Corrective Actions Necessary Are Not Complete ML20210P7871999-07-29029 July 1999 Provides bi-monthly Update on Progress of Modifications to Upgrade Audibility of Criticality Accident Alarm Sys,In Response to NRC 981217 Request 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217G1731999-10-14014 October 1999 Requests Addl Info Re Applications Dtd 990924,requesting Amends to Cocs for Paducah & Portsmouth GDPs for Revised QA Programs.Encl Identifies Specific Info Needed.Info Should Be Provided within 30 Days ML20217G1811999-10-14014 October 1999 Forwards Reissued Amend to Coc for Usec Paducah Gdp.Coc Corrects Coc Issued on 991006.Amend Number & Effective Date Were Inadvertently Incorporated as 3 & 991026,instead of 4 & 991105 ML20217B2801999-10-0606 October 1999 Forwards Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted ML20217B3521999-10-0606 October 1999 Forwards Amend 3 to Certificate of Compliance GDP-1 to Revise Six Technical Safety Requirements Sections.Sections Are 2.1.4.17,2.1.4.8,2.3.4.1,2.3.4.4,2.3.4.16 & 3.10.4.b. Compliance Evaluation Rept Also Encl ML20212K8941999-10-0404 October 1999 Forwards Insp Rept 70-7001/99-10 on 990720-0907 & Forwards NOV Indicating That Some Personnel Were Incorrectly Granted Unescorted Access to Controlled Access Areas Without Having Necessary Specific Training ML20212F0981999-09-22022 September 1999 Forwards Insp Rept 70-7001/99-12 on 990830-0902.Purpose of Insp Was to Determine If Security Requirements Adequately Implemented & Included Review of Approved Plant Security Plan.No Violations Identified ML20212B6611999-09-15015 September 1999 Forwards Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted ML20212A5441999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-07 ML20212A5531999-09-14014 September 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/99-08 ML20211P2091999-09-0909 September 1999 Provides Staff Written Clarification of NRC Reporting Expectations of When Double Contingency Losses Should Be Reported to NRC IAW Bulletin 91-001, Reporting Loss of Criticality Safety Controls, & Suppl ML20211P3831999-09-0303 September 1999 Forwards Coc GDP-1,amend 3 & Coc GDP-2,amend 4 for Paducah (Pgdp) & Portsmouth (Ports) Gdps,Respectively by Revising Pgdp & Ports QAPs in Vol 3 of Respective Certificate Applications ML20211L6441999-09-0202 September 1999 Forwards Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20211B5021999-08-20020 August 1999 Forwards Amend 2 to Certificate of Compliances GDP-1, Revising Paducah GDP Technical Safety Requirements Re Audibility Requirements for Criticality Accident Alarm Sys at Facility & Related Sections of SAR ML20211A7011999-08-17017 August 1999 Forwards Copy of Final Amend to 10CFR76 for Info of Subcommittee.Final Rule Is Being Transmitted to Fr for Publication.Final Rule Will Amend Regulations That Apply to Paducah & Portsmouth Gaseous Diffusion Plants ML20210P7421999-08-10010 August 1999 Forwards Insp Rept 70-7001/99-08 on 990529-0719 & Nov. Violations of Concern Because Late Reporting of Problems with safety-related Equipment Could Negatively Impact Continued Availability of Equipment ML20210L6571999-08-0404 August 1999 Informs That Staff Completed Initial Review of 990720 Application to Amend Coc GDP-1.Staff Anticipates Completing Review by 990930 ML20211A7901999-08-0404 August 1999 Forwards Info Requested During Briefing by NRC Staff on 990726 Re NRC Interactions with Usec ML20210F9761999-07-28028 July 1999 Forwards Compliance Evaluation Rept Prepared to Support Amend of Coc GDP-1 Re Criticality Accident Alarm Sys Audibility.Notice of Amend Forwarded to Ofc of Fr Also Encl ML20210G0391999-07-26026 July 1999 Forwards Compliance Evaluation Rept & Fr Notice for Revised Qaps,Per 990212 Application ML20210D8181999-07-23023 July 1999 Submits Response to SA Toelle Ltr Dtd 990614, 10CFR76.68(a)(3) Decreased Effectiveness Reviews & RAI for Paducah & Portsmouth Transmittals of 1999 Annual Update to Certification Applications ML20210V3481999-07-16016 July 1999 Informs That Staff Completed Review of New Payment Surety Bonds (Psb) for Paducah & Portsmouth Gdps,Which Were Provided in .Cancelled Psbs for Liberty Mutual Insurance Co & Safeco Insurance Co of America,Encl ML20209F0611999-07-0909 July 1999 Forwards Insp Rept 70-7001/99-09 on 990621-25.No Violations Noted ML20196K0981999-07-0101 July 1999 Forwards Insp Rept 70-7001/99-07 on 990413-0528 & Nov. Violations Re Failure to Fully Evaluate Situation in Which Safety Sys Relied Upon to Mitigate Consequences of Accident Was Inappropriately Returned to Svc ML20196A1571999-06-17017 June 1999 Confirms Discussions Between K O'Brien & L Jackson to Conduct Meeting on 990630 to Discuss Apparent Violation ML20207F1311999-06-0404 June 1999 Responds to Requesting Copy of OI Rept 3-1998-033 Re Docket Potential Violation of 10CFR76.7 Concerning Employee Protection at Plant.Request Denied for Listed Reasons ML20207F2571999-06-0202 June 1999 Informs That NRC Disagrees with Usec Conclusion for Not re-opening Issue 2 of Compliance Plan,Since Proposed Change to Sarup Submittal Constitutes Major Rev to Operating Safety Bases Contained in Technical Safety