ML20082F718

Forwards Partially Deleted Response to 910619 Telcon Re Request for Specific Details Concerning Safety Concerns Presented by Atty

ML20082F718
Person / Time
Site:	Crystal River
Issue date:	07/23/1991
From:	Wollesen E AFFILIATION NOT ASSIGNED
To:	Miranda O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20082F706	List: ML20082F718
References
NUDOCS 9108160033
Download: ML20082F718 (37)

Text

- _ _ _ _ _ _ _ - _ _ _

i Edward S.

Wolleson 1200 N.

Tiger Point 420 Winona Blv'd.

Lecanto, Pl. 32661-9762 Rochester, N.Y.

146.7 1

(904) 746-6848 (904) 266-1156 Work (800) 950-3190 July 23, 1991 TO:

Mr. Oscar De Miranda Senior Allegations Coordinator, Region II US Nuclear Regulatory Commission P.O.

Box 845 Alanta Ga. 30301

Dear Sir:

This letter is being written per our conversation of June 19, 1991, when you requested that I

supply more specific details about the safety concerns presented by my attorney.

The format that follows readdresses the actual items from the letter (summarized), followed by the details to assist your investigation.

Item Number 1:

1,500-3000 instruments in the nuclear

plant, most of wich are identified to be safety related or important to safety, rre not being controlled as required by the regulatio e of the Nuclear Regulatory Commission.

DETAILS:

Quality film record storage rolls 4006 and 4007 contain a copy of the Master Instrument List when many of the tag numbers were being assigned.

There are two additional filmed copies of the Master Instrument List, one prior to the above rolls and one after, which do not contain the instruments (1,500 - 3000).

An Engineering and plant management decision was reportedly made to eliminate these PLANT INSTTRUMENTS from the computerized listing and therefore there is no reference to determine the t-the instruments.

Some of these

~

safety classification instruments are the sama instruments the NRC identified as over due for calibeation in 19,J.

used to monitor the Emergency Diesel Generators.

Thesre instruments are not identified on the drawings either.

As a

Nuclear Maintenance Specialist.

.I identified these instruments as early as 1965 or early 1986.

This topic was brought to the Nuclear Maintenance Superintendent, Dan Smith, and the Nuclear Plant Manager, Pual P. McKee.

Others workin on the project and kmnowledgable of the oblem were In my capiedty as a

ear Maintenance specialist I was tasked with fixing the Master Instrument List and the Master Instrument Calibration Program to meet the NetC findings and concerns and INPO concerns.

9108160033 91080s DR ADOCK 05000302 3

PDR E

Ao c Senior Nuclocr Quality Accuranco Spacioliot, undor tho supervision of Victor Hernandez and manager Ken Lancaster, these were addressed to the Quality Audit Department for followup with the 88-Main Audit 01 and 02 findings; Robert Nicholas was the team leader.

And at that time I tried to resolve the issue with the 88-05 Surveillance concerning the resolution of NCOR 88-137 ( I bellive the numbers are close or correct) over due calibration Nonconformance Report.

Both attempts were stoppped.

In the positions above I worked with the Relay Technicians, now refered to as system protection departement

( or something close).

They were concerned because they had a very difficult time determining the safety classification of the instruments.

The Calibration programs require the determination of the safety classification.

To assist, I went back to a response FPC made to the NRC that went something like thist equipment associated with safety related systems or instruments is a

system that contained any safety related instruments, would be evaluated to determine their safety classification.

Engineering (SNES) on site interpreted the response that if Engineering did r.ot evaluate the instrument it was to be considered as non-safety related.

I further pursued the issue to etermined that the response rom te neering may not meet the intent of the FPC Responso to the NRC.

Nuclear Operations Engineering then responded again.

This response was more in line to follow the FPC response to the NRC item.

For copies of the letters mentioned, Contact Mention my name and the fact that the letters from engineering concerning the relay instruments that are were not classified.

COMMENT:

These instruments, to the best of my knowledge, were a part ci the confidential letter I sent to Paul McKee that resulted in my badge being pulled, and I was sent to the Corporate Physcoligist (spelling) for evaluation.

His Comment was to the effect: You don't need to be here but someone does.

As grounds for keeping my job, Joe Lander explained that I usurpped line management authiority by presenting the issues to upper management.

(line management refused to address the issues; Jeff Warren was my supervisor)

Also it was very clear to me that FPC would hold against me any information that I

would take to the NRC as usurping line management authority.

NOTE:

the current tape conversation that FPC made, this topic was tested.

The Security person, John Pellham, asked me AffI hadlany safety donderns.

He refused to clarify the question:

I was told that I could not To Me he was, testing the point that reveal any thing to him as it would be again the usurping of

$11ne management authority; therefore I was forced to say no.

7

'did clarify the answer to include that none that were not documented.

The concerns were not written up as problems as I was still trying to address them through the FPC methods and procedures.

Other respor.ses FPC wanted I gave them to"get out' of;the meeting as I had other things toldock for my dalughters wedding; they did not uant the truth, just wirds; and I was not 2

ouro whct for.

Now it to opporont that they wcnted me to any things _that they could make out to be other than-the truth.

Item Number 2:

Florida Power stated in recent Quality Audit Reports (which are required by the NRC under Florida Power's license commitments) that v.arious audited programs, including Security and fire protection, complied with NRC requirements.

DETAILS:

1991 audit reports, 91-02-ISEC, 91-02-IDRG, 91-03-SSUP, stated that-the programs-audited were in compliance except for the deficiencies in the findings the SSUP and IDRG audits stated reccommendations that procedures required for the programs should be documented in the program documents.

The fact of the matter is that the audit team spent much time trying to determine which procedures implemented the programs.

The Tech. Spec. require the PRC to review and approve these implementing procedures prior to implementing the procedures.

If the Quality Audit Department could not determine the program implementing procedures, and the responsible organization did not know which procedures implement their program, how does the PRC meet the T.S.

requirements?

The PRC also does,not have procedures or. approved instructions to define the review that the T.S.

requires of procedures.

And the previous Adiminstrative Instructions (AI-400 Series Procedures) required the PRC review after the Qualified Reviewer review prior to the PRC review and Approval.

Since the PRC review is not defined, the present practice has no review of thew procedures.

The PRC only reviews an interprethtion of the 50.59 Safety Review.

The items approved by the PRC are not often known to the members of the PRC prior to the meetings in which the approvals are given.

That is one of-the contributing causes that PM-200 Revision 4,5,6 were apporved

'when they did not implenent the requirements of a calibration program.

This and

^~.e ineffectiveness of the Qualified Reviewers review were brought up to the audit teams on seversal occassions, and no follow-up or investigsstion was performed.

This I believe is due to the upper level management attitude that they do not have to have procedures and are not required to follow the procedures.

More examples of this are covered in the next items.

COMMENT:

In the 1991 IDRG audit. reportr the report 'left an itesu requiring a response from the-audited" organization and used an approach to document the required response in the use of an "open recommendation."

This is not covered in the Quality Assurance Procedures (QAP).

Items requiring' responses are covered by findings, problem reports; recommendations are suggested enhancements and the audited groups are not required to respond.

In my professional experiance and training, this method is not allowed by the current (or the current programs of that time) programs.

I brought this issue' up to the Audit l

Team

Leader, Steve Chernenko, he in my opinion, seemed disturbod by my conclusion that the PRC could not perform their

function, and the program was not auditable in the present form, therefore there is a need for at least one problem report L

that I he or I will have to write.

3

For more-information refer.to Attachment'1, o copy of the Audit information I assembled for Steve Chernenko, the Audit Team Leader.-

Some information in' Attachment 1 is appropriate for-Item 4 e lso. -

Item Number 3:

Florida Power's license requirements with the NRC require it to meet the Technical Specifications (TS) for_the Nuclear Plant.

Florida Power has not adequatley-defined and does not know the exact requirements of-the Technical Specifications for the nuclear plant, therefore Florida Power cannot accurately report that it is complying with the TS, and it is impossible to audit the TS program.

DETAILS:

TS 6.8.2.1 (I

believe this is the TS for procedure review) requires the PRC to review and approve the implementing procedures for the Security

Plan, Fire Protection, Administrative Instructions, prior to implementation.

These programs are not defined and the review required by the PRC is also not defined.

Also the Permenant members of the PRC hava no requirements for training nor proficiency to be able to l

_ perform the review.-

Instructions of Peg Guide 1.33 Appendix.A The Administrative L

refer to Administrative Procedures and there are no ties as to-l-

how the AI's or other instructions uddressed in the TS and

" clarified" in Nuclear Operations Department Procedures (NOD) 12; clarification of TS 6.8.2.la.

During the audit' process for

~the IDRG; PRC section, no one-could determine which procedures

[

are the Administrative Instructions / Procedures of the TS and l

Reg Guide 1.33 Appendix A.

The Audit activities revealled that' many proceduras not in. the-plant AI series-perform the activities in the Reg Guide.

Therefore the procedures-would not ever be alerted to get the review.

Secondly, how-is an audit possible if there in no' clear resolution to the_ confusion of which procedures implement the TS review requirement.

-The PRC also has-no requirements to demonstrate the -review to be performed'by the PRC.

The present method of review and approval of the procedures requiring review by the PRC only get a1 review of the 50.59 safety evaluation review.

This - is a reduction in'the previous _ reviews, including a review-by the

" Qualified Reviewers" (all P0QAM ' procedures did get.the QR l

review-prior to the current AI-400 procedures; therefore there l

has-been a reduction in the Quality Program to a point that there is no review, Intradepartmental Qualified Reviewer, nor interdepartmental Qualified

Reviewer, nor review of the procedure by the PRC.

COMMENT:

Review of PM-200, Master Instrument Calibration-Program, Revision 4,5,6 all were performed in response to on 88-MAIN audit and did not meet the requirements for the l

Calibration Program by the calibration requirements in 10CFR50 L

Appendix B

Criterion XII.

CONTROL OF MEASURING AND TCST_

4 l

EQUIPMENT, Cnd in thO Monogament Control Elomonto, cnd in tho

FSAR, and in the Nuclear Operations Commitment System, that Measures shall be established to assure that tools,

gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.

This highlighted that the Qualified Reviewer Review was not effective.

I was asked by Robert Nicholas to ask the reviewers what they reviewed.

They, 9

both Hugh (Albert)

Gelaton and Roger Murgatroyd, when they reve1wed the copy of PM-200 Rev. 5 PRHP with the Procedure Review Package of the Committments implemented by the procedrue, they both saw some of the deficiencies.

