L-16-160, Pant - Response to Request for Additional Information Regarding VIO 05000440/201510-01
| ML16169A103 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/14/2016 |
| From: | Hamilton D FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16169A136 | List: |
| References | |
| IR 2015010, L-16-160 | |
| Download: ML16169A103 (30) | |
Text
{{#Wiki_filter:FENOC' Perry Nuclear Power Plant P.O. Box 97 10 Center Road Perry, Ohio 44081 RrstEnergy Nuclear Operating Company David B. Hamilton 440-280-5382 Vice President PERSONALLY IDENTIFIABLE INFORMATION - WITHHOLD UNDER 10 CFR 2.390 (May be decontrolled upon removal of enclosures A, B, C and E) June 14, 2016 L-16-160 10 CFR 2.201 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Regarding VIO 05000440/2015010-01 By correspondence dated January 15, 2016, (Accession No. ML16020A453) FirstEnergy Nuclear Operating Company (FENOC) submitted a response to notice of violation (VIO) 0500440/2015010-01, Unqualified Radiation Protection Manager. By correspondence dated February 1, 2016, (Accession No. ML16033A194) the NRC requested additional information to complete the staff's review. FENOC's submitted a resporise on February 24, 2016, (Accession No. ML16057A810). By correspondence dated April 19, 2016, (Accession No. ML 116110A423) the NRC requested additional information pertaining to FENOC's initial response for additional information. The additional information is contained within Attachment 1. A teleconference was held with NRC Region Ill staff on May 3, 2016, to clarify the requested additional information. At this time an extension to the required response was approved to allow FENOC time to address NRC staff concerns and facilitate additional discussions prior to final submittal. Enclosures A, B, C and E contain personally identifiable information and should be withheld from public disclosure under 10 CFR 2.390 There are no regulatory commitments contained in this letter. If there are any questions, or if additional information is required, please contact Mr. Nicola Conicella, Manager - Regulatory Compliance, at (440) 280-5415. Sin~n ~ ~~ oavi~s.Z:!'
L-16-160 Page2
Attachment:
- 1. Second Response to Request for Additional Information Regarding VIO 05000440/2015010-01 Enclosures A. NOP-SS-4002-01, Personnel Qualification Checklist B. Fleet Oversight Memo FMOV 15-001 C. DSO Memo to File D. USAR Change Notice 16-085 E. GPM Memo Designating Tee. Spec. Qualified RPM and Radiation Protection Department Brief F. Condition Report 2016-06326 cc: NRC Region Ill Administrator NRC Resident Inspector
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Attachment 1 L-16-160 Second Response to Request for Additional Information Regarding VIO 05000440/2015010-01 Page 1of5 L-16-160 Page 2 of 5 By correspondence dated January 15, 2016, (Accession No. ML16020A453) FirstEnergy Nuclear Operating Company (FENOC) submitted a response to notice of violation (VIO) 0500440/2015010-01, Unqualified Radiation Protection Manager. By correspondence dated February 1, 2016, (Accession No. ML16033A194) the NRC requested additional information to complete the staff's review. FENOC submitted a response on February 24, 2016, (Accession No. ML16057A810). By correspondence dated April 19, 2016, (Accession No. MLx116110A423) the NRC requested additional information pertaining to FENOC's response to the request for additional information. The request for additional information (RAI) is presented in bold type, followed by the FENOC response. The failure to implement a formal process to resolve questions and issues regarding the incorrect conclusion determined by NOP-SS-4002 does not address the issue that NOP-SS-4002 failed to identify that the candidate for Radiation Protection Manager did not meet the minimum requirements of your license to operate the nuclear power plant. Your response indicates that your selection, qualification, and verification process (procedure NOP-SS-4002) did not ensure that the Radiation Protection Manager was qualified for the position before designation. Your response also indicates that NOP-SS-4002 does not need to be revised 11nd therefore, may suggest that the instructions were not implemented as written. The response provided does not fully address the concern that NOP-SS-4002 was not implemented as written and therefore, we are requesting additional information to help in our review. Please indicate if NOP-SS-4002 was implemented as written. If it was, please indicate how it was determined that no revision was necessary; if it was not, please indicate why. In addition, please provide any and all data associated with the selection of the candidate and the verification that the candidate satisfied the minimum requirements for Radiation Protection Manager. Please include a timeline for these activities.
Response
NOP-SS-4002 was implemented as written. This procedure provides the methods and requirements to verify that the education and experience of personnel selected to fill positions that meet the functional levels and responsibilities detailed in ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, meet or exceed the minimum qualifications listed in this standard. This includes Nuclear Regulatory Commission license requirements. The procedure is generic in nature and references the specific regulatory guidance to ensure proper qualifications are met. In this case, RG 1.8 was referenced within the procedure to ensure compliance with the requirement for the Radiation Protection Manager (RPM). The reason for the violation was the failure to implement an available formal process (i.e., Corrective Action Program, Operational Decision Making, etc.) when the qualifications of the designated RPM were questioned. Therefore, inputs from different organizations, and new facts (i.e., level of commitment to Regulatory Guide 1.8 - September 1975) were not documented, considered or addressed in a formal process to ensure risk was addressed and the proper decision was made. When performing the review of the RPM candidate's qualifications it was mistakenly determined the candidate was qualified based on credit for experience as a radiation protection technician, L-16-160 Page 3 of 5 specific radiation protection related assignments and as a licensed SRO qualified as a Unit Supervisor meeting the professional experience requirements. The basis for determining the RPM candidate met the professional qualification requirements is the interpretation of the Technical Specification 5.3.1 requirement as meaning the RPM qualifications shall be in accordance with Regulatory Guide 1.8-1975 not ANSI N18.1-19-1971. Therefore, the regulatory guide specifies requirements that the RPM "should" meet as opposed to "shall" meet. NUREG/CR-5569 Rev. 1, Health Physics Positions Data Base, HPPOS-113, was referenced in making this determination. HPPOS-113 states: "Enforcement can be made against those sections of the Regulatory Guides referenced in the Regulations as "shall", but enforcement cannot be made against those sections which are recommended "should" or allowed as optional "may"." A corrective action was implemented to provide a lessons learned presentation