View source for B16811, Forwards Rev 2 to CA Plan (CAP) Updating Actions & Schedules to Reflect Util Current Plans for Addressing Identified Deficiencies in Licensed Operator Initial Training & Licensed Operator Upgrade Training Programs

{{Adams
| number = ML20199B964
| issue date = 11/14/1997
| title = Forwards Rev 2 to CA Plan (CAP) Updating Actions & Schedules to Reflect Util Current Plans for Addressing Identified Deficiencies in Licensed Operator Initial Training & Licensed Operator Upgrade Training Programs
| author name = Amerine D
| author affiliation = NORTHEAST NUCLEAR ENERGY CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000213, 05000245, 05000336, 05000423
| license number = 
| contact person = 
| document report number = B16811, NUDOCS 9711190162
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 40
}}

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                                                                   . Northeast Nucient Fmrgy Company P.o. Bus 128 Waterford, CT 06385-0128 (860) 447 1791 Fas (860) 444 4277 The Northemat Utihties System November 14,1997 Docket Nos. 50-213 50-245 50-336 50-423 B16811 US Nuclear Regulatory Commission ATTN. Document Control Desk Washington, DC 20555 Haddam Neck Plant Millstone Nuclear Power Station, Units 1,2 & 3 Revision To Corrective Action Plan For Trainina Reference (a):     H. J. Miller and W. D. Travers, USNRC letter to B. D. Kenyon, "Cohfirmatory Action Let*er," dated March 7,1997 Reference (b):     J. K. Thayer letter to USNRC, " Response to initial Operator Licensing Examination Report No. 50-245/96-12," dated March 3, 1997 Reference (c):     J. K. Thayer letter to USNRC, "Results of Initial Review of Licensed Operators' Records," dated March 14,1997 Reference (d):     J. K. Thayer !etter to USNRC, " Response To Confirmatory Action Letter," dated March 31,1997 Reference (e):     J. K. Thayer letter to USNRC, " Revised Corrective Action Plan for Operator Training," dated April 18,1997                                             gCb By {{letter dated|date=March 7, 1997|text=letter dated March 7,1997}}, the NRC Staff transmitted Confirmatory Action Letter (CAL) 1-97-010 [ Reference (a))- regarding licensed operator training records and
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programs at Millstone Station and the Haddam Neck Plant. The letter confin                      .he commitments that Connecticut Yankee Atomic Power Company (CYAPCly and 9711190162 971114                    Q })()' g gg roa v     ^* "SiiA'_                           ks;I og7           lilElEl ERR.IH.RH.

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U.S. Nucle:r Regul: tory Commission B16811\Page 2 Northeast Nuclear Energy Company (NNECO) had made to ensure that weaknesses in the Licensed Operator Initial Training (LOIT) and Licensed Operator Upgrade Training (LOUT) programs would be corrected. These commitments were noted in our {{letter dated|date=March 3, 1997|text=letter dated March 3,1997}} [ Reference (b)). Specifically, CYAPCO and NNECO committed to complete a number of actions and to submit the results of expanded reviews by April 2, 1997. The result of our initial reviews into these issues was provided in our {{letter dated|date=March 14, 1997|text=letter dated March 14,1997}} [ Reference (c)). Our response to the commitments, including submittal of a '' Corrective Action Plan For MP1 LOUT IRT Recommendations," was provided in our {{letter dated|date=March 31, 1997|text=letter dated March 31,1997}} [ Reference (d)) and as revised on April 18,1997
[ Reference (e)). Contained within our letter of March 31,1997 was a commitment to complete the corrective actions by their associated due dates as noted in the Corrective Action Plan.
This letter provides Revision 2 to the Corrective Action Plan (CAP) as Attachment 1.
This revision updates the actions and schedules to ref!ect NNECO's current plans for addressing the identified deficiencies. The corrective actions contained within the CAP are specific to Millstone Station and the Nuclear Training Department unless otherwise specified.
Attachment 2 contains the current status for each corrective action contained within the CAP along with a summary of, and basis for, any revision to the corrective action. The originai CAP consisted of 53 items. Through the course of completing the corrective actions, several items have been added, expanded into multiple items, replaced by alternate items, or canceled as the actual needs were better understood. These changes have resulted in a CAP which now consists of 71 individual items. Of the current items listed within the CAP,49 have been closed and validated as of November 11,1997. There are 22 items remaining, two of which are rollup activities which will be closed upon completion of subordinate activities, All but five of the remaining 22 items will be completed by December 31, 1997. Three of the five items scheduled for completion in 1998 will be completed on or before February 28, 1998, with the remaining two items being completed in association with commencement of the related Unit 1 and 2 training programs, Dates on which closure packages for individual items were finalized are shown in the status column of Attachment 2. Some of these completion dates reflect closure past the due date. This is the result of heightened expectations with respect to both the thoroughness of the corrective action and the level of documentation acceptable for Cosure. Recent reviews of closure packages determined that follow-on enhancements were relevant to closure. A Condition Report (CR M3-97-4035) has been sitten to
!                        address these discrepancies.
Three of the corrective actions contained within the CAP have been identified on the Significant items Lists (SIL). These corrective actions are identified in the ' Status" column of Attachment 2. Only one of these three items is tied to Unit 3 restart. This l                        item will be completed prior to December 10,1997. The other two corrective actions
!                        are related to training program restart rather than unit restart. Action on these items is in l
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                     -- U.S; Nucle:r Regul: tory Commission                                                                                                       -
B18811\Page 3 z progress and 'wdss completed prior to recommencing the applicable Operator Training .
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                    - Piease contact Mr.- R. W.- Flanagan at (860)_437-5817. should you' have any questions                                                       .
regarding this matter!                                        ,
Very truly yours,                                                                               q CONNECTICUT YANKEE ATOMIC POWER COMPANY                                                          '
N RTHEAST NUCLEAR ENERGY COMPANY -
;                                             f                                       )        ]       y Dave B. Amerine, Vice President -
I Nuclear Engineering and Support Services Attachments (2) cci          H. J.         Miller, Region i Administrator
                                 ' G. W. Meyer, Chief of Operator Licensing, NRC Region I
            &                    - F. J.         Miraglia, Deputy Director, NRR W. D. Travers, Ph.D., Director, Special Projects Office W. D. Lanning, Deputy Director, Inspections, Special Projects Office F               -
P. F. McKee, Deputy Director, Licensing and Oversight, Special Projects Office J. P.         Durr, Branch Chief Inspections, Special Projects Offee                                               ,
M. B. Fairtile, NRC Project Manager, Haddam Neck Plant W.' J. Raymond, Senior Resident inspector, Haddam Neck Plant S.            Dembek, NRC Project Manager, Millstone Unit 1 i'
T.- A.        Easlick, Senior Resident inspector, Millstone Unit 1 D. G. Mcdonald, Jr., NRC Senior Project Manager,' Millstone Unit 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit 2 4
J. W. Andersen, NRC Project Manager, Millstone Unit 3 A. C. Cerne, Senior Resident inspector, Millstone Unit 3 q'                                                                                                                     '
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                                  ,-                                    Millstone Nuclear Power Station, Units 1,2, and 3                                      ,
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l U.S. Nuclear Regulatory Commission B16811%ttachment 1\ Page 1 Corrective Action                             Due Date IRT Recommendations                                 l Executive Summary (ESI                                                                     .
: a. Analyze the staffing and expenence levels of all Operator              5/1/97 ES-1         Draw upon INFO loanees or industry experts to temporari!y function in the MP-1 Operator Training                    Training Branch (OTB) sections and augment with indus'.ry Branch until the experience level of the incumbents                   experts and/or INPO loanees in all Om secbons as can be raised to an appropriate level.                                necessary.
: a. Perform a review of the licensed operator requalifcabon               Complete ES-2         Conduct in-depth reviews for appicabiltty of issues (LORT) program for MP1, MP2, MP3 and HNP, against the                 (3/3/97)*
from the investigation to the other training programs for all Millstone Units. Consider temporary *stop-work"                   accredited training program requirements.
orders for those programs determined to be unacceptable.                                                                                                                           Prior to program b-1. Perform a review of the non-licensed operator training -
i programs for MP1 against the accredited training                       restart program requirements.
b-2. Perform a review of the non-ficensed operator training            Prior to pmgram programs for MP2 against the accredited training                       restart program requirements.
b-3. Perform a review of the non-licensed operator training            Prior to program programs for MP3 against the accredited training                       restart program requirements.
b-4. Perform a review of the non-licensed operator training                 Prior to programs for HNP againct the accredited training                  transitioning to program requirements.                                              Certified Fue8 Handler Training Program
: c. Develop a corrective action plan for the MP1 LOIT/ LOUT           Prior to program program and implement prior to program restart.                        restart
* Completed prior to initial submittsi of CAP on March 31,1997 [Referer'ce (d)].
Items shown in bold are changes from the previous submittal made in NNECO's correspondern,
* Response To Confirmeory Action t.etter," dated March 31,1997 and as updated by
* Revised Corrective Action Plan for Operator Training.* dated April 18,1997
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U.S. Nuclear _ Regulatory Commission                                                                          ~
bis 811\ Attachment 1\ Page 2                                                                                                                  -
IRT Rscommendations                                  l                             Corrective Action                           Due Date
: d. Develop a corrective action plan for the MP2 LOIT/ LOUT        Pnor to program program and implement prior to program restart.                    res' art
: e. Conduct an assessment of the ongoing MP3 LOIT program              5/15/97
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against the acciedited program requirements prior to submittal of the license applications to the NRC. Develop a corrective action plan, as necessary and implement prior to the NRC examinations of the cuvent LOIT/ LOUT Class.
    - ES-3     Evaluate competencies of the licensed RO to SRO                   a. For the 3 Unit One SRO epg.~ade candidates, remediation           12/31/97 candidates based on examination results.                               plans will be developed based on the} identified (3 SRO candidates from MP1 1996 License Exam)                          weaknesses and will be completed prior to reactivating their licenses.
Evaluate how identified weaknesses of tne candidates              b. With respect to the remainder of the MP1 licensed staff, the       8/29/97 pertain to the remainder of the licensed staff (Millstone              MP1 Requalification Training for cycles 1 through 4 have Unit 1).                                                               been inodified to focus on ideatif.ad weaknesses. Delivery of the modified training fulfills the commitment.
ES-4     Conduct reviews of previously identif:ed problem areas            a. Utilizing the review of the 1995/1996 self assessments (see        6/15/97 and expedite ciose-out of those relating to                            Crective Action for 4.2.3.B), develop a plan to resolve the accreditation, regulations, and training quality. This                 identified problem areas. The Nuclear Training Department should include re-evaluating priorities and resource                   (NTD) Excellence Plan will be evaluated fcilowing a commitments against other Nuclear Training                             comparison I review with thb corrective action plan and Department excellence initiatives.                                     priorities will be adjusted as appropriate.
ES-5     Implement an effective corrective action program that             a. The ES-5 recommendation will be complete when                     12/15/97 includes accountability for closure in a timely and                    corrective actions for weaknesses identified in "Self effective manner.                                                      Assessment and Corrective Action Programs
* have been comp!eted (4.2.3A-4.2.3E).
r items shown in bold are changes from the previous submittal made in NNECO's correspondence," Response To C(.nfirmatory Action Letter," dated March 31,1997 and as updated by
* Revised Corrective Action Plan for Operator Training,' dated April 18,1997
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U.S. Nuclear Regulatory Commission B16811\ Attachment 1\ Page 3                                                                                                                                      .
Corrective Action                          Due Date IRT Recommendations                                 l The ES-6 recommendadon wi!! be cc- pete when                    12/10/97 Senor management should clanfy and reinforce                    a.
ES-6 expectations of Training and Operat:ons management                    corrective actions for weaknesses identified in regarding their responsibilities for oversight of training.           -Management Oversight, involvement and Accountability" have been completed (4.1.3A-4.1.3D).
Implement methods and measures to ensure that oversight is effective.
Manaaement Overilaht, involvement
                                                    '                     and Accountability (MO)
Note: Corrective actons a-e must be accomplished to complete IP.T Recommendations 4.1.3A-4.1.3.D.
: a. Research industry pracuces with respect to oversight of         5/20/97 4.1.3.A Review industry guidance and INPO identfed 'best performers
* With respect to management oversight                     training  and modify the existing oversight structure process as app 0 cable. (Willinclude a review of the training advisory l                                                                                     committee /cumculum advisory committee process and l     4.1.3.B Reinforce with Training and Operations management their responsibilities regarding oversight of training.               structure.) Line management will be involved in the .Tview ant., modification of the existing process
: b. Publish and distnbute to training and line managemeAt the        5/15/97 4.1.3.C   Establish high expectations regarding oversight and Chief Nuclear Officer expectations for training oversight.
implement methods to ensure that oversight is documented, frequent, and useful.
: c. Evaluate the iraclementation of a group so:h as a Training       6/1/97 4.1.3.D   Ensure that oversight feedback is communicated and                                                                                               -
addressed consistently across all units.                              Executive Steera Committee, to provide strategic direction fortraining. Implement,if appropriate.
: d. Evaluate existing oversight of training performance              6/1/97 indicators (Pis) and make improvements as necessary. (Pis to be utilized to ensure consistency and to focus oversight)
: e. Utilize INPO and in-house expertise to provide training        12/31/97 workshops to Line and Training Management on the
                                                                                      " Oversight cf Trcining."                                                .
)
l items shown in bold are changes from the previous submittal made in NNECO's correspondence," Response To Confirmatory Action Letter," dated March 31,1997                {
i and as updated by
* Revised Corrective Action Plan for Operator Training," dated April 18,1097 l

