ML20045A842
| ML20045A842 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/07/1993 |
| From: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20045A843 | List: |
| References | |
| EA-93-130, NUDOCS 9306150055 | |
| Download: ML20045A842 (7) | |
See also: IR 05000245/1993080
Text
T
5
e
Docket Nos. 50-245
50-336
50-423
Mr. John F. Opeka
Executive Vice President - Nuclear
Northeast Nuclear Energy Company
P. O. Box 270
Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT:
COMBINED TEAM INSPECTION REPORT NOS. 50-245/93-80,
50-336/93-80, 50-423/93-80
Region I conducted an announced safety team inspection led by Mr. R. Conte of this office
during the period April 14 - 23 and on May 12,1993, at the three Millstone Units. The
enclosed report discusses the findings and observations the team made during the weeks'
inspection. The specific objectives of this inspection were to: assess the licensed operator
requalification training (LORT) programs at the three Millstone units with respect to a
systems approach to training (SAT) with emphasis on Unit 1; independently assess the root
cause of the repetitive unsatisfactory determination of LORT for Millstone 1 in
September 1992; and, on a limited scope basis, identify common and divergent strengths and
weaknesses in MP-2 and 3 LORT with reference to the MP-1 program in light of the 1991
and 1992 unsatisfactory program results. The unit LORT programs are to provide a
substantial contribution to safe operations at the station.
A number of positive areas were noted in the current LORT programs for all three units at
the Millstone Station. A program strength was noted for Unit 1 on the use of the advanced
trainer classroom.
However, divergent LORT program and procedural implementation for each unit was noted
>
for common policies and principles and resulted in program weaknesses isolated to specific
,
units. Also, three program weaknesses were identified that were common to all three units.
You are requested to provide your perspective on all program weaknesses identified in this
report, along with any corrective actions taken or planned. We note that your letter of
December 7,1992, on Unit 1 indicated that a status meeting would be held in six months.
i
OFFICIAL RECORD COPY
A:MS9380. INS
9306150055 930607
ADOCK 05000245
G
q,o\\ \\ ,
L
y
.o-
.
Mr. John F. Opeka
2
JUN
71993
A status meeting covering all 3 units would be an appropriate forum to discuss your
perspectives, proposed or completed corrective actions, and the transition from the Unit 1
project team to normal training functions. In particular, please address how you will align
and implement all three unit LORT programs according to common standards, policies, and
administrative controls. A written response on these program weaknesses should be
submitted no later than 20 days after this status meeting. You will be contacted shortly
concerning a date for this meeting.
Also, the team reviewed the root causes for each unsatisfactory program evaluation in 1991
and 1992. All symptoms and potential causes of these problems were listed specifically by
the team in the attachments to this report. Overall, the team concluded that there was a
management control system breakdown in the Unit 1 LORT prior to the 1991 program
evaluation. The review for root cause for the 1992 unsatisfactory determination was
inconclusive. The team noted considerable evidence that the Project Team organization for
Unit 1 is addressing a majority of these past problems that manifested themselves in the two
repetitive unsatisfactory determinations. It is not clear that sufficient management controls
are in place to sustain the program when the project team is disbanded.
Further, based on the results of this inspection, the team identified a number of apparent
violations and deviations from written commitments, which we concluded were
manifestations of the management control system problem noted above. These are being _
considered for escalated enforcement action in accordance with the, " General Statement of
Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy),10 CFR Part 2,
Appendix C (1992). The apparent violations (section 2 of the report) involve: (1) the failure
1
of licensed operators to attend requalification training during the 1991/1992 cycle (Units 1
and 2); and (2) the failure to conduct technical specification audits of LORT programs (all
three units, previously cited for Unit 1, with licensee response indicating applicability to
Units 2 and 3). Once the audits were completed (for Units 1 and 3), they further identified a
I
number of instances of non-adherence to administrative controls in the LORT area. The
apparent deviations (section 2 of report) involve: (a) failure to properly implement a policy
for management observation in the simulator at the specified frequency; (b) two instances of
failing to meet written commitment dates for corrective action as a result of the Unit 1 LORT
'
unsatisfactory determinations; and (c) failure to use video taping during routine training.
Accordingly, no Notice of Violation or Deviation is presently being issued for these
,
inspection findings. In addition, please be advised that the number and characterization of
i
apparent violations described in the enclosed inspection report may change as a result of
'
further NRC review.
OFFICIAL RECORD COPY
A:MS9380. INS
4
i
!
o
i
.
Mr. John F. Opeka
3
JUN
7 1993
An enforcement conference to discuss these regulatory matters has been scheduled for
July 1,1993, at 10:00 a.m. in the Region I office. The purpose of this conference is to
i
discuss the apparent violations and deviations, their cause(s) and safety significance, to
provide you the opportunity to point out any errors in our inspection report, to provide an
opportunity for you to present your proposed corrective action, and to discuss any other
information that will help us determine the appropriate enforcement action in accordance with
.
the Enforcement Policy. With respect to safety significance, a central concern in this matter
,
is the number and impact of non-proficient licensed operators on a per crew basis who
'
operated Unit 1 in 1991/1992. The safety implications of the apparent violations to Units 2
and 3 with respect to operator proficiency should also be considered.
