UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 

March 18, 1996

NRC INFORMATION NOTICE 96-17: REACTOR OPERATION INCONSISTENT WITH

THE UPDATED FINAL SAFETY ANALYSIS

REPORT

Addressees

All holders of operating licenses or construction permits for nuclear

power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this

information notice to alert addressees to instances of reactor

operation that may not conform to the licensing basis. It is expected

that recipients will review the information for applicability to their

facilities and consider actions, as appropriate, to avoid similar

problems. However, suggestions contained in this information notice

are not NRC requirements; therefore, no specific action or written

response is required. 

Description of Circumstances

On August 21, 1995, the NRC received a petition under 10 CFR 2.206

which was supplemented on August 28, 1995, that requested NRC to shut

down Millstone Unit 1 and take enforcement action based upon alleged

violations of licensed activities related to operation of spent fuel

pool cooling systems and refueling practices. Followup of the issues

raised in the 2.206 petition, including the findings from

investigations conducted by the Office of the Inspector General,

found that certain activities at Millstone Unit 1 may have been

conducted in violation of license requirements and that refueling

activities may not have been conducted consistent with the Updated

Final Safety Analysis Report (UFSAR). In a letter dated December 13,

1995, [Accession No 9512150278], NRC subsequently required that the

licensee submit additional information under oath or affirmation

pursuant to Section 182a of the Atomic Energy Act of 1954, as amended,

and 10 CFR 50.54(f). Specifically, the licensee was required to

report on actions taken to ensure that future operation of Millstone

Unit 1 will be conducted in accordance with the terms and conditions

of the Millstone Unit 1 operating license, the Commission regulations,

including 10 CFR 50.59, and the Millstone Unit 1 UFSAR. 

Discussion

As one element of its response to the letter of December 13, 1995,

Northeast Utilities Service Companies, the licensee for Millstone Unit

1, established an Event Response Team to determine the causes for

inaccuracies contained in the Millstone Unit 1 UFSAR. A copy of the

Executive Summary and of the text of 

the resulting licensee report is attached. The complete document,

including 

9603150213
 IN 96-17

 March 18, 1996

 Page 2 of 2

attachments, has been placed in the NRC Public Document Room (PDR) in

Washington, D.C. and the local public document rooms (LPDRs)

(Accession No. 9603150021).

The Report identifies a number of fundamental factors that led to an

inaccurate UFSAR for Millstone Unit 1. The Report states that because

of the nature of the causes that the team has identified, the

potential exists for similar configuration management conditions at

Haddam Neck and Millstone 

Units 2 and 3. As a result, the NRC issued two letters dated March 7,

1996, that are similar to the letter of December 13, 1995. Because of

a number of operability and design concerns involving Millstone Unit

2, one letter (which is attached) required the licensee to submit to

the NRC no later than 7 days before restarting Unit 2 from its current

outage the actions taken to ensure that future operation of Unit 2

will be conducted in accordance with the license, regulations, and

UFSAR. The second letter from NRC requested information from the

licensee within 30 days regarding actions taken to date and future

plans to address the conclusions expressed in the 7007 report at

Millstone Unit 3 and Haddam Neck. This letter is available in the NRC

PDR and the LPDRs (Accession No. 9603120179). 

This information notice requires no specific action or written

response. If you have any questions about the information in this

notice, please contact one of the technical contacts listed below or

the appropriate Office of Nuclear Reactor Regulation (NRR) project

manager.

signed by

Dennis M. Crutchfield, Director 

Division of Reactor Program Management

Office of Nuclear Reactor Regulation 

Technical contacts: Phillip F. McKee, NRR

 (301) 415-2040

 Internet:pfm@nrc.gov

 T. Jerrell Carter, NRR

 (301) 415-1153

 Internet:tjc@nrc.gov

Attachments: 

1. NU Report ACR 7007

2. March 7, 1996, Millstone 2 Letter

3. List of Recently Issued NRC Information Notices
ATTACHMENT 1 EXECUTIVE SUMMARY 

 

An Event Response Team was chartered to determine the causes for

inaccuracies contained in the Millstone Unit 1 Updated Final Safety

Analysis Report (USFAR). The team reviewed documents and interviewed

personnel to gather information pertaining to five areas: 1) Licensing

Commitments, 2) USFAR updates, 3) the Design Basis Document Project,

4) Administrative Controls, and 5) events and corrective actions

associated with licensing commitments and design basis. The team used

root cause analysis methods described in Nuclear Group Procedure 3.15

to determine fundamental causes and contributing factors.

