ML20094A172

Proposed Tech Specs,Relocating Audit Frequencies in Former TS 6.5.2.9 to Operational QA Manual

ML20094A172
Person / Time
Site:	Callaway
Issue date:	10/23/1995
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20094A168	List: ML20094A172 ULNRC-03281, Forwards Revised TS Pages,Relocating Audit Frequencies in Former TS 6.5.2.9 to Operational QA Manual,In Response to NRC & 951010 Telcon W/Nrc
References
NUDOCS 9510300209
Download: ML20094A172 (42)

Text

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ATTACHMENT 4 ULNRC-0 3281 PROPOSED TECHNICAL SPECIFICATION CHANGES SPECIFICATIONS:

INDEX MARKUP 6.2.3.1 MARKUP 6.5.1 MARKUP 6.5.2 MARKUP 6.5.3.1 MARKUP 6.8.3 MARKUP SPECIFICATIONS:

INDEX RETYPED 6.2.3.1 RETYPED 6.5.1 RETYPED 6.5.2 RETYPED 6.5.3.1 RETYPED 6.8.3 RETYPED 9510300209 951023 PDR ADOCK 05000483 P

PDR

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6 ggl ocT 10 '95 01:13PM Ut NUCLEAR

01. Il5fo

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i ADMINISTRATIVE CONTROLS 1NotptNDfNT 1AffTY ENGINEERfNC CROUP (TEFc)

,',). s.2.3 i

FUNCTION The' 15EG shall function to examine plant operating characteristics, NR issuances, industry advisories, REPORTABLE EVENTS and other sources 6.2.3.1 j

design and operating experience information, including plants of similar which may indicate arens for improving plant safety.

l recommendations for revised procedures, equipment m f

Manager,.Lu;7 0;fn'Qu.0%;r-y N:;.rdr;:: and the Plant.

Assvenw Dm to-lod 5

.7,;' !---

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COMPOSITION The 15EG shall be composed of at least five, dedicated, f 6.2.3.2 engineers located on site.related science and at least 2 years professional le

,2 f

RESPONSIBILITIES The ISEG shall be responsible for maintaining surveillance of plant activities to provide independent verification

• that these activities are 6.2.3.3

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performed correctly and that human errors are reduced as much as pr N

ADW j

f RECORDS Records of activities performed by the ISEC shall be prepared,r4 maintained, and forwarded each calendar month to the Manager, R.:r h':"[g, 6.2.3.4

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and the Manager, Callaway Plant.

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6.2.4 5HIFT TECHNICAL ADVISOR The Shift Technical Advisor (STA)** shall provide technical support to j

Supervisor in the areas of thermal hydraulics, reactor engineering and p analysis with regard to the safe operation of the unit.

j I

UNIT STAFF OUALIFICATIONS 6.3 l

Each member of the unit staff shall meet or exceed the minim 3.1-1978 with the following exceptions:

6.3.1 qualifications of ANSI /ANS Shif t Supervisors, Operating Supervisors, Reactor Operators, and l

3.1-1981 as Technical Advisors shall meet or exceed the qualifications of ANSI /ANS 6.3.1.1 l

endorsed by Reg. Guide 1.8, Revision 2, with the same exceptions as c the current revision to the Operator Licensing Examiner Standards, NURE E5-202.

The Radiation Protection Manager shall be a supervisor with line responsibility for operational health physics who meets or exceeds the 6.3.1.2 diation J

qualifications of USNRC Regulatory Guide 1.8, September 1 j

Protection Manager.

J Plant Manager, i

'tiot responsible for sign-off function.

"The STA position shall be manned in MODES 1, 2, 3 and 4 unless the S j

Supervisor or the individual with a Senior Operator license meets th qualifications for the STA as required by the NRC.

1 l

.I Amendment No. 60,92 6-6 CALLAWAY - UNIT 1

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06

// M ADMIN 7STRAT1YE CONTROLS T RATHING_

A retraining and replacement training program for the unit staff shall be j

6.a i

maintained under the direction of the Superintendent, Training.

6.4.1 Operators, and Shif t Technical Advisors shall me 3.1 1981 as endorsed by Regulatory Guide 6.4.2 recemnendations of Section 5 of MSI/MS1.8. Rev. 2. with the same Operator Licensing Examiner Standards, MUREG-1021. ES-202, an All other training programs shall meet or exceed the requirements and 6.4.3 3.1 1978.

reconnendations of Section 5 of MSI/MS Training shall include familiarization with relevant industry operation 6.4.4 I

l experience identified by the ISEG.

6.5 REVIEW AND AUDIT ON-SITE REVIEW COW.1TTEE (ORC)

(TN /.5 S 6 C T/ W b 6 L E-T B o) g Q

l 6.5.1 p

i

$NCT 10N The ORC shall function to advise the Manager, Callaway Plant on a l

6. 5.

1 related to nuclear safety.

jmatter l

COMPOSITI OR member-ager, Callaway Plant shall be Chainnan of the ORC.e e minimum of six additional members appointed by 6.5.1.2 The Assurance.

(

tional member appointed by the Manager, Qualit i

ship shall inclu le for the

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Chainnan and an a include, at a minimum, management responsentation and Selected members sha operations, mHntenance, inst ering, and f

following areas of expe *ise:te, health physics, nuclear engi controls, chemistry, radw ndividual zay cover multipi disciplines.

j quality assurance.

A single I

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A1.T ERNATES_

ed in writing by the ORC oi All alternate members shall be 6.5.1.3 Chairman to serve on a temporary basis.**

i MEET 1HG FRE00ENCY r month and as convened 6.5.1.4 The ORC shall meet at le once per cale ated alternate.

by the ORC Chainnan or his des l

000RUS

. the ORC necessary for the perfonnance o. + e ORC respons all consist y provisions of these Technical Specifications

6. 5.1. 5 The quorum o more or his designated alternate and four members of whic bility and author i

of the Chairma be alternate.s.

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pthan two sh for the alternate for Quality Assurance who is appointed by the 1

ce?

Kanager Quality Assurance.

l Amendmen; No. Jf.22.66 63 6-7 CA' L AWAY, UNIT 1 i

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OR r GrtJAL O/. //54 i

ADMINISTRATIVE CONTROLS

.)

g ESPONSIBILITIES 6.

1.6 The ORC shall be responsible for:

Review of all Administrative Procedures; a

eview of the safety evaluations for (1) procedures, (2) cha e to cedures, equipment, systems or facilities, and (3) tests r exper-b, fy that completed under the provision of 10 CFR 50.59 to ve p

ime

• on;

• tions did not constitute an unreviewed safety ques such equipment, proposed procedures and changes to proceduresafety c.uestion Review o systems or 'acilities which may involve an unreviewed c.

hnical 10 CFR 50.59 or involves a change in T as defined i Specifications test or experiments which ma involve an unreviewed safety question as efined in 10 CFR 50.59 or 'equires a change in d.

Review of propose Technical Specificat ns; ecifications or the Review of proposed chan., s to ' Technical e.

Operating License;

/

of e Technical Specifications f.

Investigation of all violatio covering evaluation and recom-including the f orwarding of rep r+

the Senior Vice President-Nuclear

., af mendations to prevent recurrenc j

and to the HSRB; ities, deviations from expected Review of reports of oper.ing abnorr nticipated deficiencies in perfomance of plant eqtJ(pment and of ui tems or components that g.

the design or operaticr' of structures, s affect nuclear safe 4 I

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h.

Review of all RE RTABLE EVENT 5; I

l recomended 2

i.

Review of th plant Security Plan and shall submi changes to e NSRB; hall submit the Radiological Emergency Response Plan and j

j.