This was communicated to Robert

Nicholas, with no follow-up nor resolution.

Note:

This was a topic that would have been detailed and further reported during the last job assignment I was given in the Nuclear Compliance Manager, prior to my termination.

Item Number 4:

The NRC requires that Florida Power not include mandatory instructions in uncontrolled manuals used by nuclear operations (ANSI Standard N45.2.10-1973).

This is because uncontrolled manuals may be outdated, causing personnel to implement the wrong procedure.

FPC's Plant Review Committee Guidelines Manual, an uncontrolled manual, includes mandatory instructions for nuclear operations.

DETAILS:

i During the PRC audit, a portion of the requirements to meet INPO and NRC required actions were in the uncontrolled manual.

l There were a listing of problems with the manual.

AI-300 Rev.

30, Section 2.1 IMPLEMENTING REFERENCES, step,

2.1.3 States

"PRC Guideline Manual" This is the uncontrolled manual that did contain not only outdated information but j

contained two sets of instructions and several copies of AI-300, dif ferent revisions.

Also

recently, I was amased that the-Manager,,J.

Alberdi, L

responsible for the P1Gnt Operations Quality Assurance Manual (POQAM) Administration Instruction procedures AI-40C series did not feel that he needed to follow his own procedures.

They were working therefore he determined that conformance to the required writers guide was not need.

I did have several discussions in the recent past weeks that discussed this point tad how effective car.

the audit results be if the Manager in control sets an example that in cases he does not have to comply.

Also in the recent past with the same Manager, J.

Alberdi, I had several discussions that were against his wishes concerning the controls in AI-300, Plant Review Committee Charter.

I wro*e up that the controls in the procedure did not implement the requirements and the referenced "PRC Guideline Manual 5

contoinod instructiono roquired to comply with tho Technical Specifications, this is nor allowed by the standards that defines " guidelines".

Guidelines can only contain reconmended methods not instructions; not as the PRC Guidelines are presently.

Also the manual I used was out of date.

Three copies of AI-300, two revisions, both out of date, and the information in the manual was also over one year out of date.

Some of the information I forwarded to the Audit Team Leader, Steve Chernenko is in the attachment 1.

COMMENT:

Item Number 5:

The January 1991 OPS Audit identified problems with the instrument calibration at the nuclear plant.

Florida Power had recently adopted a program to remove the instrument calibration stickers from the plants instruments.

DETAILS:

During the Audit I, at the direction of the Audit Team Leader, Ed Ural, went to Maintenance to get a better understanding of the current controls on the Instrument Calibration program due to the cancellation of the PM-200 procedure and the issuance of the Letter from Roger Murgatroyd listing instruments that would be out of the calibration frequency.

This appeared to be a method that the plant was trying to run the plant to letters and not to procedures.

There were no instructions nor procedures to govern the activities being performed to notify the operators and the operators were not all informed on this method of allerting them that the instruments were past due.

The NSS told us that they were responsible to tell the operators of any instruments that could not be used for readings in the Surveillance Procedures.

Not only was this not performed by procedure, but what happens when the operator needs a gauge not in the SP for something else, was the NSS to be following each operator to assure they did not use an out of calibration instrument?

What would allert anyone that the instrument is used for In-Service Inspection and there was no grace -period?

These questions and others were developed and I met with Larry Ganstine (

I guessed at his spelling).

I gave an over view of the requirements of a calibration program to larry including copies of the requiroments from the Management Control Elements, PSAR, Reg. Guide 1.30 for definations and others.

The Audit Team was told to forget these issues they were not a part of the audit.

The audit team over view indicated that many of the controls that were in place to comply with the NRC required activities to control instruments were cancelled when the new AI-605 covered the Instruments.

No evidence of data verification of the transfer of data was made, no verification that the dates in the data base were real dates (when PM-200 computerized data base was created by Keller and Wreath Associated in 1983 or 84, they loaded dates to verify the computers capacity to generate the new dates.

The dates used were selected to manpower best manpower laod the calibration schedule.

Errors in the i

6

reviaiono to PM-200 totcIly took the proceduro out of ennpliance with the requirement for the 3.25 and in some cases the 1.25 frequency requirement.

Mike Wilson was a Supervisor and a worker on the program when controls were reduced.

NOTE:

From this time I

was watched and acused of performing my own audits on topics npot related to the current audit.

My Supervisor, Ray Yost III, talked to me on several occassions and there was no problem ever identified.

He even questioned me a few days before my new position temporary assignment, there was no problem.

C0KMEN1:

Jack Giacalone closed the calibration program findings based on the Maintenance Department issuing AI-505.

No requirements no commitments were reviewed, no research to determine that the new procedure implemented the requirements.

I brought this up during January's Audit of Operations. I also was questioned by the Maintenance Superintendent and assistants thrm:gh the QPD Management because the Audit Team was trying to determine why the Maintenance department issued a letter to tell the Operatiers of out of date instruments; neither the calibration program nor the computer was notifing the Operators that the instruments were cet of calibration.

Again this was a topic that prompted the Auditors to give me more work and have me stop effective auditing.

The calibration issue was documented as a minor recommendation.

The operators were not all informed of the process.

Also during the OPS audit I identified that the Operator did not know what to do when the oil of pumps turned colcr.

This appeared to be an operability problem, not issued.

Also the Operator was not familiar with the requirements of AI-1000, Housekeeping.

We collected many things that were not per the instructions that He would have missed.

In January I

questioned the calibration Program.

And my management was upset by the response from maintennace and had the audit pass the issue.

Heavy pressure was apparent on the Audit Team Leader, Ed Ural, to stay on the issues and not to look at the calibration program.

Additional information:

Many times I have been the target of FPO harrassment.

In 1985-6 the 1500-3000 instruments was a hard spot and I was rated poorly for finding and trying to resolve the issue.

Some time in 1987, after an evaluation (poor one)

I went to grievance to try and get an answer.

The results were that Roger

. Murgatroyd and Jeff Warren (Tyler Montgomery was a kind of acting supervisor for the procedure revisions) said only 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> were needed to completely revise a procedure; since I couldn't perform to that I was rated as below Compentent.

Then the plant goes out and hires contractors and under Tyler Montgomery spends 40-80 hours on si le rocedure changes, more for the more complicated.

I worker with me on the job is familiar with t e whole thing 7

In the late summer, early fall of 1987, Several innues FPC committed to have completed in September were not completed and were not on the schedules.

And our Supervisor demanded some strange _ things of us.

I wrote to Paul McKee, as a friend to solicit help prior to getting formal repremands from the NRC.

My Badge was pulled and I was told, By Joe Lander, to work in the nuclear plant you do as your supervisor tells you and you don't report anything above your direct line management.

If he says he will take care of it drop it.

And reporting anything to the NRC will be requarded as usurpping line management.

If I

usurped line management again I

would be the day following the Evaluation I had to go terminated.

This was to'in Tampa.

The result was that I was under more stress than in 1981 and I did not need to be there but someone should be.

That is why I regarded the Interigation by John Pelham to be an FPC harrassment.

If I say I have I safety concern and share it with him, They go back to the old records and terminate me for usurping line authority.

When John would not rephrase the question I knew it was a trick question.

John has been known to tackle people and therefore from that point on I gave him the answer he wanted not the truth or a le al answer: it was a set up that FPC wanted for a long time.

Ask he saw something comming a while ago.

From some time in 1985 or 1986 I have been in counselling due to the pressures of the job.

1988 the company, Denise Russo(now Denise Robinson) tried to have me fired because I went to the FPC sponsored blood bank on my own time.

nor I understand what hold To this day FPC has on a blood bank that an employee should be threatened.

That is why I

think I was working in an area that the plant was uncomfortable and they would not come forth with it: therefore just try to terminate me instead.

1990, November I was Displaced and the management that terminated me wanted to give me little time to find work and offered me only a

position in the Electrical shop at $10,000 less than my current I brought up the human resources manual provisions that dun't wage.

seem to allow that and asked for time.

That was granted but one month after I was made permenant, FPC found what they think is a

good reason to ternminate me and they pulled me off vacation to prove their strength.

This was also the day before my oldest Daughters we i

I have concluded this is another ploy of FPC as they did to anagmen perceived that wante notarity so they fired him to show others they w not tolerate poor perceptions; perception is reality.

Again I was informed around January that

~

Perception is reality.

During 1981 that lead personnel to improperly handle problems to give the proper perception.

I was in the position, recently, that the perception would be poor so FPC spent time following me and some of my personnal life to find some thing to hold over my head; my poor marriage.

Why don't they just follow the rules?

Some of the reason I

think are that the instruments they failed to identify are too expensive, to makeg Quality 55erefore they don't want any one to identify them.

j J

9 8

t I'm norry f or the length of this but there in o lot bohind the whole situation.

I've been trying to fix things for a long time.

I've spent many hours home after hours to make sure I

get information to the supervision in a timely manor.

This is my reward.

professional paper at work on the plant computer and I

formated a

adm.itted that and the plant thought I was conducting business on the plant computers on company time.

Ar.y one that knows me knows that I put in more than thew required 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> per week for the company.

I have had no supervisor that has had any problem with the time I spend for the company nor the productivity; what is all of this garbage about me conducting a business on company time?

Nonsense, just another form to let FPC push a devoted employee around.

PPC weighs heavy on the attitude of the NRC.

I think that they hope you won't find anything important like you did with the pump covers from before.

If the NRC is again light in this whole problem and the lessening of the Qualit Assurance program by merging Surveillance into Audits and squelching into a position that he would not work on plant issues; I e

o see what PPC will allow to keep up their perception.

The 1980-3 issue of the nonsafety gauges in safety systems by using a T-Mar open for 5 years and Preventive Maintenance Control Sheets that altered as found conditions of relays in the Engineered Safeguards system were just a couple things that made the perception good for a short while.

No one saw problem reports nor any other documents and PPC was not fined so people think that those tactics are good to follow.

Sincerely

~

M

\\-

r S.

W sgsen cc:

Louis D.

Putney 1

s se 9

L

~

t ATTACRMENT 1 CF NRC LETTER.

