ML20077G284

Forwards Nuclear Planning,Licensing & Budgeting Self-Assessment of Completeness & Accuracy of Outgoing NRC Correspondence in Response to Concern Re Process Used by Nu to Ensure Docketed Info Contained in Unit 2

ML20077G284
Person / Time
Site:	Millstone
Issue date:	11/28/1994
From:	Kacich R NORTHEAST UTILITIES, SEP OWNERS GROUP
To:	Blough R SEP OWNERS GROUP
References
NUDOCS 9412200038
Download: ML20077G284 (23)

Text

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_ - RICHARD H. KACICH u,

DIRECTOR

[; NUCLEAR PLANNING, LICENSING & BUDGETING N!;k '

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November 28, 1994 hi y

a TO: Randy Blough 15 ' '

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During a meeting at CY on 8/30/94 between GI l

' hQf' ~ John Opeka, Tim Martin and yourself, you

1. 1. expressed a concern regarding the process igi

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used by NU to ensure docketed information contained in a Unit 2 letter (8/23/94)

I gg regarding the RCP oil collection piping /

ay U Appendix R issue.

h?' In light of this, for your information, I  !

y;' have enclosed a copy of a recently completed l Lp s;,

self-assessment on the completeness and

( 142 accuracy of out-going correspondence.

i h Should you have any questions regarding the l f)? report, please contact either Mike Wilson I

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dg 203/440-2081 or myself at 440-2076.

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NUCLEAR ~ PLANNING, LICENSING AND BUDGETING

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SELV-ASSESSMENT OF COMPLETENESS AND ACCURACY OF >

OUTGOING NRC CORRESPONDENCE' l -

Self-Assessment Team William J. Quinlan James M. Peschel Robert S. Royce .s .

William J. Temple A November 9, 1994

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~ EXECUTIVE

SUMMARY

The assessment team did not identify any recurring, historical problems with 10'CFR 550.9(a) compliance. However, at least four submittals to the NRC in the last-12 months have contained erroneous _ factual information that required subsequent correction or clarification. In addition, the assessment team identified a fifth recent-submittal that contains either erroneous or misleading statements which likely will require correction. The assessment team believes that this near-term trend raises sufficient concern to recommend changes to the preparation, review, and approval process for outgoing NRC correspondence.

The assessment team has found that the basic process for preparing, reviewing, and approving NRC correspondence is consistent with the approach taken by other utilities, and-does-provide a framework for producing complete and accurate submittals. The recent series of problems have developed primarily as a result of_ inadequate implementation of the 7

process. This conclusion is similar to the findings of an independent review, conducted by Nuclear Safety Engineering, which evaluated errors found in a 1986 Mills"one Unit 1 exemption request under 10 CFR 550.49 for two valves in the Reactor Water-Cleanup system.

The assessment team believes that both Nuclear Licensing and the line organization understand their respective roles and responsibilities for the completeness and accu acy of NRC submittals. Both entities appear to understand the importance of 10 CFR 550.9(a) compliance, and the expectations of senior management in this regard have been communicated effectively.

.1 However, the assessment team believes that certain process l modifications are necessary to prevent recurrence of completeness and accuracy problems. The most important step is ensuring that the appropriate (i.e., most knowledgeable) line organization ,

staff are involved throughout the preparation, review, and '

approval process. The assessment team concludes.that there is no substitute for initial technical and factual inputs which_are complete and accurate. In addition, reviewers must be instructed to verify, to the maximum extent possible, the existence of objective evidence in support of a submittal's factual assertions. ,

The assessment team also recommends that a department with lead R technical responsibility be clearly identified for each l submittal, and that this department accept overall responsibility '

for the completeness and accuracy of the. correspondence. The assessment team believes that the existing process, multiple reviewers with similar responsibilities, dilutes the review process and results in situations where no one is taking ownership from a completeness and accuracy perspective. The i 2

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L assessment team believes that establishing a single. point of contact will result in increased accountability. Since.

management generally delegates the detailed review function, the assessment team believes that both.the; responsible. manager and

the delegatee be signatories for-the lead line organization.

