ML20249B465
| ML20249B465 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 06/17/1998 |
| From: | Jonathan Brown UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7002-98-05, 70-7002-98-5, GDP-98-2025, NUDOCS 9806230182 | |
| Download: ML20249B465 (5) | |
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o V USE.C
. A Global Energy Company June 17,1998 GDP-98-2025 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) 70-7002/98005 Notice of Violation (NOV)
The subject Inspection Report (IR) contained a violation involving a failure to revise on-the-job training modules when procedure changes necessitate the training modules to be revised. USEC's response to this violation is provided in Enclosure 1. Enclosure 2 lists the commitments made in this report. Unless specincally noted, the corrective actions specined in each enclosure apply solely to PORTS.
USEC recognizes that weaknesses in the execution of procedural requirements contributed to this violation and notes that the deficiencies identined in this violation are similar to that identined in IR 97011 and 98008. Accordingly, in our response to IR 98008, which is due to NRC by June 29, 1998. USEC will address actions we are taking to improve our performance in this area.
If you have any questions regarding this submittal, please contact Dave Waters at (740) 897-2710.
Sincerely, J. Morris rown General Manager I
Portsmouth Gaseous Diffusion Plant g(Jb
Enclosures:
As Stated cc:
NRC Region III Of6ce NRC Resident Inspector-PORTS 9906230182 990617 I,
PDR ADOCK 07007002 C
PDR;
.' O P.O. Box 800, Portsmouth, OH 45661
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Telephone 614-897-2255 Fax 614-897-2644 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC
GDP 98-2025 Page1of3 UNITED STATES ENRICIIMENT CORPORATION (USEC)
REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98005-10 Restatement of Violation Technical Safety Requirement 3.9.1. requires, in part, that written procedures shall be implemented for activitic described in Safety Analysis Report Section 6.11.4.1, and listed in Appendix A, '.o Safety Analysis Report, Section 6.11.
Appendix A, to Safety Analysis Report, Section 6.11 requires, in part, that training activities shall be covered by written procedures.
Procedure XP2-TR-TR1030, " Conduct of Training," Revision 0, Change C, dated December 31, 1997, Section 6.6.1.J," Developing and Approving Lesson Plans and Training Guides, " requires, in part, that the training group revise training modules when necessitated by procedure changes.
Contrary to the above, prior to April 8,1998, the training group did not revise 16 on-the-job training modules when procedure changes necessitated the training modules be revised. Specifically, the training modules which were available for use and not revised after procedural changes were made are as follows: MTM02.07.21; MTM02.12.20; MTM02.07.10; MTM09.20.38; MTM09.20.42; MTM09.20.32; MTM09.20.34; MTM09.20.43; MTM09.20.31; MTM09.20.30; MTM09.20.29; MTE08.01.10; MTIl 6.19.30; MT109.03.30; MT108.01.30; and, MT101.01.44.
USEC Response I
I.
Reasons for Violation The reason for the violation was due to lack of enforcement of the procedure requirements of several implementing procedures which resulted in a breakdown in communications between the Procedures and Training group. Specifically, procedure UE2-PS-PS1031;"UE l
Policy and Procedure Control Process," requires the procedure writer to communicate procedure changes to the Training group by sending an informational copy of the procedure development activity to the applicable Training Representative of the affected area (s). The j
Training Representative then determines if there are any existing training guides / modules that need to be developed, revised, or deleted because of such changes. Additionally, procedure XP2-PS-PS1033; " Procedure Change Process," directs the procedure writer to ensure a Training Summary Form is completed and the affected pages of the changed procedure forwarded to the applicable organizational Training Representative. Because this procedura requirement was not strictly enforced, the Procedures group did not forward l
I.
change information to the Training group. Therefore, the Training Representative was not I-
GDP 98-2025 Page 2 of 3 aware of the procedure changes when they were effective and would not otherwise have learned of the changes until the three year review of the training guide / module was performed.
Contributing to the vio;ation was an ambiguous procedure. Specifically, procedure XP2-TR-TR1030; " Conduct of Training," does not specify or provide clear guidance as to how a periodic review of training guides / modules should be performed.
II.
. Corrective Actions Taken and Results Achieved 1.
On April 8,1998, the Training Manager issued a cessation of training using the "OJT Guide" module format until verification of current source documents was completed and the extent of the identified condition determined.
1.
The review, as noted above, identified 83 of 104 maintenance OJT guides which had not been updated to reflect the latest version of the procedures (this includes the 16 OJT guides identified in the cited violation). Fifty-two of the 83 guides required only a pen and ink change to denote the procedure change while the remaining 31 OJT guides will require a more detailed review or revision prior to being released for use.
As of April 14,1998, the 83 identified OJT guides were placed on administrative hold and removed from active status until the OJT guides can be revised. This specific action prevents crediting plant personnel with training which have not been revised to reflect the most current procedures.
2.
Refresher training and a review of management expectations for procedure use was conducted with procedure writers and training personnel. These actions were completed on June 15,1998. The training was designed to ensure procedure writers and trainers have a full understanding of the importance ofcommunicating procedure changes to Training. In addition, the training stressed the importance and benefits of reviewing a training module prior to conducting a class or OJT activity.
3.
.To provide clear guidance as to how a periodic review should be performed,
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classroom training was provided to training personnel on the systems approach to training requirements for training guide / module reviews and revisions. This action was completed on June 15,1998.
.III.
Corrective Steps to be Taken USEC will revise procedure XP2 TR.TR1030;" Conduct ofTraining," procedure to
' describe the process for conducting training guide / module reviews and revisions.
This action will be completed by July 1,1998.
4 Enclosure I GDP 98-2025 l ':
Page 3 of 3 W.
- Date of Full Compliance
. USEC achieved full compliance on April 14,1998, when the cited OJT guides were removed
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from the active list to prevent their use.
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GDP 98-2025 Page1of1 UNITED STATES ENRICilMENT CORPORATION (USEC)
I REPLY TO NOTICE OF VIOLATION (NOV) 70-7002/98005-10 List of Commitments NOV 70-7002/98005-10 USEC will revise procedure XP2-TR-TR1030;" Conduct ofTraining," procedure to describe the process for conducting training guide / module reviews and revisions. This action will be completed by July 1,1998.
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