The considerable scope and historical nature of this event preclude an

analysis to an absolutely strict standard and definition of root

cause. This analysis does identify the fundamental factors that led

to an inaccurate UFSAR and exacerbated the extent of the inaccuracies. 

This report also identifies generic implications and other adverse

conditions that were discovered during the investigation. This report

does not address the safety significance of Unit 1 UFSAR inaccuracies.

The Northeast Utilities 50.54(f) Project Completion Plan activities

will, when completed, ascertain the extent and safety significance of

the inaccuracies in the Unit 1 UFSAR and associated design basis

documents.

In recent years (1994-1995), NU corrected some specific UFSAR

inaccuracies as they were identified. To some degree these individual

efforts mitigated the extent of the Unit 1 UFSAR inaccuracies. These

efforts not withstanding, the era preceding these years created and

sustained the ACR 7007 event pattern through January 1996.

The fundamental causes for the Millstone Unit 1 UFSAR inaccuracies are

as follows:

! The original 1986/1987 UFSAR contained errors and omissions.

! The administrative control programs (e.g., Design Control,

Corrective Action, Commitment Tracking) did not fully address

regulatory requirements. Assuming the original UFSAR was

accurate, verbatim compliance with previous and current

administrative programs would not have maintained an accurate 

UFSAR. Corrective actions for events and internal assessments

did not fully address the adequacy of administrative programs for

meeting regulatory requirements.

! NU did not fully implement the administrative programs. NU did

not see the UFSAR as a document that was required to be accurate. 

! Internal correspondence and events involving the design basis

(e.g., NOVs, LERs) from 1985 through 1996 show a pattern of

information communicated to NU management. This information

consistently identified weaknesses and risks associated with the

UFSAR and design bases. NU management made commitments, on the

docket, to correct these deficiencies. The actions were

ineffective, partially implemented, or not done.
! NU oversight did not identify this event pattern to management,

its significance, or the effectiveness of corrective actions to

prevent recurrence.

Due to the nature of the causes identified in this report, the

potential exists for the presence of similar configuration management

conditions at Connecticut Yankee and the other millstone units. The

team cannot ascertain the full extent of the implications without a

sample similar to the set of 50.54(f) initiatives currently in

progress for Unit 1. The team recognizes that Engineering initiated

these efforts concurrent with the completion of this report.

Other adverse conditions are as follows:

! There is an organizational tendency to focus narrowly on the

technical aspects of issues and their technical resolution. This

lack of a questioning attitude inhibits the identification of

root causes, generic implication, and the corrective actions to

prevent a class of recurrent issues.

! While there is a strong emphasis on safety as a stated objective,

the organization does not consistently recognize or emphasize the

collective set of administrative (e.g., the proposed Determine

Course of Action (DCA) concept ) and technical process (e.g.,

Setpoint Control) that demonstrate and assure that objective is

met.

! There is a general lack of understanding and appreciation for the 

relationship between 10 CFR 50, design bases, licensing bases,

industry codes, and NU’s administrative programs.

! Line managers use a limited stet of tracking and trending tools. 

