ML18164A089
| ML18164A089 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/11/2018 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18164A087 | List: |
| References | |
| ULNRC-06443 | |
| Download: ML18164A089 (9) | |
Text
Attachment 1 to ULNRC-06443 OPERATING QUALITY ASSURANCE MANUAL (OQAM) REVISION 33 DESCRIPTION AND JUSTIFICATION FOR CHANGES The descriptions and justifications listed below for OQAMCNs17-001, 17-002,17-003 and 1 7-004 refer to OQAM section changes as indicated by the marked-up pages of interim Revision 32b provided in Attachment 2. The OQAMCNs were previously reviewed internally, and the OQAM continues to meet the requirements of 10 CFR 50 Appendix B. None of the changes to the approved Quality Assurance Program were determined to constitute a reduction in commitment in accordance with 10 Cf R 50.54(a)(3). The basis for the conclusion that these changes did not constitute a reduction in commitment is provided in the change descriptions below.
OQAMCN 17-001 Sections Description Justification Addition of grace period is not considered a reduction in commitment in accordance tvith Added A 90-day grace 10 CFR 50.54(a)(3) due to approval by an NRC 1 8 1 1 and period may be applied to SER of a similar change at another facility. This this activity. change is consistent with the SER provisions.
Reference NRC ADAMS accession number ML101820108 dated 07/22/1998.
Added verbiage: Supplier Audits Section C.3.b.(2) of Reg. Guide 1.144. Revision I states that audits he performed on a triennial
- basis
. Addition of grace period is not considered a Appendix . . .
The 90-day grace period reduction in commitment in accordance with A
may be applied to this 10CFR 50.54(a)(3) due to approval by an NRC Re ulator activity. SER of a similar change at another facility. This Guide change is consistent with the SER provisions.
Supplier Evaluation
- 1. 144 Reference NRC ADAMS accession number discussion. Section C..b.(2) of Reg.
ML101820108 dated 07/22/1998.
Guide 1.144, Revision 1 states that documented evaluations be performed annually. The 90-day grace period may be applied to this activity.
Page 1 of9 to ULNRC-06443 OQAMCN 17-002 Sections Description Justification 1.2, 1.3.3, 1.7.3, Editorial changes.
174 7 11 Changes made to replace gender specific 2173 14
. , .. 5 verbiage with gender neutral verbiage. Examples Appendix A include; he is to they are or this individual
. H ,, P RG 1 38
. . is, he to they, the individual or this discussion page ,, ,, ,,
. person he has to they have his to their 12 of 28, and and, infrequently, deleted the pronoun. These are RG 1 146
. . editorial in nature.
discussion on page 27 of 2$.
Added a new section stating: The Senior Vice See below.
President and Chief Nuclear Officer is responsible for ensuring an independent review of matters involving safe operation of the plant is conducted at least once per twelve months. The review addresses matters that management determines warrant special attention, such as plant programs, perfonnance trends, employee concerns, or other matters related to safe plant operations. The review is perfonncd by a team 1 7
.. consisting of personnel with experience and competence in the activities being reviewed, but independent (from cost and schedule considerations) from the organizations responsible for those activities. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence. Results are documented and reported to the Senior Vice President and Chief Nuclear Officer.
Revise to read, The Onsite Review Committee See below.
1 .6 (CRC) and NOS shall provide the required independent review function.
1.7.5 Delete and the NSRB. See below.
I .7.6.f and I Delete and to the NSRB. See below.
Delete and shall submit recommended changes See below.
1.7. 6 .i an d j to tleNSRB.
Replace Chairman of the NSRB with Senior See below.
1 76n
. Vice President and Chief Nuclear Officer.
Page 2 of 9 to ULNRC-06443 Delete and submitting recommended changes to See below.
. 7 6 1 the NSRB.
I .7.7.d Delete and the NSRB See below.
1 .7.7.e Delete NSRB and the. See below.
1 .8 Delete section. See below.