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IJ.S. Nuclear Regulatory Commission B16811%ttachment 1\ Page 4                                                                                                                                 -
1 Corrective Action                       Due Date 1RT Recommendations                                               ,
Self Assessment and Correci ve Action Program (SC)
Note: Correction Actions a-h must be accomplished to complete iRT Recommendabons 4.2.3.A- 4.2.3 E.
Improve the Self assessment process within the NTD to         6/1/97 a.
4.2.3.A Review industry guidance and INPO identfied 'best penormers" with respect to self assessment correctve                 meet    industry standards. Establish clear roles and action. Adopt best practices in the NTD self                         responsibilities  and issue expectations to the training and assessment and corrective action process.                            line  organizations.
: b. Formally train all applicable NTD and line personne1          6/1/97 4.2.3 B Conduct an " urgency review" of previously identfied problem areas and expedrte close out of those relating               perfcaming training assessments.
to accreditation and/or regulatory issaes.
: c. Establish and issue expectations on the use of the Station's  5/15/97-4.2.3.C   Ensure corrcctive actions are developed and tracked for allidentfied training issues.                                    corrective action process within the NTD.
: d. Review the Training 1995 and 1996 self assessments to         6/1/97 4.2.3.D   Review effectiveness of past corrective actions.
incorporate this review into the self assessment                     identify weak areas. Review the commitments for these process.                                                             self assessments for effective closure. Initiate Condition Reports as appropriate.
e-1. Develop r, atrix of potential weaknesses from                  6/1/97 4.2.3 E Develop. communicate and reinforce clear expectations regarding the Self Assessment and                       designated inspections and audits of training. The Corrective Action process for a!!!evels of                           tentative list of source documents includes: INPO management, supervision and staff.                                   assist visit reporas; internal and external audit reports; 1905 and 1996 self assessment reports; Accreditaticn Reports; and EIA reports.
l l
e-2. Review the identified matrix for repeat findings and         6/23/97 l                                                                                                   init: ate Condition Reports against those that continue l
I to exist based on recent self assessment or audit findings.
Items shown in bold are changes faom the previous submittal made in NNECO's correspondence. " Response To Confirmatory Action Letter." dated March 31,1997 and as updated by " Revised Corrective Action Plan for Operator Training? dated April 18,1997

U.S. Nuclear Regulatory Commission B16811%ttachment _n Page 5                                                                                                                                     -
_                                            i Corrective AcFon                        Due Date IRT Recommendatione                                  l e-3. Prioritize identi' led continuing weaknesses based on         6/24/97 importance to safe operaUons, startup, and accreditation. Initiate Condition Reports as appropriate.
Perform systematic review of outstanding NRO                  12/15/97, e-4.
commitments back to 111189 to verify closure, contir.ued implementation, or whether modifiwlot. is needed to improve effectiveness.
: f. Evaluate the current training assessment tools for real time Canceled performance indicators. Enhance as necessary.
: g. Evaluate the existing 1997 self assessment plan and revise    6/15!97              j based on the findings of items in tnis section. Tino 1997                         .(
Self Assessment Pian will include assessments that evaluate the effectiveness of the actions of this corrective action plan.
: h. Evaluate the existing tracking and closure 'ools for           5/15/97 corrective action commitments available to the NTD and enhance as appropriate.
Systematic Approach to Training (SA)
Note: Corrective actions a4 must be accomplished to complete IRT Recommendations 4.3.3.A -4.3.3.F.
: a. Review the current SAT process within the Nucisar Training    2/28/98 4.3.3.A Evaluate existing NTD procedures and instructions (OTCis) and ensure these procedures meet NTD                           Cepartment  (N1D), including a review of the Nuclear expectations for the training process.                                Training  Manual   (NTM) to hclude recommendations for .
improvement (willinclude a review of OTBIs).
b-1    Perform regulatory compliance review of Technical            12/10/97 4.3.3.B- Revise NTD procedures and instructions (OTB!s) as required.                                                             Training Program procedures.
items shown in bold are changes from the previous submittal made in NNECO's correspondence," Response To Confirmatory Action Letter,* dated March 31,1997 and as updated by " Revised Corrective Action Plan for Operator Training.* dated April 18,1997