of this violation for all Perry Nuclear Power Plant (PNPP) management and designated FENOC management and Oversight personnel. Based on discussions with NRC Region Ill staff, FENOC will review NOP-SS-4002 and make appropriate revisions to provide guidance for similar circumstances involving personnel selections in the future. This action is being tracked by condition report 2016-06326 (Enclosure F). See Enclosure A through Enclosure D for documents pertaining to the selection of the candidate. The timeline of activities, as documented in condition report 2015-16548, is as follows: Date Event Reg. Compliance requested by DSO to review qualifications of RPM candidate. Reg. Compliance concluded individual was qualified after reviewing March 30, 2015 TS 5.3.1, ANSI 18.1-1971 and Reg. Guide 1.8-1975. Reg. Compliance considered time as RP technician and control room unit supervisor as meeting professional experience requirements. April 6, 2015 Candidate named Acting Manager Radiation Protection (MRP) Personnel Qualification Checklist, NOP-SS-4002-01 Rev. 2, completed by HR April 7, 2015 Representative and Reg. Compliance. (Enclosure A) Fleet Oversight issues memo FMOV 15-001 to DSO detailing difference of April 29, 2015 opinion regarding the Acting MRP professional experience as required by Reg. Guide 1..8-1975. (Enclosure B) Reg. Compliance completes draft ODMI recommending designating a qualified individual as RPM and delegate certain duties to the current Acting MRP as a solution to the Fleet Oversight concern. The basis for this ODMI was an April 30, 20151 assumption that a determination would be made by PNPP management that the Acting MRP did not meet the Reg. Guide 1.8-1975 qualification requirements. DSO issues memo to file to regarding concerns with minimum time of professional experience by identifying additional actions to address potential July 29, 2015 1 vulnerabilities with selecting an RPM with non-traditional experience. The NRC in Inspection Report 05000440/2015010 stated that these actions did not restore compliance. (Enclosure C) E-mail from Director - Fleet Regulatory Affairs to DSO regarding discussions held with NRC Region Ill Health Physics Branch stating that 1) The Health August13,2015 Physics Branch does not consider being a supervisor in the plant, regardless of license status, as meeting the professional time requirements and 2) that Perry committed through our license (TS 5.3.1) to meet the minimum L-16-160 Page 4 of 5 Date Event requirements of Reg. Guide 1.8. Three recommendations were provided by Fleet Regulatory Affairs; 1) review work experience for actual time performing professional radiation protection duties; 2) develop compensatory measures that provide for candidate continuing in position but ensure RPM duties are not compromised; 3) pursue temporary TS change to allow compensatory measures to be in place until professional time requirement is fulfilled. NRC inspectors verbally notified Site Vice President that, in their opinion, the August 28, 20151 actinq MRP did not satisfy the requirements for the position as RPM. USAR Change Notice 15-165 initiated to allow for the assignment of a TS September 29, 2015 qualified RPM in the event the Manager, Radiation Protection Section does not fully satisfy the Reg. Guide 1.8 requirements. (Enclosure D) October 5, 2015 USAR Change Notice 15-165 approved. Acting MRP named Manager- Radiation Protection Section without additional October 19, 2015 compensatory measures to ensure RPM duties are not compromised.
- Exit meeting held with NRC Region Ill personnel, by teleconference, to debrief November 30, 2015 cited violation for RPM not meeting the TS 5.3.1 requirements.
NRC issues inspection report 05000440/2015010 with GREEN cited violation December 4, 2015 05000440/201510-01 for RPM not meeting the TS 5.3.1 requirements. December 9, 2015 CR 2015-16548 initiated to document cited violation.
- 1. These events occurred on or about the date indicated.
We have reviewed the provided USAR Change Notice and request a clarification before we can assess compliance with NRC requirements. Specific areas are the insertions "A" and "B" of the USAR Change Notice: Insert A (Replaces Bubble A on page 12.5*1): The Manager, Radiation Protection Section is designated as the Radiation Protection Manager defined in "Regulatory Guide 1.8." He is responsible for directing all activities associated with radiation protection and other radiological control services required to support plant operation ~nd maintenance activities. This includes all radiation protection activities and for conducting the plant radiological survey activities required to ensure that personnel exposure to radiation and radioactive materials is maintained within regulatory guidelines and that such exposure is kept as-low-as-reasonably-achievable (ALARA). If the Manager, Radiation Protection Section, does not meet the qualifications specified in "Regulatory Guide 1.8," a qualified individual shall be designated as the technical specification qualified RPM, who shall be responsible for all aforementioned activities for which the RPM is responsible, including reviewing, approving and signing/countersigning all associated documents. The Manager, Radiation Protection Section reports to the General Plant Manager. Insert B (Replaces Bubble Bon page 13.1-16): Manager, Radiation Protection Section The Manager, Radiation Protection Section is designated as the RPM defined in "Regulatory Guide 1.8." His responsibilities include, but are not limited to, directing all activities associated with radiation protection and other radiological control services L-16-160 Page s*of 5 required to support plant operation and maintenance activities. This includes conducting the plant radiological survey activities required to ensure that personnel exposure to radiation and radioactive materials is maintained within regulatory guidelines and that such exposure is kept ALARA. If the Manager, Radiation Protection Section, does not meet the qualifications specified in "Regulatory Guide 1.8," a qualified individual shall be designated as the technical specificatiOIJ qualified RPM. Who shall be responsible for all aforementioned activities for which the RPM is responsible, including reviewing, approving and signing/countersigning all associated documents. The Manager, Radiation Protection Section reports to the General Plant Manager. It was understood that the revisions were made to address situations when the Manager, Radiation Protection Section, was not qualified to be the technical specification RPM, as in the current conditions at Perry. However, in this situation, it appears the two individuals either have the same responsibilities or share the responsibilities, please clarify, Additionally, the revision does not describe the reporting chain of the technical specification qualified RPM in the current conditions. Furthermore, please describe the communication methods used to ensure that technical questions raised by the plant staff related to radiation safety are directed to the appropriate individual. Report page(s) and any supporting evaluation documentation associated with this change.