I Edward S. Wollesen 91-02-IDRG Notes Page 10 of 20 February 21, 1991 UP-DATED February 26, 1991 LIST OF ITEMS FOR FOLLOW-UP TOPICS THAT ARE POTKNTI AL PROBLF'3t AREA SUMRT H

FAILURE TO ESTABLISH TMSTRDCTIONS._

REQUIREMENTS:

ANSI N18.7, 5.2.15 Review, Approval and Control of Procedures states:

"The adminiertative controls and quality assurance program shall provide measures to control and coordinate the approval and issuance of documants including changes 6thereto, which prescribe all activities affecting quality...These measures shall assure that documents, including revisions or changes, are reviewed for adequacy by appropriatly qualified personnel and approved for release by authorized personnel...and used by the personnel performing the prescribed activity, and that procedures are provided to avoid the misuse of outdated e-inappropriate documents...Proce ures shall be d

approved as designated by the owner organization before initial use.

Rules shall be established which clearly delineate the review of procedures by knowledgeable personnel other than the orginiator and the approval of procedures and procedure changes by authorized individuals.

Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approva? unless the owner organization designates another qualified organization.

The reviewing organization shall have access to pertinent background unformation upon which to base it's approval and shall have adequate understanding of the requirements and the intent of the original document.

Those participating in any activity shall be made aware of, and

use, proper and current instructions, procedures...for performing the activity.

Participating organizations shall have procedures for control of the documents and changes thereto to preclude tha possibility or use of outdated or inappropriate' documents..."

PROCEDURES DO NOT ADEQUATELT CONTROL THE FOLLOWING; a)

PRC review; no clear instruction show the review criteria for documents and/or issues the PRC is to review to meet TS 6.5.1.6 PRC Responsibilities, b)

Secretary duties for minutes, What constitutes general discussion vs significant minutes, c)

Review requirements requiced by NOD-12 (TS 6.8.1, Reg Guide 1.33) i)

Procedures in POQAM for PRC review are not delineated, 11)

Managers procedure review and delineation of applicablility to NOD-12 Attachment A items has not been established.

10

ATTACID(ENT 1 OF NRC LETTER.

Edward S.

Wo11esen 91-02-IDRG Notes Page 11 of 20 Pebruary 21, 1991 UP-DATED February 26, 1991 d)

Action item assignment and required activities for adequate response are not prescribed in instructions / procedures / documents.

e)

Membership qualifications are not prescribed in instructions / procedures / documents that should include:

1.

training, 11.

materials to the members-for new and esemblished

members, iii no controls on the membership list, ata positions acceptable 7 h)

Controls are not prescribed for "The Crystal River Unit 3 Plant Review Committee Guideline Manual.

2_1 FAILURF_TO FOLLOW PROCEDURE.

REQUIREMENTS:

ANSI N18.7, 5.2.2 Procedure Adherence.

States:

" Procedures Phall be 'followed and the requirements for use of procedures shall be prescribed in writing.

a)

Revision to AI-300 was not inaccordance with AI-400C, Step 4.1.1.3, NOCS 5404 b)

Records for the PRC are not identified nor controlled in AI-300, per AI-1100.

c)

AI-300 does not conform to instructions in AI-402B 1)

FAILURE TO ESTABLISH INSTRUCTIONS.

a)

PRC REVIEN OF ADMINTSTRATIVE INSTRUCTIONSt Potential violation of Technical Specification Section 6.8 (Procedures) which requires that administrative instructions and -changes thereto are reviewed and approved prior to implementation.

Paragraph 6.8.2.1.

a.

covers the administrative instructions shall be PRC reviewed and approved prior to use: paragraph 6.8.2.1. b. covers all other procedures are required to have the 10CFR Part.50.59 review reviewed by the PRC within 14 days of approval of the procedure.

The requirement discussed for ALL other procedures related to other procedures in Reg. Guide 1.33 Appendix A.

REFERENCES:

I)

ANSI N18.7,5.2.15 (refer to the. Summary)

II)

Technical Specificationar 6.8 PROCEDURES 6.8.1 SCOPE Written procedures shall be established, implemented and maintained covering the activities referenced below:

a.

The applicable procedures recommended in Appendix "A"

of Regulatory Guide 1.33, November 1972.

11

A_TTACEMFJtT 1 0F KRC LETTER, Edward S.

Wo11esen 91-02-IDRG Notes Page 12 of 20 February 21, 1991 UP-DATED February 26, 1991 b.

Refueling operations.

r c.

Surveillance and test activities of safety related equipment.

d.

Security Plan implementation.

e.

Emergency Plan implementation.

f.

Fire Protection Program implementation.

g.

Systems Integrity Program implementation.

h.

Iodine Monitoring Pr6 gram implementation.

1.

PROCESS CONTROL PROGRAM implementation.

j.

OFFSITE DOSE CALCULATION MANUAL implementation.

k.

Quality Assurance Program for effluent and environmental monitoring.

6.8.2 REVIEW PROCESS 6.8.2.1 Each procedure and administrative policy of 6.8.1

above, and changes thereto, shall be reviewed and approved prior to implementation as follows:

a.

The Emergency

Plan, Security

Plan, Fire Protection Plan and implementing procedures, Administrative Instructions and those test procedures associated with plant modifications that affect nuclear safety shall be reviewed and approved by the PRC and the Director, Nuclear Plant Operations prior to implementation.

b.

For all other procedures, the review cycle shall consist of: an intradepartmental review by a

Qualified Reviewer, and interdisciplinary review by Qualified Reviewer (s) in interfacing departments, as specified in administrative procedures, and approval by the responsible l

Superintendent or

Manager, as specified by l

administrative procedures.

The PRC shall then review the 10 CFR 50.59 evaluation within 14 l

days of approval.

6.8.2.2 The training and qualification of Qualified Reviewers l

j shall be governed by administrative procedures, with final certification by the Director, Nuclear Plant i

Operations.

Racertification will be required on a

i periodic basia and upon transfer between departments.

As a minimum, all Qualified Reviewers shall meet the l

requirements of ANSI N18.1-1971, Sections 4.2, 4.3, 4.4, or 4.6, or the equivalent.

6.8.2.3 Each procedure and administrative policy of 6.8.1 shall be reviewed on a periodic basis as set forth in administrative procedures.

ATTACHMENT 1 APPLICABLE ACTIVITIES AT CRYSTAL RIVER UNIT 3 This attachment is presented in the same format as Appendix A to Regulatory Guide 1.33.

Those activities in that Appendix that are performed at boiling water reactors or at pressurized water reactors of a

different design than CR-3 are listed as N/A.

Activities 12

o ATTACHMENT 1 OF WRC LETTER.

Edwcrd S.

Wollocon 91-02-IDRG Notes Page 13 of 20 February 21, 1991 UP-DATED Febru.sry 26, 1991 performed at CR-3 may have been revised to present the CR-3 specific nomenclature.

A.

Administrative Procedures 1.

Security and Visitor Control (SS Series Procedures) 2.

Authorities and Responsibilities for Safe Operation and Shutdown (AI-500, OP's, EP's, AP's, FP's, and AR's.)

3.

Equipment Control (e.g.,

locking and tagging)

(CP-123, and CP-115) 4.

Procedure Adherence and Temporary Change Method

( A I 2207, AI-400 Series, CP-134) 5.

Procedure Review and Approval (AI-400 Series, CP-134) 6.

Schedule for Surveillance Tests and Calibration

( SP-440,1,2,3, SP-701) 7.

Shift and Relief Tornover (AI-500) 8.

Log Entries and Record Retention (AI-500, and AI-400E) 9.

Access to Containment (OP-417) 10.

Bypass of Safety Functions and Jumper Control

( CP-113A, and CP-113B) 11.

Recall of Standby Personnel to Plant.

(EM-206)

III) NOD-12, Implementation of Technical Specification 6.8.1.a.

Technical Specification 6.8.1.a was further defined for implementation in NOD-12, Implementation Of Technical Specification 6.8.1.a.

Careful review of thw entire NOD-12 should be performed.

However the following sections are very important.

1.

V.

B.

1.

Managers of all procedure manuals utilized for work at CR-3 plant shall review the procedures within their respective groups and delineate which procedures are utilized for performing applicable activities at the CR-3 plant (see attachment 1).

In addition, all new and revised procedures shall include such delineation.

2.

For those procedures identified in V.B.1 above as being used to perform applicable activities, the review and approval methodology shall include the requirements of Technical Specification 6.8.2.1.a or 6.8.2.1.b.

PROCEDUkES DO NOT ADEQUATELT CONTROL THE FOLTENfING:

EXAMPLES:

la)

Neither the AI-400 series nor AI-300 prescribe the PRC review

. criteria for procedures listed in Reg Cuide 1.33 Appendix A, 1.,

Administrative Instructions, nor the criteria for responsibilities in TS G.5.1.6.

Neither the activities nor required performance are c1carly prescribed in procedures.

The PRC Alternate Chairman told QPD Auditors that he thought the reviews requirement was only to perform the 50.59 review.

Careful reading of the requirements reveals that the TS intends that the PRC members are the most qualified and therefore Qualified PRO members and only PRC members 13

-. - - - ~ _. -

ATTACIDEENT 1 CF WRC LETTER.

Edward S. Follenen 91-02-IDRG Notes Page 14 of 20 February 21, 1991 UP-DATED February 28, 1991 are qualified to perform the entire review for the. designated procedrues.

Therefore, based on the information reviewed, interviews conducted and deviations identified (below),

our audit conclusion is that the required reviews are not performed, nor are the controls prescribed in administrative procedures / instructions / documents.

NOTE: Reg.

Guide 1.33 Appendix A defines Administrative-Procedures (these are the same as -identified in NOD-12).

The procedures at-CR-3 that satisfy the 1.33 App.A include sose: OP, SP, EP, AP, FP, ' -CP, AI, etc.

The-procedure review process, in the AI-400. series, does not require any review of some procedures, and does not specify the correct review for these procedures.

Ib)

AI-300 requires the minutes to contain:

"A Report of general discussion items which summarizes-.the concerns expressed by. the committee-members and their disposition."

The minutes reviewed contained:

" Items of significant discussion are as follows:."

i There are no instructions for the PRC secretary to determine the

~

significant nor general discussion items.

From the seatings j

attended, the

" general discussion" iterns were not recorded as required-by AI-300.

Ic)' NOD-12 specifies the type control procedures that require the PRC review.

However,-the current FPC program, P0QAM, has-no. prescribed procedures / instructions / documents that delineate those-' procedures p

that implement the-required plant-activity control listed in N00-12 H

and1 Reg Guide 1.33 Appendix A.