( U.S. Nuclear Regulatory Commission                                                                                                                                                                              1 B16811%ttachment 1\ Page 6                                                                                                                                                                                  -
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Corrective Action                           Due Date IRT Recommendations                                               _
l Perform regulatory compiiance review of Engineering                   12/5/97 4.3.3.C          Management and supervision should enst%s                                               b-2 compliance with existing procedures.                                                         Support / Profess,lonal Development Training Program procedures.
I Perform NRC regulatory cornpliance review of ad other ~              10/16197 4.3.3 D Evaluate the as taught LOUT program against                                                     b-3 accreditation standards and ensure that all                                                  Operator Training programs not covered by SA-B accreditation commitmen's were met.                                                          reviews.
: c. Utilizing assistance from industry experts, conduct refresher         8/30/97 4.3.3 E Develop and implement corrective actions for the issues identified in the recently performed intemal                                          trairdng for the N' D staffin the SAT process.
!                   assessment of accreditation criteria.
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: d. Enhance the Continuing Instructor Training program to                12/30/97 l   4.3.3.F          Implement the previously exist"            an for reviewing the Systems Approach to Traiinng as part of the 1997                                         include increased emphasis on SAT process.
Continuing inrtructor Training Program.                                                                                                                           12/20/97
: e. Re-estabOh and issue expectations with respect to procedure compliance end usage within the NTD.
f-1. Develop initial compliance trending indicators.                     Canceled
: g. With respect to the as. taught MP1 LOUT orogram, the                 Complete applications (398 Forms) for this class have been                    (3/3/97)*
withdrawn.
: h. Utilizing the review of the 1996 self assessment, (see                6/15/97 Corrective Action fur 4.2.3.B) and corrective actions e and b above, identify all training programs with issues with respect to the SAT process.
: i. Develop specific corrective action plans for the identified           7/25/97 traininr: programs in corrective action h.
* Completed prior to initial submittal of CAP on March 31,1997 [ Reference (d)].
l ltems shown in bo d are changes from the previous submittal made in NNECO's correspondence," Response To Confirmatory Action Letter," dated March 31,1997 and as updated by Revised Corrective Action Plan for OperatorTraining,* dated April 18,1997

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* l U.S. Nuclear Regulatory Commission B16811'#ttachment 1\ Page 7                                                                                                                                      .
Corrective Action                        Due Date IRT Recommendations                                 l Conduct self assessments to determine the                       2/28/98 J.
effectiveness of the completed corrective actions plans developed in response to corrective action I.
Experience and Staffina (EX)
Note: Corrective actions a-d must be accomplished to complete IRT Recommendatons 4 4.3 A -4 4.3 D.
: a. Analyze the sta'+ing and expenence levels of a'4 Operator        5/1/97 4.4.3 A Management should consider the use of INPO Loanees or industry experts to function in the Unit 1               Training Branch (OTB) sectons and augment with industry OTB chain of command untd experience level of the                   experts and/or INPO loanees in all OTB sections as incumbents can be raised to an appropriate level.                   necessary. (Same as ES-1a)
Analyze the staffing and experience levels in the remaining    12/31/97 4.4.3.B   Management should review current condit:ons and                b.
practices which resuit in difficu!ty of NTD to retain               NTD groups. Identify and implement corrective action as quahfied and experienced staff.                                     necessary.
: c. Review industry best practices on staff retention, rotation     5/20/97 4 4.3 C Management should develop and implement an and succession planning in training programs.
aggressive succession plan for all key positions in training (Training Coordinator and above).
4.4.3 D Training Management should take a proactive stance               d. Implement a Training Staff Retention Plan. The Retention in ensunng that transition and tumover for individuals              Flan is to include:
being promoted or transferred is completed.                                                                                       Canceled 1.1       issue a draft rotational plan.
1.2       Receive Executive Council approval on the            12/30197 rotational plan policy.
1.3       issue an interim retention plan for OTB               6/10/97 instructors.
2.1       Draft succession plan submitted to Director,         Canceled Nuclear Training, for review.
I 2.2       Director, Nuclear Training, approve Succession       12/1/97 Plan for Training.
Items shown in bold are changes from the previous submittal made in ' NECO's correspondence
* Response To Confirmatory Action Letter," dated March 31,1997 and as updated by Revised Corrective Action Plan for Operator Training
* dated April 18,1997

f U.S. Nuclear Regulatory Commis:: ion
  ' B16811\ Attachment 1\ Page 8 l                        IRT Recommendations                                 l                           Corrective Action                          Due Date -
l Selection Process and Criteria for Program Entry and NRC Exam (SP)
Note: Corrective actions a-c must be accomplished to complete IRT Recommendations 4.5.3.A - 4.5.3.C 4.5.3.A    Operatons Management should formaitze the SRO                   a. Establish a formallicense candidate selection process and        7/25/97-l candidate selection process similar to its recent                     promulgate as an intemal NU document.
instruction for RO candidate selection. The process should include involvement and input from NTD.
4.5.3.B    Benchmark industry *best performers' and develop '              b. Evaluate current assessment and remediaton processes of          6/10/97 formal process to assess the candidates' readiness to                 license candidates and enhance as appropriate to ensure take the simulator exam.                                              candidates' readiness to be examined.
4.5.3 C Senior Management should reinforce its expectations               c. Issue Chief Nuclear Officer expectations on the Operations       8/22/97 of Training Department and Unit personnelin fulfilling                and Training Management's responsibilities associated with their responsibilities for thoroughly assessing and                   the selection, assessment and remediation processes.
remediating the performance of license candidates.
Maintenance of Pronram and Student Records (MR)
Note: Corrective actions a-f must be accomplished to complete IRT Recommendations 4.6.3.A - 4.6.3.C.
4.6.3.A Ensure that the investigation associated with ACR M1-             a. A record review of the MP1 LOUT class (ACR M1               Complete 97-0117 verifies that all licensed operator training                  0117) for this class has been completed. The license            (313/9 7)*
records are in compliance with 10 CFR requirernents.                  applications (398 Forms) have been withdrawn.
4.6.3.B   implement the approved records management system.
: b. Complete implementation of Northeast Utilities Training -        2/28/98 4.6.3.C   Implement extemal program auditing at a frequency                      Information Management' ystem (NI'TIMS). During the appropriate to ensure record retention requirements                    transition to NUTIMS, establish expectations for records are being met.                                                         managenent for the interim period (to include expectations for use).
* Completed prior to initial submittal of CAP on March 31,1997 [ Reference (d)].
Items shown in bold are changes from the previous submittal made in NNECO's correspondence," Response To Confirmatory Action Letter
* dated March 31,1997 and as updated by " Revised Corrective Action Plan for Operator Training," dated April 18,1997