Review ded changes to the NSRB; rec DOSE Rev'ew of changes to the PROCESS CONTROL PROGRAM, the OFFSI i

k.

j

' CULATION PMUAL, and Radwaste Treatment Systems; j

Review of any accidental, unplanned or uncontrolled radioactive p

release including the preparation of reports coverin 1.

j j

recurrence and the forwarding of these reports to the Kanager, 4]

Callaway Plant and to tne HSRB; I

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g AT,encment No.

29 i

6-8 CALUWAY - UNIT 1

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t OREGENkG 0 4. //5 4 ADMINISTRATIVE CONTROLS (Continued)

RESPONSIBILITIES Review of Unit operations to detect potential hazards to nuclear safety; m.

Investigations or analysis of special subjects as requested by the n.

Chairman of the NSRB; and view of Unit Turbine Overspeed Protection Reliability Progr o.

ions thereto; and re ended changes the Fire Protection Program and submitting r p.

Review to the HS '.

6.5.1.7 The ORC shall, a.

Recomend in writ to the Manager, Calla Plant approval or disapproval of iterns nsidered under S.ifications 6.5.1.6a through e.,

i., J.,

k.,

o., and p above, th regard to whether or not each b.

Render determinations in wr ing ions 6.5.1.6b. through e., and m.,

item considered under Specifi above, constitutes an unre 'ewed fety question; and l

Provide written notifi tion within hours to the Senior Vice

.) c. President-Nuclear the Nuclear Safe Review Board of disagreement between the ORC d the Manager, Callawa lant; however, the ay Plant shall have responsi lity for resolution of Hanager, Call

.l.above.

ements pursuant to Specification such disag RECORDS o that, at a 6.S.I.VThe ORC shall maintain written minutes of each OR vided

• he responsi-miniity provisions of these Technical Specifications.

a the Senior Vice President-Huclear and the Nuclear Safety Review Board.

b NUCLEAR SAFETY REVIEV BOARD (NSRB)_ ( 7// /3 SgcQy ggy /fAt 6.5.2 f

[f44-N

{FUNCTIONThe HSRB shall function to provide indehent review and audit e

f

.2.1 ted activities in the areas of:

des car power plant operations, f

a.,

f b.

Nuclear

intering, c.

Chemistry and iochemistry, I

d.

Metallursy.

Instrumentation and co

.o, e.

f.

Radiological,sa S.

Mechanic ' nd electrical engineering, an

{l ty assurance practices.

H iear

• hose h.

nB shall reco n to and advise the S*.nior Vice President-u:

creas of responsibility stated it. Specifications 6.5,2 S and 6.5.2.9.

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/cendment No. 20, 29 6-9 CM.LAWAY - UNIT i i

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^ ADMINISTRATIVE CONTROLS A,,j pd6 l

D*J POSTTION 6.

2.2. The NSRB shall be composed of at least the following member.

Manager, Licensing and Fuels

• hairman:

Manager, Nuclear Engineering edness f

l mber:

Manager, Nuclear safety and Emergency Prep i

Me er:

Manager Quality Assurance j

Hem Nuclear Operations Membe Vice President,ineer, Nuclear Fuels Member:

Supervising Eng k

Additional membe and'Vice Chairman may be appointe by the Chairman.

ALTERNATES 6.5.2.3 All alternate mbers shall be appoi ed in writing by the NSRB l

r, no more than two alternates i

Chairman to serve on a te orary basis; howeactivities at any one time.

I shall.: participate as votin members in NSR CONSULTANT 3 as determined by the HSRB Chairman to 6.5.2.4 Consultants shall be ut ize provide expert advice to the NSRB.

)MEETINGFREQUENC_Y l

least on e per calendar quarter during the l

The NSRB shall meet a el loading and at least once per 6 6.5.2.5 initial year of unit operatic following months thereafter, f

OUALiFitAT1081 degree in an engineering or 6.5.2.6 The HSRB mem rs sha'.1 hold a Bachelor' nd a minimum of 5 years of

, or equivalsnt experience, all be in one or more of

/

physical science fie of which a minimum of 3 years technical experten I

the disciplines o Specification 6.5.2.1.

OUORuti e of the NSRB quorum of the NSRB necessary for the performa hall consist of 6.5.2.7 Th review ar.. audit functions of these Technical Specifications rum shall s of the NSRB members inc!uding alternates. No more than a minority of the q the Chai For the pur se of a ne reaponsibility for operation of the unit.

e Vice l

, thosa considered to have line responsibility will include have

esident, ident, huclear Operations, and personnel reporting to the Vice cuor Pr N clear Operations.

d s

Amendment No. fif, AS, 88 CALLAWAY - UNIT 1 Correction Letter of 9/21/94 6-10 l

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of /I5(,

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ADMINisfRATIVC CONTROLS (hi D r :.

_ -7444 l,s., ". '-

,ygw of:

lhe H5RB sh411 be ruponsible for the review 6.5.

8 (1) changes to procedures, ecuto t,

f The safety evaluations for:

vstems or facilities; and (2) tests or experiments completed uncer a.

ctions provision of Section 50.59,10 ~CFR', to verify that such t

et constitute an unreviewed safety Question; did lities changes to procedures, equipment, systees or f a.

b, Propose Ive an ur. reviewed safety cuestion as defined n

which in Section 50. 9, 10 CFR; t

or experiments which involve an unre iewed safety c,

Proposed test question as de ned in Section 50.59, 10 CFR; Technical Specificationssor this Operating d.

Proposed changes t License; Violations of Codes, r ulations, orders, chnical Specifications, dures or instructions e.

license requirements, or of internal pro having nuclear safety sig. ficance; ities e deviations from normal and

.).'

f.

Significant operating abnors nt that affect nuclear safety; expected performance of unit e ip

,/ ' ',

(,,'.,

g.

.All REPORTABLE EVENT 5; an una *icipated deficiency in some h.

All recognized indications on of stru ures, systems, or components aspect of design or operat that could affect nuclear safety; and i

Reports and meetings nutes of the ORC.

s AU0 f 75_

6.5.2.9 Audits of unit tivities shall be performed unde the cognizance of tno HSRB. These audits shall encompass:

ined within the The confor ance of Unit operation to provisions con ions at least Technic Specifications and ADplicable license cond A.

once p 12 months; perf ormance, training a'nd qualifications of the ent ae unit b.

Ihs aff at least once per 12 ' months ;

in Pet, ult!. of actions taken to correct deficiencies occur ing

'c.

the structures. systems or methoc of operation Sat uni t euulpinent.

alteet nuclear safety at least once per 6 months;

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AC)ilNISTRATIVE C0hTROLS

-24 44 fAUDITS (Continued)

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B,10 CFR Part 5,

d.

at least once per 24 months; The Fire Protection progrannatic controls including the impleme.ing rocedures at least once per 24 months by qualified licensee e.

p onnel;

least re protection equigrnent and program implementation once p - 12 months utili:ing either qualified offsite 1 censee fire The f.

n engineer or an outside independent fire pr.ectionensultant shall protect An outside independent fire protection consultan be used at ast every third year, g.

The Radiologic Environmental Monitoring Progr. and the results thereof at least nee per 12 months; h.

The OFFSITE DOSE CAL ATION MANUAL and im ementing procedures at least once per 24 nths; i.

The PROCESS CONTROL PROG and impi nting procedures for proces-tes at least once per 24 months;

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sing and packaging of radio ative w ired by the Quality Assurance j.

The performance of activities antal monitoring, at least once Program for effluent and envi per 12 months; ar.d dered, appropriate by the NSRB I

k.

Any other area of unit op ation con or the Senior Vice Pres ent-Nuclear.

I RECORDS _

6.5.2.10 Records of HS activities shall be prepared, proved, and distributed i

as indicated below:

i ved and forwarded each NSRB meeting shall be prepared, apr 110 wing each 1

I Minutes o to the Lnior Vice President-huclear within 14 days

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a.

j meetin ;

rts of reviews encompassed by Specification 6.5.2.8 a ove, shall dent-I i

prepared, approved and forwarded to the Senior Vice Pre b.