Also-those procedures-for.CR-3 are throughout-- the P0QAM, Therefore the TS. reviews have not been performed due to the lack of delineating thoese specific procedures that satisfy the controls listed in the requirements.

2d)

Action Items -are described in AI-300,

however, the criteria for assignment of action item numbers and the activities required to respond and adequately answer the items are not-in place.

In some

-Examples that follow, questions were brought to the attention of the

PRC, but appear to have-been answered 1 abruptly and. responses were-based on uncontrolled outdates information/ documents.

The results,

-in the repairs to the EQ Seals for NI-14 and NI-15, were that a QPNR L

was issued documenting and resolving the issue that questionable materials-and a person unknown qualifications leads to undeterminate-

.EQ seals.

le)

The Plant-Review Committee Membership List, dated February 14,1991, contained Titles of personnel in certain departments, incorrect phone nubebers,. incorrect listing of members.

No controls for the

list, criteria for membership were identified, nor the materials supplied to the members and alternates.

l l

14 l

l ATTACHMENT 1 OF NRC LETTER.

i Edward S.

Wo11esen 91-02-IDRG Notes Page 15 of 20 February 21, 1991 UP-DATED February 26, 1991 If)

The Crystal River Unit 3 Plant Review Committee Guideline Manual has good information in it, however there is no way to identify what revision level is current.

New Members get information, not spoke of as a manual.

A manual reviewed was full of outdated information, procedures and miscellaneous examples of thingr.

There was no control number.

The reviews conducted (or required to be conducted) were not covered in the manual.

Some of the information was duplicate to the instructions in AI-300.

When this is

done, instructions in one of the two instruction mediums can be out of date consistently.

The beginning of the book had:

1)

" Sample" Problem Reports, 11)

MAR packages, iii) unreadable T.S.

pages, iv)

AI-300, Revision 29 (out of Date),

v)

Plant Review Committee Meeting Schedule, that stated:

"On the normal schedule, Plant Review Committee (PRC) meetings will be held each Tuesday and Thursday, at 10:00 A.M.,

in Conference Room 204 of the Nuclear Administration Building."

vi) further in the information in front of the index it states:

"on the normal schedule (non-outage),

Prc meetings are held each Tuesday and Thursday of the week.

To assure that special presentations are properly scheduled, anyone involved with a specini presentation should notify the PRC secretary by 12:00 Noon of the preceding Friday.

Special presentations should be scheduled for the Tuesday meetings."

'ADTE:

There are only Thursday meetings at this time, vii) Agenda items are to the PRC secretary less than two days prior to the meeting, By the time she assembles the materials ui puts them in the mail, the items may reach j

the members the afternoon before the meeting.

NOTE:

Manager Site QA, Ken Lancaster often retcaived the information on the topics to be discuased after the meeting that the approval team givern.

viii)

PRC members only receive the training summaries for procedure changes and MAR review sheet for the MARS.

These are distributed only to the members, not the alternates.

Therefore if the alternate needs to attend the

meeting, he may not even kn'ow what is being presented.

The T.S.s included in the package were copies off of the page, not readab'.e.

ix)

A copy of AI-300, Plant Review Committee Charter, Revision 28 was in the material in front of the

index, TWO R*.: VISIONS OUTDATED.

x)

The responsibilities of the PRC Chairman are listed in the pages are more than in AI-300 Responsibilities.

xi)

The explanation of Alternate Members i

l 15

n.

3

'd ~10101 3

'd Clirl 16/60/80

$1Ny 110-I' 9 3d WOd d e

ATTACC--wT 1 OF NHC LETTER.

~

Edward S. Wollesen Page is of 20 91-02-IDRG/ Notes February 21, 1991 UP-DATED February 26, 1991 DISCUSSIONS:

Tho review required by the TS is not in procedures.

The PRC representative understood the review by the PRC is only for the safety ovoluation, 50.59, not a Qualified / Technical / Administrative review.

Tho person representing the PRC, Jim Kraiker, in the meeting (conducted on 02/22/91, in Room 204 at 1330) told QPD Auditors that the PRC does not nood procedures, and the PRC does not have to " verbatim" Comply with AI procedures.

Tha DNPO and the VPN0 endorsed a letter, PER90-0034, that was to remind ths plant that:

...Wherever a procedure / document uses words such as "chould", "will", "shali", etc., this indicates TOU DO IT --

no latitude io intended or implied..."

This was not the position presented at the mOcting above.

Tho AI-2207 Interpretation Contact told QPD that the procedure policy in AI-2201 is not for all activities.

ASSES e mT OPIFIOWs My opinion is that the PRC is suppossed to be the most qualified and theratore they alone are required to perform the specified procedures to establish strict control for the review on procedures in NOD-12, attachment 1 (1.33 appandix A

Administrative Instructions).

In that light, we FPC have NOT performed that type of a review for many years.

The impact is questionable.

Until the rewriting Of the AI-400 Procedures in

1990, the process required Qualified ROviewers to review the procedures and the PRC to approce them.

After the change, no review is required.

Good control and attitude was approached by the Corporate safety DOpartment in their campaign, " Attitude Convnym Cmmitment."

The Attitude rcpresented at the meeting Firday was not one I would consider acceptable for the PRO or any nuclear plant workers.

9 ASSESSMENT QUESTIONS:

1)

WRAT IS TER STATUS OF ALL THE PROCEDURES THE PRC MAS ITTENDED TO FDI.LY REVIEN?

2)

WHAT IS THE REVIEGE REQUIRED BY THE PRC7 D)

MRAT ACTIVITIES ARE REQUIRED TO BE PERFORMED BY THE PRC?

4)

DO PROCEDURES GOVERN THOSE ACTIVITIES 7 0)

WHAT TRAINING DO TEE PRC MEMBERS RECEIVE 7 0)

IS TRAINING PERIODIC?

7)

DO THE ALTERATES CET THE SAME TRAINING 7 8)

DO THE PRC wnsnERS GET AMPLE TIME TO PERFORM THE REVIENS?

0)

ARE PRC RECORDS ADEQUATE?

10) wErd THE CORRECTIVE MCR 2850 ACTIVITIES EFFECTIVE FOR THE PROCEDURE CONTROL OOVERNING THE RECENT AI-800 REVISION 7 11)

IS INDEPENDANT ASSESSMENT OF THE ORC ACTIVITIES ADEQUATE 7 i)

WHAT DOES THE ASSESSWENT REQUIRE?

t 11)

ARE THE INSTRUCTIONS ADEQUATE 7 111) IS EmOOOR INFORMATION StiPPLIED FOR AE ASSESSMENT?

16

ATTACHMENT 1 CF NRC LETTER.

Edward S. Wollesen 91-02-IDRG Notes Page 17 of 20 February 21, 1991 UP-D&TED February 25, 1991 RECONNENDATIONS:

3)

Nuclear Licensing should be consulted f or a formal interpretations:

1) the PRC review requirements for TS 6.8.2.1 a; 2) for PRC responsibility for providina the Minutes to the Vice Pret; dent and the Chairman of the NGHC as required in TS 6.5.1.8; and for the PRC's responsibility to submit reportable events to the NGRC and the VP, Nuclear Operations, per TS 6.6.1 (b).

2)

A full assessment of the procedures should be performed.

3)

Procedure adharance should be addressed, "verbatir."

compliance should not be discretionary; all personnel need to understand that, especially the PRC, 4)

Make an assessment of PRC members to assess their understanding of the requirements.

5)

The required performance of the PRC needs to be reflected in appropriate instructions.

6)

Review NCR 2850, Procedure Control, to assure the corrective actions taken resolved the issue and that some of the deviations above and that follow are not a result of ineffective corrcetive actions to close the NCR.

7)

PRC Action Items should be delineated to establish conforminity in the activities of the PRC.

With the appropriate controls and instructions, the PRC will professionally handle situations to a plan and instructions.

Reconstruction of the activities, providing an auditable trail, will result.

The purpose would not be for the auditable trail but being able to assess any problems that arrise and make appropriate adjustments in the program.

Some of the example items that follow do not have enough information in trhe record to determine where better controls wculd preclude recurrance of the examples.

8)

AI-2207, Human Performance Enhancement Procedure, Revision 1,section 1.0 1.1 states:

"This policy applies to every member of the plant work force at the CR-3 Nuclear Plant, those employed directly by Florida Power and those employed by contractor and Subcontractor organizations.

It is the duty and the responsibility of every member of the CR-3 Nuclear Plant work force to strictly adhere to written policies and to comply verbatim with procedures written for the CR-3 Nuclear Plant..."

OPINION: This is a most obscure place for this requirement.

This.

would better serve the personnel in the plant if it was in a procedure used more ofter, and/ or titled so the contents were known.

AI-2207 is titled " Human Performance Enhancement Procedure."

RECENT PRC ACTIVITIES THAT SHOW REVIEW / ACTION PROBLENS:

a)

Organization change and the failure to change the procedures was documented in Draft _QAPR-910PS-0001.

b)

Related to the PRC, AI-700 was canceled due to organization change; AI-200 was not up-dated neither were several others.

The PRC -is required to " review administrative procedures?" What is required by the review?

c)

The PRC reviewed and approved the Gamma-Metrics procedure for the vendor to perform he procedure on site.

The vendor was to perform 17

j ATTACHMENT.1 0F WRC I.RTTER.

l Edward S. Wollesen 91-02-IDRG Notes Page 18 of 20 February 21, 1991 UP-DATED February 26, 1991 work in response to a 10 CFR part 21 reporting that the EQ sealing of the NI-14 and 15 cables was failing at other installations and the process used was the apparent cause of the degraded EQ boundary.

Conversations with a QA representative in the PRC meeting referred to conversations that questioned the SNES Engineer who presented the procedure to the PRC to determine if the proper approval process, CP-121, was implemented.

The response, hear say, was that the procedure was presented in accordance with AI-400B provisions for vendor procedures to be approved for use in the plant.

Question for the PRC: Did a follow up item get issued? WO Should a follow up item have been issued? YES, in my opinion.

Six (6) noncompliance were documented in QPNR90S-019 as a result of this issue.

The vendor was installing parts on the EQ seals for NI-14 and 15 from his brief case under a non-safety related plurchase contract.

If Site Nuclear Qua31ty Assurance Surveillance not pursued this issue the plant would have started up with the vendor briefcase parts and a

art 21 issue resolved non-matet -related work.

were involved in the insue, d) ew and approval of contractor procedure for the B&W Eddy Current testing resulted in a QPNR addressing the fact that inspections required by the NP&SM were not in the procedure or the inspection plans attached to and PRC approved.

