ML20070A793

Application for Amend to License NPF-30,deleting TS Sections Describing On-Site Review Committee & Nuclear Safety Review Board

ML20070A793
Person / Time
Site:	Callaway
Issue date:	06/21/1994
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20070A796	List: ML20070A793
References
ULNRC-3033, NUDOCS 9406290163
Download: ML20070A793 (8)

Text

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53 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D.C. 20555 Gentlemen: ULNRC-3033 DOCKET NUMBER 50-483 CALLAWAY PLANT REVISION TO TECHNICAL SPECIFICATION 6.0 ADMINISTRATIVE CONTROLS Union Electric Company herewith transmits an application for amendment to Facility Operating License No. NPF-30 for Callaway Plant.

This amendment application deletes the sections describing the On-Site Review Committee (ORC) and the Nuclear Safety Review Board (NSRB) from the Technical Specifications. All of the information contained in these sections is also contained in Chapter 13 of the Callaway Plant Final Safety Analysis Report. This change was suggested in an NRC letter to the Technical Specification Committee Chairmen of the four owners groups dated October 25, 1993, " Content of Standard Technical Specifications, Section 5.0, Administrative Controls."

Attachments 1, 2, 3, and 4 contain the Safety Evaluation, the Significant Hazards Evaluation, the Environmental Evaluation, and the Proposed Technical Specification Changes in support of this amendment request.

This change request has been approved by the Callaway Onsite Review Committee and the Nuclear Safety Review Board.

Very truly yours,

.. p Donald F. Schnell RMD/kea Attachments 9406290163 DR 940621 ADOCK 03 coo 4gv . ) i PDR

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• Attachments ULNRC-3033 Attachment 1 - Safety Evaluation Attachment 2 - Significant Hazards Evaluation Attachment 3 - Environmental Consideration Attachment 4 - Proposed Technical Specification Changes

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STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

Alan C. Passwater, of lawful age, being first duly sworn upon oath says that he is Manager, Licensing and Fuels (Nuclear) for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By ###

Alan C. Passwater Manager, Licensing and Fuels Nuclear SUBSCRIBED and sworn to before me this N/- day of slune -

, 1994.

/ NA UL '? ff BARBARA J. hkAF1' k k [/

NOTARY PUBLIC-STATE OF MISSOURI Mf COMMISSION EXPIRES APRIL 22, 1997.

SI. LOUls COUNIX l

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. I cc: T. A. Baxter, Esq. I Shaw, Pittman, Potts & Trowbridge i 2300 N. Street, N.W.

Washington, D.C. 20037 M. H. Fletcher CFA, Inc.

18225-A Flower Hill Way i Gaithersburg, MD 20879-5334 L. Robert Greger '

Chief, Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 801 Warrenville Road Lisle, IL 50532-4351 Bruce Bartlett Callaway Resident Office U.S. Regulatory Commission RR#1 Steedman, MO 65077 L. R. Wharton (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory 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 3 Jefferson City, MO 65102 l

Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 l

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Attachmant 1 Page 1 of 2 ULNRC-3033 SAFETY EVALUATION Backaround Effective July 1, 1994 the Manager, Nuclear Safety and Emergency Preparedness (a member of the Nuclear Safety Review l Board) will retire. That position will no longer exist, and the j responsibilities will be divided between the Manager, Quality Assurance and the Manager, Emergency Preparedness and l Organizational Support.

Rather than making a Technical Specification change of narrow scope now, and making subsequent changes upon each title or organizational change, we request a Technical Specification -

revision of the Administrative Controls section based on the latest proposed revision of the Standardized Technical Specifications.

Proposed Chances "

The proposed technical specification changes delete the sections describing the On-Site Review Committee (ORC) and the Nuclear Safety Review Board (NSRB). All of the information contained in these sections is also contained in Chapter 13 of the Callaway Plant Final Safety Analysis Report (FSAR). >

In addition, references to the Independent Safety Engineering Group (ISEG) will reflect that it now reports to the Manager, Quality Assurance, who is also a member of the NSRB, instead of the Manager, Nuclear Safety and Emergency Preparedness. All references to the Manager, Nuclear Safety and Emergency Preparedness will be removed as that position no longer exists.

The affected Technical Specification Sections are 6.2.3,  ;

6.5.1, 6.5.2, 6.5.3, and the Index.

Evaluation i The sections being deleted describe the function, composition, alternate membership, meeting frequency, quorum, responsibilities, and records of the On-Site Review Committee (ORC) and the Nuclear ,

Safety Review Board (NSRB) . These topics- are covered in equivalent .

detail in the Callaway Plant Final Safety Analysis Report (FSAR)  !

and plant administrative procedures as required by our commitment  !

to ANSI N18.7-1976. Changes to the FSAR are controlled based on 10CFR50.59 and updated in accordance with the requirements of 10CFR50.71(e). No change is made to the ORC or the NSRB, except for the retirement of the Manager, Nuclear Safety and Emergency {

Preparedness, and no change is made to the manner in which they  !

function.