Re i

. uclear within 14 days f ollowing completion of 'the review; a d b

Audit reports encompassed by Specification 6.5.2.9 above, shal be 1

fomarded to the management positions responsible for :ne areas i

audited and sumaries of audits shall be prepared and femarded to j

N.,

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j the Senior Vice President-Nuclear within 30 days af ter completion 3

]

of the audit by the auditing organization.

b Amendment No. 39 6-12 CALLAWAY - UNIT i j

1 a N vi" % c : m - p u m p p p y g g g y,

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.~.) ADMINISTRATIVE CONTROL 5

' 6,5.3 TECHN10.at REVtfW AND CONTROL ACTIVITIES 6.5.3.5 Activities which affect nuclear safety shall be conducted as Procedures required by Specification 6.8 and o a.

Each such procedure or procedure change reviewed and approved.

shall be reviewed by a cualified individual / group other than the but who may be from the same organization as Procedures other which prepared the procedure or procedure change.

than Administrative Procedures shall be approved by the appropria Department Head as designated in writing by the Vice President, The Manager, Callaway Plant, shall approve Administrative Procedures and Radiological Emergency Response Nuclear Operations.

The Manager, Operations Support, shall Temporary' implementing procedures.

approve the Security Plan implementing procedures.

changes to procedures which do not change the intent of the a procedures shall be approved for implementation by two mem the plant staff, at least one of whom holds a Senior Operator license, and documented.. The temporary changes shall be appro the original approval authority within 14 days of implementation.

For changes to procedures which may involv

}

procedure shall approve the change prior tu implementation; a

Proposed changes or modifications to plant n b.

Each such modification shall be by the Manager, Callaway Plant.

reviewed by a qualified individual / group o organization as the individual / group which designed the Proposed modifications to plant nuclear safety-related structures, systems and components shall be approved modifications.

to implementation by the Manager, Callaway Plant; Proposed tests and experiments which affect plant nuclea are not addressed in the Final Safety Analysis Report or Tech c.

Each such Specifications shall be prepared, reviewed, and approved.

test or experime".t shall be reviewed by a qualified individual / gro other than the individual / group which prepared experiment.

implementation by the Manager, Callaway Plant;

}

Amendment No. /1%, 88 6-13 cal.LAWAY - UNIT 1 Correction Letter of 9/2i/94

Nf s

04, //54 ADMINISTRATIVE CONTROLS

}

ACTIVITIES (Continued)

Individuals responsible for reviews perfomed in accordance w Specifications 6.5.3.la., 6.5.3.lb., and 6.b.3.1c., shall be m d.

Opera-of the management staff previously designated by the Man is necessary.

whether or not additional, cross-disciplinary, revie tions Suppor*.

personnel of the appropriate discipline; Each review shall include a determination of whether or not anPurs unreviewed safety question is involved.

10 CFR, NRC approval of itans involving unreviewed safety q e.

shall be obtained prior to the Manager, Callaway Plant, appro for implementation; and The Plant Security Plan and Radiological Emergency Respo and impienenting procedures, shall be reviewed at least once pe f.

Recomended changes to the im.plementing proceduresRecomen shall be approved in accordance with 6.5.3.1.a.to t 9-3o 9g 12 months.

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$sf,f" e + Sp;ci#i::tions-Gr5.'. 0 :nd 0..2.NRO approval shall be obtained as app Callaway Plant.

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7 RECORDS Callaway Plant. ORC and/or NSRB as necess 6.5.3.2

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rep 0RTABLE EVEhi ACT10t{

6.6 The following actions shall be taken for REPORTABLE EVENTS:

6.6.1 The Comission shalf be notified and a report sutnitted pursuan 50, and to the requirements of Section 50.73 of 10 CFR Part a.

Each REPORTABLE EVENT shall be reviewed by the OR l

to the RSRB and the Senior Vice President-Nuclear.

b.

SAFETY LIMIT VIOLATION _

6.7 The following actions shall be taken in the event a Safety L 6.7.1 violated:

The NRC Operations Center.shall be notified by telephone l

possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Nuclear and the a.

The report shall j

A Safety Limit Violation Report shall be prepared.

(1) applicable This report shall describe:

i l tion i

circumstances preceding the viciation; (2) effects of the v o a 3

be reviewed by the ORC.

(2) corrective upon f acility components, systems or structures; and i

j action taken to prevent recurrence; 3i Amendnent No. 76,39 6-14 5

CALLAWAY - UNIT 1 j,

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//6d ADmfNISTRATIVE CONTROLS

)

f SAFETY LIMIT VIOLATION _ (Continued)

The Safety Limit Violation Report shall be submitted to l

c.

14 days of the violation; and Critical operation of the unit shall not be resumed until authorized d.

by the Comission.

PROCEDURES AND PROGRAMS Written procedures shall be established, implemented, and maintained 6.8 6.8.1 covering the activities referenced below:

The applicable procedures reconinended in Appendix A.of Regulatory Guide 1.33. Revision 2 February 1978; a.

The emergency operating procedures required to implement the re ments of HUREG-0737 and Supplement 1 to NUREG-0737 as stated b.

Section 7.1 of Generic Letter No. 82-33; Plant Security Plan implementation; c.

Radiological Emergency Response Plan implementation; d.

PROCESS CONTROL PROGRAM implementation; e.

OFFSITE DOSE CALCULATION MNUAL implementation;

s. Quality Assurance Program implementation for effluent and e f.

mental monitoring;..

s Turbine Overspeed Protection Reliability Program; and

.)

h.

Fire Protection Program implementation.

and changes thereto, including temporary change 1.

i to 0'

6.8.2 4

implementation as set forth in Specification,6.5 above.

.,m in accorcance withGd fication f.! ' 5-)nd approve g g

.8.3 (Yh Specification 6.5.31'O ine assoiiatec implementing procedures and cha i

i 6.5.3.1.

g-hereto snali be reviewed and approved in accordance with Specif cat on The following programs shall be established, implemented and m 6.8.4 Reactor Coolant Sources Outside Containmant.

A program to reduce leakage from those portions of systems o a.

j g

containment that could contain highly radioactive fluids during a N

i The serious transient or accident to as low as practical levels.

,k hSSWq j

systems include the recirculation portion of the Containment -)

System. Safety injection System, Chemical and Volume Contr g44

_f The program shall include the following:

s and RHR System.

~_

Preventive maintenance and periodic visual inspection

. 4 1) requirements, an Amendment No.

30, 39 6-15 5?

CALLAWAY - UNIT 1 o

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e INDEX ADMINISTRATIVE CONTROLS SECTION PAGE t

l 6.1 R E S P O N S f B i L I TY..............................................................j 6.2 ORGANIZATION 6.2.1 ONSITE AN D OFFSITE O RG ANIZATION............................................ 6 1 l

6.2.2 cU NIT. S TA F F............. i. :..i rc................ a r.T. c..

FIGURE 6.21 DELETED..............................................................................63 l

'4 F I G U R E 6. 2 2 D E L ET E D......................................................

l TABLE 6.21 MINIMUM SHIFT CREW COMPOSITION................................... 6 5 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

Function........................................................................................66 Composition...................................................................................,66 R e s p on si bili ti e s............................................................................... 6 6 Records.........................................................................................66 6.2.4 S H I FT TE C H N I C A L A D VI S O R.................................................

6.3 UNIT STA FF Q U A ll FIC ATIO N S.................................................

6.4 TRAINING......................................................................................67 6.5 REVIEW AND AUDIT 6.5.1 O N SITE R EVIEW C OMMITTE E (O RC)................................................