Further, the' final sign-off by the. lead organization should not occur until all other' comments have been reconciled'.

The assessment team also believes that. process improvements can be realized by increasing cc.mmunication and teamwork between Nuclear. Licensing.and the responsible line organizations. The selection of. reviewers is one area in which early coordination is

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warranted. In addition, Nuclear Licensing staff should assist line management in communicating the importance of 10 CFR S50.9(a) compliance and industry lessons learned to line organization members.

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, , a I A. INTRODUCTION ,

Purnos_g The subject topical _ team assessment was performed.to evaluate.thefcompleteness and accuracy of correspondence submitted to the Nuclear Regulatory' Commission (NRC) by Nuclear Licensing (:NL) pursuant to NGP 4.01, " Communications with the Nuclear Regulatory. Commission." The intent'of the assessment team was to identify the existence of any b

favorableLor adverse trends and provide recommendations ~for improving the effectiveness of the assessed activities.

Scope

-The scope of the assessment was limited to correspondence submitted under the signature of the Executive Vice President-Nuclear, and therefore did not address correspondence submitted directly by the_ individual units.

Assessment Team Leader:

W. J. Quinlan Attorney Assessment Team Members:

J. M. Peschel North Atlantic Regulatory Compliance-Manager W. J. Temple Senior Analyst - Nuclear Licensing R. S. Royce Millstone Operator Training Instructor B. ASSESSMENT METHODS The assessment team performed its evaluation in accordance with NGP 2.38, " Nuclear Assessment Program" and the sub-tier

" Nuclear Planning, Licensing and Budgeting Self-Assessment Program" procedure. In general, the assessment team reviewed existing processes, procedures and a representative sample of recently docketed correspondence to ascertain the degree of compliance with the 10 CFR 550.9(a) requirement that information provided to the NRC by a licensee be complete and accurate in all material respects. The assessment team focused specifically upon the current approach, as detailed in Nuclear Licensing Branch Procedure NL 3.010, " Nuclear Regulatory Commission Correspondence,"

used to prepare, review and approve such outgoing

> correspondence.

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The assessment team conducted the following specific activities:

e A historical review consisting of an electronic keyword search and subsequent hard copy evaluation of correspondence submitted to the NRC between January 1, 1992 and May'31, 1994, e An independent review of celected correspondence, Submitted to the NRC between June 6, 1994 and July 5, 1994. ,

e A comparative analysis of internal processes and process information solicited from other utilities, including some who have received Notices of Violation cited against 10 CFR S50.9 and others who are reported-to have superior performance in the nuclear licensing area.

e An informal root cause evaluation of four recent NL submittals that were known to have completeness and accuracy problems.

• Interviews with key NL personnel and line management from each of the three Millstone units.

C. BACKGROUND As background, a chronology of relevant even a is contained in Appendix 1.

D. FINDINGS I. Illstorical Review To identify the existence of any discernible trends, the assessment team conducted an electronic search on NL's Licensing Information Search Tool (LIST) for previous submittals that contained either incomplete or inaccurate information which subsequently required correction or clarification. Various search techniques, focusing on certain key words, were employed by the assessment team during this effort.

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i 'The LIST search was conducted on outgoing correspondence submitted to the NRC-from January"1, 1992'through'May. 31,' 1994.' In that timeframe,.a total of 780 letters (307 'in- 1992, - 339 in 1993, and 134 through May 31, 1994) were submitted.to the.tGUC. The keyword searchsidentified. numerous submittals~that required further-review. The assessment. team'found ultimately that the majority of.these.submittals were responses to NRC questions concerningl proposed changes to plant. technical specifications. In addition, the assessment team identified a number of instances where minor corrections (i.e., typographical errors) and clarifications were required.for various submittals.