Response
USAR Change Notice 15-165 was initiated to define clear lines of responsibility when the Manager- Radiation Protection Section did not meet the requirements of Technical Specification 5.3.1 by naming a qualified individual to perform the duties of the Radiation Protection Manager. Based on discussions with NRC Region Ill staff, FENOC has made the appropriate USAR changes, under USAR Change Notice 16-085 (Enclosure D), to clarify the separation of duties and organizational reporting put in place by USAR Change Notice 15-165. This action was completed under condition report 2016-06326. Additionally, FENOC will review applicable documentation, including the Quality Assurance Program Manual, determine if changes are requireq to organization charts or job descriptions for the Manager Radiation Protection Sections and the Technical Specification RPM and effect any required changes. This action is being tracked under condition report 2016-06326. The General Plant Manager has issued a memorandum designating the Technical Specification qualified Radiation Protection Manager, the assigned duties and the designated individuals direct reporting to the General Plant Manager or Site Vice-President for sufficient operational freedom to assure independence from operational pressures. Additionally, a Radiation Department Briefing was distributed to Radiation Protection personnel detailing the communication requirements to assure technical questions raised by the plant staff related to radiation safety are directed to the appropriate individual; and restating that at any time, any individual has the right to take information to the hig,hest levels of the organization, or outside the organization if they feel it necessary. (Enclosure E)
Enclosure D L-16-160 USAR Change Notice 16-085
CHANGE NOTICE FORM NOP-LP-4008-01 Rev. 02
+ t ~/zc1t Page 1 ot- !L/1 SECTION 1 - INITIATION 0 BV1 0 BV2 0 DB [gl PY Change Notice No. 16-085
[gl UFSAR 0 Technical Specification Bases 0 TRM 0 10 CFR 72.212 Report 0 DCSS-FSAR ffected Sections, Tables, Figures (Attach applicable pages, annotated as necessary to indicate proposed changes .) Section Pages Attached Section Pages Attached 12.5.1 12.5-1 13.1.2.2.1 13.1-16 Initiating Document or Activity: Personnel Assignment Description and basis for change: D Additional pages attached This change delineates the distinction in responsibilities by position for the Radiation Protection Manager (RPM) and the Manager, Radiation Protection Section at the Perry Nuclear Power Plant. It also provides additional information with respect to these two positions. CN16-085 marks-up CN15-165, see attached. CN15-165 was approved in October 2015. Additional supporting documents: RAD-Exempt UFSAR Change Evaluation Form (NOP-LP-4008-02) Attached D Not required 1:8:1 RAD Form (Form NOP-LP-4003-01) Attached E( Not required 0 10CFR50.59 Screen (Form NOP-LP-4003-02) Attached D Not required fVt' 10CFR50.59 Evaluation (Form NOP-LP-4003-03) Attached D Not required ff Approved Operating License Amendment Attached D Not required 1:8:1 Other (Required by RAD) : Attached D Not required 1:8:1 Preparer: , _J/ '7/JA - ~ Date: Date: Matt Minniti 1/4M/f f.,,..,,..,_.vl,,/ 6/-zt, /{, ~ht, liol SECTION 2 - REVIEW AND APPROVAL Section Owner Reviewer: Comments Provided: Yes 0 No Date C. Elliott(12.5) 5j31 z.o*lo Section Owner Reviewen~ D Date ,/ /, M. lmobersteg (13.1) &? ,:;>L- /G Other Reviewer: 0 No Bl Date J . Spahr (RPM) S-31-Jb Other Reviewer: D No ~ T. Brown 0 No ~ Date . I ~D ~ 1"' jc_e,. ~fi commW' P(':vided: Yes D No ~ AW I £1 ' N 3 - INCORPORATION Document Revision 0 Operations Training Complete 0 Operations Training Not Required Incorporation Verified by Fleet Licensing Comments Provided: Yes 0 No O Date:
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CHANGE NOTICE FORM *'j/ NOP-LP-4008-01 Rev. 02 Pag~ot~ // SECTION 1 - INITIATION 0 BV1 0 BV2 0 DB [81 PY Change Notice No. 16-085 t8I UFSAR 0 Technical Specification Bases 0 TRM 0 10 CFR 72.212 Report 0 DCSS-FSAR ffected Sections, Tables, Figures (Attacti applicable pages, annotated as necessary to indicate proposed changes.) Section Pages Attached Section Pages Attached 12.5.1 12.5-1 13.1.2.2 .1 13.1-16 Initiating Document or Activity: Personnel Assignment Description and basis for change: 0 Additional pages attached This change delineates the distinction in responsibilities by position for the Radiation Protection Manager (RPM) and the Manager, Radiation Protection Section at the Perry Nuclear Power Plant. It also provides additional infonnation with respect to these two positions. CN16-085 marks-up CN15-165, see attached. CN15-165 was approved in October 2015. Additional supporting documents: RAD-Exempt UFSAR Change Evaluation Form (NOP-LP-4008-02) Attached 0 Not required l8J RAO Form (Form NOP-LP-4003-01) Attached E Not required D 10CFR50.59 Screen (Form NOP-LP-4003-02) Attached 0 Not required g 10CFR50.59 Evaluation (Form NOP-LP-4003-03) Attached 0 Not required [81 Approved Operating License Amendment Attached 0 Not required l8J Other (Required by RAD): Attached 0 Not required (81 Preparer: , _J.f 'JA 4 * ~ Date: Supervisor: Date: MattMinniti/U4'1/ !~ 6/u 'II, ~ s-\4120\ SECTION 2 - REVIEW AND APPROVAL Section Owner Reviewer: Comments Provided: Yes D No C. Elliott(12.5) Section Owner Revlewe . 0 Date / ./ M. tmobersteg (13.1) ~ Ol--J IG Other Reviewer: 0 No Bl Date J. Spahr (RPM) r-3t .... Jb Other Reviewer: 0 No;;{ T. Brown 0 No a Date
-~1'111~
Section Owner Manage Comments Provided: Yes 0 No Jl Date J. Spahr (RPM) N 3 - INCORPORATION Document Revision 0 Operations Training Complete 0 Operations Training Not Required Incorporation Verified by Fleet Licensing Comments Provided: Yes 0 No 0 Date:
CHANGE NOTICE FORM NOP-LP-4008-01 Rev. 02 PagJ:of~// SECTION 1 - INITIATION 0 BV1 0 BV2 0 DB 181 PY Change Notice No. 16-085 181 UFSAR 0 Technical Specification Bases 0 TRM 0 10 CFR 72.212 Report 0 DCSS-FSAR ffected Sections, Tables, Figures (Attach applicable pages, annotated as necessary to indicate proposed changes.) Section Pages Attached Section Pages Attached 12.5.1 12.5-1 13.1.2.2.1 13.1-16 Initiating Document or Activity: Personnel Assignment Description and basis for change: D Additional pages attached This change delineates the distinction in responsibilities by position for the Radiation Protection Manager {RPM) and the Manager, Radiation Protection Section at the Perry Nuclear Power Plant. It also provides additional information with respect to these two positions. CN16-085 marks-up CN15-165, see attached. CN15-165 was approved in October 2015. Additional supporting documents: RAD-Exempt UFSAR Change Evaluation Form (NOP-LP-4008-02) Attached D Not required RAD Form (Form NOP-LP-4003-01) Attached 'g( Not required 10CFR50.59 Screen (Form NOP-LP-4003-02) Attached 0 Not required 10CFR50.59 Evaluation (Form NOP-LP-4003-03) Attached 0 Not required Approved Operating License Amendment Attached 0 Not required Other (Required by RAD): Attached 0 Not required Date:
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SECTION 2 - REVIEW ANO APPROVAL Section Owner Reviewer: Comments Provided: Yes 0 No C. Elliott(12.5) Section Owner Reviewe . 0 M. lmobersteg (13.1) Other Reviewer: D No Bl Date J. Spahr (RPM) .r-.3J-Jb Other Reviewer: T. Brown 0 No Jtt 0 No a Date
-~l "111~
Section Owner Manage D No~* M. Imobersteg (13.1) 3 - INCORPORATION Document Revision Effective Date D Operations Training Complete 0 Operations Training Not Required Incorporation Verified by Fleet Licensing Comments Provided: Yes 0 No 0 Date:
- t. ;; e ~
CN 15* 165; PageT-of /{)j~//.s,- This change notice (CN-15-165): 12.5 RADIATION PROTECTION PROGRAM Delete Bubble A and replace with Insert A 12.5.1 ORGANIZATION e Manager, Radiation Protection Section Bubble A Protec
- n Manager defined in <Regulatory activities and for activities required to ensure radioactive that such of the Radiation Protection Technicians and the implementation of the operational Radiation Protection Program.