Revise title of Director, Engineering Design or Editorial change to reflect Projects to Director, Engineering Design & culTent organization.
2.4 Proj ects. Typographical change reflecting combination of the two groups under one director.
In first paragraph, delete and the Nuclear Safety See below.
Review Board (NSRB).
3.18 In second paragraph replace NSRB with ORC.
5.6.6 Replace, ORE andor NSRB with and ORE. See below.
16.8 Delete the NSRB and. See below.
17.1 1 .2.k Delete and the NSRB. See below.
Delete The NSRB shall selectively review audit See below.
reports of onsite atidits.
Iii the next to last sentence, replace The NSRB t$.6 shall also periodically review the onsite audit program as developed by the NOS Department, with The Director, Nuclear Oversight shall ensure an independent review of the onsite audit program is conducted periodically.
Delete first bullet. Revise wording to split the See below.
introductory sentence after functions and 18 8
. include the remaining wording in the first bullet list introduction.
l8.8.i Delete the NSRB or. See below.
Delete In addition to audits conducted under the See below.
18.8.1 cognizance of the NSRB, and capitalize The.
Change: 1 8.8.a) j) should be 1 8.$.a)
- 1). Correct typo.
18 8
- (Typographical correction) 18.15.1 Delete under the cognizance of the NSRB. See below.
Appendix A Change reference in last sentence of lead-in Correct typo.
under Regulatory Guide 1 .8 from ANSI/ANS Page 3 of 9 to ULNRC-06443 18.1-1971 to ANSI/ANS Nl8.1-197t.
(Typographical correction)
Changed the year refelTed to in the lead-in under Correct typo.
Regulatory Guide 1.39 from ANSI N45.2.3-1975 to ANSI N45.2.3-1973. This corrected an error in which a non-existent revision was Appendix A referenced consistent with multiple references in the following discussion to the collect standard ANSI N45.2.3 1973. (Typographical correcti on)
Justification for OQAMCN 17-002 Changes The wording changes to replace gender specific wording with gender neutral wording are editorial improvements. Additionally, other changes noted as typographical in nature reflect clarifications and corrections. Per 10 (FR 50.54(a)(3) changes of this nature are not considered reductions in commitment.
The remaining changes collectively eliminate the Nuclear Safety Review Board (NSRB). These changes are equivalent to changes approved for another nuclear organization, i.e., the Nuclear Management Company (NMC), as documented in the NRC Safety Evaluation Report (SER) for those changes, dated 1/13/2005 (
Reference:
ADAMS accession number ML050210276).
Callaway Energy Centers (CECs) proposed OQAM changes are consistent with the NMC SER in that they allow for the reviews conducted by On-site Review Committee (CRC) and Nuclear Oversight (NOS) to be an acceptable method for performing the independent reviews of the scibjects and activities listed in ANSI N 18.7 1976, without the need for an NSRB (when coupled with the additional annual review activity described in OQAM section 1.2.2). As such, the changes are not considered a lessening of commitment in accordance with 10 CfR 50.54(A)(3)(ii). These changes are described in further detail below.
Conformance to Independent Review Requirements Specified per Industry Standard/Guidance OQAM Appendix A describes Callaway Energy Centers commitment to ANS-3.2 IN 18.7-1976, American National Standards Institute (ANSI) Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, as endorsed by Revision 2 (February 1978) of NRC RegLilatory Guide 1.33, Quality Assurance Requirements. Section 4.1 of the standard describes general program requirements for reviews and audits of activities affecting plant safety during the operational phase. It notes these programs may take different forms. Examples given are assigning these functions to separate organizational units independent of the onsite operating organization, or appointing a standing committee comprised of individuals from within the owner organization to perform reviews and exercise overview of audits. The section further describes that an independent offsite organizational unit may be assigned review responsibilities, including review of audit reports provided by onsite staff members, or both functions may be assigned an organizational unit that is independent of line responsibility for operating activities.
