ML20034A759

Forwards Response to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey in Form of Completed Questionnaire

ML20034A759
Person / Time
Site:	Callaway
Issue date:	04/11/1990
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-90-01, GL-90-1, ULNRC-2194, NUDOCS 9004240230
Download: ML20034A759 (12)

Text

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$23 April 11, 1990 U.

S. Nuclear Regulatory Commission ATTN:

Document Control Desk Mail Station Pl-137 Washington, D.C.

20555 Gentlemen:

ULNRC-2194 DOCKET NUMBER 50-483 CALLAWAY PLANT UNION ELECTRIC'S RESPONSE TO GENERIC LETTER 90-01 NRC REGULATORY IMPACT SURVEXE Please find attached Union Electric's responses to Generic Letter 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey.

The various responses are attached and are compiled using a separate questionnaire sheet per type of survey.

If Callaway has had no inspection, or audit visit from a particular agency, that particular questionnaire sheet has been omitted.-

Finally the "self-assessment" questionnaire has also been omitted since this is a routine activity at Callaway and not amenable to the itemization nature of tha curvey.

If there are additional questions, please contact Dave Shafer (314-554-3104) of my staff.

Yours very_trul,

4' Donald F.

Schnell DJW/jal Attachments DI 33CAOsogg,4g3 1 <is n;4s:

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cci Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C.l20037 Dr. J. O. Cermak CFA, Inc.

4 Professional Drive (Suite 110)

Gaithersburg, MD 20879 R..C.

Knop Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 S. V. Athavale (2)

Office of Nuclear Reactor Regulation U.S. Nuclear kegulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Mr. Joe F. Colvin NUMARC

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1776 Eye Street, N.W.

Suite 300 Washington, D.C.

20006-2496 i

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ULNRC-2194' 4

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bec: D. Shafer/A160.761

/QA Record (CA-758)

Nuclear Date E210.01 DFS/ Chrono D. F..Schnell J. E. Birk J. V. Laux-M..A.

Stiller G.

L. Randolph R..J.

Irwin-

'H.'Wuertenbaecher W. R.-Campbell' A. C..Passwater R. P. Wendling D. E.

Shafer D. J.. Walker O. Maynard (WCNOC)

N. P. Goel (Bechtel)

T. P.. Sharkey NSRB (Sandra Auston)

Amo. 412 (90 -ol)

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ULNRC-2194 I

i NRC REGULATORY IMPACT SURVEY a

QUESTIONNAIRE SMEET l

1

1. Type of inspection, audit or evaluations j

NRC TEAM INSPECTIONS I

2.

Based on actual experience over the past several years, about how often is this activity conducted?

I Seldom, approximately 2 to 3 per year

3. Operations / Construction areas covered

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a. Emergency Operating Procedures i

b. Regulatory Effectiveness Review (Security)

c. Radiological Environmental Response Plan - annual i

drill i

d. Not license examination I

4. Extent of the activity (how many people, for how long)

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a. Four inspectors, 12 days on-site

b. Approximately seven inspectors, 4 days on-site

c. Four-sight inspectors for typically 3 days'on-site per year

d. Four inspectors, 5 days on-site per year (note: none in 1988, two exams in 1989)

5. Approximate manhours of time (on an annual basis) which f

the following managers must spend in direct involvement t

before, during, and in response to the activity. described in Item #1.

a. Plant Department Heads 390 (number involved) 15

b. Plant Manager 52

c. Corporate Department Heads 46 (number involved) 2

d. General Manager, Nuclear operations

_ 20 (number involved) i

e. Chief Nuclear Officer 10 J

f. Management / Supervision 926 (number involved) 29 l

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ULNRC-2194 l

NRC REGULATORY IMPACT SURVEY QUESTIONNAIRE SHEET i

1. Type of inspection, audit or evaluation:

OTHER NRC RESIDENT, REGIONAL, HEADQUARTURS INSPECTIONS / AUDITS I

2.

Based on actual experience over the past several years, about how often is this activity conducted?

a. Approximately a resident inspections per year

b. Approximately 10-12 regional inspections per year

c. NRC license requalification exams

3. Operations / Construction areas covered:

Not applicable per Generic Letter Instructions

{

4.

Extent of the activity (how many people, for how long) i

a. Resident inspections, two inspectors, 1.5 months per inspection l

b. Regional inspections, typically 1-4 inspectors, I

for 4-5 days per inspection

c. License requalification (Jan-Feb 1990)

Preparation for exam 4 inspectors, for 5 days (note: less than a hours per day)

Actual exam: 4 inspectors, for 6-days, 14-18 hours per day

5. Approximate manhours of time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a. Plant Department Heads 498 (number involved) 12 b.

Plant Manager 62

c. Corporate Department Heads 170 (number involved) 3

d. General Manager, Nuclear Operations 60 (number involved) 1-

e. Chief Nuclear Officer 15

f. Management / Supervision 800 (number involved) 30

ULNRC-2194 f

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i NRC REGULATORY INPACT SURVEY i

QUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

IMPO EVALUATIONS r

2.

Based on actual experience over the past several years,

{

about how often is this activity conducted?

Every 18 months

3. Operations / Construction areas covered:

Normal Plant Evaluations 4.