Appendix 2 provides'a description of these submittals.

The assessment team concluded that with one' exception, none of these corrections involved erroneous L information that would meet the materiality criteria under 10 CFR 550.9(a).

The one significant correction that the assessment team identified during this review. relates to a CYAPCO letter (COTRAP #B14585) submitted to the NRC.on November 1, 1993. This letter erroneously stated that

. 83 human engineering deficiencies (HED) were completed during the cycle 17 refueling outage. A subsequent letter (COTRAP #B14766), dated April 25, 1994, corrected the earlier correspondence and stated that not all HED's had been completed as previously.

reported. The assessment team believes'that this instance met the materiality criteria of 10 CFR S50.9(a).

Overall, the assessment team concluded that, based solely on the results of the electronic search, no-recurring long-term problem has existed with respect to the completeness and accuracy of outgoing NRC correspondence.

II. Indeoendent Review The assessment team performed an independent review of the technical completeness and accuracy of selected  ;

correspondence from a randomly chosen month. The  ;

chosen time period was June 6, 1994 to July 5, 1994. )

i Of the approximately thirty letters submitted to NRC-l during this period, four which contained technically i complex information were selected by the assessment i team for review. Appendix 3 lists P.he four submittals i that were reviewed.

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, Lone;of{the1submittals (COTRAPi#B14863),1concerning the g Millstone, Unit l3, fire' protection. system,fcontained.

L .certain.technicalirepresentationslwhich theiassessment L team believed-to be erroneous.or1 misleading!. :The:

assessment team'has reported the potential problemsLtol

, ' Nuclear, Licensing management'for final' resolution. ' Thel assessment team concluded:thatLthe'three(other) .

'submittals were' generally well written and contained.no .

4 significant technical inaccuracies..

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III. Comoarative Analysis "

'- The assessment 1 team. contacted' eight other: utilities, a former e'mployee of a ninth utility, and the'Nuclea'r' Energy' Institute- to better - understand the preparation, review and; approval processes that are being: utilized in'the industry.for correspondence submitted'to the;. .

NRC. The assessment team attempted to select utilities'

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that have-had recent 10 CFR 550.9 difficulties, and' others.who have_a reputation.as; sound performersLin the ,

nuclear licensing arena. The assessment team engaged these utilities in discussions and received <copiesLof relevant-procedures in order to perform a. comparative analysis with NU's internal-processes and procedures.

Thc utilities contacted were: ,

1. Tennessee Valley Authority ,

8 North Atlantic Energy Service Corporation -

Seabrook

1. Carolina Power and Light -' Robinson & Shearon Harris

• Commonwealth Edison - Byron' 8 Northern States Power Company - Monticello

- # Omaha Public Power System

1. Union' Electric

1. Entergy --Arkansas Nuclear One

1. Georgia Power - Vogtle .

The assessment team compared ~NCP 4.01, and specifically.

the Blue Sheet process, to the procedures and processes of these other utilities. The' assessment team concluded that the general approach used by Nuclear Licensing to prepare, review, and approve outgoing correspondence is very similar to that employed by most of the utilities contacted.

The assessment team noted that some utilities'had responded to earlier completeness and accuracy problems i

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i by' introducing additional reviews or procedural controls. .The various approaches undertaken by these-utilities included:

1.- Requiring an independent review of outgoing correspondence to verify all material statements

and commitments.

2. Creating a " traveller" that would be attached to-the submittal sign-off sheet listing all. material' statements and commitments. Each statement or.

commitment would have a source document identified. The sign-off process would then require a signature verifying that use of the source document as objective evidence.to support the statement or commitment was appropriate.

3. Creating a document input list for all references that were utilized to develop the correspondence.

4. Assigning individual responsibility on a paragraph-by-paragraph basis for the accuracy and-completeness of each such paragraph,

5. Assigning a lead department within the line P organization that would be responsible for verifying the overall completeness and accuracy of the correspondence.