Task completion and scheduling compliance are the primary

management focus. There is an absence of performance or success

criteria for processes (e.g., license commitments) and programs

(e.g., corrective actions preventing recurring events).
TABLE OF CONTENTS

Cover Page 

Executive Summary ......................... 1

Table of Contents ......................... 3

1.0 Introduction ........................ 4

2.0 References ......................... 6

3.0 Persons Involved ...................... 6

4.0 Compilation of Facts . . . . . . . . . . . . . ....... 7

5.0 Conclusions ......................... 7

6.0 Corrective Actions . . . . . ................ 9

7.0 Comments . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Attachments

A. Barrier Analysis Summary . . . . . . . . . . . . . . . . 13

B. Analysis of Events Involving the Design Basis . . . . . 17

C. Administrative Programs Review . . . . . . . . . . . . . 26

D. UFSAR Update Review . . . . . . . . . . . . . . . . . . 44

E. Design Basis Documentation Program Review . . . . . . . 55

F. Oversight Review . . . . . . . . . . . . . . . . . . . . 64

G. Employee Interviews . . . . . . . . . . . . . . . . . . 65

H. References . . . . . . . . . . . . . . . . . . . . . . . 82

I. Definitions . . . . . . . . . . . . . . . . . . . . . . 95
1.0 INTRODUCTION

1.1 Event Description

The UFSAR, system description and design basis documents

contain inaccuracies.

1.2 Scope

This event analysis determined the causes for inaccuracies

contained in the UFSAR and associated documents. There are

several general considerations affecting this work scope. The

first consideration is understanding the location and role of

the UFSAR in the logic process connecting regulatory

requirements to the implementation of these requirements in

operational procedures and the physical plant. The following

model graphically depicts this logic. The documents shown

below the model are examples of applicable documents for each

step of the process. The UFSAR captures licensing

commitments, design criteria establishing the bounding

parameters for a system’s operation, the description of

physical plant, and the description of operational and

maintenance procedures. The UFSAR also describes the

commitment to implement administrative controls for the

processes associated with each logic block.

A second consideration is the evolution of changes in each of

the four logic blocks over the twenty five year operating

history of Millstone Unit 1. The event scope includes a

chronological review of the applicable process changes for the

logic blocks.

The third consideration addresses the adequacy of the process

controls and their implementation. Specifically, what

administrative controls governed the work activities

implementing regulatory requirements for each logic block and

how effective was their implementation? The adequacy of these

process controls may have generic implications and lead to

multi-unit analyses. These general considerations frame the

detailed event scope. The detailed event scope includes five

areas:

 Licensing 

 UFSAR Updates

 Design Basis
 Administrative Controls

 A review of prior internal and external

assessments 

The Licensing commitments detailed scope included a chronology

of processes used to make, manage and track commitments, the

process for ensuring that the design incorporated these

commitments, and the methods for documenting this information.

The UFSAR Update scope included a chronology of the UFSAR, the

10 CFR 50.71 (e) rule making applicability, the 1986-1987

reconstituted UFSAR process and content, the process for

incorporating subsequent updates, and the UFSAR update process

interfaces with other processes.

The Design Basis detailed scope analyzed the Design Basis

Document Project, how it reflects and incorporates licensing

commitments, interfaces and existing processes (e.g. Design

Error Detection and Correction), other design basis

documentation (e.g. calculations, drawings, specifications),

and design basis maintenance.

The Administrative Controls evaluation reviewed programs and

procedures applicable to Licensing commitments, UFSAR Updates,

changes to the UFSAR, and operational procedures resulting

from design changes, and 10 CFR 50.59 evaluations. This

review included the chronological development and evolution of

these Administrative Controls. This work scope reviewed the

adequacy of prior process controls and the effectiveness of

their implementation.

The final detailed area addressed the collective body of prior

and current corrective actions associated with Licensing

Commitments and Design Basis. This part of the evaluation

established the chronology of internal and external

assessments identifying design issue events (since 1985),

their analysis, associated corrective actions, and the

effectiveness of the Corrective Actions to preclude recurrent

design events. These events were the primary input to the

root cause analysis.
Document reviews and personnel interviews were the primary

data collection methods. The analysis involved the root cause

methods (e.g., Barrier Analysis, Event and Causal Factor

Analysis Charting, Change Analysis), actual performance for

each area, comparison of the above between each areas, and the

effectiveness of prior corrective actions.

