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I-97-23 March 7, 1997
NOTE TO EDITORS:
The Nuclear Regulatory Commission staff issued the attached confirmatory action letter to Northeast Utilities this afternoon.
Mr. Bruce D. Kenyon President and Chief Executive Officer Northeast Nuclear Energy Company P.O. Box 128 Waterford, Connecticut 06385-0128
SUBJECT: CONFIRMATORY ACTION LETTER
Dear Mr. Kenyon:
The purpose of this letter is to confirm your ongoing efforts and commitments to evaluate and correct problems found within the licensed operator training programs at Millstone Units 1, 2, and 3, and Haddam Neck. These efforts and commitments were described in a letter dated March 3, 1997, from Mr. Jay Thayer, Recovery Officer, Nuclear Engineering and Support Services.
Specifically, NRC administered senior reactor operator (SRO) license examinations to seven applicants at Millstone Unit 1 on December 2 - 6, 1996. Grading of the examinations determined that six of the seven applicants failed the examinations. Based on facility assessments of the examinations, Mr. J. Thayer commissioned an independent review of the causes of the examination failures. NRC Examination Report 50-245/96-12, dated February 7, 1997, provided the results of the examination to Northeast Utilities and requested that the results of the ongoing independent review be submitted to the NRC. Subsequently, your Independent Review Team (IRT) identified several instances in which the licensed operator training program at Millstone Unit 1 had not been completed, such that information on the operator license applications (NRC Form 398) may have been inaccurate regarding the applicants' completion of the training program. In response, Northeast Utilities began a separate review of license training programs at Millstone Units 1, 2, and 3 and Haddam Neck that had been completed over the last few years and communicated preliminary results of these reviews to the NRC on February 27, 1997.
The March 3, 1997, letter provided the IRT report regarding the recent Millstone Unit 1 examination failures, the findings regarding training program irregularities including compliance with systems approach to training at all four units, the actions taken for currently licensed operators to compensate for the findings, and commitments for ongoing evaluations and corrective action plans. Further, the letter stated that, "the NRC Forms 398 (for recent Millstone 1 applicants) were submitted to the NRC based on inaccurate information provided to those signing the forms." The letter withdrew the license applications (Form 398s) for the seven 1996 SRO applicants at Millstone Unit 1.
Also, the attachments to the letter provided the details related to efforts at each of the four units to prevent any licensed operator from performing licensed duties until all identified irregularities in their initial license training and qualification have been addressed, and until completion of the training program can be demonstrated.
Further, the attachments to the letter addressed your evaluations regarding licensed operator requalification training and short term corrective actions and concluded that it was appropriate to resume training at Millstone Units 1, 2, and 3 and to continue training at Haddam Neck. It is our expectation that facility management will ensure that these corrective actions have been implemented in a manner to enable effective training.
Based on the importance to nuclear safety of thoroughly trained licensed operators, we are confirming your written commitments in the March 3, 1997, letter. Specifically, we understand that you will:
1. Submit the complete corrective action plan, including a schedule for addressing each of the identified IRT weaknesses and a review of the extent of the problems and root causes for the training area to the NRC staff by April 2, 1997. As part of the corrective action plan, clearly define roles and responsibilities for completing NRC Form 398.
2. Complete corrective actions for the Millstone Unit 1 LOIT/LOUT (licensed operator initial/upgrade training) program prior to restarting respective classes.
3. Complete corrective actions for the Millstone Unit 2 LOIT program prior to restarting LOIT classes.
4. Complete corrective actions for the Millstone Unit 3 LOIT/LOUT program prior to NRC examinations of the current LOIT/LOUT class.
5. Conduct a thorough review of the Millstone Unit 3 LOIT program against the accredited program requirements prior to submittal of the license applications to the NRC.
6. Forward the scope of NRC Form 396 (medical certification) process review and its expected completion date for Millstone Units 1, 2, and 3 and the Haddam Neck plant (HNP) by April 2, 1997.
7. Submit the results of HNP data reviews of LOIT/LOUT findings to the NRC by April 2, 1997.
8. Submit the results of initial reviews of additional classes on all the units to the NRC by March 15, 1997.
9. Complete specific reviews of the HNP LORT (licensed operator requalification training) program by April 4, 1997.
Further, in discussions with Glenn Meyer, NRC, Region I on March 6, 1997, Mr. J. Thayer confirmed that the "complete corrective action plan" discussed in item 1 above would address Northeast Utilities' efforts to provide the necessary assurance that the skills and abilities of all currently licensed operators meet facility standards.
None of these commitments shall preclude you from taking actions as necessary to ensure the health and safety of workers and the public, protect the environment, and comply with applicable regulatory requirements.
Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, you are required to:
1) Notify us immediately if your understanding differs from that set forth above;
2) Notify us if for any reason you cannot complete the actions within the specified schedule and advise us in writing of your modified schedule in advance of the change; and
3) Notify us in writing when you have completed the actions addressed in this Confirmatory Action Letter.
Issuance of this Confirmatory Action Letter does not preclude issuance of an order formalizing the above commitments or requiring other actions on the part of the licensee, nor does it preclude the NRC from taking enforcement action for violations of NRC requirements or other actions as appropriate that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, and your response will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding [e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information]. If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Sincerely,
ORIGINAL SIGNED BY:
Hubert J. Miller Regional Administrator NRC Region I
ORIGINAL SIGNED BY:
William D. Travers Director Special Projects Office Office of Nuclear Reactor Regulation
Docket Nos. 50-213, 50-245, 50-336, and 50-423
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