2 U.S. Nucle:r Regulatory Commission B16811%ttachment 1\ Page 9 IRT Recommendations                                       l                            Corrective Action                        Due Date '
: c. Devdop an enhanced review and approval process for the        12/30!97 NRC Form 396/398. Revise and irnplement the requisite procedures (to include clearly defined owners, roles, responsibilities and expectations).
: d. Issue Chief Nuclear Officer expectations conceming the        6/15/97          i enhanced 396/398 process.
: e. Based on the findings in Operating Training Branch (OTB),     12/10/97 assess the current state of records management practices in all remaining areas of NTD, to include analysis of weak areas and recommendations for improvement.
: f. Perform an evaluation of the implementation of OTBI-5,        12/10/97
                                                                                         " Maintenance of Training Records and Files," to determine if it has been effective. Apply the results of this evaluation to the existing programs and practices with Technical, Engineering Support, and Professional Development training programs. Revise these programs as necessary. Issue these documents frorn the Director, Nuclear Trainirs, with the appropriate expectation. Revise as necessary the self assessment
,                                                                                        program within the NTD to include an assessment on the effectiveness of the revised practices.
4 Items shown in bold are changes from the previous subnQtal rnade in NfetiOO's correspondence.
* Response To Confirmatory Acbon Letter," dated March 31,1997 and as updated by " Revised Corrective Action Plan for Operator Training," dated April 18,1997
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U.S.' Nuclear Regulatory _ Commission                                                                                             ,
B16811\ Attachment 1\ Page 10                                                                                                                                     _
IRT Recommendations                                l                             Corrective Action                           Due Date ~
Training Materids (TM)
Note: Corrective actions a-e must be accomplished to complete 4.7.3.A - 4.72E.
4.7.3.A Review and revise att training matenal to include                 a. Gunng the assessment and upgrade of training matenais             4/15/97         :
PDCR and procedure changes.                                          phase, establish expectations for the standards of training materials prior to being used for teining.
4.7.3.8    Evaluate the issue of training material quahty for             b. Evaluate the current method in the NTM for maintaining and        12/31197 applicobihty to all training programs.                                upgrading training materials based on plant configuraton changes (Plant Design Change Record [PDCR}. procecure changes, etc.). This review shall include recommendations 4.7.3.C . Management should ensure the requirements of NTNI                     for improvement. Revise the process to ensure standards 1.04, Commitment tracking are being met.                             are maintained.
j-   4.7.3.D    Ensure that instructional materials are adequately             c. Develop an assessment process to allow for the evaluation          5/2057 l              upgraded and maintained before being used in                          of the current state of training materials in all NTD training.                                                             programs.
4.7.3.E    Develop and implement a process that ensures that              d. Implement an assessment process to evaluate the                    6/1/97 applicable PDCRs and procedures changes are                           condition of training materials; process to include the ce;7;iiionicated to NTD in a timely manner.                           analysis and prioritization of findings and guidance on the actions to be taken.
: e. Develop Continuing mstructor Training (CIT) modules              Canceled for the SAT process.
I
   !! ems shown in bold are changes from the previous submittal made in NNECO's corresponcence,' Response To Confirmatory Action Letter," dated March 31,1997 and as updated by ' Revised Corrective Action Plan for Operator Training," dated April 18,190'

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U.S. Nuclear Regulatory Commission                                                                                              _
B16811%ttachment 1\ Page 11                                                                                                                                     .
Corrective Action                           Due Date IRT Recommendations                               l NRC Exam. Review, and Validation (NE)
Note: Ccrrective actions a-f must be accomplished to complete 4.8.3.A - 4.8.3.D Utiltzing :ndustry best pracbces, enhance the NTD's current       8/1/97 4.8.3.A Upgrado exam bank to industry standards. Implement                a.
NTM 4 01 to ensure exam questions are properly                      examination   bank process. Develop a new standard for examination bank quality.
constructed and documented.
Evaluate the current examination banks to the new                 8/20/97 4.8.3.8 ' Benchmark industry *best performers' and adopt                  b.
                        . practices into a formalized process for the review and              examination bank qua'ity standard.
validation of NRC exams. Provide expectations and Develop a plan and schedule for the examination bank              8/29/97       v training t: individuals sc%duled for exam review and          c.
validation.                                                         apgrade to the new standard based on the evaluation findings.
: d. Evaluate NTD's current review and valiot 'n process for           6/1/97 4.8.3 C Une Manage;nent should incorporate exam functions '
into their resource scheduling to ensure that                       examination approval, to include roles ani . tesponsibilities appropriate personnel who are representative of the                 for Training and Line Management. Revise the process as target audience are available for NRC exam review                   necessary.
and validation.
: e. Provide expectations and training to all personnel involved       6/15/97 4.8.4.D     Separate the review and validation of NRC exams in examination review and validation, based on the new
                        . processes so that they do not occur concurrently.
review and validation process.
: f. During the evaluation and upgrade process, establish              5/15/97 it'terim expectations that the new examination standard will tw utilized.
Items shown in bold are changes from the previous submittal made in NNECO's correspondence. " Response To Confirmanry Action Letter,' dated March 31,1997 l
and as updated by " Revised Corrective Action Plan for Operator Training." dated April 18,1997 L _ _ _ - .
                                                                                                                                                            ~

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5 Docket Nos. 50-213)
                                                                                                                                                    .50-245-50-336:                           ,
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B16811 t
tt-5 i
Attachment 2 Haddam Neck Plant Millstone Nuclear Power Station Units 1,2, and 3'
                                                                                 - Status of Corrective Actions for i                                                            Revision 2 to the Corrective Action Plan 1
r 1
November 1997 fji   ";
           ,n                               : -r

U.S. Nuc'9ar Regulatory Commission B168111 ~.;tachment 2\ Page 1 Corrective Action            Commitment #                                   Current Status AITTS #
Executive Summary 4
An: lyze the staffing and experience levels ES-1A           Due: 5/1/97 of all OperatorTraining Branch (OTB)        97008316-01     COMPLETED: 5/1/97 sections and augment with industry experts and/or INPO loanees in all OTB sections as                 Completion was documented in Memo JFS-97-011.
necessary.
Perform a review of the licensed operator  ES-2A           COMPLETED: 3/3/97 requalification (LORT) program for MP1,    N/A             Completed prior to initial submittal of CAP on March 31,1997 [ Reference MP2, MP3 and HNP, against the accredited (d)].
training program requirements.
. Perform a review of the non-licensed       ES-2B-1         Due: Prior to program restart.
operator training programs for MP1 against 97008316-02     COMPLETED: 5/1/97 the accredited training program requirements.                                              Completion was documented in Memo OT-3-97-039 for the Non-Licensed Operator Initial Training (NLIT) program and in Memo OT-2-97-037 for the Non-Licensed Operator Continuing Training (NLCT) program.
Change Justification: The original assignment, covering all four units, was split into four assignments to provide better tracking of actions for completion. The original assignment was superseded by these assignments. This corrective action is one of the four corrective actions created as a result.

U.S. Nuclear Regulatory Commission                   Status of B16811%ttachment 2\ Page 2                   Corrective Action Plan                                                                      .
Commitnmnt #                                   Cermnt Status
[
Corrective Action AITTS #
Perform a review of the non-licensad         ES-28-2        Due: Prior to program restart.
l operator training programs for MP2 against   97008316-03    COMPLETED: 5/1/97 the accredited training program Completion was documented in Memo OT-3-97-039 for the Non-Licensed requirements.
Operator initial Training (NLIT) program and in Memo OT-2-97-037 for the
                                                             ! Non-Licensed Operator Continuing Training (NLCT) program.
Change Justification: The original assignment, covering all four units, was spht into four assignments to provide better tracking of actions for I                completion. The original assignment was superseded by these assignments. This corrective action is one of the four corrective actions created as a result.
Perform a review of the non-licensed        ES-28-3         Due: Prior to program restart.
operator training progrcms for MP3 against   97008316-04     COMPLETED: 5/1/97 the accredited training program Completion was documented in Memo OT-3-97-039 for the Non-Ucensed requirements.
Operator initial Training (NLIT) program and in Memo OT-2-97-037 for the Non-Licensed Operator Continuing Training (NLCT) program.
Change Justification: The original assignment, covering all four units, was split into four assignments to provide better tracking of actions for completion. The original assignment was superseded by these assignments. This corrective action is one of the four corrective actions created as a result.

U.S. Nuclear Regulatory Commission                 S+atus of B16011%ttachment 2\ Page 3                 Corrective Action Plan                                                                          .
Commitment #  l                                 Current Status Corrective Action AITTS #
ES-28-4         Due: Pnor to transitioning to Certified Fuel Handler Training Program.
Perform a review of the non-licensed operator training programs for HNP against 97008316-05     COMPLETED: 9/17/97 the accredited training program Completon was documented in " Training Corrective Action Plan requirements.                                              Assessment for Connecticut Yankee Non-Licensed Training Programs,"
dated 9/17/97.
Change Justification: The original assignment, covering all four units, was split into four assignments to provide better tracking of actions for completion. The original assignment was superseded by these assignments. This corrective action is one of the four corrective actions created as a result. Additionally, this assignment was modified to reflect the transition to a Certified Fuel Handler Training Program.
Develop a corrective action plan for the  ES-2C           Due: Prior to program restart.
MP1 LOIT/ LOUT program and implement      97008316-06     MP1 LOIT is tentatively scheduled to begin in February 1998.
prior to program restart.                                 This Corrective Action is on the Significant items List (SIL) for Unit 1 and is not tied to Unit 3 restart.
Develop a corrective action plan for the  ES-2D           Due: Prior to program restart.
MP2 LOIT/ LOUT program and implement      97008316-07     MP2 LOIT program is tentatively scheduled to begin in the second quarter prior to program restart.                                 of 1998.
This Corrective Action is on the Significant items List (SIL) for Unit 2 and is not tied to Unit,3 restart