Extent of the activity (how many people, for how long)

INPO Team 12-15 members for two weeks

5. Approximate manhours of time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in l

Item #1.

a. Plant Department Heads 1000 (number involved) 20

b. Plant Manager 80

c. Corporate Department Heads 20 (number involved) 1

d. General Manager, Nuclear Operations 16 (number involved)_11

e. Chief Nuclear Officer 16

f. Management / Supervision ~~400 (number involved) 20

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ULNRC-2194 4

NRC REGtiLATORY INPACT SURVEY QUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

INSURER 8 (ANI)

2. Based on actual experience over the past several years, about how often is this activity conducted?

a. Annual inspections and reports

b. Ongoing inspections, quarterly reports

c. Intermittent inspections, triennial reports

3. Operations / Construction areas covered:

a. 1989: RPV head studs, health physics, radioactive effluent monitoring, on-site safety review

b. Systems availability inspections, system inspections, object inspections

c. Site buildings and selected portions of the power block

4. Extent of the activity (how many people, for how long)

a. Facility engineer and account engineer on-site for three and one working days, respectively

b. Inservice inspector on-site a half week per month i

Inspector on-site for six days per year c.

1

5. Approximate manhours of time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in i

Item #1.

7

a. Plant Department Heads 24 (number involved) 6

b. Plant Manager 2

c.

Corporate Department Heads 11 (number involved) 2

d. General Manager, Nuclear Operations (number involved)

e. Chief Nuclear Officer

f. Management / Supervision 653 (number involved) 13 i

ULNRC-2194 NRC REGULATORY INPACT SURVEY QUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

OSKA 2.

Based on actual experience over the past several years, about how often is this activity conducted?

Osha has arrived only once on-site as the result of an anonymous contractor employee complaint

3. Operations / Construction areas covered:

one ladder was allegedly not in compliance with osRA regulations 4, Extent of the activity (how many people, for how long)

Two 08KA repretientatives for four hours

5. Approximate manhours of time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

Not applicable since not an annual occurence

a. Plant Department Heads (number involved)

b. Plant Manager

c. Corporate Department Heads (number involved)

d. General Manager, Nuclear Operations (nuuber involved)

e. Chief Nuclear Officer

f. Management / Supervision (number involved) i

ULNRC-2194

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NRC REGULATORY INPACT SURVEY QUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

DOT

2. Based on actual experience over the past several years, about how often is this activity conducted?

Annually

3. Operations / Construction areas covered:

Compliance with 49CFR, 100FR71, and 10CFR61 regulations pertaining to packaging, transportation, and disposal of radioactive wastes

4. Extent of the activity (how many people, for how long)

Three people (Radchen Foreman, Radwaste Supervisor, superintendent, Chemistry and Radwaste) for 2-5 hours each, including entrance and exit meetings t

5. Approximate manhours of time (on an annual basis) which f

the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a. Plant Department Heads 2 (number involved)

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b. Plant Manager 1

c. Corporate Department Heads (number involved)

I

d. General Manager, Nuclear Operations (number involved)

e. Chief Nuclear Officer

f. Management / Supervision _5 (number involved)_1

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ULNRC-2194

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NRC REGULATORY IMPACT SURVEY r

QUESTIONNAIRE SHEET l

(

l. Type of inspection, audit or evaluation:

STATR/ LOCAL AUTHORITIES (NPDES) 2.

Based on actual experience over the past several. years, about how often is this activity conducted?

Annually

3. Operations / Construction areas covered:

Non-radiological liquid discharges 4.

Extent of the activity (how many people, for how long)

One to two people 2 -3 days

5. Approximate manhours of time (on an annual basis) which the following managers must spend in direct involvement.

before, during, and in response to the activity described in e

Item #1.

I

a. Plant Department Heads 100 (number involved)

_1 b.

Plant Manager 25

c. Corporate Department Heads (number involved)

d. General Manager, Nuclear Operations (number involved)

e. Chief Nuclear Officer

f. Management / Supervision 200 (number involved) 2 i

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ULNRC-2194 l

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NRC REGULATORY IMPACT SURVEY QUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

NRC REQUIRED QA AUDITS 2.

Based on actual experience over the past several years, r

about how often is this activity conducted?

l Rpproximately 29 audits per year

3. operations / Construction areas covered:

Not applicable per Generic Letter instructions i

4.

Extent of the activity (how many people, for how long)

Approximately 4.4 auditors per audit.

Audit duration tipica11y 5-10 workdays.

(Note: This does not include time spent preparing for the audit or time spent writing the audit report)

5. Approximate manhours of time (on an annual basis) which the following managere must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads 722 (number involved) 12

b. Plant Manager 81

c. Corporate Department Heads 492. (number involved) 3

d. General Manager, Nuclear operations 53 (number involved)_1

e. Chief Nuclear Officer 38

f. Management / Supervision 3900 (number involved) 32 l

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• ULNRC-2194 i

NRC REGULATORY INPACT SURVEY QUESTIONNAIRE SHEET

1. Type of inspection, audit or evaluation:

OTHER-NRC EP INSPECTIONS AND RERP DRILL POR SCORE (Note: Some data may overlap the survey for NRC Team Inspections)

2. Based on actual experience over the past several years, about how often is this activity conducted?

Annual

3. Operations / Construction areas coveredt Emergency Preparedness

4. Extent of the activity (how many people, for how 1cng)

Three man inspection team for one week

5. Approximate manhours of time (on an annual-basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a. Plant Department Heads 80 (number involved)

_3

b. Plant Manager _2

c. Corporate Department Heads (number involved)

d. General Manager, Nuclear Operations 2

(number involved)_1

e. Chief Nuclear Officer 2

f. Management / Supervision ~[100 (number involved) 20 i