The CQAM changes (eliminating the NSRB) would not undermine compliance with the recommendations and guidance of the above. In lieu of using the NSRB as a standing committee Page 4 of 9 to ULNRC-06443 to perform the noted review functions, an alternative method relying more on independent reviews by organizational units will be utilized.
To date, CEC has used a mixture of organizational units and two standing committees to perform independent reviews. The two standing committees consist of the ORC and the NSRB. ORC functions to perform independent reviews and advise the Senior Director Nuclear Operations, who chairs the ORC, on all matters related to Nuclear Safety. Results of ORC activities are reported to the SVP/CNO. The NSRB functions to report to and advise the Senior Vice President and Chief Nuclear Officer (SVP/CNO) on assigned independent reviews and audits of designated activities, which include reviews of matters related to nuclear safety that are redundantly performed by the ORC and/or specific areas that are already audited under OQAM section 18.8.
A comparison of the review functions performed by the NSRB to those performed by the CRC shows that for the review functions/activities noted in Table I below, there is sufficient redundancy such that the review functions/activities are satisfied by the CRC alone (i.e.. without the NSRB). Table I provides this comparison.
Table 1 Current OOANI ORC and NSRB Review Reauirements NSRB ORC 1.8.10 a) The 10 CfR 50.59 and 1 .7.6 b) Review of 10 CFR 50.59 and 10 Cf R72.48 evaluations regarding: 10 CFR 72.48 evaluations regarding:
- procedures,
- procedures,
- changes to procedures, equipment,
- changes to procedures, equipment.
systems or facilities; and systems or facilities; and
- tests or experiments completed under
- tests or experiments completed under the provision of Section 10 CfR 50.59 the provision of 10 CfR 50.59 and and 1 0 CFR 72.48, to verify that such 10 CFR 72.48 to verify that such actions did not require prior NRC actions did not require prior NRC approval; approval.
b) Proposed changes to procedures, c) Review of proposed procedures and equipment, systems or facilities which changes to procedures, equipment, systems or involve a license amendment as defined in facilities which may involve prior NRC 10 CFR 50.59 and 10 CFR 72.4$; approval as defined in 10 CFR 50.59 and 10 CFR 72.48; c) Proposed tests or experiments which d) Review of proposed test or experiments involve prior NRC approval as defined in which may involve prior NRC approval as 10 CFR 50.59 and 10 CFR 72.4$, defined in 10 CFR 50.59 and 10 CFR 72.48; d) Proposed changes to Technical e) Review of proposed changes to Technical Specifications or the Operating License; Specifications or Operating License; e) Violations of Codes, regulations, orders, f) Investigation of all violations of the Technical Specifications, license Technical Specifications including the requirements, or of internal procedures or forwarding of reports covering evaluation and instructions having nuclear safety recommendations to prevent recurrence to the significance; Senior Vice President and Chief Nuclear Officer and to the NSRB; Page 5 of 9
Attachment I to ULNRC-06443 f) Significant operating abnonnalities or g) Review of report of operating deviations from non-nal and expected abnonTlalities, deviations from expected performance of unit equipment that affect performance of plant equipment and of nuclear safety; unanticipated deficiencies in the design or operation of structures, systems or components that affect nuclear safety; g) ALL REPORTABLE EVENTS; li) Review of all REPORTABLE EVENTS; h) All recognized indications of an rn) Review of Unit operations to detect unanticipated deficiency in some aspect of potential hazards to nuclear safety; design or operation of structures, systems or components that could affect nuclear safety; NOS is a separate organizational unit at CEC that is independent of the operational organization and its activities. The Director, NOS is currently a member of the NSRB, and NOS performs the majority of independent reviews and all audits detailed to the NSRB. The Director, Nuclear Oversight reports directly to the SVP/CNO and is responsible for ensuring the Operating Quality Assurance Program (OQAP) is being effectively implemented for operating activities, directing the overall OQAP for CEC (including program development, maintenance), and providing constant and independent overview of nuclear plant safety as described in OQAM section 1.3.