The Radiation Protection Technicians perform the various radiological surveys and associated analysis to ensure compliance with the radiation protection program. At least one Radiation Protection Technician is provided for each shift. Qualification and training requirements for the Radiation Protection Section's supervisory positions are described in <Section 13 . 1 . 2 . 2>,
<Section 13 . 1.3.2>, and <Section 13.2 . 3> .
Revision 18 12 . 5- 1 October, 2013
operation upon the environment, obtaining appropriate state and federal permits for air and water, and r eporting as necessary to demonstrate compliance with applicable environmental regulations. The chemistry activities include development and implementation of the chemistry program, wet chemistry, plant process chemistry, system operations performed by chemistry and monitoring of all plant systems for chemical parameters to ensure compliance with regulatory requirements and reports to the 1.8>. His directing all exposure to radiation and guidelines and Site Radiation Protection reports to t Manager, Site Outage Management Section The Manager, Site Outage Management Section, responsibilities include, but are not limited to, directing the scheduling and coordination of all Outage Management Section, reports to t This change notice (CN-15-165): Delete Bubble B and replace with Insert B Revision 17 13.1-16 October, 2011 I{! I/ cµ /& -{)f~ ~>* ~ ~""'
~~left
Byl!!J ~ CN 15-165; Page~ /p~~s C ,J I(, - o 8°) p (J5.'Tb) Change Notice 15-165 11.J,-'=1 f All!tG ll.Af>;( ft>Jl/ Insert A (Replaces Bubble A on page 12.5- ,4 pDS 'j,;J~ I The Manager, Radiation Protection S tion is designated as the Radiation Protection Manager defined in <Regulatory G
- e 1.8>. He_!~_re$ponsible for directing all activities associated with radiation protecti and other-radiological control services required to support plant operation and m
- tenance activities. This includes all radiation protection activities and for conducting e plant radiological survey activities required to ensure that personnel exposure t adiation and radioactive materials is maintained within regulatory guidelines a that such exposure is kept as low as reasonably achievable (ALARA). If the Man er, Radiation Protection Section, does not meet the qualifications spec' d in <Regulatory Guide 1.8>, a qualified individual shall be designated as th technical specification qualified Radiation Protection Manager, who shall be respo . ible for all aforementioned activities for which the Radiation Protection Manager is sponsible, including reviewing, approving and signing/countersigning all associat documents. The Manager, Radiation Protection Section reports to the Gener Plant Manager.
Insert B (Replaces Bubble Bon page 13.1-16): ..ri~ c,; ,, _~r l>"'"' Manager. Radiation Protection Section f'H*~ fhlf.-~GtZf}fff fiA1iJ m:> PS J:: P ~cnt-'f 'Z-The Manager, Radiation Protection Secti is designated as the Radiation Protection Manager defined in <Regulatory Guid .8>. His responsibilities Include, but are not limited to, directing all activities asso ated with radiation protection and other radiological control services requlli Cf to support plant operation and maintenance activities. This includes conduc
- g the plant radiological survey activities required to ensure that personnel expos to radiation and radioactive materials Is maintained within regulatory guidelines nd that such exposure is kept as low as reasonably achievable (ALARA). If t Manager, Radiation Protection Section, does not meet the qualifications specified * <Regulatory Guide 1.8>, a qualified individual shall be designated as the te nical specification qualified Radiation Protection Manager, who shall be responslb for all aforementioned activities for which the Radiation Protection Manager is resP, nsible, including reviewing, approving and signing/countersigning all associated do ments. The Manager, Radiation Protection Section reports to the General Pia Manager.
CN 16-085 Insert 1 (Replaces Bubble A on page 12.5-1 contained in CN 15-165): The Manager, Radiation Protection Section is designated as the Radiation Protection Manager [as] defined in <Regulatory Guide 1.8>. [The Radiation Protection Manager]* is responsible for directing all activities associated with radiation protection and other radiological control services required to support plant operation and maintenance activities. This includes all radiation protection activities and for conducting the plant radiological survey activities required to ensure that personnel exposure to radiation and radioactive materials is maintained within regulatory guidelines and that such exposure is kept as low as reasonably achievable (ALARA). If the Manager, Radiation Protection Section, does not meet the (Radiation Protection Manager] qualifications specified in <Regulatory Guide 1.8>, a[n] individual, [who meets the Radiation Protection Manager qualifications specified in <Regulatory Guide 1.8>,] shall be designated as the technical specification qualified Radiation Protection Manager, who shall be responsible for all [of the] aforementioned activities for which the Radiation Protection Manager is responsible, including reviewing, approving and signing/countersigning all associated documents. [The Radiation Protection Manager has direct reporting authorization to the General Plant Manager and/or the Site Vice President and shall have sufficient operational freedom to ensure independence from operating pressures in order to carry out radiation protection duties. The Manager, Radiation Protection Section is responsible for staffing, budgeting, department coordination activities, and other non-technical specification Radiation Protection Manager related duties.] The Manager, Radiation Protection Section reports to the General Plant Manager.
- The information contained within the brackets is the information associated with CN 16-085.
Note to Typist, the brackets should NOT be included in the actual USAR revision . 17 // CN/t-of> /tf ~7-7
CN 16-085 Insert 2 (Replaces Bubble Bon page 13.1-16 contained in CN 15-165): Manager. Radiation Protection Section The Manager, Radiation Protection Section is designated as the Radiation Protection Manager [as] defined in <Regulatory Guide 1.8>. [The Radiation Protection Manager]* responsibilities include, but are not limited to, directing all activities associated with radiation protection and other radiological control services required to support plant operation and maintenance activities. This includes conducting the plant radiological survey activities required to ensure that personnel exposure to radiation and radioactive materials is maintained within regulatory guidelines and that such exposure is kept as low as reasonably achievable (ALARA). If the Manager, Radiation Protection Section, does not meet the [Radiation Protection Manager] qualifications specified in <Regulatory Guide 1.8>, a[n] individual, [who meets the Radiation Protection Manager qualifications specified in <Regulatory Guide 1.8> ,] shall be designated as the technical specification qualified Radiation Protection Manager, who shall be responsible for all [of the] aforementioned activities for which the Radiation Protection Manager is responsible, including reviewing, approving and signing/countersigning all associated documents. [The Radiation Protection Manager has direct reporting authorization to the General Plant Manager and/or the Site Vice President and shall have sufficient operational freedom to ensure independence from operating pressures in order to carry out radiation protection duties. The Manager, Radiation Protection Section is responsible for staffing, budgeting, department coordination activities, and other non-technical specification Radiation Protection Manager related duties.] The Manager, Radiation Protection Section reports to the General Plant Manager.