U.S. Nudear Regulatory Commission                         Status of 816811%ttachment 2\ Page 4                         Corrective Action Plan                                                                          .
Commitment #                                 Current Status Corrective Action
(    AITTS #                 -
Condud an assessment of the ongoing               ES-2E         Due: 5/15/97 MP3 LOIT program against the accredited           97008316-08   COMPLETED: 5/15/97 program requirements prior to submittal of                      NTD independent assentnent " Millstone Unit 3 LOIT and LOUT Program the license applications to the NRC.                            Assessment ~ Report (May 1997) and Nuclear Oversight Organization Audit l  Develop a corrective action plan, as                            " Independent Review Team Review of 1996-7 MP3 LOIT/ LOUT Program' i  necessary and implement prior to the NRC (June 1997) were completed. Based on the results of these reviews, cxaminations of the current LOIT/ LOUT                          corrective actions were implemented as documented in memos OT3    Class.                                                          100 (June 15,1997) and OT3-97-107(June 23,1997).
For the 3 Unit One SRO upgrade                    ES-3A         Due: 12/31/97 candidates, remediation plans will be             97008316-09   Change Justification: Completion of the Remediation Plan was developed based on their identified                             documented in Memo OT1-97-149. Remediation of the three Unit One weaknesses and will be completed prior t                        SRO upgrade candidates is in progress. Remediation process will be r: activating their licenses.                                  completed with administration of annual Requalification Examination prior to 12/31/97. Refer to Memo MJR-97-037.
With respect to the remainder of the MP1          ES-3B         Due: 8/29/97 7
l   licensed staff, the MP1 Requalification          97008316-10   COMPLETED: 8/29/97 Training for cycles 1 through 4 have been Completion of MP1, Cycle 4 Requalification Training provided closure to modified to focus on identified weaknest.es.
this corrective action.
Delivery of the modified training fulfills tne commitment.                                                    Change Justification: The Trainirg Department standdown forced a delay of the completion of this corrective action from 7/1/97 to 8/29/97.
Initial closure was determined to be inadequate, extended closure to 8/29/97. Refer to Memo OT1-97-160.
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U.S. Nuclear Regulatory Commission                                                   Status of B16811\ Attachment 2\ Page 5                                              Corrective Action Plan Corrective Action        Commitment #                                       Current Status AITTS #
Utilizing the review of the 1995/1996 self                              ES-4A               Due: 6/15/97 assessments (see Corrective Action for                                  97008316-11         COMPLETED: 7/8/97 4.2.3.8), develop a plan to resolve the                                                                                                                                       '
identified problem areas. The Nuclear                                                       Comp!etion was documented in Memos MJR-97-017, MJR-97-024, MJR-Training Department (NTD) excellence plan                                                   97-025 and MJR-97-036.
wi!! be evaluated following a comparison /
review with this corrective action plan and priorities will be adiusted as appropriate.
The ES-5 recommendation will be complete                                ES-SA               Due: 12/15/97 when corrective actions for weaknesses Refer to "Self      This is a roll-up activity for several other corrective actions. The limiting identified in "Self Assessment and Assessment          item for completion is " Perform systematic review of ouistanding Corrective Action Programs" have been and Corrective      commitments back to 1/1/89 to verify closure, continued implementation, or completed (4.2.3A-4.2.3E).
Action              whether modification is needed to improve effectiveness."
Programs" for tracking #.
The ES-6 recommendation will be complete                                ES-6A               Due: 12/10/97 when corrective actions for weaknesses Refer to            This is a roll-up activity for several other corrective actions. Limiting item identified in " Management Oversight,
                                                                          .Manaaement         for completion is " Utilize INPO and in-house expertise to provide training involvement and Accountability" have been                               Oversicht,          workshops to Line and Training Management on the Oversight of Training."
completed (4.1.3A-4.1.3D).                                                                  This item is contained within Management Oversicht. Involvement and Involvement and                 Accountability and has been extended to 12/10/97.                                 '
Accountability" for tracking #

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U.S. Nuclear Regulatory Commission                                                              Status of B16811%ttachment 2\ Page 6                                                    Corrective Action Plan Corrective Action                     Commitment #                                             Current Status AITTS #                                                                                ,
s.
Management Oversicht. Involvement and Accountability Note: Corrective actions a-e must be accomplished to complete IRT Recommendations 4.1.3A4.1.3.D.
Research industry practices with respect to MO-A                                                  Due: 5/20/97 oversight of training and modify the existing 97008316-12
                                                                  ,                                                                  COMPLETED: 5/15/97                                                             -
oversight structure process as applicable (willinclude a review of the training advisory committee / curriculum advisory committee                                                         Completion was documented in Memo MJR-97-005.
process and structure). Line management will be involved in the review and modification of the existing process.
Publish and distribute to Training and Line                           MO-B                       Due: 5/15/97 Management the Chief Nuclear Officer 97008316-13                COMPLETED: 5/12/97 expectations for training oversight.
Completion was documented in Memo NSC-97-019.
Evtluate the implementation of a group                                MO-C                       Due: 6/1/97 such as a Training Executive Steering 97008316-14                COMPLETED: 5/1/97 4
committee, to provide strateg,ic direction for
,                                  training. Implement,if appropriate.                                                               Executive Training Council established and first meeting conducted on 4/12/97. Charter approved on 5/1/97. Meeting minutes and charter on file       i with NTD.                                                                      ,
Ev !uate existing oversight of training                               MO-D                       Due: 6/1/97 performance indbators (Pis) and make 97008316-15                COMPLETED: 11/7/97 improvements as necessary (Pis to be utilized to ensure consistency and to focus                                                      Originally closed on 6/1/97, based on the current set of Pls and ow:rsight).                                                                                      annunciator windows being utilized by the individual units.                    ,
Change Justification: Closure on 11/7/97 was determined to be more appropriate based on current Pis. Refer to Memo MJR-97-040

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U.S. Nuclear Regulatory Commission                                                                                                               Status of B16811\ Attachment 2\ Page 7                                                                                                              Corrective Action Plan                                                                  '
Corrective Action                                                                     Commitment #                                  Current Status AITTS #
Utilize INPO and in-house expertise to                                                                                              MO-E          Due: 12/31/97.
provide training workchops to Line and 97008316-16   Change Justification: Reopened -Target audience was not carefully a raining Management on the ' Oversight of defined.
Training.,
Training workshops were provided, as planned to Line and Training Management. Not all of those expected to attend were able to attend prior to April 18,1997. Therefore, additional workshops were offered. As a result, the due date was initially extended from 4/18/97 to 5/15/97.
However, since a target audience had not been carefully defined, this corrective action has been re-opened to define that audience and comp'ete the required training.
Seli Assessment and Corrective Action Proaram Note: Correction Actions a-h must be accomplished to complete IRT Recommendations 4.2.3.A - 4.2.3.E.
Improve the Self assessment process within SC-A                                                                                                  Due: 6/1/97 the NTD to meet indust:y standards.                                                                                                 97008316-17   COMPLE'IED: 6/1/97 Establish clear roles and responsibilit.ies cnd issues expectations to the training and                                                                                                       Nuclear Training Department Directive (NTDD-26),"Self Assessment line organizations.                                                                                                                               Procedure' issued on 6/1/97.
Formally train all applicaisle NTD and line                                                                                         SC-B          Due: 6/1/97 personnel performing training assessments.
97008316-18   COMPLETED: 11/10/97 Applicable NTD personnel received training on or before 6/1/97. Training attendance records are on file with NTD. Refer to Memo MJR-97-047.
~
Change Justification: In order to ensure personnel performing assessments in the future are properly trained. NTDD-26, "Self Assessment Procedure,"
v.as revised on 11/10/97.
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O U S. Nuclear Regulatory Commission                    Status of B16811%ttachment 2\ Page 8                     Corrective Action Plan Corrective Action               Commitment #                                 Current Status AITTS #
Establish and issue expectations on the use SC-C           Due: 5/15/97 of the Station's corrective action process 97008316-19   COMPLETED: 5/15/97 within the NTD.
Completion was documented in Memos MJR-97-006 and RNJ-97-027.
Review the training 1995 and 1996 self       SC-D          Due: 6/1/97 assessments to identify weak areas.
97008316-20   COMPLETED: 7/8/97 Review the commitments for these self assessments for effective closure. Initiate                Completion was documented in Memos MJR-97-014, MJR-97-025 and Condition Reports as appropriate.                          MJR-97-036.                                                                    l Develop matrix of potential weakness from    SC-E1         Due: 6/1/97 designated inspections and audits of 97008316-57   COMPLETED: 7/8/97 training. The tentative list ofIource documents includes: INPO assist visit                      Completion was documented in Memos MJR-97-014 MJR-97-025 and                      ,
reports; intemal and external audit reports;               MJR-97-036.
1995 and 1996 self assessment reports:                     Change Justification: The original correctrve action was split into four Accreditation Reports; and E/A reports.                    different assignments to ensure quality review, allow time for verification of closure documents, and appropriate corrective action modification. The original assignment was superseded by these assignments. This corrective action is one of the four corrective actions created as a result.
This change also clarified the wording to better define the deliverables.