6.5.2 NUCLEAR SAFETY REVIEW BOARD (NSRB)....................................... Deleted l

i i

CALLAWAY UNIT 1 XIX Amendrnent No. 37

=..

I i

INDEX ADMINISTRATIVE CONTROLS SECTION PAGG 6.6.3 TECHNICAL REVIEW AND CONTROL Activities................................................................................................613 Records..................................................................................................6-14

• dc:6:6< - R E PO RTA B L E EV E NT A CTI O N.......................................................... 6-14" r

6.7 S A FETY L I M IT VI QL A TI O N..............................................................

6.8 P R O C ED U P ? S A N D PR O G R A M S...................................................... 6-6.9 REPORTING REQUIREMENTS 6.9.1 R O U TI N E R E P O RT S..................................................................

StartupReport...........................................................................................6-19 l

Annua l Reports...........................................................................................6-19 Annual Radiological Environrnental Operating Report.......................................

6-20 Annual Radioactive Ef fluent Release Report................................................... 6-20 l M o n thly O p e r a ti n g R e p ort............................................................................ 6 - 21 C or e O p e ra t in g Lim its R e p o rt....................................................................... 6-21 6.9.2 S P E C I A L R E P O RT S....................................................................

6.1 O R E C O R D R ET E N T I O N...................................................................

6.1 i R A DI ATI O N P R OTE CTIO N PR O G R A M............................................... 6-2 3 1

CALLAWAY - UNIT 1 XX Amendment No. 28.90. 98. 89 l

l

ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP USEE

' FUNCTION 6.2.3.1 The ISEG shall function to examine plant operating characteristics, NRC issuances, industry advisories, REPORTABLE EVENTS and other sources of plant design and operating experience information, including plants of similar design, which may indicate areas for improving plant safety. The ISEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities or other means of improving plant safety to the Manager, Ouclity Assurance and the Manager, Callaway Plant.

COMPOSITION 6.2.3.2 The ISEG shall be composed of at least five, dedicated, full-time engineers located on site. Each shall have a bachelor's degree in engineering or related science and at least 2 years professional level experience in his field.

RESPONSIBILITIES 6.2.3.3 the ISEG shall be responsible for maintaining surveillance of plant activities to provie independent verification

• that these activities are performed correctly and that human errors are reduced as much as practical.

RECORDS 6.2.3.4 Records of activities performed by the ISEG shall be prepared, maintained, i

and forwarded each calendar month to the Manager, Quality Assurance and the Manager, Callaway Plant.

6.2.4 SHIFT TECHNICAL ADVISOP, The Shift Technical Advisor (STA)*

• shall provide technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of t1e unit.

6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 with the following exceptions:

6.3.1.1 Shift Supervisors, Operating Supervisors, Reactor Operators, and Shift Technical Advisors shall meet or exceed the qualifications of ANSI /ANS 3.1-1981 as endorsed by Reg. Guide 1.8, Revision 2, with the same exceptions as contained in the current revision to the Operator Licensing Examiner Standards, NUREG-1021, ES-202.

6.3.1.2 The Radiation Protection Manager shall be a supervisor with line responsibility for operational health physics who meets or exceeds the qualifications of USNRC Regulatory Guide 1.8, September 1975, for a Radiation Protection Manager. The Radiation Protection Manager will be designated by the Plant Manager.

• Not responsible for sign-off function.

• *The STA position shall be manned in MODES 1,2,3 and 4 unless the Shift Supervisor or the individual with a Senior Operator license meets the qualifications for the STA as required by the NRC.

CALLAWAY - UNIT 1 6-6 Amendment No. 60,92

-~_

ADMINISTRATIVE CONTROLS 4

6.4 TRAINING i

' 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Superintendent, Training.

a 4 -

6.4.2 The Training programs for Shift Supervisors, Operating Supervisors, Reactor Operators, and Shift Technica' Advisors shall meet or exceed the requirements and recommendations of Section 5 of ANSl/ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Rev. 2, with the same exceptions as contained in the current revision to i

the Operator Licensing Examiner Standards, NUREG 1021, ES 202, and 10 CFR.Part-55.

j

_6.4.3 All other training programs shall meet or exceed the requirements and recommendations of Section 5 of ANSI /ANS 3.1-1978.

6.4.4 Training shallinclude familiarization with relevant industry operational experience identified by the ISEG.

.6. 5 REVIEW AND AUDIT 6.5.1 ON SITE REVIEW COMMITTEE (ORC)

(This section deleted.)

6.5.2 NUCLEAR SAFETY REVIEW BOARD (NSRB)

(This section deleted.)

CALLAWAY, UNIT 1 6-7 Amendment No. l'6. 32, 60. 63

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I ADMINISTRATIVE CONTROLS 6.5.3 TECHNICAL REVIEW AND CONTROL 4

1 ACTIVITIES 6.5.3.1 Activities which affect nuclear safety shall be conducted as follows:

)

a. Procedures required by Specification 6.8 and other procedures which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and j

approved. Each such procedure or procedure change thall be reviewed by a qualified individual / group other than the individual / group which prepared the procedure or procedure change, but who may be from the same organization as the individual / group which prepared the procedure or procedure change.

Procedures other than Administrative Frocedures shall be approved the by the appropriate Department Head as designated in writing by the Vice President, Nuclear Operations. The Manager, Callaway Plant, shall approve Administrative Procedures and Radiological Emergency Response Plan implementing procedures. The Manager, Operations Support, shall approve the Security Plan implementing procedures. Temporary changes to procedures "ihich do not change the intent of the approved procedures shall be approved for implementation by two members of the plant staff, at least one of whom holds a Senior Operator license, and documented. The temporary changes shall be approved by the original approval authority within 14 days of implementation. For changes to procedures which may involve a change in intent of the approved procedures, the person authorized above to approve the procedure shall approve the change prior to implementation;

b. Proposed changes or modifications to plant nuclear safety-related structures, systems and components shall be reviewed as designated by the Manager, Callaway Plant. Each such modification shall be reviewed by a qualified individual / group other than the individual / group which designed the modification, but who may be from the same organization as the individual / group which designed the modifications. Proposed modifications to plant nuclear safety-related structures, systems and components shall be approved prior to implementation by the Manager, Callaway Plant;

c. Proposed tests and experiments which affect plant nuclear safety and are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed, and approved. Each such test or experiment shall be reviewed by a qualified individual / group other than the individual /

group which prepared the proposed test or experiment. Proposed test and experiments shall be approved before imp!ementation by the Manager, Callaway Plant.

CALLAWAY - UNIT 1 6-13 Amendment No. 44,88 Correction Letter of 9/21/94

e ADMINISTRATIVE CONTROLS ACTIVITIES (Continued)

d. Individuals responsible for reviews performed in accordance with Specifications 6.5.3.1a., 6.5.3.1b., and 6.5.3.1c., shall be members of the management staff previously designated by the Manager, Operations Support. Each such review shellinclude a determination of whether or not additional, cross-disciplinary, review is necessary. If deemed necessary, such review shall be performed by qualified personnel of the appropriate discipline;

e. Each review shall include a determination of whether or not an unreviewed safety question is involved. Pursuant to Section 50.59,10 CFR, NRC approval of items involving unreviewed safety questions shall be obtained prior to the Manager, Callaway Plant, approval for implementation; and f.

The plant Security Plan and Radiological Emergency Response Plan, and implementing procedures, shall be reviewed at least once per 12 months.

Recommended changes to the implementing procedures shall be approved in accordance with 6.5.3.1.a. Recommended changes to the Plans shall be reviewed pursuant to the Operationsi Quality Assurance Manual and approved by the Manager, Callaway Plant. NRC approval shall be obtained as appropriate.