Question for the PRC:

was the PRC review to include the requirements in the NP&SM7 f)

AI-900, PRR 11, for the cancellation of AI-900 was based on the development of NC-01 procedure and the referenced procedures in NC-01.

NC-01 procedures do not have the same reviews per the requirements in ANSI N18.7 5.2.15 6th paragraph.

If the Nuclear Compliance Department is not performing any safety or quality activities, why do they have any requirements "shall" or "must" and the requirements for PR's and Sanding records to file following-the NOD-04 Requirements?

g)

A NSS, W.

A. Stephenson, initiated a change to AI-300 and it was approved by the PRC 1/24/91 ? (the approval date is not legible,).

[The initials NSS, in this

instance, stand for Nuclear Safety Supervisor not.to be confused with the NSS for the Nuclear Shift Supervisor.)

This revision is to correct a

problem that the p.ocedure did not meet the requirements for record retention of lifetime.

No problem report was noted either in the PRR package nor it.

the Compliance Report issued by the Nuclear Compliance Department.

Did the PRC review the procedure change?

21. Failure to follow procedure.

AT-300, Plant Review Committee Charter, Revia;3n 29 and 30, Step 4.4.1.2 defines the PRC minutes.

This defination clearly identifies the items that constitute those n.nutta.

REFERENCES:

IB

I ATTACHMENT 1 OF NRC LETTFR.

Edward S.

Wollecon Page 19 of 20 91-02-IDRG Notes February ?!, 1991 UP-DATED February 26, 1991 AT-300:

Step 4.4.1.2 requires " Minutes must include"-

o itemized list of documents and a checklist of committee recommendations, Dissenting votes shall be recorded with a brief statement o

for the reasons for the dissenting votes (committee recommendations are considered an unanimous unless the minutes contain dissenting opinions)."

o A statement that no unreviewed nafety questions exist for the items approved.

o A report of general discussion items which summarizes the concerns expressed by the committee members and their disposition, o

Action items of any unresolved items to be carried to the future meetings or any actions that are closed by the committee.

Stop 4.4.1.3 requires:

o Additional copies (of minutes) will be sent to the Vice President, Nuclear Operations and the Chairman of the Nuclear

-General Review Committee as required by T.S.

6.5.1.8 after approval by the PRC Chairman.

Technical Spectfications:

6.5.1.2 Composition requirements; o

o 6.5.1.3 Alternates (limited number of 2 to participate in a vote);

6.5.1.6 Responsibilities, documented required reviews; o

o 6.5.1.7 Authority, written approval or disapproval, render determinations in writing whether or not items reviewed constitutes an unreviewed safety question; 6.5.1.8, records requirement to maintain and forward copies.

o 6.5.1.8 The Plant Review Committee shall maintain written minutes of each meeting and copies shall be provided to the Vice President, Nuclear Operationw and chairman of the Nuclear General Review Committee.

DEVIATION EXAMPLES:

,3 )

The items defined as making up the PRC minutes were not included the "PRC minutes" sent under the cover of IOC NPRC91-0007, Dated February 4,

1991 to meet the requirements above.

The PRC Secretary indicated that only meeting minute note sheets are send to the Vice President, Nuclear Operations, not the minutes described in AI-300.

11)

The minutes reviewed reported on "Itema of significant discummion were am follows:" These comments were more than the general discussions indicated in AI-300.

The general discussion was not a part of the record.

1 l

19

u ATTACRMENT 1 OF NRC LETTER.

Edwcrd S. Wollosen 91-02-IDRG Notes Page 20 of 20 February 21, 1991 UP-DATED February 26, 1991 DISCUSSIONS:

Minutes 91-06, Meeting date 02/07/91, Item 0129, AI-400F was rejected and sent back, apparently, several times.

There was no indication of the Action Item Number assigned to this item, is an action item number required for these items?

The definition assures that needed information is included in the record.

If in some cases upper management only needs a summary of items, then that if meets the requirements in the TS and other upper level documents should be defined in AI-300.

Who determines the items of significance?

Nick name initials were used in some cases and formal initials were used in some others and first name was spelled out on others.

Some of these techniques could result in confusion of who was the person referred to?

No position titles were used.

This leaves the readers to guess at the capacity of the people making the comments.

Note:

some pos2 tion title abbreviations are the same, caution as to using abbreviations as are commonly referred to in the plant.

NTTS contains four character acronyms for most of the titles in Nuclear Operations; these title acronym could be a better reference.

RECOMMENDATIONS:

AI-2207 prescribes the Procedure Adherantee Policy, however it is not obvious to the procedreu users as to where it is.

Procedures for appropriate review of instructions should be all together, in CP-134 is not any where close to AI-400B.

CP-134 references the user to AI-400B however, AI-400B aand AI-400C do not refer the users to CP-134.

AI-1100 and AI-1000 are procedrues for all employees to use and follow to assure the. control of the plant and records are meeting the requirements.

However these procedures are not located where the procedure performers could easliy find them.

These procedur_es were not used as they are required and the results have been documented in QPNRs and NCORS over the past few years.

Consideration therefore should be given to make the POQAM procedures human factor gathered so all personne11 can easily find them and adhere to the requirements.

3)

QUALITY ASSURANCE RECORDS:

A) IDENTIFICATION:

Neither AI-3OO nor the CR 3 PRC Guideline Manual identify the records nor the lifetime.

REFERENCES:

NOD-04, Revision 7:

o Section II, Scope states:

"This procedure applies, as a minimum, to quality assurance (QA) records including those either received or generated as a result of regulatory requirements, FPC commitments, and departmental procedures 20

ACMMENT 1-CF NRC LETTER.

Edward S.

Wollesen

,91-02-IDRG Notes Page-21 of 20 February 21, 1991 DP-DATED February 28, 1991 and instructions which specify the preparation of records or which specify.the performance of defined activities requiring documented evidence that these activities were promptly performed and completed."

o Section V.

Responsibilities And Actions states:

"Every-department that generates or receives quality assurance records applicable to_CR-3 shall describe in departmental procedures methods for implementing the requirements of this program.

and Collection Of

Records, 1.

A.

Identification Identification of Records states:

"It is the responsibility of each functional group or department performing activities associated with... design,...

maintenance... or operation of CR-3 to identify QA records which are required to be generated' or received as a-result of their departmental responsibilities.

QA records shall be further identified as ' lifetime' or 'non-permanent.'"

AI-1100:

Section 4.0 Instructions,

_4.1 Identification And Classification Of Quality Assurance Records,- Step 4.1.1 Forms Logs, or other documents used in the normal course of business, which are -included in POQAM Procedures but.

~

which are NOT QUALITY ASSURANCE documents, must be identified as " Optional Records Non-Quality" within the applicable procedures...,

Step 4.1.2 states:

"It is the responsibility of each functional group-or department within Nuclear Operations performing activities associated with-the design, manufacture, construction, or operation of CR-3 to identify QA records which are required to be generated or-received-as-airesult of their departmental responsibilities.

QA records shall be further identified as

" lifetime" or "non-permanent" in accordance with section 3.0.of this procedure....."

Technical Specifications:

o-6.5.1.8:

"The Plant Review Committee shall maintain written minutes of each meeting...."

DEVIATION EEAMPLES:

1)

AI-3OO, Plant Review Committee Charter, Revision 29 and 30, does not identify records, therefore, all records and documents generated by the procedure are Quality Assurance Records.

Furthermore, those records in the procedures are not identified as to the life time as required.

11)

The records as defined in AI-300 have not been distributed L

in entirety (refer to deviation 1 for item 1 above).

l iii) AI-JOO, Section 4.3.4 Conduct of PRC Meetings Step 4.3.4.1 i

states:

" Formal guidelines for conduct of PRC meetings 21

" ATTACHMF.NT 1 FF NRC LETTER._

Edward S.

Wo)3cnon Pago 22 of 20 91-02-IDRG Notes February 21, 1991 UP-DATED February 26, 1991 must be established by the PRC Chairman."

Step 4.3.4.2 states:

"The guidelines must be written and distributed to the PRC Members and alternates."

The Crystal River Unit 3

Plant Review Committee Guideline MLnual was generated but is not identified as to the If.fe time (by default it is a

Quality Record),

not cor. trolled (

as required in further references) nor maintained.

DISCUSSIONS:

AI-300, revision 29 was recently revised to add the required documentation in the procedure to control the document retention from 5 years to lifetime of the plant.

This was done in response to a IOC SNC90-0174 from Nuclear Compliance to J Alberdi as a summary of the results from the Nuclear Compliance Activity Review 90-15, Plant Review Committee (PRC) Requirements.

The review indicated areas that AI-300 did not comply with the TS.

A Nuclear Safety Supervisor changed the spots of the procedure to call out the lifetime storage requirement.

CONCERNt a)

The events documented a situation that appears to meet the requirements of a Problem.

The Nuclear Regulatory Specialist who identified the areas of non-compliance to have procedures appropriate to the circumstance and require the TS required retention told the Senior Quality Auditor (on 02/22/91 at 16:25) that he determined that the areas were min 6 in nature.

He understood that Records Management keeps all ci tne records for ever, therefore this requirement in the procedure had no bearing on the commitment.

This was the expressed opinion for all of the issues that he identified as not meeting the requ,i rement s.

CP-111 definition for the issue reveals thAt the issue does not meet the requirements for a minor problem and the documentation that is required for that documentatio,n was not used.

This issue meats the criteria for at least a non-significant problem.

If the retention date used by records management could ever be used to discard the records on a reel before the required lifetime storage time then all of the records that are required to be maintained for the lifet'ime of the plant will need their record retention date changed.

Therefore, remedial actions of changing AI-300 may not be the only actions required to happen.

b)

A second concern is that the Nuclear Safety Supervisor changed the procedure and the PRC wasorequired to review the procedure and there is no mention of the problem report or the need for one.

The minutes of the meeting that approved the changes need to be reviewed.

22

~

ATTACHMENT 1 OF NRC LETTER.

Edward S.

Wollooon

)

Page 23 of 20 91-02-IDRG Notes j

February 21, 1991 UP-DATED February 26, 1991 DISCUSSION ON THE REVIEW BY COMPLIANCEt This review appears to be a pre-audit look see how the PRC in performing.