- The information contained within the brackets is the information associated with CN 16-085.
Note to Typist, the brackets should NOT be included in the actual USAR revision. fJ II CA./1/-pfS- /~* ~ '1 ~
No. 16-01788
-~ REGULATORY APPLICABILITY DETERMINATION Rev. 00 NOP-LP-4003-01 Rev. 03 Page 1 of 2 Initiating Activity No.
USAR CN 16-085 Rev. 0 0 BVPS 1 0 BVPS2 0 DBNPS ~ PNPP Tltle: Change Notice 16-085 - Updates the Perry USAR to delineate the distinction between RPS Manager and RPM responslbllltles Brief description of activity (what is being changed and why): Change Notice (CN) 15-165 updates the Perry USAR regarding the organizational descriptions that provide for the assignment of an individual as a Radiation Protection Manager (RPM), who satisifies the Regulatory Guide 1.8 RPM qualifications, in the event the Manager, Radiation Protection Section does not fully satisfy Regulatory Guide 1.8 quallflcatlons. This CN revises CN 15-165 by delineating the responslblltles of both the RPM and the Radiation Protection Section, Manager. It also provides the RPM's reporting authority assuming an Individual other than the Radiation Protection Section, Manager is filling the position of the RPM . CN 16-085 updates the CN 15-165 changed pages. This was done for clarity and ease of processing the two USAR CNs.
- 1. EXEMPTIONS Is the scope of the entire activity exempt from the 10CFR50.59 process because It Is limited to:
1.1 Managerial or administrative changes ............ ............................... ..... ...................... .......... .. .............. ~ YES D NO 1.2 UFSAR changes (or equivalent information) excluded from the requirement to perform a 10CFR50.59 Screen and Evaluation by NEI 96-07 or NEI 98-03? .......... ........ .... ....................... .... ... 0 YES ~ NO 1.3 Maintenance activities and temporary alterations in support of maintenance planned for 90 days or fess while at power ........... ...... .. ............ ......... .......... ............................................ .. .......... D YES ~ NO 1.4 Changes evaluated under another program that included a 10CFR50.59 Screen .. ......... ............ ... ... .......... ..................... .......... ....... ......... ........... ............ ......... ... .. ..................... D YES ~ NO
- 2. OTHER REGULATIONS 2.1 Does the activity require a license amendment?
2.1.1 Operating License ..... ...... ..................................... .. ..... .. .. ................................ ...................... ... 0 YES ~ NO 2.1 .2 Technical Specifications .......... .................. ............ .. .. ........................... ................. ... ....... .. .... ... D YES ~ NO 2.1.3 Environmental Protection Plan (BVPS and PNPP only) ..... ......................... ... .... ............ .......... DYES ~NO 2.2 Is the activity or any portion of the activity governed by one or more of the following regulations: 2.2.1 Quality Assurance Program (1 OCFR50 .54(a)) ............................. ............... ....... ...................... D YES ~ NO 2.2.2 Security Plans (10CFR50.54(p)) .. ....... .......... .. .......................................... ............ ..... ....... ...... 0 YES ~NO 2.2 .3 Emergency Plan (10CFR50.54(q)) .. ...... ...... ........... ... .................. ..... ..... ............ ........ ............... 0 YES ~ NO 2.2.4 IST Program Plan (10CFR50.55(a)(f)) ...... .... ................ ............ .... ...... .. ............... ............ ..... ... 0 YES ~ NO 2.2.5 ISi Program Plan (10CFR50.55(a)(g)) ................................... ............... .. ................... .............. 0 YES ~ NO 2.2.6 Fire Protection Program (1 OCFR50.48) ............ .............. .... ....... .... ............ .... ................ .. ..... .... 0 YES ~ NO 2 .2.7 Independent Spent Fuel Storage Facility (10CFR72.48) ............. .. .... ............ ........... ..... ... ....... D YES ~ NO 2.2.8 Another regulation : Standards For Protection Against Radiation (10 CFR 20 including ODCM) ........... ................ D YES ~ NO Specific Exemptions (10 CFR 50 .12) ......................... .. ......... ........... ....... ........................ .... ..... 0 YES ~NO ECCS Acceptance Criteria (10 CFR 50.46) ..................... .......... ..... ...... ...... ............... ........... ... 0 YES ~ NO Environmental Protection (DBNPS only) ............... .. ..... ............ ...... .. .................. .... .... ............. [Q YES [] NO Other - list the regulation(s): NIA .......... ........................ .. .. .. ......... . D YES ~ NO t/ I/ CN lt,t>?~ ;:>f'* ;:r ~ ~
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No. 16-01788 _ff~ REGULATORY APPUCABIUTY DETERMINATION Rev. 00 NOP-LP-4003-01 Rev. 03 Page 2 of 2 Initiating Activity No. USAR CN 16-085 Rev. 0 0 BVPS 1 0 BVPS 2 0 DBNPS 0 PNPP
- 3. CONCLUSION 3.1 Does 10CFR50.59 apply? .................. ..... ..... .... .... .. .. .. ........ .. .... .. .. ........ ............... ....... ...... .. ....... ...... 0 YES ~N O 3.2 Does this activity require a change to the UFSAR? Change Request No: UCN 16-085 .. ... ~YES D NO 3.3 Summarize the bases for responses: Include Keywords used to search documents.
Keywords: Radiation Protection Manager, Radiation Protection Section The proposed USAR changes clarify the USAR organization description of the Manager, Radiation Protection Section and the Radiation Protection Manager which are the result of organization changes . The proposed changes Indicate the responsibilities of the two positions, and provide the reporting authority for the Radiation Protection Manager. The proposed USAR changes are not considered a modification to the facility or a procedure but per NOBP-LP-4003A are considered administrative, since they simply provide clarification of organizational responsibilities and as a result are not subject to 10 CFR 50.59. Therefore, Exemption 1.1 was marited YES. In addition, a "change," as defined In Section 3.3 of NEI 96-07, R1, means a "modification or addition to, or removal from, the facility or procedures that affects: (1) a design function, (2) method of perfonning or controlling the function, or (3) an evaluation that demonstrates that Intended functions will be accomplished." Changes to the USAR-descrlbed organization does not meet this definition of "change." Therefore, such changes would not be subject to control under 10 CFR 50.59. Furthermore, the delineation of responsibilities between the Radiation Protection Section, Manager and the Radiation Protection Manager is similar to an example In Section 4.1.4 of NEI 96--07, R1 in that the NEI guidance describes changing the authority for performance of plant operations from one position to another postlon. The guidance states that this Is not subject to 10 CFR 50.59.
- Since the proposed changes to the USAR are administrative nor rise to the definition of a "change" listed In NEI 96-07, the proposed changes to the USAR meet the crfterla for exemption from the 10 CFR 50.59 process as indicated In Exemption 1.1.