RECORDS 6.5.3.2 Records of the above activities shall be provided to the Manager, Callaway Plant, ORC and/or NSRB as necessary for required reviews, 6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a. The Commission shall be notified and a report submitted pursuant to the requirements of Section 50.73 of 10 CFR Part 50, and

b. Each REPORTABLE EVENT shall be reviewed by the ORC and submitted to the NSRB and the Senior Vice President-Nuclear.

6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The Senior Vice President-Nuclear and the NSRB shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;

b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the ORC. This report shall describe: (1) applicable circumstances preceding the violation; (2) effects of the violation upon facility components, systems or structures; and (3) corrective action taken to prevent recurrence; CALLAWAY UNIT 1 6-14 Amendment No. VB,39

ADMINISTRATIVE CONTROLS SAFETY LIMIT VIOLATION (Continued)

c. The Safety Limit Violation Report shall be submitted to the Commission, the NSRB and the Senior Vice President-Nuclear within 14 days of the violation; and

}

d. Critical operation of the unit shall not be resumed until authorized by the Commission.

i 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

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a. The applicable procedures recommended in Appendix A of Regulatory Gu'de 1.33, Revision 2, February 1978;

b. The emergency operating procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Section 7.1 of Generic Letter No. 82-33; i

c. Plant Security Plan implementation;

d. Radiological Emergency Response Plan implementation;

e. PROCESS CONTROL PROGRAM implementation; f.

OFFSITE DOSE CALCULATION MANUAL implementation;

g. Quality Assurance Program implementation for effluent and environmental monitoring; 3

h. Turbine Overspeed Protect %n Reliability Program; and j

i. Fire Protection Program alementation.

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6.8.2 Each procedure and administrative policy of Specification 6.8.1 above, and changes thereto, including temporary changes shall be reviewed prior to implementation j

as set forth in Specification 6.5 above.

l 6.8.3 The plant Administration Procedures and changes thereto shall be reviewed in accordance with the Operational Quality Assurance Manual and approved in accordance I

with Specification 6.5.3.1.

The associated implementing procedures and changes thereto shall be reviewed and approved in accordance with Specification 6.5.3.1.

6.8.4 The following programs shall be established, implemented and maintained;

a. Reactor Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the recirculation portion of the Containment Spray System, Safety injection System, Chemical and Volume Control System and RHR System. The program shall include the following:

1) Preventive maintenance and periodic visualinspection requirements, and CALLAWAY - UNIT 1 6-15 Amendment No. 30, 39

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reports to the Vice-President Corporate Planning and is responsible for directing all activities

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related to the Planning of transmission facilities.

j The.Vice-President Corporate Planning also provides engineering and other support services when 1

j requested by the Senior Vice-President Nuclear.

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1.27 other UE divisions may provide safety-related*

1 services which augment and support selected Program activities.

These organizations shall be required i

to implement controls consistent with the OQAP requirements applicable to their scope of activ-1 ities.

The coordination of these activities is the responsibility of the senior Vice President-l Nuclear.

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OQAM Change Notice #95-04 Callaway Plant 1.28 Safety review committees shall be established to provide an independent review of those items required below. These ccmmittees are the Onsite Review Committee (ORC -- refer to Section 1.28.1) and the Nuclear Safety Review Board (NSRB -- refer to Section 1.28.2) 1.28.1 The ORC shall function to advise the Manager, Callaway Plant on all matters related to nuclear safety. The Manager, Callaway Plant shall be Chairman of the ORC.

j 1.28.1.1 ORC membership shall include a minimum of six additional members appointed by the Chairman and an additional member appointed by the Manager, Quality Assurance. Selected members shall include, at a minimum, management responsible for the following areas of expertise:

.a) Operations b) Maintenance c) Instrumentation and Controls d) Chemistry e) Radwaste f) Health Physics g) Nuclear Engineering h) Quality Assurance 1.28,1,2 All alternate members shall be appointed in writing by the ORC Chairman to serve on a temporary basis.

-1.28.1.3 The alternate for Quality Assurance is appointed by the Manger, Quality Assurance.

1.28,1.4 The ORC shall meet at least once per calendar month and as convened by the ORC Chairman or his designated altemate.

1.28.1.5 The quorum of the ORC necessary for the performance of the ORC responsibility and authority provisions shall consist of the Chairman or his designated attemate '

and four members of which no more than two shall be alternates.

1.28.1.6 The ORC shall maintain written minutes of each ORC meeting that, at a minimum, document the results of all ORC activities. Copies shall be provided to the Senior Vice President Nuclear and the NSRB.

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OQAM Change Notice #95-04 Callaway Plant 1

I 1,28.1,7 The O.RC shall be responsible for:

a) Review of all Administrative Procedures; b) Review of safety evaluations for:

procedures, change to procedures, equipment, systems or facilities, and e

tests or experiments completed under the provision of 10CFR50.59 to e

verify that such actions did not constitute an unreviewed safety question; d

c) Review of proposed procedures and changes to procedure, equipment, systems or facilities which may involve an unreviewed safety question as defined in 10CFR50.59 or involves a change in Technical Specifications; d) Review of proposed test or experiments which may involve an unreviewed safety question as defined in 10CFR50.59 or requires a change in Technical Specifications; e) ' Review of proposed changes to Technical Specifications or Operating License; f) Investigation of all violations of the Technical Specifications including the j

forwarding of reports covering evaluation and recommendations to prevent i

recurrence to the Senior Vice President Nuclear and to the NSRB; g) Review of report of operating abnormalities, deviations from expected i

performance of plant equipment and of unanticipated deficiencies in the design or operation of stru:tures, systems or components that affect nuclear safety; h) Review of all REPORTABLE EVENTS; i) Reviev, of the plant Security Plan and shall submit recommended changes to the NSRB; j) Review of the Radiological Emergency Response Plan and shall submit recommended changes to the NSRB; k) Review of changes to the PROCESS CONTROL PROGRAM, the OFFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems;

1) Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations,,

and disposition of the corrective action to prevent recurrence and the 4

forwarding of these reports to the Manager, Callaway Plant and to the NSRB; m) Review of Unit operations to. detect potential hazards to nuclear safety; n) Investigations or. analysis of special subjects as requested by the Chairman of the NSRB; 5

'o) Review of Unit Turbine Overspeed Protection Reliability 1 rogram and revisions thereto; p) Review of the Fire Protection Program and submitting recommended changes to the NSRB.

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C Channe Notice #95-04 OQAM Callaway Plant 1.28.1.8 The ORC shall:

a) Recommend in writing in the Manager, Callaway Plant approval or disapproval ofitems considered under Sections 1.28.1.7.a through 1.28.1.7 e,1.28,1.7.1,1.28.1.7),1.28.1.7 k,1.28.1.7.1,1.28,1.7,o, and 1.28,1.7.p above.

b) Render determinations in writing with regard to whether or not each item considered under Sections 1.28,1.7.b through 1.28.1.7.e, and J

1.28.1.7.m, above, constitutes an unreviewed safety question; and 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 Senior Vic President-Nuclear and the NSRB of disagreement between ORC and the Manager, Callaway Plant; however, the Manager Callaway Plant j

shall have responsibility for resolution of such disagreements.

The NSRB shall function to provide independent review and audit of 1.28.2 designated activities in the areas of:

a) Nuclear power plant operations, b) Nuclear engineering, c) Chemistry and radiochemistry, d) Metallurgy, e) Instrumentation and control, f) Radiologicalsafety, g) Mechanical and electrical engineering, and h) Quality assurance practices.

The NSRB shall report to and advise the Senior Vice President-Nuclear on 1.28.2.1 those areas of responsibility stated in OQAM Sections 1.28.2.3 and 18.8.1.