The method used appears to be a search of the NOCS data base.

It we QPD wish to assist the plant we could shed light on the fact that there are many " mother" commitments met by governing procedures such as AI-400A,B,C,D, AI-lico, AI-2207 and others that would not show up on the review that Nuclear Compliance would use.

This is the method that Nuclear Compliance selected to reduce the duplication of major commitments that govern many programs; the commitments are implemented when the programs are followed.

A commitment review will not show these areas of non-compliance.

Also, if Nuclear Compliance did the review, why did they miss the fact that the PRC is not required by procedure to review any procedure?

And that there are no review instructions for the PRC review?

B) MAINTAIN RECORDS:

Records identified as quality records are required to be established, maintained and in storage within ten days.

This is to be performed to instructions in the departmental procedures by use of transmittalo, of forms that have the required information.

REFERENCES :

NOD-04:

o V.

RESPONSIBILITIES AND ACTIONS,

2. Collection Of Records states:

"It is the responsibility of each functional group or department generating or receiving QA records to handle these records in accordance with the requirements of the above mentioned departmental procedures and instructions.

This includes records generated by FPC or records submitted to FPC in the normal Conduct of business or as required by

...or other governing documents.

Upon receipt or generation of a

record, the responsible department has ten (10) working days to transmit the record to either temporary storage or permanent storage...."

Section V Responsibilities And Action's further states:

...Shall describe in departmental procedures methods for implementing the requirements of this program."

D.

..must be turned over... turnover Turnover Of Records:

must be performed be formal transmittal as identified in departmental procedures... Transmittals must contain, as a minimum, the following...."

AI-1100:

o 4.3 Transmittal Documents-

"4.3.2 IP Enclosure 1 does not require transmittal by PATS, THTM the QA record shall be transmitted to Records Management for permanent storage by 23

ATTACHMENT 1 @F NRC I.ETTER.

Edward S. Wo11esen 91-02-IDRG Notes Page 24 of 20 February 21,-1991 UP-DATED February 26, 1991 Enclosure 2

or a similar form which contains the same information."

Comment:

The IOC does have most of the information except for the turn over signature and returning of the form.

This is required to assure that the records were turned over with in the required time.

AI-400E:

o

1.0 Purpose

...to provide instructions to personnel when performing procedures at CR-3...

Comments: But the provisions of AI-400E do not fit to working the AI-series, and may include others for the transmittals.

However there is a

transmittal, l to transmit records generated by P0QAM procedures.

Section 4.4 covers different types of the transmittal process but there is no clear usage for the transmittal from AI's in general, AI-1100 and AI-605 are listed as having transmittal sheets.

AI-300:

o AI-300 Section 4.2 Membership, Step 4.2.1 Permanent Membership, Step 4.2.1.1 defines that the Plant review Committee shall be composed of by nine members arid one

" The above positions chairman.... Step 4.2.1.2 states will be designated on the PRC Membership List."

DEVIATION EIAMPLES:

1)

The PLANT REVIEW COMMITTEE MEMBERSHIP list, dated February 14, 1991 was issued but no identifiable transmittal methods were used to maintain the record.

ii)

The mentioned list contained ten (10) members covering the-areas of expertise required by the eight categories in step 4.2.1.1, however there are inaccursw.ies in the list in that some apparent

.(by the convention of the list) alternate members are not designated an alternates, some phone numbers are not correct and differ from one sections I

of the list to another section of the list.

DISCUSSIONSt

{

o The requirement to sent this list to file was mentioned to L

the PRC Secretary to assist in assuring that the list will l

i be sent within the required time

frame, however the l

transmittal requirements are required to be clearly identified in the administrative instructions.

AI-1100 has the requirements and if this and other requirements that are required to be followed by all persons performing procedures, then some consideration should be given to gather all of these recuirements for all procedures and 24

ATTACEMENT 1 OF NRC LETTER._

Edward S. Wollonen

~

91-02-1DRG Nates Page 2S of 20 February 21, 1991 UP-DATED February 26, 1991 list or number them so that all pera-

'l can access them easily.

!iOTE: the requirement for co

'm compliance to procedures is in a procedure t i t li '.

man Performance s..g these to a

,Thancement Procedure",

AI-2207.

,orward type instruction could mal aare persons aware that they are in place.

o T1415 IS ANOTHER KKAMPLE OF THE PROBLD1 IDENTIFIED IN DRAFT 1ROHLEM REPORT QAPR-91-01-OPS-0001.

R.J. URAL IS THE TEAM LEADER OF TRAT AUDIT.

+ 41 LEGIBILITY OR RECORDEL PRC documentation is i.u: always reproducible PRHP for AI-300, PRR ggg 13, PRC Meeting number and data signed by the PRC Chairman were missing; and AI-900, Revis.on 21, PRR 11,

onduct of Nuc3 ear Compliance Procedure Review Record for the dance 11ation of the procedure also had the PRC information missing / not legible on any copies from the original.

REFERE5CES :

NOD-04:

AI-1100:

5j,

, CONTROL OF INSTRUCTIONS / PROCEDURES:

The PRC Cuideline Manual does not have any control apparent to the book itself and according to the PRC Secretary.

REFERENCES t_.

1)

Review of the Crystal River Unit 3 Plant Review Committee Guideline

Manual, MEMBER AT f,ARGE book in the Sita Quality Program Department.

c)

The responsibilities of the PRC Secretary ora listed in the guideline.

the instructions in the guidelines CONCERNt should she perform or the procedure?

Since she is performing activities to meet the T.S. then they are required to be in procedure / instructions that are approved and controlled.

d)

The Florida Power Corporation Crystal River Unit 3 Plant Review Committee Guidelines Index page after all of the other pages is documented as Revision o dated September 30, 1908.

CONCERN The information in front of the index and the page that identifies the revision number appears to be an up-date.

However there is no indication of the revision, date or what is Correct.

25

l ATTACRMgst 1 OF KRC LETTER t Edward S. Wo1103On 93-02-!DRG Notes Page 26 of in i

Pebruary 23,

'91 UP-DATED February 26, 1991 NOTEt Th t.

Auditor placed a sign on the manual that the book contained out-dated material and reported that information to the Manager site Quality Assurance, holder of the manucl.

33)

AI-300, Revision 30, Plant Review Committee Charter, Step 3.2.3 states:

"The submission of reportable events to NGRC and the Vice Pi*es id en t,

Nuclear Operations has been delegated to Site Nuclear Licensing.

This meets the requirements of Tech. Spec.

6.6.1(b)."

7.S.

6.6 Reportable. Event Action includes 6.6.1 (b) which states:

"Each Reportable Event shall be reviewed by the PRC and Submitted to the NGRC and the Vice President, Nuclear Operations."

CONCERN:

a)

Is the intent of the T.S.

to have PRC review the Events and

~.

send the report from the PRC and the event to....?

If not-what is the reason to give the NGRC and the Vice President, Nucitar Operations reports with no action for their review?

Tant appears to be a portion of the issue.

The NGRC and the Vice President, Nuclear Operations are interested in the PRC responses / actions (or lack of) as well as the issues.

(opinion here as that of the QPD Auditor based on the responsibilities placed on the NGRC.

Determination of the actual requirements has not been made) b)

Does Licensing have provisions to forward the Events to the NGRC and the Vice President, Nuclear Operations?

If not did

-this change to AI-300 lessan the Quality Program?

Have any Reportable Events not been transmitted the NGRC and the Vice-President, Nuclear Operations?

l NOTE:

The Senior Nuclear Licensing Engineer offered to advance our concerns through his management toward receiving the answers and toward assuring that CR-3.is meeting the requirements in T.S.

6.6.1_(b).

If this r'equires an

- int er p?s t at ion,

he would pursue that action.

Recommendation was made that Licensing ' and the Interpretation contact for AI-300 may need to meet to resolve this concern and establish a clear understanding of the requirements.

Further, the discussion covered the

-Audit Team's desire to assist the. plant to reach the correct actions,. as necessary, to assure CR-3 meets-the requirements.

14)

Do the-instructions, in AI-300, clearly establish the PRC's -

Membership, Authority,-Responsibility, Organization?

l CONTROL OF DoctButNTS/INSTROCTIONS 26 i

w.

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ATTACIDOUf? 1 OF URC LETTEN2 Edward S. WD12 coon J

91-02-IDRG Notes Page 27 of 20 debruary 23, 1991 UP-DATED February 26, 1991 The Crystal River Unit 3

Plant Review Committee Guideline Manual has good information in it, however there is no way to identify what revision level is current.

New Members get i

information, not spoke of as a manual.

A manual reviewed was full of outdated information, procedures and miscellaneous I

examples of things.

There was no control number.

The reviews conducted (or required to be conducted) were not covered in the manual.

Some of the information was duplicate to the instructions in AI-300.

When this is done, instructions in one of the two instruction mediums can be out of date consistently.

l h

The beginning of the book had 1)

" Sample" Problem Reports, j

11)

MAR packages, iii). unreadable T.S.

pages, iv)

AI-300, Revision 129 (out of Date),

v)

Plant Review Committee Meeting Schedule, that stated:

"On the normal schedule, Plant Review Committee (PRC) meetings will be held each Tuesday and Thursday, nt 10:00 A.M.,

in Conference Room 204 of.the Nuclear Administration Buildirg."

vi) further in the information in front of the index it states:

"on.

the normal schedule (non-outage),

Pre meetings are held each Tuesday and Thursday of the week.

To assure that special presentations are properly scheduled, anyone involved with a special presentation should notify the PRC secretary by 12:00 Noon of the preceding Friday.

Special presentations should be scheduled for the Tuesday meetings."

There are only Thursday meetings at this time, vii) Agenda items are to the PRC secretary less than two days prior to the meeting.

By the time she assembles the materials and puts them in -the mail, the itees may reach the members t,he - afternoon before the meeting.

viii)

PRC. members only receive the training summaries for procedure changea'and MAR review sheet for-

-the MARS.

These are distributed only to the members, not the alternates.

Therefore if the alternate needs to attend the meeting, he may not even know what ' is being presented.

The-T.S.s included in the package were copies off of the page, not readable.

lx)

A copy of AI-300, Plant Review Committee Charter,-

Revision 28--was in the material in front of the index, 19I0 REVISIONS OUTD&TED.

x)

The responsibilities of the PRC Chairman are listed in the pages are more than in AI-300 Responsibilities.

x1)

The explanat!an of Alternate Members' 27

A_TTACio(ENT 1 PF HRC !.ETTEM._

Edward S.