O U.S. Nuclear Regulatory Commission                      Status of B16811%ttachment 2\ Page 9                       Corrective Action Plan Corrective Action                  Commitment #                                 Current Status AITTS #
Review the identified matrix (SC-E1) for         SC-E2         Due: 6/23/97 repeat findings and initiate Condition           97008316-58   COMPLETED: 7/8/97 Reports against those that continue to exist based on recent self assessment / audit                        Completion was documented in Memos MJR-97-025 and MJR-97-036.
findings.                                                      Change Justification: The original corrective action was split into four different assignments to ensure quality review, allow time for verification of closure documents, and appropriate corrective action modification. This correchve action is one of the four corrective actions created as a result.
This change also clarified the wording to better define the deliverables.
Additionally, the due date was extended from 6/1/97 to 6/23/97 because the volume of outstanding items entered into the matrix of potential weakness from designated inspections and audits of training was significantly larger than expected.
Prioritize identified continuing weaknesses SC-E3              Due: 6/24/97 based on importance to safe operations, 97008316-59   COMPLETED: 7/8/97 startup, and accreditation. Initiate Cendit. ion Reports as appropriate.                                        Completion was documented in Memos MJR-97-025 and MJR-97-036.
Change Justification: The original corrective action was split into four different assignments to ensure quality review, allow time for verification of closure documents, and appropriate corrective action modification. The original assignment was superseded by these assignments. This corrective action is one of the four corrective actions created as a result.
This change also clarified the wording to better define the deliverables.
Additionally, the due date was extended from 6/1/97 to 6/24/97 because t
the volume of outstanding items entered into the matrix of potential weakness from designated inspections and audits of training was significantly larger than expected.

U.S. Nuclear Regulatory Commission                  Status of
- 816811%ttachment 2\ Page 10                 Corrective Action Plan Corrective Action            Commitment #                                  Current Status AITTS #                                                                                     ,
Perform systematic review of outstanding    SC-E4         Due: 12/15/97 NRC commitments back to 1/1/89 to verify                  Change Justification: The original corrective action was split into four 97008316-60 closure, continued implementation, or                     different assignments to ensure quality review, allow time for verification of whether modification is needed to improve closure documents, and appropriate correctrve action modification. The effectiveness.                                            original assignment was superseded by these awignments. This corrective action is one of the four correctrve actions created as a result.     !
This change also clarified the wording to better define the deliverables.
Additionally, the due date was extended because the volume of outstanding items entered into the matrix of potentia! weakness from designated inspections and audits of training was significantly larger than expected.
Evaluate the current training assessment    SC-F          Canceled to other NTD initiatives per Memo MJR-97-032.
tools for real time performance indicators.
97008316-22 Enhance as necessary.
Evtluate the existing 1997 self assessment SC-G           Due: 6/15/97 plan and revise based on the findings of 97008316-23   COMPi ETED: 6/14/97 i; ems in this section. The 1997 Self Assessment Plan will include assessments                  Completion was documented in Memo MJR-97-018.
that evaluate the effectiveness of the actions of this corrective action plan.
Evaluate the existing tracking and closure  SC-H          Due: 5/15/97 tools for corrective action commitments     97008316-24   COMPLETED: 5/14/97                                                               .
available to the NTD and enhance as                                                                                                        '
appropriate.                                              Completion was documented in Memo MJR-97-004.

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                                                                                                                                                                                                 .e U.S. Nuclear Regulatory Commission                                                                         Status of B16811%ttachment 2\ Page 11                                                                         Corrective Action Plan Corrective Action                                                                     Commitment #                                  Cu rent Status AITTS #
Systematic Approach to Trainina (SAT)
Note: Corrective actions a-i must be accomplished to complete IRT Recommendations 4.3.3.A - 4.3.3.F.
Review the current SAT process within the                                                           SA-A           Due: 2/28/98.
Nuclear Training Department (NTD),                                                                  97008316-25    Change Justification: Closure was originally made to Memo MJR-97-013.
including a review of the Nuclear Training This memo recommended rewrite of the Nuclear Training Manual. This Manual (NTM) to include recommendations                                                                            item has been reopened to track the Nuclear Training Manual rewrite for improvement (will include a review of project that was a recommended action. The due date was extended to s).                                                                                                          reflect the increased scope. Refer to Memo MJR-97-042.
Perform regulatory compliance review of                                                             SA-Bi          Due: 12/10/97.
Technical Training Program procedures.
97016755-03    Change Justification: A Condition Report (CR) was initiated as a result of the inadequate closure of the original corrective action. As a result, the original action was replaced with the three corrective actions from the CR.
This corrective action is one of the three correctrve actions resulting from that CR. Additionally, the due date was extended from 5/15/97 to 12/10/97.
Perform regulatory compliance review of                                                            SA-B2          Due: 12/5/97.
Engineering Support / Professional 97016755-04    Change Justification: A Condition Report (CR) was initiated as a result of Development Training Program procedures.
the inadequate closure of the original corrective action. As a result, the original action was replaced with the three correctrve actions from the CR.
This corrective action is one of the three corrective actions resulting from that CR. Additionally, the due date was re-opened to 12/5/97. Refer to Memo MJR-97-043.