The NSRB shall be composed of at least the following members:

1.28.2.2 Chairman:

Manager, Licensing and Fuel Member:

Manager, Nuclear Engineering Member:

Manager, Quality Assurance Member:

Vice President, Nuclear Operations Member:

Supervising Engineer, Nuclear Fuels 1-7c

OQAM Change Notice #95-03 Callaway Plant 1.28.2.3 Additional members and Vice Chairman may be appointed by the Chairman.

1.28.2.4 The NSRB members shall hold a Bachelor's degree in an engineering or physical science field, or equivalent experience, and a minimum of 5 years of technical experie,nce of which a minimum of 3 years shall be in one or more of the disciplines of Section 1.28.2.

1.28.2.4 All alternate members shall be appointed in writing by the NSRB Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in NSRB activities at any one time.

1.28.2.5 Consultants shall be utilized as determined by the NSRB Chairman to provide expert advice to the NSRB.

1.28.2.6 The NSRB shall meet at least once, every 6 months.

1.28.2.7 The quorum of the NSRB necessary for the performance of the NSRB review and audit functions herein, shall consist of the Chairman or his designated attemate and at least two thirds of the NSRB members including altemates. No more than a minority of the quorum shall have line responsibility for operation of the uni' For the purpose of a quorum, those considered to have line responsibility will include the Vice President Nuclear Operations, and personnel reporting to the Vice President Nuclear Operations.

1.28.2.8 Minutes of each NSRB meeting shall be prepared, approved and forwarded to the Senior Vice President-Nuclear within 14 days following each meeting.

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6 I

1-7d

i OQAM Change Notice #95-04 l

Callaway Plant 1.28.2.9 The NSRB shall be responsible for the review of:

a) The safety evaluations for:

changes to procedures, equipment, systems or facilities; and e

tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute and unreviewed safety question; b) Proposed changes to procedures, equipment, systems or facilities which involve an unreviewed safety question as defined in Section 50.59,10 CFR; c) Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59,10 CFR; d) Proposed changes to Technical Specifications or the Operating License; e) Violations of Codes, regulations, order, Technical Specifications, license requirements, or ofinternal procedures or instructions having nuclear safety significance; f) Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety; g) ALL REPORTABLE EVENTS; h) All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems or components that could affect nuclear safety; and i) Reports and meetings minutes of the ORC.

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l oQau Change Notice #95-04, 1823

'2.

oneratine cum 11tv Aamurance Manual tooAM)

The 00AM contains a delineation of.the Policy statement, quality assurance requirements,:

assignment of responsibilities, and'a defini-tion of.organisational interfaces. The OQAM is the written description of the 00AP.

Approval 1

of the 00AM is by the Senior Vice President-Nuclear and the Manager, Quality Assurance.

1947-3.

ca11mway Plant oneratine Manual The callaway Plant Operating Manual consists of l

a multi-volume set of Plant operating proce-dures prepared or reviewed by the staff with the aid of other SNUPP8 utilities, Nuclear Engineering, the Lead A/E, the MSSS

Supplier, and Fuel Fabricator.

These procedures are controlled, approved, and issued in accordance q

with Administrative Procedures contained within the Manual. This Manual includes administrative controls consistent with those required by Regulatory Guide 1.33.

isoo Administrative procedures which apply to the entire staff, and revisions thereto, shall be reviewed by the callaway Plant Onsite Review Committee (ORC) and the Quality Assurance Department.

The final approval of Administra-tive Procedures and revisions thereto shall be by the Manager, callaway Plant. The review and 4

approval of other procedures and revisions I

thereto shall be in accordance with approved Administrative Procedures which implement the 3

requirements of the Technical specifications i

and this OQAM. }

J 679 2.7 UI may employ the safety-related services of archi-1746 tact engineers, NSSS suppliers, fuel fabricators, 1787 constructors, and others which provide or augment 2293 UE efforts during the operating phase. These organ-2460 inations shall be required to work under a quality assurance program whose controls are consistent with the. scope of their effort.

This does not preclude any organization from working under the UE OQAP.

The quality assurance program of outside organizations shall be subject to review, evalua-tion and acceptance by the UE Quality Assurance Department prior to the initiation of safety-re'-

lated work.

Vendor. programs and procedures.shall, also. seet :UE's commitment' to USNRC Generic Letter 83-28..

2.8 Disputes which may arise betwaari QA or QC personnel M

and personnel.in other'~UE organizations' which 2-3 Rev. 15 6/9t e

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Channe Notice C95 04 oQAM t

tion would become irreversible (i.e.,

require extensive demolition and rework). The design vari-fication shall be complete prior to relying upon the. component, system, or structure to perform its

. safety-related function.

l2188 3.16 Action shall be initiated to correct errors found in the design process. Errors and deficiencies 1

identified in approved design documents shall be documented and the process of their correction (i.e.,

review and approval) shall be controlled.

These actions shall assure that changes to design or installed components are controlled.

3.17 Requests for design changes affecting safety-related structures, systems, and components may be originated by the unit staff, Licensing and Fuels f

or Nuclear Engineering. Design changes shall be processed by Nuclear Engineering. Design changes engineered by Nuclear Engineering shall be the responsibility of the Manager, Nuclear Engineering.

Design changes engineered by Licensing and Fuels shall be the responsibility of Licensing and Fuels.

3.18 Independent of the r'esponsibiDE.ies of the design

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organization, the requirements of the Onsite Review Committee (ORC) and the Nuclear Safety Review Board (NSRB) as defined in

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OQAM, Section 1.0 shall be satisfied. Design changes require a safety evaluation which shall be reviewed by the ORC and approved by the Manager, Callaway Plant. In addi-

tion, changes in the facility as described in the FSAR which involve a change in the Callaway plant Technical specifications incorporated in the license or an unreviewed safety question require review and approval by the NSRB and the Nuclear Regulatory Commission prior to implementation. When design is performed by an outside organization, UE shall perform or coordinate a review of the design for operability, maintainability, inspectability, FSAR commitment compatibility, test and inspection i

acceptance criteria acceptability, and design requirements imposed by Plant generating equipment.

3.19 Safety evaluations which consider the effect of the design as described in the design documents, shall be performed by the responsible UE engineering organization or outside organization (s).

These evaluations shall include the basis for the deter-i mination.that.the design chang's does'not involve an unreviewed safety question. As' deemed necessary by the evaluating organization, detailed analyses shall be performed to support the bases of safety F-~

evaluations.

All nuclear safety evaluations are 3-5 Rev. 17 6/94 1

a

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'Channe Notice #95-04 e

OQAM l

submitted to the CRC. Changes involving the substi-j tution of equivalent hardware require safety evaluations to assure that the design requirement l

consistent with and do not alter the i

are changes design criteria specified in existing design docu-monts. When design documents and safety evaluations its

' prepared by an outside organization under

+

1 are N45.2.11 program, review and approval per ANSI QA will be included.

UE will approve all outside organisations' design documents and safety evalua-l and will perform appropriate reviews neces-

tions, l

sary for final approval.

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Procedures and instructions related to equipment or 1911 3.22 I

\\2164 systems that are modified shall be reviewed and updated to reflect the modification prior to placing the equipment or systems in operation to perform safety-related functions. Plant personnel i

shall be made aware of changes affecting the performance of their duties through procedure revi-specific training in the operation of

sions, or modified equipment or systems, or other appropriate means.

2039 3.23 Records shall be maintained which reflect current 2132 design including safety analyses, safety evalua-

\\2164

tions, design change installation procedures, identification documents, procurement material documents, special process documents, equipment and 2173 installation specifications, and as-built drawings.

shall be prepared under a drawing control 3.24 Drawings system which' provides for checking methods and review and approval requirements. Drawings shall be subject to reviews by the responsible design organ-design correctness, conformance,to ization forand compliance with applicable codes and

criteria, standards.