2.0 REFERENCES

The rigor and depth of this root cause analysis led to extensive

document reviews. Attachment H lists the references used in this root

cause analysis.

3.0 PERSONS INVOLVED

3.1 Team members:

Names deleted by NRC

3.2 Individuals contacted and/or interviewed:

Design Engineering Tech. Support Engineering

Names deleted by NRC

Licensing Others

Names deleted by NRC

4.0 COMPILATION OF FACTS

Attachments A (Detailed Barrier Analysis), B (Analysis of Events

Involving the Design Bases, C ( Administrative Programs), D (UFSAR

Update), E (Design Basis Document Project), F (Oversight),

G (Employee Interviews), and I (Definitions and Criteria) comprise

the complete compilation of facts.

5.0 CONCLUSIONS

The following conclusions focus specifically on the fundamental

causes for the Millstone Unit 1 UFSAR inaccuracies. Section 7.0

lists the generic implications and other adverse conditions that

were discovered during the investigation. The analyses contained

in Attachments A- G provide the support for these conclusions. 

Attachment A is an 
analysis summary. The attachment sections supporting each

conclusion are indicated in brackets [ ].

5.1 The Unit 1 UFSAR submitted in December 1986 and March 1987

contained errors and omissions [See Attachments B,G].

5.2 Some of these errors were known by Northeast Utilities and

communicated to the NRC on the docket on multiple occasions.

[Attachment B]

5.3 Repeated commitments to provide complete and accurate

information (e.g., accurate UFSAR) to the NRC and corrective

actions to address factual errors were ineffective, not

done, or partially implemented. [Attachments A-G]

5.4 Northeast Utilities voluntarily initiated the Design Basis

Documentation Program (DBDP) to compile and summarize the

available design basis information for selected safety

related systems. Through the DBDP, NU identified that it

did not have calculations to support some parts of the

design bases. Northeast Utilities decided to reconstruct

these calculations only when required as part of a plant

modification. [Attachments B, E]

5.5 Generally, Northeast Utilities did not perceive or view the

UFSAR as a licensing basis document. They generally viewed

the UFSAR as a historical reference document that did not

have to be accurate. [Attachment G]

5.6 Regulatory requirements evolved over time. Although NU

committed to implement the applicable requirements,

administrative programs did not fully incorporate these

requirements. Assuming verbatim compliance, the

administrative controls would not assure that the design

bases were maintained or that the UFSAR was accurate. These

programs perpetuated factual errors and/or contributed to

new UFSAR inaccuracies. Some specific programmatic

weaknesses were corrected over time. Some weaknesses still

exist. [Attachment C, D]

5.7 The long term pattern of decisions and actions has generic

implications for Connecticut Yankee and Millstone Units 2

and 3. A sample of internal and external assessments and

design events (e.g., LERs) for Units 2 and 3 and Connecticut

Yankee supports the potential for generic implications. The

team cannot ascertain the full extent of the implications

without a sample similar to the set of 50.54(f) initiatives

currently in progress for Unit 1. These generic

implications do not apply to Seabrook, because both the

management team and the administrative programs affecting

Seabrook were different. [Attachments B-G]
5.8 There was a general lack of accountability and

teamwork for UFSAR accuracy. [Attachment G]

5.9 The 50.54(f) Project Completion Plan internal selfassessment addressing the underlying causes for

Northeast Utilities received the 50.54(f) letter

should address the root causes for the pattern cited

in conclusion 5.7 and comment 7.1 [NU 50.54(f) Project

Completion Plan]

6.0 CORRECTIVE ACTION

Full implementation of the current 50.54(f) Project

Completion Plan activities will correct the anomalies,

inaccuracies and omissions in the Unit 1 UFSAR. The plan

also addresses administrative control adequacy and a selfassessment of the reasons NU received the 50.54(f) letter. 

Therefore, the team recommends only two action specific to

UFSAR accuracy. Table 6.1 identifies the conclusions,

comments, and associated corrective actions.