One utility chose not to revise their submittal procedure / process evan after experiencing a 10 CFR 950.9(a) problem. Apparently, this. utility believed that additional reviews and controls would not add quality to the process, and that the solution would be to clarify responsibilities and hold individuals accountable when the process fails. The assessment.

team noted that the concept of accountability and responsibility was a theme stressed by the utilities contacted.

The first four concepts listed were described by these utilities as time-consuming and resource intensive. In some instances, the additional controls were subsequently eliminated, and the process returned to a more streamlined process. The assessment team believes. ,

that the document input list may be a useful tool for verification of design inputs, but for the most part e would relate to a small percentage of any total document and may narrow inappropriately the focus of the review process. Likewise, the paragraph-by-paragraph approach would also focus individuals on specifically identified sections of a submittal and may 8

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. result'in.a narrow review. Finally, due to the.large volume of outgoing correspondence,1the institution of additional, time-consuming steps, such as a multi- ,

discipline independent review and a " traveller" system, l

could introduce to timeliness' problems. At this point, the assessment team does not recommend the .'

implementation of any of the first four approaches,

• however, if the recent problems persist, such measures would warrant further consideration.

By performing a comparative analysis, the assessment team concluded that NGP 4.01 provides the framework for a reasonable process of ensuring that all e correspondence to the NRC'is complete and accurate. ,

The assignment of responsibility for processing an

• outgoing submittal and for verifying technical completeness and accuracy is clear. Further, the assessment team concluded that the concept of a Blue Sheet review and approval process is basically sound.

The assessment team does however endorse a number of specific changes to the current Blue Sheet process which will improve its implementation. The assessment team believes, consistent with the fifth approach identified above, that establishing single-point- )

responsibility is an important. prerequisite to ensuring i

completeness and accuracy. -

T' Root Cause Evaluation i

The assessment team ~ reviewed in detail four recent- t known problem submittals and discussed these occurrences during the interview process. The assessment team determined that the' root cause of the erroneous information could be classified in three categories:

1. Inaccurate technical or factual input to the draft submittal followed by a failure of the Blue Sheet ~ .

review and approval process to adequately verify completeness and accuracy. In these instances, an ,

adequate implementation of the Blue Sheet procese should have corrected the errors.

Fitness for Duty '

, .. The original submittal (COTRAP #B14731), dated February I 2, 1994, stated that SmithKline Beecham Clinical Laboratories' NIDA Collection / Submission Procedures,  ;

Version 2 was provided to collection personnel. The correction submittal (COTRAP #B14794), dated April 8, 1994, stated that Version 2 of the procedure was not  !

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readily'available to collection personnel. -The assessment team concluded that the erronecus statement resulted initially from inaccurate input ~to the o c '

correspondence drafter. The appropriate.line .

1 organization provided this input,and subsequently ~  ;

reviewed theLaubmittal during.the sign off process. l This error could have been prevented either.by confirmation of the initial input or by;an' adequate verification of the factual information.during the1 Blue sheet review and approval process.

HED's The original CYAPCO HED submittal'(COTRAP #B14584),

dated November 1, 1993, stated that-the HEDs for the Group 1 Emergency Diesel Generator Controls'and the Group 2 Main Control Board were complete. The correction submittal (COTRAP #B14766),. dated April 25, 1994, stated'that one Emergency Diesel Generator HED and 25 Main Control Board HED's had not been completed at the time of the original submittal. Again, the ,

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appropriate line organization ~both provided the initial factual information and participated in the sign-off process. The assessment team concluded that this occurrence could have-been prevented either by confirmation of the initial input or by an adequate f ,

verification of the factual information during the Bluc Sheet review and approval process. t

2. Inaccurate input'to-the draft submittal due to'a f ailure of the Plant Design Change : Request . (PDCR) process. The submittal.would not be corrected by the, Blue Sheet review and approval process because the verification would have stopped with the approved.PDCR.