Consistent with the NRCs basis for approval documented in the NMC SER, independent review activities will continue to be performed by the ORC and NOS. OQAM section 1 .7 describes the applicable ORC activities. These assessments include reviews of matters related to nuclear safety. NOS will continue to perform the required independent audit activities specified in OQAM section 18.
The scope, implementation, and effectiveness of NOS is periodically assessed as described in OQAM section 2. 12 to assure compliance with policy, commitments, and the requirements of 10 CFR 50 Appendix B. This assessment remains the responsibility of the SVP/CNO thus assuring his continued cognizance of NOS performance.
Additional independent review/ verification requirements and implementing organizational units!
groups are incorporated throughout the OQAM. These reviews are also subject to review by the ORC and NOS to ensure sufficient independence and technical adequacy. These changes are consistent with CECs commitment to ANS-3.2 /ANSI N 18.7-1976 as endorsed by NRC Regulatory Guide 1.33.
NMCs submittal to the NRC requesting elimination of their NSRB equivalent, included addition of the following to their Quality Assurance Program:
NMC periodical/v performs independent reviews 0/matters iinoliing the safe operation of its fleet o/nuclear power plctnts, with a minimum 0/one such review being conducted/br each generatil?g site ectch iectr. The review addresses matters that plant cind coiporate management deternthie warrant special attention, such as plant programs, performance ti-ends, employee concerns, or other matters i-elated to safe plant operations. The reviei is perfOrmed by a team consisting o/personnel iith experience and competence in the activities being revieied, bitt independent (froin cost and schedule considerations) froni the organiations responsible/Or those activities. The review is supplemented by oittside Page 6 of 9
Attachment I to ULNRC-06443 consultants or organizations as necessan to ensure the team has the requisite expertise and competence. Results are documented and reported to responsible Inanagenlent.
The NRCs SER recognized this in approving the change:
The addition ofthisfcused, perfrmancebctscd review is intended to support plant cund Coiporate management in identifiing and resolving issues potentialli aff&ting safe plant operation. The requirement is that nicunagement perioclicctllv consider plant trends, per/brmance, and einploiee input and determine iihat issues itarrant an independent review.
Such reviews would supplement the existing corrective action programs and se//
assessments. With the exception that cit least one reviet be per/armed cit ecich site ecich calendar vecir, picint cund colporcite incincugement determine the schethtflng and scope of revieii cmd ct/so the composition oft/ic tecun per/brming the reiieii.
CEC has included a similar requirement in section 1.2.2 to remain consistent with the basis for the NRCs approval as described in the SER.
OQAMCN 17-003 Sections Description Justification 1 .9 Delete section. See below.
Deletion of the Independent Technical Review section (l.9)is not considered a reduction in commitment in accordance with 10 CfR 50.54(a)(3) due to approval by an NRC Safety Evaluation Report (SER) of a similar change at another facility, i.e., the NRC SER approving eliminating License Conditions requiring the Independent Safety Engineering Group (ISEG) for Tennessee Valley Authoritys Sequoyah Nuclear Plants, Units 1 and 2 (ADAMS accession number MLO 13320500 dated 10/12/1999). The SER approval was based on concluding the ISEG function was one of oversight only, that it did not directly make changes to structures, systems, or components (SSCs), would not impact the ability of SSCs to perform safety functions, or negatively impact the ability of licensee personnel to ensure SSCs are capable of performing intended safety functions. In addition, the SER noted that the functions the ISEG was intended to provide were now an everyday aspect of TVAs operations and that improvement in TVAs operating environment, industry initiatives, and some rulemaking since 1979 have superseded the ISEG functions.
CEC Nuclear Oversight has reviewed the SER and concluded it is applicable to the subject OQAM change. CEC implements organizational elements and everyday operational activities consistent with those described for TVA in the SER approving removal of the ISEG. These are implemented by procedures, which are considered part of the CEC quality assurance program.