The proposed USAR changes do not require changes to the Operating License, Technical Specifications, or the Environmental Protection Plan, nor to any of the regulations llsted under Sections 2.2.2 through 2.2.8. 10 CFR 50.54(a) applles to the FENOC Quallty Assurance Program Manual (QAPM), which provides a description of the corporate and site organizations responsible for implementing the quallty assurance program. The Oversight organization has detennined that the changes made by this USAR Change Notice do not require a revision to the FENOC QAPM. As a result of the, neither 10 CFR 50.59 nor any other regulatory review and approval process applies to this USAR change. Preparer (Print name) Date Emley, James E 5/26/2016 Reviewer (Print name) Date Spiesman, Benjamin L 6/26/2016 Database Updated Date .L S/Zfe /zott,
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Minniti, Matthew J. From: Mlachak, Mark D. Sent: Thursday, May 26, 2016 2:38 PM To: Emley, James E. Cc: Minniti, Matthew J.; Lockard, Larry D.
Subject:
RE: QAPM Hello Jim. Based on my review of the proposed UCN and the FENOC QAPM, no change to the QAPM is required. Mark D. Mlachak Manager Fleet Oversight Office: (330) 436-1391 Cell: (440) 666-5124 Pager: (440) 733-2417 From: Emley, James E. Sent: Thursday, May 26, 2016 9:38 AM To: Mlachak, Mark D. <mdmlachak@firstenergycorp.com> Cc: Minniti, Matthew J. <mjminniti@firstenergycorp.com>
Subject:
QAPM Mark- Attached is the new UCN wording for the RPM and Manager, RPS positions. I am developing the RAD for the UCN. I need to know if Oversight believes a change to the QAPM is required. The initial UCN for this issue stated that Oversight reviewed it and indicated no QAPM change is required. I need an e-mail response for this UCN. Thanks. Jim II 11 1 CIVl~~tJR~ /'~,q-1~
Enclosure F L-16-160 Condition Report 2016-06326
Condition Renorts Header CR Identifier Orlalnatlon Date Orlalnator's Deoartment ISite Unit CR-2016-06326 05/04/2016 PY-Pl-REGC-CO IG202 1 cateaorv Due Date AF 06/03/2016 Title Reauest for Additional Information VIO 05000440/215010-01 Reauired Actions Discover Date Discover Time Event Date IEvent Time 05/04/2016 13:21 05/04/2016 113:21 Functional Location - Svdem Functional Location Eauloment Descrlotlon AP-913 IEP Eauloment I Reference Identified Bv OAFlndlmz? AME Reauest Manual EP Individual No N Eauloment N SRO Review Number of Number of All Onen Forms Required but Open 0 Initially Effectiveness SklDDed Reviews No 0 Condition Re'1Drt Descrlotlon of Condition and Probable cause Based on discussions with NRC Region Ill staff regarding the Request for Additional Information VIO 05000440/215010-01 dated April 19, 2016, (R-16-078) the following actions are required to address the NRC concerns and close the violation :
- 1. Review NOP-SS-4002, Personnel Selection, Qualifications and Employment Verification and make appropriate revisions to provide guidance for similar circumstances involving personnel selections in the future .
- 2. Revise USAR Change Notice 15-165 to clarify responsibilities and organizational reporting authority for the section manager and the Technical Specification designated RPM .
- 3. Clearly communicate to PNPP staff the responsibilities and organizational reporting authority for the section manager and the Technical Specification designated RPM .
Immediate Actions Taken Initiated condition report and discussed w ith supervision . Recommended Actions Track the reouired actions through assigned corrective actions in this condition report. Documents {Procedures, Document Design, etcl Document NOP-SS-4002 USAR Chane:e Notice 15-165 Activitv/ cause Codes ActMtyCode Related Process Code Cause Code Data Component Type Component Number Related Corrective Actions 4000; TECHNICAL Add SPECIFICATION AND REGULATORY COMPLIANCE -- Actions associated with ensuring Technical Specification and related document compliance ... 0885; Condition Add Reports - Regulatory Driven - Issues identified or driven by a regulatory agency. This event code can be used for multiple issues i. .. /nit/al Reviews Contact N. Conicella 1of10
Sunervlsor Comments No additional comments SRO Review Reaulred? No MRB Comments MRB Questions CARB IOE EFC MRW MR PE NOT 10CFR21 Reau Ired? 0 Brief SCR /n* tlon I Closure Summarv Corrective Actions Taken Radiation Protection has completed communication to the RPS staff of the responsibilities and organizational reporting authority for the section manager and the Technical Specification designated RPM. This meets the intent of the NRC reouest. (See attachment) Corrective Actions Planned
- 1. Reg. Compliance will review NOP-SS-4002, Personnel Selection, Qualifications and Employment Verification, and submit a OCR identifying required revisions to address lessons learned for similar circumstances involving personnel selections in the future.