Annendix R The original Millstone Unit 2 submittal (COTRAP

1. B14942), dated August 23, 1994, stated that the Reactor Coolant Pump (RCP) lube oil collection system, as modified and configured, was in full compliance with 10 CFR S50.9, Appendix R,Section III, Paragraph 0, with the exception of certain seismic design criteria.

The NRC subsequently inspected the modified RCP oil collection systems and identified several concerns,-

including the absence of appropriate deflectors around two pressurized plugs on the lubrication oil coolers.

The NRC addressed these discrepancies in a September >

30, 1994 letter, and noted that in their opinion the discrepancies would not have been identified during the PDCR closecut process. The NRC expressed concern 10

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regarding the. failure of the correspondence preparation, review,.and approval process to validate the statements in COTRAP #B14942, and, requested a response t'o:

Specifically describe the process used.to ,

assemble and verify the facts that formed the basia for the letter and the conclusions reached. In particular, discuss how the interface between the site and corporate-office was managed in the development of-the letter. Also discuss process improvements ,

needed to prevent a recurrence of this type of problem.

The assessment team believes that the Blue Sheet: review

. and approval process can not be expected to provide an independent review of a PDCR. Therefore, such errors o are not likely to be prevented during the~ submittal process. However, the assessment. team did identify _a discrepancy in the documentation for the Appendix R submittal. Specifically, the Blue Sheet available to-the assessment team did not contain a signature from Unit Design Engineering. The assessment team was assured in subsequent interviewees with both.NL and.

line personnel that Unit Design-Engineering _ personnel did review the letter. Apparently,LUnit Design.

Engineering signed a different copy of the Blue Sheet, however that copy was not available to the assessment team at the time of this evaluation. While the lack of a Blue Sheet signature may not.have contributed.

significantly to the error in this instance, the assessment team considers the existing lack of traceability to be a' potential serious weakness.

3. Inaccurate input and an inadequate implementation of the Blue Sheet review and approval procesa, particularly sjth respect to establishing.the appropriate-reviewers.

Service Water The original CYAPCO Service Water submittal (COTRAP

1. B14755), dated February 22, 1994, contained certain .

inaccurate statements regarding the preparation for and conduct of ultrasonic testing (UT) .- The Blue Sheet process did not include a review by the technical.

organization responsible for nondestructive examination. The inaccurate statements required later correction (COTRAP #B14809). In this instance, NL'did not assign the appropriate reviewers for the Blue Sheet, and the other reviewers failed to detect the 11 j 1

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l shortcoming. The assessment _ team believes that a i review by the cognizant technical organization could have prevented this error. j i

In addition, this oversight was exacerbated by the

, significant involvement of senior management in the i preparation of this submittal. Thezassessment team'

. i believes that the effectiveness of the review process a may have been hampered by this involvement. In such .

cases, extra' care must be taken to ensure.that the submittal receives the same vigorous and comprehensive review that all outgoing correspondence'is entitled to.

V. Interviews The following Northeast Utilities staff were i interviewed by the assessment team:

R. M. Kacich - Director, Nuclear Planning, Licensing, '

and Budgeting M. J. Wilson'- Manager, Nuclear Licensing P. J. Miner - Senior Scientist, Nuclear Licensing' E. P. Perkins'- Supervisor, Nuclear Licensing G. P. Van Noordennen - Supervisor, Nuclear Licensing R. H. Young - Senior Engineer, Nuclear. Licensing T. G. Cleary . Engineer, Nuclear Licensing P. A. Patton - Engineering Technician, Nuclear Licensing L. M. Cuoco - Senior Nuclear Counsel L C. D. Maxson -~ Supervisor, MP1 Design Engineering W. H. Becker - Supervisor, MP1 Design Engineering P. , W. Wells - Supervisor, MP2 Design' Engineering J. B. Regan - Supervisor,'MP2 Design Engineering R. A. Andren - Manager, MP3 Design Engineering D. C. Gerber - Manager, MP3 Tech Support-The interviews targeted NL management, NL staff involved in the known problem submittals, and line organization management who are routinely involved in the preparation, review, and approval of outgoing correspondence. The assessment team used the interviews to: ,

1. Determine if personnel. clearly understand the importance of 10 CFR 550.9(a) compliance. ,

2. Determine if personnel clearly understand who is responsible for verifying that correspondence is complete and accurate.