O U.S. Nuclear Regulatory Commission                   Status of                   .
B16811\ Attachment 2\ Page 12                 Cormctive Action Plan Corrective Action              Commitment #                                  Current Status AITTS #
Perform NRC regulatory compliance review SA-83             lDue: 10/16/97 of all other Operator Training programs not 97016755-05    COMPLETED: 10/10/97 covered by IRT Recommendation SA-B reviews.
Change Justification: A Condition Report (CR) was initiated as a result of the inadequate closure of the original corrective action. As a result, the original action was replaced with the three corrective actions from the CR.
This corrective action is one of the three corrective actions resulting from that CR. Additionally, the due date was extended from 5/15/97 to 10/16/97. Refer to Memo JFS-97-035 and attached report for suppor'Jng details on closure.
Utilizing assistance from industry experts,  SA-C           Due: 8/30/97 conduct refresher training for the NTD staff 97008316-27    COMPLETED: 10/7/97 in the SAT process.
SAT training conducted for NTD personnel during the Training Department standdown. Lesson Plan and attendance sheets are on file within NTD.
Enhance the Continuing Instructor Training   SA-D           Due: 12/30/97 (CIT) program to include increased 97008316-28    SAT training conducted for NTD personnel during the Training Department emphasis on SAT process.
standdown has been revised and incorporated into the CIT program.
Rev; sed CIT program description and lesson plans are on file within NTD.
In order to ensure that the Instructional staff is educated in the SAT process for the future maintenance of programs, delivery of the modules has been planned for NTD Continuing instructor Trainir>g (CIT) week in December 1997. Refer to Memo MJR-97-048.
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U.S. Nuclear Regulatory Commission                     Ctatus of B16811%ttachment 2\ Page 13                    Corrective Action Plan
                                                                                                                                                                                ~
i Corrective Action               Commitment #                                   Current Status AITTS #
Re-establish and issue expectations with       SA-E           Due: 12/20/97.
respect to procedure compliance and usage 97008316-29    Change Justification: Reopened as a ;asuit of numerous procedural non-wi+hin the NTD.
compliance Condition Reports written within NTD since the original action was completed. A Condition Report was initiated to trend this issue. This activity was re-opened to track ccmpletion of the associated root cause and corrective actions. Refer to Memo MJR-97-044 Develop initial compliance trending           SA-F1          Canceled. Compliance indicators proved not to be useful or manageable.
indicators.                                                   in lieu of indicators, compliance assessments are being performed.
97008316-61 With respect to the as taught MF-1 LOUT        SA-G           COMPLETED: 3/3/97                                                                 ;
program, the applications (398 Forms) for N/A            Completed prior to initial submittal of CAP on March 31,1997 j                                 this class have been withdrawn.
[ Reference (d)].
Utilizing the review of the 1996 self         SA-H           Due: 6/15/97 assessment, (see Corrective Action for 97008316-31    COMPLETED: 7/8/97 4.2.3.8) and the corrective actions a and b above, identify all training programs with                    Completion was documented in Memos MJR-97-017. MJR-97-025 and issues with respect to the SAT process.                      MJR-97-036.                                                                       i Develop specific corrective action plans for SA-1            Due: 7/25/97 the identified training programs in correction 97008316-32    COMPLETED: 7/25/97 action h.
Completion was documented in Memo MJR-97-029.
Change Justification: As the result of a Condit6n Report (CR) initiated on June 4,1997 in association with this activity, the due date was extended           l from 7/1/97 to 7/25/97 in order for resoonse to the CR.                           ;
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U.S. Nuclear Regulatcrf Commission                                    Status of B1S811%ttachment 2\ Page 14                                 Corrective Action Plan
                                                                                                                                                                                       ^
                                                                                                                                                                                      ~
Corrective Action      Commitment #                                     Current Status AITTS #
Conduct assessments to determine the                 SA-J               Due: 2/28/98.
effectiveness of the completed corrective Not assigned as Change Justification: This corrective action was added in Revision 2 to the actions plans developed in response to
                                                                  ,   ,                  of this date.      Corrective Action Plan.
.                                   corrective action i.
t Experience and Staffina Note: Corrective actions a-d must be accomplished to complete IRT Recommendations 4.4.3.A - 4.4.3.D.
See ES-1a (Analyze the staffing and                  EX-A               Due: 5/1/97 xperience levels of all Operator Training N/A                COMPLETED: 5/1/97 Branch (OTB) sections and augment with                                                                                                              :
industry experts and/or INPO loanees in all                             Completion was documented in Memo JFS-97-011.
OTB sections as necessary.)
Analyze the staffing and experience levels           EX-B               Due: 12/31/97.
in the remaining NTD groups. Identify and 97008316-33        Change Justification: Reopened - Analyses for Engineering implement corrective action as necessary.                                                                                                           ,
Support / Professional Development Group (ES/PDG) and Technical Training Branch (TTB) were determined to be inadequate. Refer to Memo        ,
                                                                                                          ! MJR-97-038.
Review industry best practices on staff             EX-C               Due: 5/20/97
* retention, rotation and succession planning         97008316-34        COMPLETED: 11/11/97                                                          l in trcining programs.
Change Justification- Original completion on 6/10/97 was determined to be inadeouate. Adequa6 closure was achieved on 11/11/97.
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O U.S. Nuclear Regulatory Commission                                              Status of B16811\ Attachment 2\ Page 15                               Corrective Action Plan Corrective Action                      Commitment #                                               Current Status AITTSiii implement a Training Staff Retention Plan.
The Retention Plan is to include:
1.1 issue draft rotational plan.               EX-D1-A                    Canceled.
97008316-64                Change Justification: The original closure of this item was determined to be inadequate. This item is being canceled and will be tracked with the corrective action: " Receive Executrve Council approval on rotational plan policy." Refer to Memo MJR-97-039.
The original corrective action for development and implementation of a rotational plan was split into tt ee different assignments and the original assignment was superseded. This corrective action is one of the three
                                                                                            <                            corrective actions created as a result. This change also clarified the wording to better define the deliverables. The Rotational plan was presented to the Executive Council on 5/29/97.
1.2 Receive Executive Council                  EX-D1-B                    Due: 12/30/97 approval on rotational plan 97008316-65                Change Justification: The original corrective action for development and policy.
implementation of a rotational plan was split into three different assignments and the original assignment was superseded. This correctrve acticn is one of the three corrective actions created as a result. This change also clarified the wording to better define the deliverables. The due date was extended from 6/1/97 to 12/1/97 in order to allow time for thcrough review and approval and to provide additional time for management reviews.

l                       U.S. Nuclear Regulatory Commission                               Status of B16811%ttachment 21 Page 16                       . Corrective Action Plan Corrective Action               Commitment
* Current Status AITTS #
1.3 Issue interim retention plan for               EX-D1-C       Due: 6/10/97 OTB instructors.                         97008316-66   COMPLETED: 6/4/97 Interim rotational plan was issued on 6/4/97. Refer to memo RNJ-97-038.
Change Justification: The original corrective action for development and implementation of a rotational plan was split into three different assignments and the original assignment was superseded. This corrective action is one of the three corrective actions created as a result. This change also clarified the wording to better define the deliverables. The due date was extended from 6/1/97 to 6/10/97 in order to allow time for                          4 thorough review and approval and to provido additional time for management reviews.
2.1 Draft succession plan submitted EX-D2-A                      Canceled.                                                                                        t to Director, Nuclear Training. for 97008316-37   Change Justification: The original closure of this item was determined to be                     l review.
inadequate. This item is being canceled and will be tracked with the correctrve action: " Director, Nuclear Training, approve Succession Plan for                     ;
* Training." Refer to Memo MJR-97-039.
The original corrective action for development and implementation of a succession plan for all key training positions was split into two differerit assignments and the original assignment was superseded. This corrective action is one of the two corrective actions created as a result. This char ge ialso clarified the wording o better define the deliverables. The due date lwas extended from 8/1/97 to 12/1/97 in order to provide additional time for management reviews and to allow time for the Executive Training Councii
,                                                                                               (ETC) review and approval process. Subsequently reopened as the plan submitted was determined to be inadequate.
l

U.S. Nuclear Regulatory Commission                   Status of Bt6811%ttachment2\ Page 17                   Corrective Action Plan
                                                                                                                                                                           }
Corrective Action               Commitment #                                    Current Status AITTS #
2.2 Director, Nuclear Training.      EX-D2-8          Due: 12/1/97.
approve Successica Plan for 97008316-67      Change Justification: The original corrective action for development and Training.
mplementation of a succession plan for all key training positions was split into two different assignments and the original assignment was                                                 ;
superseded. This corrective action is one of the two correcbve actions created as a result of this decision. The other action (EX-D2-A ) has been
!                                                              canceled. This change Ao clarified the wording to better define the                                            !
deliverables. The due date was extended from 8/1/97 to 12/1/97 in order                                        '
4 to provide additional time for line management reviews and to allow time for the Executive Training Council (ETC) review and approval process.                                          j Selection Process and Cnteria for Program Entry and NRC Exam Note: Corrective actions a-c must be accomplished to complete IRT Recommendations 4.5.3.A -4.5.3.C l
Establish a formal license candidate        SP-A             Due: 7/25/97 selection process and promulgate as an 97008316-38      COMPLETED: 7/25/97 intemal NU document.
CNO and NTD Director approved NTM-7.078 Reactor Operator / Instant                                             ,
Senior Operator Candidate Selection Process, Rev 0, effecthre 7/25/97.
Change Justif' cation: The due date was extended from 7/1/97 to 7/25/97 in order to a!Iow time to blend 3 unit-specific approaches into a single                                          i approach for all Millstone Units.                                                                              ,
Evaluate current assessment and            SP-B             Due: 6/10/97 remediation processes oflicense 97008316-39      COMPLETED: 6/10/97 candidates and enhance .m appropriate to ensure candidates' readiness to be                           Completion was documented in Memo JFS-97-017.
cxamined.

U.S. Nuclear Regulatory Commission B16811\ Attachment 2\ Page 18 Status of Corrective Action Plan
[
Corrective Action                Commitment #                                   Current Status i      AITTS #
. Issue Chief Nuclear Officer expectations on SP-C              Due: 8/22/97 the Operations and Training Management's 97008316-40    COMPLETED: 8/20/97 responsibilities associated with the selection, assessment and remediation                         Completion was documented in Memo NSC-97-017.
.  . processes-                                                    Change Justification: Completion of this corrective action was tied to establishment of a formallicense candidate selection process and promulgation as an intemal NU document. As a result of extending the due date for that corrective action, the due date for this action had to be
                                                                  ; extended from 7/15/97 to 8/22/97.
Maintenance of Proaram and Student Records Note: Corrective actions a-f must be accomplished to complete IRT Recommendations 4.6.3.A - 4.6.3.C.
A record review of the MP1 LOUT class          MR-A            COMPLETED: 3/3/97 (ACR M1-97-0117) for this class has been       N/A             Completed prior to initial submittal of CAP on March 31,1997 completed. The license applications (398
[ Reference (d)].
Forms) have been withdrawn.
Complete implementation of Northeast           MR-B            Due: 2/28/98.
Utilities Training information Management 97008316-41     Change Justification: Due date extended from 1/5/98 to 2/28/98 dua to System (NUTIMS). During the transition to resource limitations.
NOTIMS, establish expectations for records management for the interim period (to include expectations for use).               ;
4                                                                                                                                                                    F