2.Reg. Compliance will revise USAR Change Notice 15-165 to clarify responsibilities and organizational reporting authority for the section manager and the Technical Specification designated RPM . Hardware I Dearaded Condition Resolution Reaulred No Does the CR Involve Information obtained or an observation made of a BASIC COMPONENT that could compromise safetv? No Corrective Actions Workflow State Due Date Schedule Type Corrective Action Tvoe Wort< Center Related cause Codes Respond 07/28/2016 A-Owner CA - Corrective Action PY-Pl-REGC; PY-Assigned/Controlled Regulatory Comol iance Closure Review 07/28/2016 A-Owner CA - Corrective Action PY-Pl-REGC; PY-Assigned/Controlled Regulatorv Compliance Respond 08/30/2016 A-Owner CA - Corrective Action PY-Pl-REGC; PY-Assigned/Controlled Regulatorv Compliance INPOCodes INPOCode NO INPO CODE* No INPO Code has been assigned to this CR. flnltlal Review Checkboxesl C24:CS1 N N Workbook Events Event Status Asslaned to Created bv Created on Rnlshed bv Rnlshed on Initiate Completed Lockwood David Lockwood David 05/04/2016 13:37 EDT Lockwood David 05/04/2016 13:37 EDT Supervisor Completed Zerr, Lloyd Lockwood, David 05/04/2016 13:37 EDT Zerr, Lloyd 05/04/2016 13:42 EDT Review SRO Review Skipped Zerr Llovd 05/04/2016 13:42 EDT Zerr Llovd 05/04/2016 13:42 EDT MRB Review Completed CR CRPA Team - Zerr, Lloyd 05/04/2016 13:42 EDT Coggins, 05/06/2016 09 :31 EDT G202 Kathleen Awaiting Skipped Coggins, 05/06/2016 09:31 EDT Coggins, 05/06/2016 09:31 EDT Reoortabilitv Kathleen Kathleen Assign Closure Completed Conicella, Nicola Coggins, 05/06/2016 09:31 EDT Zerr, Lloyd 05/06/2016 13:30 EDT Summary Kathleen Closure Completed Lockwood, David Zerr, Lloyd 05/06/2016 13:30 EDT Lockwood, David 05/31/2016 13:51 EDT Summarv Pre-iob Brief Skiooed Lockwood David 05/31/2016 13:51 EDT Lockwood David 05/31/2016 13:51 EDT Trainee Skipped Lockwood, David 05/31/2016 13:51 EDT Lockwood, David 05/31/2016 13:51 EDT Investigation Investigation Skiooed Lockwood David 05/31/2016 13:51 EDT Lockwood David 05/31/2016 13:51 EDT Peer Review Skiooed Lockwood David 05/31/2016 13:51 EDT Lockwood David 05/31/2016 13:51 EDT Manager Completed Conicella, Nicola Lockwood, David 05/31/2016 13:51 EDT Zerr, Lloyd 06/01/2016 06:51 EDT Aooroval CFAM Review Skipped Zerr, Lloyd 06/01/2016 06:51 EDT Zerr, Lloyd 06/01/2016 06 :51 EDT 2of10
Workbook Events Event Status Asslanedto Created bv Created on Anlshed bv Anlshedon Root Cause Skipped Zerr, Lloyd 06/01/2016 06:51 EDT Zerr, Lloyd 06/01/2016 06:51 EDT Sponsor QA Review Skinned Zerr Llovd 06/01/2016 06:51 EDT Zerr Lloyd 06/01/2016 06:51 EDT CARB Review Skipped Zerr Lloyd 06/01/2016 06 :51 EDT Zerr Lloyd 06/01/2016 06:51 EDT VP Review Skipped Zerr Llovd 06/01/2016 06:51 EDT Zerr Llovd 06/01/2016 06 :51 EDT Actions Workine: CR Holdine: Tank Zerr Llovd 06/01/2016 06:51 EDT Attachments Attachment FW Messae:e from KM 364e.odf RP Department Brief 5-10-16 Complete.pdf 3of10
From: Spahr Joseph J. To: Zerr Lloyd p ; Locl<wood Dayjd H Cc: Elliott Christopher M
Subject:
FW: Message from KM_364e Date: Tuesday, May 17, 2016 1:46:22 PM Attachments: SPYC307-P16051710410. pdf Men: There are several initials missing, due to shift work, short term medical , etc. I do have a sheet from Freeman initialed on a separate cover, if needed. Let me know, thanks From: Wigren, Tamara S. Sent: Tuesday, May 17, 2016 11:43 AM To: Spahr, Joseph J. <jjspahr@firstenergycorp.com>
Subject:
FW: Message from KM_364e From: PYC307-P@firstenergycorp .com [majlto :PYC307-P@firstenergycorp .com ] Sent: Tuesday, May 17, 2016 11:42 AM To: Wigren, Tamara S. <tswjgren@firstenergycorp com >
Subject:
Message from KM_364e 4of10
Radiation Protection Department Brief Perry Power Plant - Radiation Protection Date: 5/12/2016 Conduct of Radiation Protection (NOP-OP-4002) Moment 4.3.2 Notifications to the RPM
- 1. Notify the RPM (or acting RPM) of events that impact or have the potential to impact the Radiation Protection Section, or that involve company or contractor personnel working in the department.
- 2. RP Supervisors are responsible for notifying the RPM. During offhours, the on-shift RPT notifies the duty RPS who then notifies the RPM.
- 3. Notify the RPM Immediately (face-to-face or by phone} of the following occurrences, or other occurrence of similar consequence:
- Potential or actual overexposure of an individual, including exceeding administrative limits
- Injured person in the RCA
- Failure to control access to a High Radiation Area, Locked High Radiation Area, or Very High Radiation Area
- Loss of radioactive material or unaccounted for sealed source
- Violation of Radiation Protection procedures or RWP
- Violation of FENOC procedure by RP Personnel
- Any RP personnel injury
- Transport of contaminated injured personnel offsite
- Any uncontrolled release or detection of radioactive material I contamination outside of the RCA
- Personnel with a positive indication of an intake
- Industrial Safety "near miss"
- Any forced power reduction >25% rated thermal power
- Personnel contamination event
- Any indication from the NRC or Quality Assurance personnel that a condition exists that might result in a Notice of Violation or a Significant Condition Adverse to Quality
- Valid (response to occupational radiation exposure) EAD accumulated dose alarm
- Spill or leak that results in a large area (>500 sq feet) contamination Page 1of3 5of10
Technical Specification RPM Perry Nuclear Power Plant UFSAR Excerpt: The Manager, Radiation Protection Section is designated as the Radiation Protection Manager defined in <Regulatory Guide 1 .8>. He is responsible for directing all activities associated with radiation protection and other radiological control services required to support plant operation and maintenance activities. This includes all radiation protection activities and for conducting the plant radiological survey activities required to ensure that personnel exposure to radiation and radioactive materials is maintained within the regulatory guidelines and that such exposure is kept as low as reasonably achievable (ALARA). If the Manager, Radiation Protection Section, does not meet the qualifications specified in <Regulatory Guide 1.8>, a qualified individual shall be designated as the technical specification qualified Radiation Protection Manager, who shall be responsible, including reviewing, approving and signing/countersigning all associated documents. The Manager, Radiation Protection Section reports to the General Plant Manager. Manager, Radiation Protection - Chris Elliott Technical Specification RPM -Joseph Spahr In addition Technical Specification 5.2 .1 States; The individuals who train the operating staff, carry out radiation protection duties, or perform quality assurance functions may report to the appropriate onsite manager: however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures. This information does not change how we are doing business presently, it is being provided to reinforce and clearly align the team on reporting requirements and whom the communications should be made to. As noted in NOP-OP-4002, the RPM is required to be notified for various situations. Additionally, RPM approval is required for many processes that we are a part of. In any matter requiring RPM Approval or Notification, Joe Spahr or designee should be notified. This should be done by the normal chain of command such as delineated in NOP-OP-4002. Organizational Freedom is assured to all individuals carrying out radiation protection duties as noted in T.S. 5.2.1. Thus free flow of information , issues, or radiological challenges can be communicated directly to the General Plant Manager and/or Site Vice Present. At any time, any individual has the right to take information to the highest levels of the organization, or outside the organization if they feel it necessary. Example: Emergent LHRA Request Approval ~ RPT notifies Duty Supervisor ~ Duty Supervisor notifies and obtains approval from T.S . RPM ~ T.S. RPM notifies Manager, Radiation Protection Page 2 of 3 6of10
Initials Raaulrad Radiation Protection Personnel R8CI Ops Reels..,, Alnlley, B j f( Chapin,F ~ Hmnlon, r4J Metler,~ Schwegler,S Bartone,L ~ J...c-P\ Anderson, J . C111Wford, AA*C Hanis, C '~ Miier, J ,j h Tlemc, c ,., Bump, C GtieJ Lynch, Schult, 0 l7J Andrei, M ~~ Diiiey, J Johnnon, C (:. Monroe, r(, if\ Trent, S .f'1 F~.K spa11r, J .JJ_r Augustynl*k.. ~ Donmldson, J~ Jones, CtJh\J P*ntcjH, A.jJ ~ \ IJVall*', A 'Jr;J Lee. S ~~ T*ylor. M /ttff BUMS, R~ 0umu.sQ) King, J ~ "-. R*benald. A , llYtson, J Long,.(/ Lv- '-" Wigren, T '1JA Brown, G 0um.m.crA l..ollsi~ Rholldes, <1"( ., \i Glmsa, B~ ~ C111Vantn,~ Chllfee, R J..~ Glass, FofH/ Mavd/.P ){. Mc:lAughlln, D
. Rossmann, N, Approved: Chris Elliott CJJ2 Page 3 of 3 7of10
ni::1na/'Jn11: 14*4<; l'<:l CR - Corrective Actions Header CA Identifier Site CR tateaorv Workflow State Orlalnator Due Date NeedsCARB CA-2016-06326- G202 AF Respond Lockwood, 07/28/2016 Review 001 David H. CAUTION - This CA is linked to Schedule Tvoe Corrective Action Tvoe Notification I WO # Work Center A - Owner Assigned/Controlled CA - Corrective Action PY-Pl-REGC; PY-Regulatory Comoliance AcceDtimr: Individual Conicella Nicola F* PY-Pl-REGC- PY-Ref.!ulatorv Comoliance
- Manager Descrlotlon Reg. Compliance will review NOP-SS-4002, Personnel Selection, Qualifications and Employment Verification, and submit a OCR identifying reauired revisions to address lessons learned for similar circumstances involving oersonnel selections in the future.