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/ 3. Obtain the user's opinion,of the quality and clarity of H

'l NGP 4.01.

4. Analyze the approach used by NL staff-to assign Blue Sheet reviewers,

5. Determine how line managers and supervisors discharge their responsibilities under NGP 4.01.

6. ' Determine how line managers and supervisors impose accountability and provide feedback to their organizations when problems related to completeness.and-accuracy arise.

7. Assess the effectiveness of various methods used to communicate information to the line organization.

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• input and recommendations for enhancing the review and approval process for correspondence.

With regard to these eight goals the assessment team

_ concluded that: -

1. The interviewees demonstrated at least a general understanding of the requirements and.importance of 10 CFR S50.9(a).

2. Both NL staff and line personnel are fully aware and in complete agreement that.the line personnel who have knowledge for the. subject matter are responsible for verifying technical completeness and accuracy. The interviewees appear'to understand that even if'NL i drafts a submittal with input'from the line organization, that the line organization retains such-responsibility.

3. NL and line personnel' agree that overall, NGP 4.01 is clearly written and unambiguous. However,'some line, personnel stated that it is sometimes not clear which-line organization (s) has the ultimate responsibility.

for verifying completeness and accuracy when numerous departments are identified on'the Blue Sheet. Various interviewees indicated that it would be preferable to have one line organization identified as the lead department responsible for verification of the technical information, with other departments involved

. at the collective discretion of NL and the lead department.

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4. NL personnel indicated that the Blue Sheet reviewers were assigned based on NL's! assessment of their experience and knowledge of the submittal. Line management identified that in some cases key reviewers are missed or'too many reviewers are assigned. Most interviewees agreed that the completeness and1 accuracy o of outgoing correspondence :bs best achieved by ensuring.

that the most knowledgeable line. organization personnel are involved in the preparation and review process.

5. Although not normally noted on the Blue Sheets,.line management indicated that they routinely distribute submittals to personnel within their organization for >

review unless they are intimately familiar with the subject matter and believe they can sign without assistance. Some managers have these additional reviewers initial the Blue Sheet, although it is not-required by the procedure. Most interviewees indicated that specifically identifying all such. reviewers will create a sense of ownership that may improve the quality of the review process.

6. The concept of accountability was cited and endorsed by i every individual interviewed. However, no' consistent approach to imposing accountability or communicating lessons learned was apparent. In general, the line organization interviewees were-unaware of completeness-and accuracy problems that had occurred at other units

, or in the industry.

7. Various" methods for disseminating information concerning the importance of 10 CFR 550.9(a) compliance were identified. Most line organization interviewees indicated that the annual memorandum from senior.

management discussing the subject.was not effective.  ;

The Plant Incident Report (PIR) was considered by many interviewees to be an effective tool for. disseminating information and correcting problems. A number of interviewees. cited "To the Point" as an effective way '

of providing immediate information at Millstone Station. Training, both routine and following specific events was mentioned as effective in a long-term scheme. Most line personnel stated that they would be willing to discuss 10 CFR 550.9(a) compliance at their. l periodic department meetings, particularly if recent examples of problem submittals were used as lessons learned. Most interviewees agreed that briefings by NL-personnel in this regard would be beneficial and would promote teamwork.