Requirements ML20207E8201999-05-18018 May 1999 Refers to Investigation Case 3-1998-033 Re Apparent Violation Involving Usec & Lockheed-Martin Utility Service, Inc Mgt Discriminating Against Employee at Paducah Gaseous Diffusion Plant.Synopsis Encl.Without Encl 2 ML20206N3851999-05-12012 May 1999 Forwards Amend 1 to Coc GDP-1 & Amend 3 to Coc GDP-2 IAW 990316 Applications,Revising Paducah & Portsmouth Gaseous Diffusion Plants Technical Safety Requirement Sections 3.1.1 & 3.10.4 ML20206H5161999-05-0606 May 1999 Informs That NRC Will Not Be Able to Complete Review of Paducah Certificate Amend Request on Criticality Accident Alarm Sys Audibility Upgrade by 990507,as Indicated in NRC .Review Should Be Completed by 990630 ML20206E6481999-04-29029 April 1999 Forwards Insp Rept 70-7001/99-04 on 990224-0412.No Violations Noted ML20205R8041999-04-20020 April 1999 Forwards Partially Withheld Insp Rept 70-7001/99-201 Conducted on 990322-26.Scope & Results of Insp Summarized in Rept ML20205K4251999-04-0707 April 1999 Forwards Compliance Evaluation Rept for GDP-1 & GDP-2, Supporting Change in Title of Executive Vice President, Operations.Notice of Amend,Which Has Been Forwarded to Ofc of Fr for Publication,Encl ML20205K4481999-04-0707 April 1999 Forwards Addl Info Needed for Staff to Complete Review of 990112 Application for Amend Re Seismic Upgrades for Bldgs C-331 & C-335 at Paducah Gaseous Diffusion Plant ML20205J3021999-04-0202 April 1999 Forwards Insp Rept 70-7001/99-05 on 990322-25.No Violations Noted.Insp Included Review of Approved Paducah Physical Security Plan ML20204H9611999-03-18018 March 1999 Forwards RAI Re 990212 Applications Requesting Amends to Coc for Paducah & Portsmouth Gaseous Diffusion Plants for Revised QAPs ML20204C2721999-03-17017 March 1999 Ack Receipt of Application to Amend Coc GDP-1,re Criticality Sys Audibility Upgrades,Transmitted by Ltr . NMSS Anticipates Completing Technical Review by 990301 ML20204F2511999-03-17017 March 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-7001/98-18.Actions Will Be Examined During Future Insp ML20207M1081999-03-11011 March 1999 Discusses Us Enrichment Corp Participation in Round Robin Sample Exchange Program Administered by Nbl for Verfying Quality of Licensee U Destructive Measurement Sys.Invoices FL0237-99 & FL0238-99 for Amount Listed Encl ML20207K3011999-03-11011 March 1999 Forwards Insp Rept 70-7001/99-01 on 990113-0223.No Violation Noted.Continuing Problems with Some Plant Staff Understanding & Adherence to long-standing Plant Policies & Procedures Were Found ML20207J7641999-03-11011 March 1999 Requests Addl Info,Specified in Encl,Re 980918 Paducah Gaseous Diffusion Plant Seismic Hazard Analysis,Rev 2,for Staff Review ML20207G2231999-03-0505 March 1999 Discusses Insp Rept 70-7001/98-18 on 981201-990112 & Forwards Notice of Violation Re Failure to Maintain Control of Classified Matter at Paducah Facility ML20207B3361999-03-0202 March 1999 Ack Receipt of 990212 Applications for Amend to Cocs GDP-1 & GDP-2.Staff Has Completed Initial Administrative Rev of Applications & No Omissions of Deficiencies Were Identified. Staff Anticipates Completing Review by 990416 ML20203G4011999-02-0909 February 1999 Forwards Insp Rept 70-7001/99-02 on 990125-29.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20202G2501999-01-29029 January 1999 Discusses 990125 Meeting with Us Enrichment Corp in Lisle,Il Re Implementation Status of C/A Plans for Nuclear Criticality Safety Program & Basis for Proposed Changes to Completion Dates for Some C/A.List of Attendees Encl ML20202F0531999-01-29029 January 1999 Forwards Renewed Cocs for Paducah & Portsmouth Gaseous Diffusion Plants Located in Paducah,Ky & Piketon,Oh. Compliance Evaluation Rept Encl Also ML20202F5731999-01-26026 January 1999 Informs That Chairman Has Sent Rept to Congress on Gaseous Diffusion Plants,As Required by Aec.Rept Discusses Status of Health,Safety & Environ Conditions at Plants Located Near Paducah,Ky & Portsmouth,Oh for Period from 971001-980930 ML20202F0461999-01-26026 January 1999 Expresses Appreciation for 981104,comments on Draft Rept to Congress.Changes Were Made to Rept to Address All of Comments Except for One.Event Notification Summary Was Not Revised to Addl Info Requested ML20202F5591999-01-26026 January 1999 Expresses Appreciation for 981104,comments on Draft Rept to Congress.Future Repts Will Be Prepared in Conjunction with Recertification Reviews ML20199H1011999-01-15015 January 1999 Forwards Second NRC Rept to Congress,Covering Period from 971001-980930.Rept Discusses Status of Health,Safety & Environ Conditions at Gaseous Diffusion Plants Near Paducah,Ky & Portsmouth,Oh ML20199G2161999-01-14014 January 1999 Forwards Amend 23 to Coc GDP-1,revising TS Requirement 2.3.4.7 on Product & Tails Withdrawal Facilities Criticality Accident Alarm Sys 1999-09-09
[Table view] |
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
- a
I t
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:
l
" 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.
1 i
I J
L .
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.
I i
3
_ - _ _ _ _ - _ _ - - - - - - - - -