IR 05000245/1993080
| ML20057E293 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/20/1993 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20057E294 | List: |
| References | |
| EA-93-130, NUDOCS 9310080294 | |
| Download: ML20057E293 (7) | |
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September 20, 1993
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Docket Nos. 50-245,50-336 and 50-423 License Nos. DPR-21, DPR-65 and NPF-49 i
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EA 93-130 l
Mr. John Executive Vice President - Nuclear Northeast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
l SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC INSPECTION REPORT NOS. 50-245,50-336, AND 50-423/93-80)
This letter refers to the NRC inspection conducted between April 14 through 23 and on May 12,1993, at the Millstone Nuclear Power Station, Units 1, 2 and 3, Waterford, Connecticut, to review the status and implementation of your licensed operator requalification
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training (LORT) program. The inspection report was sent to you on June 7,1993. During the j
inspection, two apparent violations of the NRC requirements were identified. In addition, the NRC also identified several deviations from commitments you made to the NRC.
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July 1,1993, an enforcement conference was conducted with you and members of your staff to l
discuss the apparent violations and deviations, their causes and your corrective actions.
The violations are described in the enclosed Notice, and involve: (1) numerous licensed operators, at Units 1 and 2, not fully completing the LORT program for the 1991 and 1992 requalification training period that ended on December 31,1992; and (2) the failure of the facility Nuclear Review Board (NRB), for the last six years, to either perform, or perform adequately, audits of training, retraining, qualification, and performance of the operations staff in Units 2 and 3, as required by the facility Technical Specifications and the Quality Assurance Plan commitment to ANSI 18.7-1976. The second violation was previously identified by the
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NRC in February 1993 for Unit 1. During the April-May inspection, the NRC determined that the NRB has not adequately audited these programs for any of the three units during the past six years. While some audits were performed during this time period that did cover certain aspects of these programs, auditing had not been performed in many essential program areas. This l
violation is particularly significant since there was a two year period in which the NRC found l
your licensed operator requalification program to be unsatisfactory at Unit 1.
CERTIFIED MAIL RETURN RECEIPT REOUESTED OFFICIAL RECORD COPY g:93130RE4.JGL
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Mr. john The causes of the first violation included lack of a clearly articulated policy on attendance at LORT classes, including classroom instruction, simulator sessions, and job performance tasks, which resulted in a situation where expectations for attendance by staff license holders were lower than those for attendance by operating crew license holders; inadequate priority given by management and staff to timely attendance; and ineffective monitoring of the program. The causes for the second violation included lack of formal procedural controls for NRB audits, and weak implementation of audit requirements.
In addition to the two violations, the NRC identified several deviations from your commitments made to the NRC in your October 7 and November 11, 1991 letters that addressed corrective actions for previously identified LORT program weaknesses, after your requalification program was found to be unsatisfactory in 1991. These deviations involved: (1) not completing management observations of operating crew performance on simulators at the required frequency; and (2) not developing written standards of performance for operating crews by Febraary 28,1992. The fact that these deviations continued after your requalification program i
at Unit I again was found unsatisfactory in 1992, indicates a lack of effective corrective action
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and inadequate management oversight and control of the requalification program at your facility.
The NRC's concern about the first violation is in no way diminished by the fact that staff, versus operating crew, license holders were responsible for much of the missed training. It is important that such individuals, some of whom supervised and managed the control room staffs, stay completely current with the required training, even though they are not regularly at the controls of the reactor. The NRC recognizes that the potential safety consequences of both violations was lessened by the fact that all the licensed operators who missed the training did demonstrate proficiency and overall knowledge in subsequent periodic and annual evaluations. Nevertheless, the NRC is concerned that despite your Unit I requalification training program being determined to be unsatisfactory by the NRC in 1991, the corrective actions taken at the time to improve the program were not effective in precluding the violations and did not prevent the program from being found unsatisfactory in 1992. Further, the corrective actions taken after the program was again found unsatisfactory in 1992 did not ensure that commitments made to the NRC were satisfactorily implemented.
l The violations and the deviations appear to be symptomatic of the significant program weakness that led to your requalification training program being found unsatisfactory in 1991 and 1992.
Therefore, despite the fact that the violations identified occurred during the two previous requalification training cycles, the NRC has determined that these weaknesses in the management j
oversight and control of the LORT program represent a significant regulatory concern. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, these violations have been categorized in the aggregate as a Severity Level III problem.
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.Mr. John,
The NRC recognizes that a : mber of corrective actions were taken to improve the LORT program after the September 1992 unsatisfactory requalification program and again when these i
violations were most recently identified.
These actions included improvements in the l
accountability, leadership, and partnership between the Operations and Training departments; a change in certain management personnel; addition of a human behavior specialist to the training staff; communication of management expectations on training and performance to the staff via a revised policy statement and meetings between management and staff; conduct of various workshops and training sessions with your staff; and the monitoring of performance on a periodic basis at the executive Vice President level. The above corrective actions, the positive appraisal of many aspects of your LORT program contained in the inspection report, and your frank, self-critical evaluation of the findings of our inspection which you presented at the enforcement conference are encouraging actions. The NRC emphasizes the importance of proper implementation and completion of these actions to preclude recurrence of the violations; and to ensure the requalification programs at your facilities in the future are not found to be i
unsatisfactory.
Notwithstanding those actions, to emphasize the importance of adequate and continuing management attention to the LORT, so as to assure all training requirements are completed in a timely manner, and appropriate audits are performed to verify completion (particularly in light of two successive unsatisfactory determinations by the NRC of your requalification program),
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I have been authorized, after consultation with the Dircetor, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operation and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for the Severity Level III problem.
The base value of a civil penalty for a Severity Level III violation or problem is $50,000. The
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escalation and mitigation factors set forth in the Enforcement Policy were considered. The base civil penalty was mitigated 50% because of your prompt and comprehensive corrective actions once these violations were identified. However, the base civil penalty was also escalated 50%
because the NRC identified the violations. The other adjustment factors in the Policy were considered and no further adjustment to the base civil penalty was considered appropriate.
Therefore, on balance, no adjustment to the base civil penalty resulted.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken ar.d any additional actions you plan to prevent recurrence. In addition to responding to the violations you should address the actions you have taken or will take to ensure commitments made to the NRC are properly implemented. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance OFFICIAL RECORD COPY g:93130RE4JGL
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.Mr. john with NRC regulatory requirements. You are requested to make copies of this action available
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to all individuals at your facility who hcid NRC licenses. While this action focuses on your overall administration of the licensed operator requalification program and the oversight of the program, each of your NRC licensed operators should be reminded that they are also individually responsible for compliance with the conditions of their licenses.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Sincerely, Onginal Signed By:
Thomas T. Martin Regional Administrator Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty
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. M r. john