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8. Many interviewees cited time limitations imposed during the review and approval process as a challenging obstacle to ensuring the completeness and accuracy of outgoing correspondence. However, the interviewees recognized that the most important aspect of a .

submittal is the initial development of the. technical and' factual inputs. Therefore,.there was little support for various. approaches ~taken by other. utilities which would increase the duration of the review and approval cycle to the potential detriment of the initial preparation efforts. Most interviewees seemed to recognize'the benefits of identifying clear lines of responsibility and increasing team work and communications between those involved in a particular submittal.

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E. RECOMMENDATIONS e Modify NGP 4.01 and sub-tier Nuclear Licensing procedure NL 3.01Q to formalize the following review concepts / processes:

Clear identification of the line organization that will assume primary responsibility for completeness and accuracy of the submittal. Identification should include an appropriate notice as.to what role and responsibilities are being accepted by that organization, Nuclear Licensing lead coordinates with the manager of the lead line organization to identify reviewers, both within that organization and in other organizations, Nuclear Licensing coordinates parallel review and reconciles comments with lead line organization involvement, Lead organization approves final draft of submittal, which is then processed for approval by Senior management.

• Increase sensitivity to the importance of completeness and accuracy by communicating with line organization staff the changes to the submittal process, and then providing feedback when subsequent problems are encountered either at NU or in the industry.

e' Increase the sample size of the independent review to cover a statistically significant population of submittals to determine whether the problems identified by the assessment team are widespread or isolated.

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APPENDIX 1 EVENT CHRONOLOGY DATE

SUMMARY

January 21, 1988 Manager - Nuclear Licensing issues memo (NE-87-L-70) to senior managers explaining the requirements of_the recently promulgated 10 CFR S50. 9 (a) .

February 1, 1988. ' Senior Vice President - Nuclear issues memo (NEO-88-G-081) to senior managers providing interim guidance to ensure compliance with the new reporting requirements while NEO procedures update is pending.

February 1, 1988 Effective date of 10 CFR 550.9(a)

" Completeness and Accuracy of Information."

March 10, 1989 Nuclear' Safety Engineering issues root cause determination (PC-89-030) concerning errors made during a 10 CFR S50.49 exemption request-for~two valves in the Millstode Unit'1 Reactor Water Cleanup System. The root-cause team concluded that' personnel involved'in'the-correspondence review process did not, comply with the requirements of NEO 4.01 for verifying that the. submittal was technically correct, unambiguous, legally sound and reflective of corporate position or policy.

July 7, 1989 Senior Vice President - Nuclear issues memo (NEO-89-G-448) to senior managers reemphasizing the importance of providing complete and accurate information to the NRC '

and indicating that similar memos will be issued on an. annual basis to maintain awareness of the importance of this issue.

5' ' April 23, 1992 NRC issues Information Notice 92-30,

" Falsification of Plant Record", concerning the falsification of records discovered at Seabrook Station and reminding licensees of the 10 CFR 550.9(a) requirements.

June 4, 1992 NU issues letter to the NRC (COTRAP #B14160) to NRC advising them of the PEP Action Plan for improving overall performance, including PEP Action Plan 2.3.7 that was designed to capture, organize, and maintain the licensing 17

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basis, thrreby facilitating compliance with 10'CFR 550.9(a).

October 20, 1993 NRC issues Generic Letter 93-03,

" Verification of Plant Records", reminding licensees, that the NRC may take. direct-enforcement action against,not only the licensee but also any.individualfwho deliberately causes a violation of NRC requirements, including 10 CFR 550.9.

November 1, 1993 CYAPCO letter (COTRAP #B14584) concerning human engineering deficiencies completed during the cycle 17 refueling, outage contains erroneous information. The erroneous information was subsequently corrected-in a letter dated April 25, 1994. (COTRAP

1. B14766).

February 2, 1994 CYAPCO and NNECO response.to an NRC Notice of Violation (COTRAP #B14731) contains erroneous information related to the Fitness for-Duty program. The erroneous information was subsequently corrected in a letter dated April 8, 1994. (COTRAP #B14799).