6.1 Corrective Actions for UFSAR Accuracy

6.1.1 Conduct a verification effort, similar to the

Millstone Unit 1 effort, for Millstone Unites 2 and 3

and Connecticut Yankee. The initial efforts should

use a sampling method to ascertain the content,

quality and availability of design bases information

and the current licensing basis. The team recognizes

that Engineering initiated this corrective action

during the preparation of this report. (Refer to

Conclusion 5.7)

6.1.2 Develop and implement a Corrective Action Monitoring

Plan. (Required per NGPs 3.15 and 2.40)

6.2 Corrective Actions for Comments

6.2.1 Nuclear Group Directors should develop and conduct a

program to educate employees (including contractors

on the requirements and linkage between Title 10,

current licensing bases, industry codes, NU's

administrative programs and design activities. This

action should not be delegated. (Refer to Comment

7.3)

6.2.2 Unit 1 Engineering should take the lead for

developing measurement tools for functional area

performance (e.g., PDCR close-out. (Refer to Comment

7.6)
 Table 6.1

Conclusion/Comment Corrective Action

5.1 UFSAR submitted to NRC in

1986/87 with errors.

Addressed by 50.54(f) Project

Completion Plan.

5.2 NU knew about these errors. Historical fact; no action

required.

5.3 Commitments to correct the

errors were ineffective.

Addressed by 50.54(f) Project

Completion Plan.

5.4 Calculations did not exist

to support some of the design

bases, and were not

reconstructed.

Addressed by 50.54(f) Project

Completion Plan.

5.5 NU did not view UFSAR as a

licensing basis document.

Corrective action 6.2.1:

develop and implement

education program.

5.6 NU’s administrative

programs did not fully

incorporate regulatory

requirements.

Addressed by 50.54(f) Project

Completion Plan.

5.7 Decade-long pattern of

decisions and actions has

generic implications.

Corrective action 6.1.1:

conduct a verification effort

at MP2, MP3, CY.

5.8 Lack of accountability and

teamwork for UFSAR accuracy.

Corrective action 6.1.2:

develop and implement a

Corrective Action Monitoring

Plan.

5.9 Root cause for 5.7 will be

identified by 50.54(f) selfassessment.

Addressed by 50.54(f) Project

Completion Plan.

7.1 Issues and their causes

were identified to management;

management should have been

accountable for the corrective

actions.

Addressed by 50.54(f) Project

Completion Plan.

7.2 NU Oversight did not

identify administrative

programs weaknesses or pattern

of design control events.

Addressed by recent

reorganization and corrective

action 6.1.2.

7.3 Employees do not understand

relationship between 10 CFR,

design bases, industry

standards, administrative

programs.

Corrective action 6.2.1:

develop and implement

education program.

7.4 Organization does not

appreciate processes needed to

achieve stated 

safety objectives.

Corrective action 6.2.1:

develop and implement

education program.
Conclusion/Comment Corrective Action

7.5 Organization focuses

narrowly on problems and

their resolutions.

Corrective action 6.2.1:

develop and implement

education program.

7.6 Line managers use a

limited set of tracking and

trending tools.

Corrective action 6.2.2:

develop measurement tools

for functional area

performance.

7.0 COMMENTS

7.1 The causal factors of the Unit 1 UFSAR accuracy issue

parallel root cause themes identified in other internal and

external assessments and event analyses. (Attachment C to

the January 1996 Nuclear Safety Concerns Program SelfAssessment provides a partial listing of prior assessments

and related themes.) These assessments, across multiple

functional areas, indicate that the assessment process

worked as intended to identify issues and their causes to

management since 1985 (the period of interest). 