Current Resoonse Tvoe Assianee
- Lockwood, David Resoonse Required Outa2e Number Approval Level N/A Workbook Events Event Status Assl2ned to Created bv Created on Finished bv Finished on Initiate Completed Lockwood David Lockwood David 05/31/2016 13:39 EDT Lockwood David 05/31/2016 13:39 EDT Acceot/Assif.!n Comoleted Conicella Nicola Lockwood David 05/31/2016 13:39 EDT Zerr Lloyd 06/01/2016 06 :47 EDT Director Skipped Zerr, Lloyd 06/01/2016 06:47 EDT Zerr, Lloyd 06/01/2016 06 :47 EDT Acceptance Resoond Working Lockwood David Zerr Lloyd 06/01/2016 06:47 EDT 8of10
ni:;1nann1i:; 14*4<; i:c;1 CR - Corrective Actions Header CA Identifier Site CRtateaorv Workflow State Orlalnator Due Date NeedsCARB CA-2016-06326- G202 AF Closure Review Lockwood, 07/28/2016 Review 002 David H. CAUTION - This CA is linked to Schedule Tvoe Corrective Action TVD@ Notification I WO # Work Center A - Owner Assigned/Controlled CA - Corrective Action PY-Pl-REGC; PY-Regulatory Compliance Acceotlna lndMdual Conicella Nicola F* PY-Pl-REGC* PY-Ree:ulatorv Comoliance
- Manae:er Descrlotlon Reg. Compliance will complete a new USAR change notice to revise USAR Change Notice 15-165 to clarify responsibilities and organ izational reporting authority for the section manager and the Technical Specification designated RPM . RC will work with Fleet Licensing to process the USAR chane:e ICN 16-0851.
Resnonse Tvne Completed as Written Resnonse USAR Change Notice 16-085 was aooroved on June 8 2016 and is ava ilable for viewing in FileNet. Required Outaae Number Approval Level N/A Review Review Level Review Results Additional Review Approvedw/ Date Comments Comments Approval Ao a roved 06/09/2016 Closure Review Workbook Events Event Status Assl1medto Created bv Created on Finished bv Finished on Initiate Completed Lockwood David Lockwood David 05/31/2016 13:47 EDT Lockwood David 05/31/2016 13:47 EDT Accept/Assign Completed Conicella Nicola Lockwood David 05/31/2016 13:47 EDT Zerr Lloyd 06/01/2016 06:50 EDT Director Skipped Zerr, Lloyd 06/01/2016 06 :50 EDT Zerr, Lloyd 06/01/2016 06:50 EDT Acceptance Respond Completed Lockwood David Zerr Lloyd 06/01/2016 06 :50 EDT Lockwood David 06/09/2016 10:42 EDT Initial CARB Skipped Lockwood, David 06/09/2016 10:42 EDT Lockwood, David 06/09/2016 10:42 EDT Review RC Verifv Skiooed Lockwood David 06/09/2016 10:42 EDT Lockwood David 06/09/2016 10:42 EDT Approval Completed Zerr Lloyd Lockwood David 06/09/2016 10:42 EDT Zerr Lloyd 06/09/2016 11:12 EDT QA Review SkiPPed Zerr Lloyd 06/09/2016 11:12 EDT Zerr Lloyd 06/09/2016 11:12 EDT CARB Review Skiooed Zerr Lloyd 06/09/2016 11:12 EDT Zerr Llovd 06/09/2016 11:12 EDT Closure Review Working CR CRPA Team - Zerr, Lloyd 06/09/2016 11:12 EDT G202 9of10
ni:;/nQ/')n1i:; 1A *A<:: F<;l CR - Corrective Actions Header CA Identifier Site CRcateaorv Workflow State Orlalnator Due Date NeedsCARB CA-2016-06326- G202 AF Respond Lockwood, 08/30/2016 Review 003 David H. CAUTION - This CA is linked to Schedule Tvoe Corrective Action Tvoe Notification I WO # Work Center A - Owner Assigned/Controlled CA - Corrective Action PY-Pl-REGC; PY-Regulatory Comoliance Acceotlna lndMdual Zerr Llovd P.
- PY-Pl-REGC-CO* PY-Comoliance
- Suoervisor Descrlotlon Regulatory Compliance will review applicable documentation, including the QAPM, determine if changes are required to organization charts or iob descriotions for the Manager Radiation Protection Sections and the Technical Soecification RPM and effect anv reauired changes.
Current Resoonse Twe Asslanee Zerr Llovd Resoonse Required Outa2e Number Approval Level N/A Workbook Events Event Status Assl1medto Created bv Created on Finished bv Finished on Initiate Completed Lockwood David Lockwood David 06/09/2016 11:13 EDT Lockwood David 06/09/2016 11:13 EDT Acceot/Assign Comoleted Zerr Llovd Lockwood David 06/09/2016 11:13 EDT Zerr Llovd 06/09/2016 11:34 EDT Director Skipped Zerr, Lloyd 06/09/2016 11:34 EDT Zerr, Lloyd 06/09/2016 11:34 EDT Acceptance Resoond Working Zerr Llovd Zerr Llovd 06/09/2016 11:34 EDT 10of10}}