U.S. Nuclear Regulatory Commission               Status of B16811%ttachment 2i Page 19               Corrective Action Plan Corrective Action           Commitment #                                Current Status AITTS #
iDevelop an enhanced review and approval MR-C            Due: 12/30/97 process for the NRC Form 396/398. Revise                The enhancements to the process for review and approva! of the NRC 97008316-42 and implement the requisite procedures (t Form 398 were implemented on June 10,1997 with the issuance of OTBI-2 nclude clearly defined owners, roles, (Rev. 4) and OTBI-7 (Rev. 0). The enhancements to the process for responsibilities and expectations).
review and approval of NRC Form 396 were impleme.1ted at Millstnne Station on June 6,1997, with the issuance of ' Medical Department instruction - Operator License 396 Submittals (MDi-12).'
Change Justification: Reopened as a result of numerous Condition Reports written conceming submittal of updated NRC Forms 396 since the original action was compseted. A Condition Report was initiated to trend this issue.
This activity was re-opened to track completion of the associated root cause and corrective actions. Refer to Memo MJR-97-050.
It was determined that enhancements to the process for revieve and approval of NRC Form 396 process at HNP were not warranted.
Issue Chief Nuclear Officer expectations  MR-D          Due: 6/15/97 conceming the enhanced 396/398 process. 97008316 4 3 COMPLETED: 6/13/97 The Chief Nuclear Officer's expectations for Millstone Station submittal of NRC Forms 396 and 398 were issued by mamo (NSC-77-025) on 6/13/97.
Issuance of the Chief Naclear Officer: expectations for HNP submittal of NRC Forms 396 and 398 was determined to be unnecessary.
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U.S. Nuclear Regulatory Commission                    Status of B16811%ttachment 2\ Page 20                    Corrective Action Plan Corrective Action              Commitment #                                 Current Status AITTS #
Based on the findings in Operating Training MR-E           Due: 12/10/97 Branch (OTB), assess the current state of                  Change Justification: Reapened - Due te limited resources, the original due 97008316-44 records management practices in all                        date was extended from 6/20/97 to 7/30/97. Subsequently, the correctice remaining areas of NTD, to include analys.ts               action was closed due to the Technical Training Branch analysis isst,ed on cf weak areas and recommendations for                      6/20/97. However, Engineering Support Program and Professional impro"ement.
Development Group have not yet completed the analysis. Refer to Memo MJR-97-051.
Perform an evaluation of the                 MR-F          Due: 12/10/97.
implementation of OTBI-5," Maintenance of 97008316-45   Change Justification: The wording on this ccmmitment was revised to Training Records and Files," to determine if better define the deliverables. Due to an increase in the scope that               .
It has been effective. Apply the results of required implementing a new standard, assessing the effectiveness of the this evaluation to the existing programs solutions implemented in OTB, and determining their applicability to the and/ practices with Technical, Engineering other NTD branches, the original due date was extended from 7/20797 to Support, and Professional Development 12/10/97.
training programs. Revise these programs as necessary. Issue these documents from                   This Corrective Action is on the Significant items List for Unit 3 and is tied the Director, Nuclear Training, with the                   to Unit 3 restart.
appropriate expectation. Revise as necessary the self-assessment program within the NTD to include an assessment on the effectiveness of the revised practices.

'l U.S. Nuclear Regulatory Commission                    Status of                                                                             .
816811%ttachment 2\ Page 21                   Corrective Action Plan Corrective Action               Commitment #                                   Current Status AITTS #
T.r_ainina Materials Note: Corrective actions a-e must be accomplished to complete IRT Recommendations 4.7.3.A - 4.7.3.E.
During the assessment and upgrade of         TM-A            Due: 4/15/97 training materiale phase, establish           97008316-46     COMPLETED: 6/30/97 cxpectations for the standards of tra. .ining materials prior to being used for training.                   Expectations were issued in memorandum RNJ-97-015 Expectations for Procedural Compliance, dated 4/15/97. Due to the fact the expectations for training materials were issued in conjunction with the expectations for procedural compliance, Nucleas Oversight felt that they did not star,d alone. More complete cicsure of this item was obtained with the issuance of the Nuclear Training Restart Process Instruction en June 30,1997.
Refer to Memo MJR-97-049.
Evaluate the current method in the N' M for TM-B             Due: 12/31/97.
maintaining and upgrading training            97008316-47     Change Justification: Reopened as the result of identified weaknesses in materials based on plant configuration                        the procedure review process in NTD. Refer to Memo MJR-97-046, ch nges (Plant Design Change Record
[PDCR), procedure changes, etc.). This review is to include recommndations for improvement. Revise process to ensure standards are maintained.
k l

U.S. Nut. ear Regulatory Commission                         Status of B16811%ttachment 2\ Pane 22                          Corrective Action P!an
* Corrective Action                Commitment #                                 Current Status AITTS #
Develop an assessment process to allow for TM-C               Due: 5/20/97 the eva!uation o.'the current state of training 970083164 8 COMPLETED: 6/30/97 materials m all NTD programs.
This item was originally closed to MJR-97-008, NTO Training Materials Assessment Process TM-C, dated 5/20/97. This memorandum outlined a proposed assessment process which was not utilized due to the Training Standdown that occurred a month later. Completion was actually obtained with the issuance and impiementation of the Nuclear Training Restart                               ;
Process Instruction (issued on June 30,1997). Refer to Memo MJR I                                                                  049.
Implement an assessment process to              TM-D          Due: 6/1/97 evtluate the condition of training materials,   970083164 9   COMPLETED: 11/7/97 process to include the analysts and prioritization of findings and guidance o.,                   This item was originally closed to MJR-97-008. NTD Training Materials the actions to be taken.                                      Assessment Process TM-C, dated 5/20/97 which was not implemented as described. The Nuclear Training Standdown occurred on June 27,1997, during which the Nuclear Training Restart Process Instruction was implemented, and has since been superceded by NTM 5.05 and NTM 5.06. All training materials are required to undergo a thorough SAT process review prior to use. Implementation of the process instruc' ion and the current NTM requirements accomplishes the training material review process outlined in MJR-97-008. Refer to Memo MJR-97-045.

U.S. Nuclear Regulatory Commission                         S2atus of 816811%ttachment 2\ Page 23                        Corrective Action Plan
* Corrective Action                 Commitment #                                   Current Status AITTS #
Develop Continuing Instructor Training         TM-E            Canceled (CIT) modules for the SAT process.              97008316-50    Change Justification: This item duplicated the function of the corrective action contained within Systematic Approach to Training (SAT) which stated, " Enhance the Continuing Instructor Training (CIT) program to include increased emphasis on SAT process." Refer to Memo MJR-97 048.                                                                        _
NRC Exam, Review, and Validation Note: Correciive actions a-f must be accorcolished to complete IRT Recommendations 4.8.3.A - 4.8.3.D. Correctue actions contained within this section apply only to Operator Training Branch.
Utilizing industry best practices, enhance      NE-A           Due: 8/1/97 the NTD's current examination bank              97008316-51    COMPLETED: 8/1/97 process. Develop a new standard for examination bank quality.                                      OTBI-9. Exam Bank Process Control Instruction, Rev. O was approved on 8/1/97.
Change Justification: The original due date was extended from 7/1/97 to o                                                                 8/1/97 in order to allow sufficient time to perform benchmarking against other utilities.
Evaluate the current examination banks to       NE-B           Due: 8/20/97 the new examination bank quality standard.
97008316-52    COMPLETED: 8/29/97 Change Justification: The original de date was extended from 7/20/97 to 8/20/97 in order to allow sufficient tir.t to perform benchmarking against other utilities.
t i

U.S. Nuclear Regulatory Commission                    Status of                                                                            ,
B16811%ttachment 2\ Page 24                    Corrective Action Plan                                                                     y Corrective Action              Commitment #                                  Current Status AITTS #
Develop a plan and schedule for the          NE-C          Due: 8/29/97 cxamination bank upgrade to the new 97008316-53   COMPLETED: 8/29/97 standard based on the evaluation find.ings.
Change Justification: The original due date was extended from 8/1/97 to 8/29/97 in order to allow suffic;ent time to perform benchmarking against other utilities.
Evaluate NTD's current review and            NE-D          Due: 6/1/97 validation process for examination approval; 97008316-54   COMPLETED: 5/30/97 to include roles and responsibilities for Training and Line Management. Revise the                   Corr.pletion was documented in Meme JFS-97-015.
process as necessary.
Provide expectations and training to all     NE-E          Due: 6/15/97 personnel involved in examination review 97008316-55   COMPLETED: 6/13/97                                                              .
and validation, based on the new review                                                                                                    :
and validation process.                                    Completion was documented in Memo JFS-97-018.'
During the evaluation and upgrade process, NE-F            Due: 5/15/97 establish interim expectations that the new 97008316-56   COMPLETED: 5/15/97 cxamination standard will be utilized.
Completion was documented in Memo JFS-97-011.
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