Most pertinent among these include:
- Location of the Engineering organizations at the CEC with responsibilities encompassing development and maintenance of plant design bases, configuration management programs, and S SC monitoring, trending, maintenance optimization, performance reporting, and issue resolution.
Page 7 of 9
Attachment I to U LNRC-06443
- CEC has a mature operating experience review program implementing Institute of Nuclear Power Operations (INPO) guidance.
- Industry training requirement implemented to comply with 10 CfR 50. 1 20, Training and Qualification of Nuclear Power Plant Personnel.
- Establishment of a probabilistic safety analysis for CEC and incorporated risk assessments into work activities and use of software tools to enhance risk oversight.
- Self-assessments and trending arc conducted by tine organizations as tools to monitor and improve perfonuance.
- NOS incorporates reviews of the above areas into normal assessments.
This section is considered redundant to the verbiage contained in section 1.7 for the Onsite Review Committee (ORC) and for verbiage in other sections describing independent NOS assessment activities such as 10.) Inspection, 16.) Corrective Action and 18.) Audits. It is also noted that other independent review/verification requirements are specified in other OQAM sections and are incorporated into plant processes. Examples include:
- Section 2.9 requiring independent third-party inspection coverage of Code items by an Authorized Nuclear Inspector.
- Section 3. 14 requiring an independent third-level review be employed as an additional verification when Arneren Missouri judges that a design involves unique or special design features. This section also includes requirements for design verification to be performed by competent personnel other than those who performed the original design and who shall not have established a singular design approach, have ruled out certain design considerations, or have established the design inputs for the particular design aspect being verified.
- Section 4.10 requiring the originating organization perform a documented independent review of procurement documents.
- Section 5.6 provides requirements for modifications, tests and experiments, and procedures for or affecting safety-related structures, systems, and components to he reviewed by individuals/ groups other than the individuals/ groups which designed or prepared the product.
- Section 1 0. 1 requiring inspection and monitoring of processes which serve an inspection function be performed by personnel qualified to perform assigned tasks and who are independent of individuals who perform the activity.
- Section 14.3 requiring plant procedures governing the operational status of safety-related structures, systems, and equipment include independent verification to assure necessary changes have been implemented colTectl y.
OQAM independent review/verification requirements for CRC, NOS, and plant groups ensure reviews are perfonned by appropriately qualified personnel. The specific wording remaining in OQAM section 1 .9 was previously performed by the Independent Safety Engineering Group (ISEG). The ISEG implemented NUREG-0737 requirements which were incorporated into licensing documents for plants licensed after June 26, 1980. The ISEG was originally a stand alone group at CEC. The ISEG was later incorporated into NOS, along with many of its review Page $ of 9
Attachment I to ULNRC-06443 requirements. These are performed as part of NOS normal assessment activities and other plant review activities regardless of the ITR requirements/guidance specified in OQAM section 1 .9.
As discussed above, specific independent review requirements are also specified in other OQAM sections.
OOAMCN 17-004 Sections Description Justification Personnel assigned receipt inspections duties are Clarifies that only Quality provided training as needed for the type of Control personnel assigned inspection. Personnel performing performing receipt general receipt inspections and those inspection 7
. inspection are required to be requiring unique technical skiLls or knowledge do certified to ANSI N45.2.6- not require QC inspector qualification. Training 1978. to ANS 3.1-1978 is sufficient for these personnel.
Deletes sentence describing The change aligns nuclear ftiel nonconformance QC personnel involvement resolution closure responsibilities with Nuclear 1 5.7 in verification nuclear fuel Engineering and fuel Cycle management nonconformance personnel. This is consistent with OQAM dispositions. jsection 15.4.
These changes address subjective language that was challenged by members of the 2017 Nuclear Industry Evaluation Program (NIEP) assessment team. The OQAMCN 1 7-004 changes are not considered a reduction in commitment in accordance with 10 CFR 50.54(a)(3).
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