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OQAM c3,,g, gotic,,93 g4 Callaway Plant 3.20 The ORC and NSRB shall review design changes pursuant to the requirements of OQAM, Section 1.0 4

3.20.1 Design changes which require an amendment of the license, shall be submitted on an application to the Nuclear Regulatory Commission for approval in accordance with 10 CFR 50.90.

3.21 DELETED.

6 3-6a

Chance Notice #95-04

%M 16.2 Conditions adverse to quality which are classified as nonconformances, shall be controlled in accor-dance with the additional requirements described,in OQAM, section 15.

16.3.

Conditions adverse to quality which impede the

,' implementation or reduce the effectiveness of the

• Operating QA Program shall be considered signifi-cant conditions ' adverse t;o quality.

significant conditions adverse to quality may include, but are not limited to, noncompliance with procedural requirements which impact nuclear or personnel safety; reportable occurrences required by regula-tions; adverse nonconformance trends; deficiencias identified in the OQAP; recurring conditions for which past corrective action has been ineffective; and managerial controls which could result in the m

failure of a plant system to perform it's intended function. Examples of such conditions include those

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16.4 Conditions adverse to quality which involve defects f

in basic components or deviations from technical requirements in procurement documents shall be reviewed for reporting applicability under 10CFR21 i

and other Federal reporting requirements.

Repor-table conditions adverse to quality are classified as significant.

16.5 The nature of the condition adverse to quality may be such that remedial actions must be taken imme-

diately, whereas development and implementation of corrective action to preclude recurrence may take substantially longer.

1871 16.6 Nuclear Engineering personnel shall review condi-tions adverse to quality which involve design defi-ciencies or which involve recommending design changes as corrective action. Licensing and Fuels should review conditions adverse to quality for fuel-related issues. The ORC shall review signifi-cant conditions adverse to quality.

16.7 Corrective. action documents shall be closed by in'lementation and adequacy of verifying the p

corrective action. The closure of corrective action documents shall be accomplished as promptly as -

practicable after the corrective action taken has w ~

accomplished

.be been verified. ' verification may

_ ritten communica '

through direct observations, t io'n s',

re-audit, surveillances, or other approp-riate means.

16-2 Rev. 16 6/93 c,v yy..,..-

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_ _ _ _ _Page 2 of 2 Prem: Mechael W. Buel, Engmeet Tet D$ Walker Dee:10/16/95 Time:13:54:00 1

e I

OQAM Channe Notice #95-04 Callaway Plant j

1 INSERT A i

... Sections 1,28,1,7,f, g, h,1, m (potential hazards to nuclear safety) of this OQAM and NPDES violations.

l 16-2a

Channe Notice #95 04 17.0 pc1LITY 1saVRAMCI KRC01D4 1851 17.1 Quality assurance record systems governing the collection, storage, and maintenance of records-2126 2127 nhall be established by UE. They shall apply to 2130 records associated wl.th startup testing, operation,*

2173 maintenance, repair, refueling, and modification of safety-related structures,, systems, and components at the Callaway Plant.

1851 1'7. 2 During the operating phase, quality assurance 2128 records shall be maintained to furnish. documentary 2132 evidence of the quality of items and activities 2133 affecting quality. Applicable design specifica-procurement documents, test procedures, tions,ional procedures or other documents shall 2137 operat 213s 2173 specify the quality assurance records to be gener-ated by, supplied to, or held by UE.

Documents shall be considered quality assurance records when completed.

Records may be maintained for varying periods and shall be identified as litetime or nonpermanent records in that a lifetime or finite retention period shall be specified. Records shall provide sufficient information to permit identifi-cation to the item or activity to which it applies, and be retrievable.

2337 17.3 Quality assurance records include, but are not 2364 limited to, operating logs; maintenance and modifi-J cation procedures and inspection results; report-able occurrences; results or reviewsp inspections,

tests, audits and material analyses; qualification of personnel, procedures, and equipment; and other f

Mg_ D documentation including drawings, specifications, procurement documents, nonconformance documenta-

tion, corrective action documents, calibration procedures and results, and the results of moni-toring work performance (e.g., surveillance).

1936 17.4 Inspection and test records shall contain the following as a minimum:

1.

A description of the type of observation 2.

The date and results of the inspection or test 3.

Identification of the inspector or data recorder 4.

3 valuation of the acceptability of'the results 5.

Action.taken in connectioir with any deficien-s cies noted s.

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I 3865 18.5 The Manager, Quality Assurance shall be responsible for. assuring the implementation of a comprehensive system of planned audita to verify compliance with the OQAP..The Manager, Quality Assurance has suffi-j cient authority and organisational freedom to i

schedule and perform both internal and external audits. He has the organisational responsibility to measure and assure the overall effectiveness of the i

oQAP and is independent of the economic pressures l

of production when opposed to safety or quality.

The Manager, ice President-Nuclear. Quality Assurance has direct acce the Senior V j

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1790 18.6 The audit system shall include internal and i

1799 external audits. The system shall be planned, 1800 documented, and conducted to assure coverage of I

3871 the applicable elements of the OQAP, and overall coordination and scheduling of audit activities.

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Audit results shall be periodically reviewed by the j

QA Department for quality trends and results reported to the appropriate management.

The

Manager, Quality Assurance shall monitor the OQAP audit program to assure audits are being accoup-lished in accordance with the requirements described herein and for overall Program effective-i ness.

The NSRB shall selectively review audit I

reports of onsite audits. The HSRB shall also peri-I odically review the onsite audit program as devel-l oped by the QA Department, to assure that audits are being performed in.accordance with

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Appropriate levels of management shall be provided copies of internal and external audit Esports.,0.g _gjjj{jjn_ y jj,'_i_ U f.__, M..y.

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I 1792 18.7 Internal audits shall be conducted by the QA 1816 Department and shall be performed with a frequency l 2188 commensurate with their safety significance. An l

3873 audit of safety-related functions shall be completed in accordance with formal audit schedules within a period of two.(2) years. Each element of

-i the OQAP, such as design control and document control, and each area of Plant operations shall be audited.

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l 1800 18.9 During Plant modifications or other majo~r unique 3873 activities, audits shall be scheduled as required

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to assure that Quality Assurance Program require-i monts are properly implemented.

1 3577 18.10 External audits shall be conducted by or for the QA 3584 Department as a method for the evaluation of f

3596 procurement sources and as a post-award source verification of conformance to procurement docu-ments.

Audits conducted by other organisations (with similar orders with the same supplier),

including other utilities or A/E's, may be employed as a means of post-award source verification in lieu of UE performed audits and may not necessarily audit specific items furnished to UE. These audits and surveillances shall utilise personnel qualified in accordance with this OQAM and shall be conducted in accordance with this oQAM and QA Department procedures.

commercial grade items do not require pre-or post-award audits. Similarly, items which are relatively simple and standard in design and manufacture may not require supplier qualification or post-award audits to assure their quality.

1780 18.11 Applicable elements of suppliers' quality assurance programs shall be audited (post-award) on a l3565 3596 triennial basis. Audits generally should be 3878 initiated when sufficient work is in progress to 3872 determine whether the organisation is complying with the established quality assurance provisions.

Subsequent contracts or contract modifications which significantly enlarge the scope of activities by the same supplier shall be considered in estab-lishing audit requirements. In addition, the need I

for a triennial audit may be precluded upon evalua-tion and. documentation by the QA Department that l

the results of mini-audits performed during source verification and source surveillance activities confirm the adequacy and implementation of the supplier's QA Program.

