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September 8, 1999

Mr. J. N. AdkinsVice President - ProductionUnited States Enrichment CorporationTwo Democracy Center6903 Rockledge DriveBethesda, MD 20817

SUBJECT: RESPONSE TO INSPECTION REPORT 70-7002/99005

Dear Mr. Adkins:

This refers to your July 23,1999, response to our letter dated June 11,1999, with InspectionReport 70-7002/99005. We have reviewed your corrective actions and have no furtherquestions at this time. Your corrective actions will be examined during future inspections.

If you have any questions, please contact me at (630) 829-9806.

Sincerely,

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M e P. Phillips, Acting ChiefFuel Cycle Branch

Docket No. 70-7002Certificate No. GDP-2

cc: J. M. Brown, Portsmouth General ManagerP. J. Miner, Manager, Nuclear Regulatory Affairs, Portsmouth ;H. Pulley, Paducah General ManagerS. A. Toelle, Manager, Nuclear Regulatory

Assurance and Policy, USECPortsmouth Resident inspector OfficePaducah Resident inspector OfficeR. M. DeVault, Regulatory Oversight Manager, DOEE. W. Gillespie, Portsmouth Site Manager, DOE

DOCUMENT NAME: G:\SEC\POR99005.RES

To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy)

|C | | ;OFFICE RDF;) , jNAME # Milli [pli)#6 |DATE 09/f/69

OFFICIAL RECORD COPY

9909150155 99090s,

PDR ADOCK 07007002PDR

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bec w/ltr dtd 07/23/99: PUBLIC IE-07R. Pierson, NMSSP. Ting, NMSSW. Troskoski, NMSSP. Harich, NMSSR. Bellamy, RIEJM, Ril (e-mail)D. B. Spitzberg, RIVGreens w/o enci

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uly 23,1999GDP 99 7--

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U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, D.C. 20555-0001

Portsmouth Gaseous Diffusion Plant (PORTS) |Docket No. 70-7002 -

Response to Nuclear Regulatory Commission Concern in Inspection Report (IR) 70-7002

The subject IR contained two violations concerning failure to follow plant procedures. While the IRdid not require the United States Enrichment Corporation (USEC) to respond to these violations, theNRC requested USEC to respond to the " apparent generic weaknesses in your staff s knowledge andrigor ofimplementation of plant procedures that the individual violations indicate."

A multi-disciplined team was assembled which performed an extensive review of this issue. Theresults of their review and the corrective actions that USEC is taking to address this issue areprovided in Enclosure 1. Enclosure 2 lists the commitments contained in this submittal. Unlessspecifically noted, the corrective actions specified in the enclosures apply solely to PORTS.

Ifyou have any questions regarding this submittal, please contact Peter J. Miner at (740) 897-2710.

Sincerely,

W/

. Morris BrownGeneral ManagerPortsmouth Gaseous DifTusion Plant

Enclosures As Stated

cc. NRC Regional Administrator - Region IIINRCyesident InspectorfPORTSi #

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United States Enrichment CorporationPortsmouth Gaseous DifTusion PlantP.O. Box 628, Piketon, OH 45661

JUL 3 0 1999<

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Enclosure 1GDP 99-2034

Page1of4

UNITED STATES ENRICIIMENT CORPORATION (USEC)-

RESPONSE TO NRC CONCERN IN INSPECTION REPORT (IR) 70-7002/99005

1. Hackground Information

In IR 99005, the NRC issued two violations concerning failure to follow plant procedures.While the IR did not require the USEC to respond to these violations, the NRC requestedUSEC to respond to the " apparent generic weaknesses in your staff s knowledge and rigorofimplementation of plant procedures that the individual violations indicate." In response,USEC assembled a multi-disciplined team to investigate the site procedure noncompliances,determine the root causes of the noncompliances, and develop corrective actions. This teamconsisted ofindividuals from Maintenance, Operations, Engineering, Production Support, Siteand Facilities, Admhiistrative Support, Environmental Safety and Health, Work Control |andRegulatory AtTairs. Additionally, an individual from the Paducah Gaseous Diffusion Plantalso assisted in the investigation.

The objectives of the team were to determine in each organization the extent of the condition,the root causes and contributing causes using the Taproot * analysis methodology, and todevelop a corrective action plan to improve performance in this area. To investigate the |

) extent of this condition, trend reports were reviewed relating to failure to follow proceduresand inadequate procedures. These trend reports, along with their raw data, were then

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analyzed by the team members. Based on their review and analysis, the team identified the |following: '

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Over the past year (June 1,1998 to May 31,1999) there have been approximately'a

360 Problem Reports (prs) relating to failure to follow procedures. A review of thetrends for this area revealed there has been an increase in failure to follow procedures '

over the past year on a per month basis.

Approximately 80% of procedure violations identified over the past year relate to*

noncompliance with administrative procedures (which are primarily Information Useprocedures). The major categories of these procedure noncompliances were:- Radiation Protection / Radiological Control- Lockout /Tagout

Calibration-

In an earlier efTort to address procedure noncompliances (i.e., those identified in IR.

98005), site training was conducted at PORTS on June 17,1998 to emphasize theimportance of procedure compliance. During that training, managementconcentrated on adherence to work procedures (i.e., In-Hand and General Intentprocedures) and what to do if deficiencies in these procedures were discovered. A

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Enclosure 1GDP 99-2034

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review _of trend reports and raw data revealed that the number of work procedure <

violations have been reduced and the number of problem reports identifyinginadequate work procedures has increased. This indicates that the work force isaware of the importance of adhering to work procedures and identifying workprocedure deficiencies.