February 22, 1994 CYAPCO response to an NRC Request for- ,

Information (COTRAP #B14755) contains erroneous information related to the Connecticut Yankee service water system. The erroneous information was subsequently

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corrected in a letter dated April 26, 1994.

(COTRAP #B14809).

May 5, 1994 NU issues letter to NRC (COTRAP #B14810) informing them that PEP Action Plan 2.3.7 was fully operational. -

June 21, 1994 NRC notifies NU that the NRC Office of Investigation concluded that NU deliberately failed to provide complete and-accurate information in a November 13, 1989 letter regarding the question of management harassment, intimidation, and discrimination of a supervisory employee, but that no regulatory action was warranted.

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July 29, 1994 Director - Nuclear Planning, Licensing and Budgeting issues a memo (RMK-94-158),

regarding completeness and accuracy of outgoing correspondence, to the Executive Vice President - Nuclear responding to certain recommendation, made during an independent review of the CY Service Water submittal.

August 3, 1994 Manager - Nuclear Licensing issues memo (NL-94-264) to nuclear group management personnel providing interim guidance to address submittals to the NRC that are suspected of having incorrect information.

August 23, 1994 NNECO response to an NRC Request for Information (COTRAP #B14942) contains erroneous information related to the Appendix R requirements of the Millstone Unit 2 reactor coolant pump motor lube oil collection system.

September 7, 1994* Nuclear Tieline entry provides information concerning the importance of complying with NGP 4.01, " Communications with'the NRC."

September 30, 1994 NRC requests NNECO to respond'to certain erroneous information contained in the aforementioned [[letter::B14942, Informs That NNECO in Final Phase of Completing Mods to RCP Motor Lube Oil Collection Sys.Facility Removed from Svc on 940727 Due to RCP a Motor Lube Oil Sys Leakage Not Collected by RCP Lube Oil Collection Sys|letter dated August 23, 1994]].

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APPENDIX 2 SUBMITTALS REOUIRING MINOR CORRECTION / CLARIFICATION Date of Submittal Description May 7, 1992 Millstone Unit No. 2 letter (COTRAP

1. B14138) submitted to correct a typographical error.

June l', 1992 Millstone Unit No. 3 letter (COTRAP

1. B14146) submitted a response to a request for information .(RAI) . The NRC stated that NNECO did not provide sufficient information in a previous submittal regarding the' Inservice Inspection program.

January 21, 1993 Millstone Unit No. 3 letter (COTRAP

1. B14354) submitted a response to an RAI.

The NRC stated that NNECO did not provide sufficient information in a previous submittal regarding a snubber' functional test. The NRC, in Question No. 3, stated that "a generalization <

describing the likely cause of excessive-external loadings is unacceptably weak."

March 22, 1993 Millstone Unit No. 1 letter-(COTRAP '

1. B14413) submitted a response to an RAI.

The NRC stated that NNECO did not

> address the "special circumstances" "

pursuant to 10. CFR 50.12 (2) (v) .

July 16, 1993 Millstone Unit No. 2 letter (COTRAP

1. B14530) submitted to' advise the NRC that a phrase was inadvertently omitted from a sentence in a previous submittal.

November 12, 1993 Millstone Unit No. 1 letter (COTRAP

1. B14664) submitted a response to an'RAI.

The NRC stated that NNECO did not provide a basis or justification in a previous submittal that states why a-certain condition was. acceptable, i

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L ' APPENDIX'3

'SUBMITTALS SUBJECTED TO INDEPENDENT REVIEWE COTRAP # Subiect 'Date B1'4860 Connecticut Yankee Foxboro LED June 14, 1994 B14861 Millstone 1 TBSCCW Modification June 30, 1994 B14863 Millstone 3 Fire Protection June 6, 1994 B14875 Millstone 3 Degraded Grid Setpoint June 30, 1994 a

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