Wo11esen 91-02-IDRG Hotes Page 28 of 20 February 21, 1991 UP-DATED February 26, 1991 ADDITIONAL FACTS.

ANSI N18.7 5.2.15 Review, Approval and Control of Procedures The adminiertative controls and quality assurance program shall provide measures to control and coordinate the approval and issuance of documants including changes

thereto, which prescribe all activities affecting quality...These measures shall assi e that documents, including revisions or changes, are sviewed for adequacy by appropriatly qualified persenne and approved for release by authorized personnel.. and used by the personnel performing the prescribed

activity, and that procedures are provided to avoid the misuse of outdated or inappropriate documents... Procedures shall be approved as designated by the owner organization before initial use.

Rules shall be established which clearly delineate the review of procedures by knowledgeable personnel other than the orginiator and the approval of procedures and procedure changes by authorized individuals.

Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the owner organization designateu another qualified organization.

The reviewing organization shall have access to pertinent background unformation upon which to base it's approval and shall have adequate understanding of the requirements and the intent of the original document.

Those participating in any activity shall be made aware af, and use, proper and current instructions, procedures...for performing the activity.

Participating organizations shall have procedures for control of the documents and changes thereto to preclude the possibility or use of outdated or inappropriato documents..."

'.2 Glossary of terms 2.

Definations, 2

Review A deliberately critical examination, including observations of plant operations, evaluation of audit

results, procedures, certain contesplated actions, and I

after the fact investigations of abnormal conditions (see independent review).

ANSI N45.2.10 Procedure-A document that speciffro or describes how an activity is to be performed.

It may include methord to be employed, equipment or materials to be used and sequence of operations.

Technical Specifications:

6.5 Review and Audit, 6.5.1 Plant Review Committee (PRC),

Meeting Frequency 6.5.1.4 28 l

s' M

ATTACHMENT 1 OF FRC LETTEa Edward S. Wo13ese.1 Page 29 of 20 91-02-1DRG Wates February 21, 1993 (TP-DATED February 25, 1991 The PRC snall meet at least once per calendar month and as convened by the PRC Chairman or his designated alternate.

Quorm 6.5.1.5 A quorm of the PRC shall consist of the chairman or his designated alternate and five members including alternates.

Responsibilities 6.5.1.6 1he PRC shall be responsibile fort a.

Review of

1) all procedures and changes thereto as required by Specifications 6.8.2, 2) and other proposed procedures or changes thereto as determined by the Lirector, Nuclear Plant Operations to affect nuclear safety, b.

Review of all proposed tests ans experiments that affect nuclear safety.

c.

Review of all proposed changes to the Appendix "A" Technical Specifications, d.

Review of all proposed changes or modifications te plant systems or equipment that affect nuclear safety, and changwa to radwaste systems which could significantly alter their ability to meet Appendix 1.

e.

Investigation of all violations of the Technical specifications including the review and forwarding of reports covering evaluation and recommendstions to prevent recurrence to the Vice President, Nuclear Operations and to the chairman of the Nucient General Review Committee.

f.

Review Of all REPORTABLE EVENTS.

D.

Review of facility operations to detect potential nuclear safety hazards, h.

Reivew of the Plant Security Plan and Icplementing

- proceduces.

j.

Review of the Emergency Plan and Implementing Procedures, k.

Review of every unplanned on-sits release of '

radioactive material to the environs (sic), including the review and forewarding of reports covering evaluation, recommendations and disposition of the corrective action taken to prevent recurrence to tho' Plant Manager and Nuclear General Review Committee.

1.

Review of changes to the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.

Authority 6.5.1.7 The PRC shallt Recommend to the DNPO written approval or disapproval a.

of items considered under 6.5.1.6 (a) through (d)

above, b.

Render determinations in writing with regard to whether or not each item considered under 6.5.1.6 29

_. _ _. _ _ _ _. ~. _. _ _

• • e e

ATTACEMENT 1 PF WRC LETTER.

Edward S. Wollesen 91-02-IDRG Notes Page 30 cf 20 February 21, 1991 (JP-DATED February 26, 1991 J

(a) through (e) above constitutes an unresolved safety question.

c.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice Presicent, Nuclear Operations and the Nuclear General Review Committee of disagreements between the PRC and the DNPO; however, the DNPO shall have responsibility for the resolution of such disagreements pursuant to 6.1.1 sbove, i

Records 6.6.1.8 The PRC shall maintain written minutes of each meeting and copies shall be provided to the Vice President, Nuclear Operations and Chairman of the Nuclear General Review committee.

Reportable Evnet Acition 6.6, 6.6.1 (b) i Each REPORTABLE EVENT shall be reviewed by the PRC and submitted to the NGRC and the Vice President, Nuclear operations.

(Under the Respont'bilities of the NGRC falls this i

requirement for the PRC) 6.8 PROCEDURES, 6.8.1 SCOPE Written procedures shall be established, implemented and maintained covering the activities referenced belows a.

The applicable procedures recommended in Appendix "A"

of Regulatory Guide 1.33, November 1972, b.

Refueling operations.

c.

- Surveillance and-test activities of safety related equipment.

d.

Security Plan. implementation.

e.

Emergency Plan implementation.

f.

Fire Protection Program implementation, g.

- Systems Intagrity Program implementation.

h.

Iodine Monitoring Program implementation.

1.

PROCESS CONTROL PROGRAM implementations j.

OFPSITE DOSE CALCllLATION MANUAL implementation.

k.

Quality-Assurance Program.

for

_, effluent

-and

_ environmental monitoring.

3 6.5.2 REVIEW PROCESS 6.s.2.1 Each procedure and administrative policy of-6.8.1

above, and-changes thereto, shall b'e reviewed. and 1

approved prior to implementation as follows:

a.

The Emergency

Plan, Security

Plan, Fire Prot 6ction Plan and implementing procedures,

Administrative Instructions and those test procedures associated with plant modifications that affect nuclear safety shall be reviewed and approved by the PRC and the Director, Nuclear Plant Operations prior to implementation.

b.

For all other procedures, the review cycle shall consist-of:

an intradepartmental review by a

'l 30 vt w e~ry

?-

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ATTACHMENT 1 0F FRC LETTER._

Page 31 of 20 91-02-IDG? Notes February 21, 1991 UP-DATED February 26, 1991 Qualified Reviewer, and interdisciplinary review by Qualified Reviewer (s) in interfacing departments, as specified in administrative procedures, and approval by the responsible Superintendent or

Manager, as specified by administrative procedures.

The PRC shall then review the to CFR 50.59 evaluation within 14 days of approval.

6.8.2.2 The training and qualification of Qualified Reviewers shall be governed by administrative procedures, with final certification by the Director, Nuclear Plant Operations.

Recertification will be required on a periodic basis and upon transfer between departments.

As a minimum, all Qualified Reviewers shall meet the requirements of ANSI N18.1-1971, Sections 4.2, 4.3, 4.4, or 4.6, or the equivalent.

6.8.2.3 Each procedure and administrative policy of 6.8.1 shall be reviewed on a periodic basis as set forth in administrative procedures.

MOD-12:

Implementation of Technical Specification 6.8.1.a.

NOTE:

Technical Specification 6.8.1.a war further defined for implementation in N00-12, Impleuentation of Technical Specification 6.8.1.a.

Careful review of the entire NOD-12 should be performed.

However the following sections are very important.

V.B.1.

Managers of all procedure manuals utilized for work at CH-3 plant shall review the procedures within their respective groups and delineate which procedures are utilfred for performing applicable activities at the CR-3 plant (see attschaent 1).

In

addition, all new and revised procedures shall include such delineation.

V. B. 2.

For those procedures identified in V.B.1 above as being used to perform applicable activities, the review and approval methodology shall include the requirements of Technical, Specification 6.8.2.1.a or 6.8.2.1.b.

(NOD-12)

ATTACHMENT 1 APPLICABLE ACTIVITIES AT CRYSTAL RIVER UNIT 3 This attachment is presented in the same format as Appendix A to Regulatory Guide 1.33.

Those activities in that Appendix that are performed at boiling water reactors or at pressurized water reactors of a different design than CR-3 are listed as N/A.

Activities performed at CR-3 may have been revised to present the CR-3 specific nomenclature.

A.

Administrative Procedures 31

ATTACHMENT 1 0F WRC !ETTER2 Edward S. Wollooon 91-02-IDRG Notes Page 32 of 20 February 21, 1991 UP-DATED February 26, 1991 1.

Security and Visitor Control (SS Series Procedures) 2.

Authorities and Responsibilitien for Safe Operation and Shutdown (AI-600, OP's, EP's, AP's, FP's, and AR's.)

3.

Equipment Control (e.g.,

locking and tagging)

(CP-123, and CP-115) 4.

Procedure Adherence and Temporary Change Method

( AI-2207, AI-400 Series, CP-134)

}

5.

Procedure Review and Approval (AI-400 Series, CP-134) 6.

Schedule for Surveillance Tests and Calibration

( SP-440,1,2,3, SP-701) 7.

Shift and Relief Turnover (AI-500) 8.

Log Entries and Record Retention (AI-500, and AI-400E) 9.

Access to Containment (OP-417) 10.

Bypass of Safety Functions and Jumper Control (CP-113A, and CP-113B) it.

Recall of Standby Personnel to Plant, g!M-206)

PSAR 1.7.1.2 Quality Pronrams states:

...FPC has an indoctrination and training program for personnel performaning quality activities to assure that they are knowledgeable of the Quality Program's procedrues and requirements.

The indoctrination and training program includes appropriate procedures and personnel records.

Farsonnel responsible for performing quality activities are instructed as to th epurpose, scope and implementation of the quality-related

manuals, instructions, and procedures.

Personnel performing quality activities are trained and qualified in the activity being performed...."

M' j

32

ATTACHMENT 1 OF NRC LETTER.

Edward S. Wo11eaen Page 33 of 20 91-02-IDRG Notes February 21, 1991 UP-DATED February 26, 1991 AI-3OO, Pt. ANT REVIEW CONMMITTEE CRARTER 1.0 PtTRPOSE The purpose of this procedure is to define the duties of the Plant Review Committee (PRC).