The audit and review function requirements of 10 CFR

50. 3 6 (c) (5) continue to be described in Technical Specification t section 6.5.3 and is controlled by the Operating Quality Assurance Manual (OQAM).

Attachment 1 Page 2 of 2 ULNRC-3033 ,

l The proposed changes are administrative in nature. No change l is required to plant facilities, components, or systems. The i changes do not significantly reduce the overall base of experience at the Callaway Plant nor the commitment to minimum qualifications. ,

Callaway Plant personnel will continue to have the training,  !

experience, and expertise necessary to recognize, analyze, assess, evaluate, and effectively respond to plant transients or other )

abnormal events. l l

The proposed changes to the Technical Specifications do not 1 involve an unreviewed safety question because operation of the  !

Callaway Plant with these changes would not:

1. Increase the probability of occurrence or the consequences i of an accident or malfunction of equipment important to  !

safety previously evaluated in the safety analysis report. l The proposed changes do not affect accident initiators or assumptions. The radiological consequences of any accident j previously evaluated remain unchanged. The changes are i administrative and equivalent descriptions and requirements for these oversight committees are contained in FSAR Section 13.4.

2. Create the possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report.

The proposed changes do not create any new accident initiators nor involve any modifications or changes in the plant. The changes are administrative and equivalent descriptions and requirements for these oversight committees are contained in FSAR Section 13.4.

3. Reduce the margin of safety as defined in the basis for any .

technical specifications. I The proposed changes do not affect any safety limits or boundary or system performance. The changes are administrative and equivalent descriptions and requirements I for these oversight committees are contained in FSAR Section 13.4.

On the basis of the above discussions and the considerations presented in the Significant Hazards Evaluation, the proposed changes do not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.

Attachment 2 Page 1 of 2 ULNRC-3033 SIGNIFICANT HAZARDS EVALUATION The proposed technical specification changes delete the sections defining the composition and responsibilities of the on-Site Review Committee (ORC) and the Nuclear Safety Review Board (NSRB). All of the information contained in these sections is also contained in Chapter 13 of the Callaway Plant Final Safety Analysis Report (FSAR).

In addition, references to the Independent Safety Engineering Group (ISEG) will reflect that it now reports to the Manager, Quality Assurance instead of the Manager, Nuclear Safety and Emergency Preparedness. The Manager, Quality Assurance is also a member of the NSRB. All references to the Manager, Nuclear Safety and Emergency Preparedness will be removed as that position no longer exists.

The affected Technical Specification Sections are 6.2.3, 6.5.1, 6.5.2, 6.5.3, and the Index.

The proposed changes do not involve a significant hazards consideration because operation of Callaway Plant with these changes would not: l

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

The changes are administrative and equivalent descriptions ,

and requirements for these oversight committees are  !

contained in FSAR Section 13.4. i

2. Create the possibility of a new or different kind of accident from any previously evaluated.

These changes do not involve any physical alterations to the plant. There is no new type of accident or malfunction created and the method and manner of plant operation will not change. The changes are administrative and equivalent descriptions and requirements for these oversight committees are contained in FSAR Section 13.4.

3. Involve a significant reduction in a margin of : safety.

The margin of safety remains unaffected since no design l change is made and plant operation remains the same. The changes are administrative and equivalent descriptions and requirements for these oversight committees are contained in FSAR Section 13.4.

Attachmsnt 2

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Page 2 of 2 i ULNRC-3033 As discussed above, the proposed changes are strictly administrative in nature and have no effect on plant operations.

They do not involve a significant increase in the probability or consequences of an accident previously evaluated or create the possibility of a new or different kind of accident from any i previously evaluated. These changes do not result in a i significant reduction in a margin of safety. Therefore, it has  !

been determined that the proposed changes do not involve a  :

significant hazards consideration.

l Attachment 3 l Page 1 of 1 '

ULNRC-3033 ENVIRONMENTAL CONSIDERATION l l

l This amendment application requests revisions to Technical i Specification Sections 6.2.3., 6.5.1, 6.5.2, 6.5.3, and the Index.

The proposed changes delete the sections describing the On site  ;

Review Committee (ORC) and the Nuclear Safety Review Board (NSRB).

All of the information contained in these sections is also contained in Chapter 13 of the Callaway Plant Final Safety Analysis Report (FSAR).

In addition, references to the Independent Safety I Engineering Group (ISEG) will reflect that it now reports to the ,

Manager, Quality Assurance instead of the Manager, Nuclear Safety  !

and Emergency Preparedness.

Union Electric has determined that the proposed amendment involves changes in record keeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (10) . Pursuant to 10 CFR 51.22(b) no l environmental assessment need be prepared in connection with the issuance of this amendment. j l

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