Please note that we are requesting two separate meetings - the enforcement conference to
discuss specific violations and deviations for occurrences in the past; and a future status
meeting to discuss issues present and future, with only minimal review on past problems.
However, you may wish to include in the enforcement conference your perspective and
related corrective actions for current issues as they relate to the violations and deviations
noted herein.
We received your letter dated April 5,1993, transmitting the response to the violation
dealing with failure to audit the training of Unit 1 staff. While the violation was for Unit 1,
the enclosed report discusses the similar problem at Units 2 and 3. We will review your
corrective actions for all three units at a future date.
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.
A reply to this letter is required. Your cooperation with us in this matter is appreciated.
Sincerely,
.
Original Signed By:
Marvin W. Hodges
Marvin W. Hodges, Director
Division of Reactor Safety
{
Enclosure: NRC Region I Combined Team Inspection Report Nos.
-
50-245/93-80, 50-336/93-80, 50-423/93-80
.
1
OFFICIAL RECORD COPY
A:MS9380. INS
y
,
,:~
Mr. John F. Opeka
4
&
7g
cc w/ encl:
W. D. Romberg, Vice President - Nuclear, Operations Services
S. E. Scace, Vice President, Millstone Station
H. F. Haynes, Nuclear Unit Director, Unit 1
J. S. Keenan, Nuclear Unit Director, Unit 2
F. R. Dacimo, Nuclear Unit Director, Unit 3
M. Brown, Project Team Manager
B. Ruth, Manager, Operator Training
M. Wilson, Licensing Manager
R. M. Kacich, Director, Nuclear Licensing
G. H. Bouchard, Director of Quality Services
Gerald Garfield, Esquire
Nicholas Reynolds, Esquire
K. Abraham, PAO (2) All Inspection Reports
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Connecticut SLO
OFFICIAL RECORD COPY
A:MS9380. INS
I
.
.
Mr. John F. Opeka
5
JUN
7 1993
bec w/enci (VIA E-MAIL):
M. Hodges, DRS
E. Imbro, DRS
,
V. McCree, OEDO
J. Stolz, NRR/PD I-4
J. Anderson, NRR
J. Lieberman, OE
W. Swenson, HFB/NRR
D. Jaffe, PM, NRR (Millstone 1)
G. Vissing, PM, NRR (Millstone 2)
V. Rooney, PM, NRR (Millstone 3)
-
J. Wiggins, DRP
L. Bettenhausen, DRS
R. Conte, DRS
R. Blough, DRP
L. Doerflein, DRP
D. Holody, EO
H. Williams, DRS
M. Biamonte, Training and Assessment Specialist, NRR
A. Burritt, DRS
S. Hansell, DRS
K. Shembarger, Reactor Engineer, Region III
B. Boger, DRCH
D. Lange, OLB
>
bec w/ encl:
Region I Docket Room (with concurrences)
H. Williams, DRS
R. Conte, DRS
- previous concurrence
RI:DRS
RI:DRS
RI:DRS
NRR:HFB
RI:DRP
Williams /dmg
Conte
Bettenhausen Swenson
Blough
y
.
.
.
06/03/93
06/03/93
06/ /93
06/03/93
06/'y/93
RI:DRS
W
06///93
OFFICIAL RECORD COPY
A:MS9380. INS
lh h)
.
.
-
.
.
Mr. John F. Opeka
5
g g p gg3
bec w/enci (VIA E-MAIL):
M. Hodges, DRS
E. Imbro, DRS
V. McCree, OEDO
J. Stolz, NRR/PD I-4
J. Anderson, NRR
J. Lieberman, OE
,
W. Swenson, HFB/NRR
!
D. Jaffe, PM, NRR (Millstone 1)
G. Vissing, PM, NRR (Millstone 2)
V. Rooney, PM, NRR (Millstone 3)
,
J. Wiggins, DRP
L. Bettenhausen, DRS
l
R. Conte, DRS
R. Blough, DRP
,
L. Doerflein, DRP
,
D. Holody, EO
H. Williams, DRS
M. Biamonte, Training and Assessment Specialist, NRR
A. Burritt, DRS
g(g
-)
S. Hansell, DRS
3.30 7 s
K. Shembarger, Reactor Engineer, Region III 4 7),y
og
b
' b , O b6
bec w/ encl:
!
Region I Docket Room (with concurrences)
H. Williams, DRS
R. Conte, DRS
1
- previous concurrence
R1:DRS
RI:DRS
RI:DRS
NRR:HFB
RI:DRP
Williams /dmg
Conte
t enhausen Swenson
Blough
a
.
.
06/03/93
06/03/93
06/7/93
06/03/93
06/ /93
RI:DRS
j
Hodges
06/ /93
OFFICIAL RECORD COPY
A:MS9380. INS
.
.;
m
Mr. John F. Opeka
5
.. JUN
71993
bec w/ encl:
Region I Docket Room (with concurrences)
H. Williams, DRS
.
b
i
t
?
A
RI:DRS
RI:DRS
RI:DRS
NRR:HFB
RI:DRP
Williams /dmg
C te
Bettenhausen Sw nson
Blough
(P'
bc
06/03/93
06d/93
06/ /93
06/J93
06/ /93
RI:DRS
Hodges
06/ /93
OFFICIAL RECORD COPY
A:MS9380. INS
_
,