Specifically, internal management correspondence and event

analyses (e.g., LERs, SSFIs) periodically and consistently

provided management with information on the status of Unit

One’s design basis and UFSAR accuracy, from 1986 to present

day. Management should have been accountable for both the

adequacy of the administrative programs (e.g., Design

Control) to ensure employee success (e.g., producing an

accurate UFSAR), and for taking effective corrective

actions to prevent recurrent events. [Attachments B-E]

7.2 Until 1995, NU oversight did not identify the pattern of

adminstrative program weakenesses and envents concerning

the design bases to managment or verify the effectiveness

of corrective actions for know issues. [Attachment F]

7.3 Most of the engineers and managers contacted during this

analysis (individuals who should be well versed in design

control requirements) have not read Title 10 of the Code of

Federal Regulations, Regulatory Guides, or ANSI Standards

pertinent to design control. There is a general lack of

understanding and appreciation of the relationship and

implications between 10 CFR 50, design bases (50.2),

licensing bases, industry codes, and NU’s administrative

programs controlling configuration and design. [Attachment

G]

7.4 The team's interviews and document reviews indicate an

organizational emphasis on safety as an objective. 

However, the
organization does not emphasize or recognize the collective

set of administrative (e.g., the proposed Determine Course

of Action (DCA) concept) and technical processes (e.g.,

Setpoint Control) that demonstrate and assure that the

objective is met. For example, the team identified many

activities that could result in the need to change the

UFSAR. Each of these activities has independent

administrative controls, rendering them fully effective

only if another activity which could change the UFSAR is

not in progress. The overall UFSAR change mechanism

processes are not integrated and create the potential for

omissions and conflicts. The organization needs to acquire

a balanced perspective and appreciation for safety as both

process and objective. [Attachment G]

7.5 The "event" data for this root cause reveals an

organizational tendency to focus narrowly on the technical

aspects of issues and their technical resolution. The lack

of questioning attitude inhibits identification of generic

implications, root cause analysis, and the corrective

actions to prevent a class of recurrent issues. [Attachment

B]

7.6 This root cause analysis found that line mangers use a

limited set of tracking and trending tools. Line managers

do not use routine performance measurement tools with

defined success criteria. Ther are few objective measures

indicating the relative or actual status of overall or

specific perfrmance. For example, submittal of UFSAR

changes is required within 30 days of a PDCR being declared

operable. Neither this information nor other USFAR change

processes (e.g. Design Calculations) are tracked or

trended. Therefore, it is not possible to measure

performance to the success criteria of a UFSAR that

accurately describes the facility and its procedures.

8.0 ATTACHMENTS

Attachment A - Barrier Analyis Summary

Attachment B - Analysis of Events Involving the Design Basis

Attachment C - Administrative Programs Review

Attachment D - UFSAR Update Review

Attachment E - Design Basis Documentation Program Review

Attachment F - Oversight Review

Attachment G - Employee Interviews

Attachment H - References

Attachment I - Definitions and Criteria
Mr. Robert E. Busch ATTACHMENT

2

President - Energy Resources Group

Northeast Utilities Service Company

P.O. Box 128

Waterford, CT 06385

Dear Mr. Busch:

On December 13, 1995, the NRC issued to Northeast Utilities (NU) a

letter requesting NU pursuant to Section 182a of the Atomic Energy Act

of 1954, as amended, and 10 CFR 50.54(f) to "describe actions taken to

ensure that future operation of Millstone Unit 1 will be conducted in

accordance with the terms and conditions of the Millstone Unit 1

operating license, the Commission's regulations, including 10 CFR

50.59, and the Millstone Unit 1 Updated Final Safety Analysis Report

(UFSAR)." Since that time NRC has continued to conduct inspections

and investigations at the Millstone Station to determine the state of

compliance of NU nuclear facilities with NRC requirements. As part of

these efforts, NRC has obtained a copy of an internal NU document,

"ACR 7007 - Event Response Team Report" (7007 Report), dated February

22, 1996.