Approximately 66% of the root cause investigations conducted on failure to follow.

administrative procedures have resulted in cause codes of either " accountability" or;

" enforcement needs improvement," while an additional 25% have a cause code of" communication of procedure change and/or new procedures needs improvement."

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The nature of the procedure noncompliances is not limited to a few isolated.

procedures but is spread over numerous programs. -

Many of the PORTS XP2 procedures (i.e., those procedures that apply to more than.

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one site organization) do not have formal training modules and many that do are fconducted only on an "as required" basis. There is a tendency to rely heavily on '

required reading to communicate procedure revisions, which has been ineffective, inmany cases.

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Less than 10% of prs relating to failure to follow procedures have personnel or.

nuclear safety significance. Rather, they relate to administrative requirements suchas documentation or communication.

In order to gain additional insight into the problems associated with failure to followprocedures, a questionnaire was developed and interviews were conducted with over 80personnel in a variety of organizations. This additional investigation identified a number ofproblems which were reviewed and categorized into problem statements. The problem jstatements were then analyzed using the Taproot * analysis methodology.

!II. Causes of Procedure Noncompliance !

Based on the results of the reviews and the analysis described in Section I, the following root,

causes were identified: )

Administrative procedures are not properly communicated to the personnel.

responsible for implementing them and the requirements are not reinforced on an i

ongoing basis. Personnelinterviewed stated that they are not always familiar withthese type procedures, and in some cases, there is little or no continuing training. |

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LEnclosure 1

GDP 99-2034Page 3 of 4

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The procedure development process does not take skill-of-the-craft -into.

consideration, which sometimes results in procedures containing excessive detail.Additionally, the verification and validation process does not effectively utilizefeedback from personnel who use the procedure.

III. Corrective Actions

In February 1999, PORTS conducted a site-wide stand down regarding an adverse -.

trend in Human Performance. This stand down discussed recent human performanceerrors including procedure noncompliances. This stand down emphasized that i

personnel must clearly follow procedures and pay attention to detail.

Procedure Compliance at PORTS has been added to the " Adverse Trend" section of.

the PORTS Corrective Actions Program Report. This will first appear in the July1999 report. This performance indicator will be reviewed monthly by PORTS SeniorManagement to determine if effective corrective actions are being taken.

Organization Managers will review with their employees the requirements of those.

administrative procedures that their organization have experienced the mostnoncompliances with and the employee's responsibilities for following theseprocedures. This action will be completed by August 21,1999.

The procedure change process will be revised to incorporate the first time use.

concept into the validation process to gain feedback from the individuals doing thework. This action will be completed by September 30,1999.

Administrative procedures will be evaluated to identify those which present a risk to.

personnel or nuclear safety when a single violation of the procedure occurs. Thisaction will be completed by October 15,1999. Following this evaluation, actions willbe developed to add or revise training on these procedures, as appropriate.

The process for issuing / revising procedures will be revised to strengthen the process.

of training on administrative procedures. Specifically, this revision will addresscontinuing training for administrative procedures. This action will be completed byJanuary 15,2000.

. The procedure change process will be revised to require that a training summary be.

developed for procedure revisions. This training summary will highlight theprocedure requirements and changes. This training summary will be utilized whenconducting required reading or crew briefings for procedure training. This action willbe completed by January 15,2000.

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Enclosure 1GDP 99-2034

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A follow-up assessment will be initiated to evaluate the effectiveness of the above.

corrective actions to determine if the desired result is being achieved and to determineif additional actions are warranted. The PORTS Nuclear Regulatory Affairs Manager jwill advise the NRC Senior Resident Inspector of the results of this assessment. Thisaction will be completed by June 23,2000.

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Enclosure 2GDP 99-2034

Page1of2

- List of Commitments' ~

Organization Managers will review with their employees the requirements of those.

administrative procedures that their organization have experienced the most noncomplianceswith and the employee's responsibilities for following these procedures. This action will becompleted by August 21,1999.

The procedure change process will be revised to incorporate the first time use concept into.

the validation process to gain feedback from the individuals doing the work. This action willbe completed by September 30,1999.

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Administrative procedures will be evaluated to identify those which present a risk to*

personnel or nuclear safety when a single violation ~of the procedure occurs. This action'willbe completed by October 15,1999. Following this evaluation, actions will be developed toadd or revise training on these procedures, as appropriate.

The process for issuing / revising procedures will be revised to strengthen the process of.

training on administrative procedures. Specifically, this revision will address continuingtraining for administrative procedures. This action will be completed by January 15,2000. ,

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The procedure change process will be revised to require that a training summary be developed !.

for procedure revisions. This training summary will highlight the procedure requirements and !changes. This training summary will be utilized when conducting required reading or crewbriefings for procedure training. This action will be completed by January 15,2000.

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A follow-up assessment will be initiated to evaluate the effectiveness of the above corrective*

actions to determine if the desired result Is being achieved towards procedure compliance |and determine if additional actions are warranted. The PORTS Nuclear Regulatory Affairs i

Manager will advise the NRC Senior Resident Inspector of the results of this assessment. i

This action will be completed by June 23,2000. '

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' Regulatory commitments contained in this document are listed here. Other correctiveactions listed in this submittal are not considered regulatory commitments in that they are eitherstatements of actions completed, or they are considered enhancements to USEC's investigation,procedures, programs, or operations.

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