2.0 REFERENCES

2.1 IMPI.EMENTING REFERENCES 2.3.1 CP-111, Processing of Problem Reports Which Are Reportability or Plant / Personnel Safety Concerns 2.3.2 AI-400A, Description and General Administration of Plant Procedures 2.1.3 PRC Guideline Manual 2.3.4 CP-211, Problem Reporting 2.3.5 AI-iO4, Reactor Trip Review and Analysis 2.2 DEVELOPMENTAL RFFERENCES 2.2.1 CR-3 Technical Specifications 2.2.2 10 CFR 50, Appendix "B"

2.2.3 ANSI N18.7-1976 2.2.4 Table 1-3 of PSAR 2.2.5 10CFR50.59 3.0 PERSONNEL IB1XCTRINATION 3.1 DEFINITIONS None 3.2 RESPOKSIBILITIE5 3.2.1 The PRC Chairman is responsible for the content of this procedure.

3.2.2 The PRC Chairman or Alternate Chairman shall act as the interpretation contact for any questions regarding intent.

3.2.3 The submission of reportable events to NGRC and the Vice President, Nuclear Operations has been delegated to Site Nuclear Licensing.

This meets the requirements of Tech.

Speg. 6.6.1(b).

3.3 DESCRIPTION

This procedure describes the PRC duties as referenced in Technical Specifications.

4.e YEvratKnrTess 4.3.3 In accordance with the duties and responsibilities of the Plant Staff described in this procedure, a specified group constitutes the PRC.

4.3.2 The PRC provides review of plant operations and maintenance to assist the Director, Nuclear Plant Operations (DNPO) in 33

ATTACRMF.NT 1 OF WRC LETTER._

Edward S. Wollenen 91-02-IDRG Notes Page 34 of 20 February 21, 1991 UP-DATED February 26, 1991 maintaining surveillance of plant activities with particular emphasis on safety-related matters.

4.1.3 The following Committee items are intended to be in acesRoanappeneth "Bect And Tableot-37mdhnbea rs ARpecificat ions, o

Committee Membership o

Qualifications o

Meeting Frequency o

Quorum o

Alternates o

Responsibilities o

Authority o

Records o

Procedures 4.2 NEMBF.RSHIP 4.2.1 Permanent Membership 4.2.1.1 The Plant Review Committee shall be composed of nine members

]l and one chairman from Nuclear Operations Supervisory Persennel responsible for the following areast operations o

o Health Physics o

Security o

Maintenance Ro@itkeat hgns o

o Nuclear Safety o

Quality 4.2.1.2 The above positions will be designated on the PRC Membership List by the DNPO.

4.2.1.3 Changes to positions on the PRC Membership List must be made in accordance with 10CPR50.59.

4.2.2 Alternate Members 4.2.2.1 During absences of the permanent PRC members, alternates may serve on a

temporary basis as defined in Technical Specification C.S.1.3.

4.2.2.2 The PRC Chairman shall appoint such alternates in writing.

4.2.2.3 In any

case, no more than two (2) alternates shall participate in a

vote in accordance with Technical Specification 6.5.1.3.

4.2.3 Committom Officers 4.2.3.1 The PRC Chairman is designated by Technical Specification 6.5.1.2.

4.2.3.2 The annignment of PRC Alternate Chairmen and PRC St r9tary 4.2.3.3 sha l l h bt andat hy c ha i PREn ch a i r&sti d a. wrd e d pgna i bi l i t i es,

and qualifications shall be the same as those of the PRC Chairman when acting for the Chairman.

4.2.3.4 The Chairman and Alternate Chairman are non-voting members of the committee.

4.2.4 Qualifications The qualifications of the regular members of this Committee shall meet or exceed the requirements of Technical Specification 6.3.

4.2.5 Onorum 34

g.. o ATTACHMENT 1 OF NRC 12TTER.

Edward S. Wollesen 91-02-IDRG Notes Page 35 of 20 February 21, 1991 UP-DATED February 26, 1991 4.2.5.1 A quorum of the Committee members and alternates shall be as defined in Technical Specifications 6.5.1.5 and 6.S.1.3.

4.2.5.2 A member way be considered present if he is in telephone communication wits the Committee chairman or Alternate Chairman, but in no caso shall this be done for more than one (1) member (including the Chairman or Alternate Chairman) in any single meeting.

4.2.5.3 If a regular telephone is used, only one (1) item should be reviewed.

4.2.S.4 A speaker phone should be used if more than one (1) item is to be reviewed at the discretion of the Chairman or Alternate Chairman and other members present.

NOTE:

Any number of subset meetings during a work week (Monday through Sunday) in to be considered one meeting.

4.3 g ETING REQUIREMENTS 4.3.1 Frecruency 4.3.1.1 The minimum frequency of Committee meetings shall be in accordance with Technical Specification G.S.1.4.

4.3.1.2 Other meetings (special meetings) may be held when scheduled by the Chairman or his designated alternate (Alternate Chairman).

4.3.2 Attendance 4.3.2.1 All PRC members should attend all normally scheduled meetings.

4.3.2.2 If a member will be off-site or otherwise unable to attend, it is that member's responsibility to ensure his alternate attends in his place.

4.3.2.3 If a member is unable to be represented, he should inform the PRC Chairman or escretary.

4.3.3 Scope 4.3.3.1 The PRC shall be responsible for reviewing those items listed in CR-3 Technical Specifications 6.5.1.6 and 6.7.1(C),

and for performing those duties listed in Technical Specification 6,5.1.7.

4.3.3.1.1 For the purpose of the.above reviews, a proposed change,

test, or experiment shall be deemed to involve an unreviewed safety question if:

o The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report may be increased; o

A possibility for an accident or malfunction of a

different type than any evaluated previously in the Safety Analysis Report may be created; o

The margin of safety as defined as the basis for any Technical Specification is reduced.

4.3.3.2 The responsible department is delegated the responsibility oft o

Investigating all violations of the Technical Specifications 35

,.. s ATTACHMENT 1 OF NRC LETTEM.

Edward S. Wollesen 91-02-IDRG Notes Page 36 of 20 February 21, 1991 UP-DATED February 26, 1991 o

Presenting to the PRC (for their review) the report of the investigation of the violations of Technical specifications including recommendations to prevent recurrence of the violations.

4.3.3.3 The report of the investigation of all violations of the Technical Specifications including actions to prevent recurrence are forwardad from ths PRC to the Vice President Nuclear Operations and to the Chairman of the Nuclear General Review Committee.

4.3.3.4 Prior to restart, following an unplanned reactor trip, the PRC shall review the restart package in accordance with AI-704, " Reactor Trip Review and Analysis."

4.3.4 Conduct of PRC Meetings 4.3.4.1 Formal guidelines for conduct of PRC meetings must be established by the PRC Chairman.

4.3.4.3 The guidelines must be written and distributed to PRC members and alternates.

4.3.5 Review of Items 4.3.5.1 As shown on Enclosure 1, an item for review is placed on the Review Item Log.

4.3.5.2 A formal Committee meeting is scheduled then held at which time the item is explained to the committee and discussed by Committee members as necessary.

4.3.5.3 JZ all members and alternates comprising the quorum are not in unanimous agreement, THEN a vote is taken and the majority rules.

4.3.5.3.1 Dissenting opinions are handled in accordance with Section 4.3.5.3.2 Thd. Item is either recommended for approval, withdrawn from consideration, or recommended for disapproval by the Committee as designated on the Review Item Log attached to the minutes.

4.3.5.3.3 All items not withdrawn from consideration are submitted to the

Director, Nuclear Plant Operr.tions (DNPO) for his approval in accordance with approved POQAM procedures.

4.3.5.3.4 All items withdrawn from consideration are returned to the 4.3.5.4 Apphtcahbe SeeklodsSupppebred obydeshonetc or

DNPO, it is controlled.and distributed per the applicable procedures contained the Nuclear Operations Department (NOD)

Hanual governing Document Control / Records Management activities.

4.3.5.4.1 Any PRC member has signature authority for the PRC on items which have completed review by the PRC.

4.4 REcbaDSSecretary of the PRC shall be responsible for maintaining a continuing record of the activities of the committee in the form of:

o Minutes o

Review Item Log o

Action Iteu Tracking System Log o

NembwesRdpoDbeun6nhation Items o

Other Correspondence 4.4.1 Minutes 36

j ATTACEMENT 1 OF KRC LETTEQ2 Edward S. Wollesen 91-02-IDRG Notes Page 37 of 20 February 21, 1991 UP-DATED February 26, 1991 4.4.1.1 The PRC Secretary.

or an alternate designated by the Rhe t tngn o f p hepf Fos Mir ties for each regular and special 4.4.1.2 Minutes must include the followingt a

cttendees o

An itemized list of documents reviewed and a checklist of the Committee's recommendations, o

Dissenting votes shall be recorded with a brief statement f eeomtthada t knanare f ocons t.de r eld sme ntdngnin2us ut) Comm i t tke Minutes contain dissenting opinions).

o A statement that no unreviewed safety questions exist for the items approved, A report of general discussion items which summarizes the o

concerns expressed by committee members and their o

adspositions of any unresolved items to be carried to future meetingu or any action items that are closed by the Committee.

4.4.1.3 The Minutes shall be prepared by the Secretary as soon as practicable following the meeting.

o The Secretary should make a reasonable effort to have the Minutes completed within two (2) working days following The keeketaryhdthi thouteetHagerbyrmaheld.the PRC Chairman o

(or Alternate Chairman) for his approval by signature.

o Additional copies will be sent to the Vice-President, Nuclear Operations and Chairman of the Nuclear General Review Committee (NGRC) as required by Technical Specification 6.5.1.8 after approval by the PRC Chairman (or Alternate Chairman).

o Minutes requiring changes after approval will be identified as "REVISFD MINUTES."

o Rhokeed Minutes w1A1 follow the same distribution as o

Minutes will be identified by sequential numbers and dates.

o The Minutes shall be retained for the duration of the facility operating license.

4.4.2 Problem Reports 4.4.2.1 droblem Reports (prs) will be processed in accordance with CP-111, Processing of Probles Reports Which Are Reportability or Plant / Personnel Safety Concerns.

4.5 PLANT REVIEW CCAS(ITTEE GUIDELINE MANUAL The purpose of the Plant Review Committee Guideline Manual is to provide guidance to accomplish Committee funct. ions.

Sometime I met with J. Alberdi about the problems with AI-300, Plant Review Committee Charter.

He did not want nor think he had to follow the writers guide for his precedures.

This to me is a poor example, and I expressed that feeling to others in the Quality Programs Departent.

6 37

_