The Executive Summary of the 7007 Report states that an Event Response

Team was chartered to determine the causes for the inaccuracies in the

Millstone Unit 1 UFSAR. The fundamental causes for these inaccuracies

were found by this Team to include:

- The original 1986/1987 UFSAR contained errors and omissions;

- Administrative control programs such as Design Control, Corrective

Action, and Commitment Tracking did not fully address regulatory

requirements;

- NU did not fully implement the administrative programs. NU did not

see the UFSAR as a document that was required to be accurate;

- Internal correspondence and events involving the design basis from

1985 through 1996 show a pattern of information communicated to NU

management. This information consistently identified weaknesses

and risks associated with the UFSAR and design bases. NU

management made commitments, on the docket, to correct these

deficiencies. The commitments to correct these deficiencies were

ineffective, partially implemented, or not done;

- NU oversight did not identify this event pattern to management, its

significance, or the effectiveness of corrective actions to prevent

recurrence.

The 7007 Report further states that, due to the nature of the causes

that the Team has identified, the potential exists for the presence of

similar configuration management conditions at Millstone Unit 2. It

notes that
R. Busch -2-

without a sample similar to the initiatives currently in progress for

Millstone Unit 1 as a result of the 10 CFR 50.54(f) letter of December

13, 1995, the full implications for Millstone Unit 2 cannot be

ascertained. The 7007 Report recognizes that those efforts may be

underway. This Report also addresses Millstone Unit 3 and Haddam Neck

which we are addressing by separate letter. 

Current licensee reviews and NRC inspections of Millstone Unit 2 have

identified a number of operability and design concerns. Millstone

Unit 2 shutdown on February 20, 1996, when a potential design

deficiency was identified that could block or reduce safety injection

flow during the recirculation phase of an accident. During this

shutdown, other design discrepancies were identified in which NU had

not maintained the current design or licensing basis for Millstone

Unit 2. For example, NU's inspection of the containment sump screen

mesh revealed that debris larger than the design value could pass

through with potential adverse consequences to the emergency core

cooling systems. NU identified that the flood protection enclosure

could not be installed on one of the service water pumps that has been

relied on for ultimate heat sink operability. Further, the NRC

identified that the post-accident containment hydrogen monitor design

was flawed in that insufficient sample flow would be available at low

containment pressures when the monitor must be operable.

Consequently, there is a question as to whether Millstone Unit 2

conforms to the UFSAR, license conditions, and Commission regulations. 

Therefore, the NRC requires additional information to be submitted

pursuant to Section 182a of the Atomic Energy Act of 1954, as amended,

and 10 CFR 50.54(f) in writing, under oath or affirmation, to

determine whether or not the license for Millstone Unit 2 should be

suspended, modified, or revoked. The information is to be submitted

no later than 7 days prior to Millstone Unit 2 restart (prior to

criticality) from its current outage and is to describe actions taken

to ensure that future operation of Millstone Unit 2 will be conducted

in accordance with the terms and conditions of the Millstone Unit 2

operating license, the Commission's regulations, including 10 CFR

50.59, and the Millstone Unit 2 UFSAR.

The submittal should describe actions taken to assure that

deficiencies identified at Millstone Unit 2 based on your ongoing

review have been evaluated for operability, existence of unreviewed

safety questions, and reportabilty. In particular, seriously degraded

conditions must be reported pursuant to 10 CFR 50.72(b)(2)(i) and

50.73(a)(2)(ii).

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a

copy of this letter and your responses will be placed in the NRC

Public Document Room (PDR) the Gelman Building, 2120 L Street, NW.,

Washington, DC, and in the local public document room located at the

Learning Resources Center, Three Rivers Community-Technical College,

574 New London Turnpike, Norwich, CT 06360. The NRC also intends to

place in the PDR a copy of the 7007 Report on March 15, 1996, unless

you provide a sufficient basis to withhold this Report by March 12,

1996. Any request for withholding must be accompanied by a bracketed

copy of the Report that identifies the information that you seek 
R. Busch -3-

to have protected and a redacted copy that deletes such information. 

You must provide for each portion of the document you seek to be

withheld the bases for your claim of withholding. 

Sincerely,

William T. Russell, Director

Office of Nuclear Reactor Regulation

Docket No. 50-336

cc: See next page

Waterford, CT 06385