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Channe Notice #95-04 OQAM Callaway Plant 18,8 Supplementary to the biennial requirement to audit safety-related functions, audits of Unit activities (listed below) and Radiological Emergency Response Plan SHALL be:

performed under the cognizance of the NSRB, and conducted on a performance based frequency by the QA Department, not to exceed 24 months a) The conformance of Unit operation to provisions contained within the Technical Specifications and applicable license conditions; b) The performance, training and qualifications of the entire Unit staff; c) The results of actions taken to correct deficiencies occurring in Unit equipment, structures, systems or method of operation that affect nuclear safety; d) The performance of activitics required by the Operational Quality Assuranco Program to meet the criteria of Appendix B,10 CFR Part 50; e) The Fire Protection equipment, programmatic controls, and implementing procedures utilizing either a qualified offsite licensee Fire Protection Engineer or an outside independent Fire Protection Consultant (non Union Electric).

However, an outside independent Fire Protection Consultant (non Union Electric) SHALL be used at least every third year, f) The Radiological Environmental Monitoring Program and the results thereof; i

g) The OFFSITE DOSE CALCULATION MANUAL and implementing procedures; h) The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes; i) The performance of activities requi.*ed by the Quality Assurance Program for efnuent and environmental monitoring; and j) Any other area of Unit operation considered appropriate by the NSRB or the Senior Vice President Nuclear.

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OQAM Change Notice #95-04 Callaway Plant i

18,8,1 in addition to audits conducted under the cognizance of the NSRB, the following areas shall be audited per the frequency specified in applicable regulations:

I o Special Nuclear Material Accountability program o Radiological Protection program o Security program o Fitness For Duty program l

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3565 14.12 Supplomantary to audits, annual evaluations of suppliers shall be performed which take into

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account, as applicable:'l) the review of supplier furnished documents such as certificates of confor-

mance, nonconformance notices, and.

corrective actions; 2) results of previous source verifica-

tions, audits, and receiving inspections; 3) oper-ating experience of identical or similar products furnished by the same supplier; and 4) results of audits from other sources.

3565 14.13 Audits shall also be conducted whent 1) significant changes are made in functional areas of the Quality l3872 3874 Assurance Program such as significant reorganiza-3883 tion or procedure revisions; or 2) when it is suspected that the quality of the item is in jeopardy due to deficiencies in the Quality Assur-ance Program; or 3) when a systematic, independent assessment of Program effectiveness is considered necessary; or

4) when it is necessary to verify implementation of required corrective action.

3876 18.14 Audits shall be conducted using written plans in 3878 accordance with QA Department procedures. The 3881 procedures require evaluation of work areas, activ-

ition, processes, goods, services, and the review of documents and records for quality-related prac-

tices, procedures, and instructions to determine the effectiveness of the implementation of the OQAP and compliance with 10 CFR 50, Appendix A 6 0;ilir:^;

rl nt T: ' ' rri 0;:-i'ir:'i-- _ The audit plan shall identify the audit scope, the require-

ments, the activities to be audited, organizations i

to be notified, the applicable documents, the

schedule, and the written procedures or checklists as appropriate.

The audit plan and any necessary reference documents shall be available to the audit team members.

3877 18.15 An audit team consists of one or more auditors.

A Lead Auditor shall be appointed Audit Team Leader.

The Audit Team Leader shall be responsible for the written plans, checklists, team orientation, audit notification, pre-audit conference, audit perfor-

mance, post-audit conference, reporting,

records, and follow-up activity to assure corrective action.

Any adverse findings shall be reported in a post-audit conference with team members and the audited organization subject to the clarification of Section 4.3.3 of ANSI N45.2.12 in Appendix A. When a post-audit. conference is. held it shall be,..t o discuss, items and arrive at a general agreement on the.identi'fication of the findings. ______

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the audited organization for internal audits conducted in accordance e

with Section 18.7, or the Senlot.Vice President Nuclear for audits conducted under the e

cognizance of the NSRB in accordance with Section 18.8, 1

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LETTER FROM NRC DATED SEPTEMBER 1.1995 l

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wanennston, o.c. manwam september 1, 1995 Mr. Donald F. Schnell Senior Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, MO 63166

SUBJECT:

CALLAWAY PLANT - TECHNICAL SPECIFICAT10N AMENDMENT RFWF.5T RELATED TO THE RELOCATION OF REVIEW AND AUDIT REQUIREMENTS (TAL. N0. M90017)

Dear Mr. Schrall:

By your application dated June 21, 1994, Union Electric Company requested to amend the Callaway Technical Specificatiens to relocate the review and audit requirements of the On-site Review Committee (0RC) and Nuclear Safety Review Board (NSRB). The specific contention that prevents the staff from issuing the requested amendment is your proposed relocation of the review and audit requirements to the callaway Plant Final Safety Analysis Report (FSAR and' ~

control of subsequent changes to thoss requirements in accordance wit 10 CFR 50.59, " Changes Tests and Experiments." The NRC staff and Union Electric have had severai discussions regarding this issue and this letter documents the staff's positions.

The staff has found that the relocation of some technical specification requirements is acceptable provided that they are placed into an appropriate licensee controlled program. The t.equirements must be relocated to programs with adequate controls regarding future changes and provisions for NRC review if an applicable regulatory threshold is exceeded. Guidance related to the possible ralocation of requirements contained in limiting conditions for operation (LCOs) was provided by the Coenission's Final Policy Statement on Jechnical Specifications Improvements and was subsequently incorporated into a revis, ion of 10 CFR 50.36. The staff has discussed the acceptability of relocating the existing technical specification administrative controls related to review and audit requirements in several meetings and documents, including the October 25, 1993, letter from W. Russell to the four owners group., Generic Letter 93-07, " Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans,' the January 17, 1995, letter from C. Grimes to the four owners grcups, and technical spec'ification amendments issued to other licensees.

While relocated LCOs have usually dependd on 10 CFR 50.59 for control of subsequent changes, the relocation of some administrative controls 'has relied upon regulatory requirements other than 10 CFR 50.59 in order to control changes and. initiate possible NRC review. The October 25, 1993, letter to the owners groups specifi'cally requested'that they develop details for the relocation of the affected administrative controls, including the identification of the licensee-c'ontrolled documents which would receive the

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requirements and the associated process for chan e control.

The Quality' Assurance (QA) Plan was' mentioned as a possible ocation fR GBEgca. tte?}g.

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relocated administrative controls.

Followin the staff has worked with the owners groups. g the October 25, 1993, letter, i

and reached a general consensus that the review and audit requirements may be relocated to the QA Plan and i

changes controlled in accordance with 10 CFR 50.54(a). A letter from C.

I Grimes to the owners groups dated January 17, 1995, provided additional i

details regarding the relocation of audit functions to the QA program.

This letter specifically addressed the relocation of fire protection audits and i

i instructed the owners groups to retain current audit frequencies pending future changes to the fire protection regulations.

In related activities initiated by the staff and industry to reduce unnecessary regulatory burdens, Nuclear Energy Institute (NEI) has petitioned 1

the NRC to revise 10 CFR 50.54(a). The pGition requests that the 10 CFR 50.54(a) change control process used to detemine the need for NRC review be~ replaced with the criteria given in 10 CFR 50.59. The petittsn 1

would establish the same controls for the quality assurance program as your amendment request has proposed for the relocated review and audit frequencies, l

However, the HE1 petition is in an early stage of the rulemaking process and the staff cannot foresee the final changes that will be incorporated into 10 CFR 50.54(a).

With respect to your application dated June 21, 1994, the staff requests that you revise your application as follows:

1.

The destination of the re1 % ted review and audit requirements should be the Callaway QA hogram, FSAR Chapter 17, 2.

Your revised QA Program description should be included in the supplemental submittal.

3.

As part of the QA Program provided in your supplemental submittal, the audit frequency require'nents of existing TS 6.5.2.9 may be conducted on a performance based frequency, not to exceed 24 months, except for the following:.

Is a.

Audit frequencies contained in regulations (e.g., security and emergency plans as discussed in Generic Letter 93-07) b.

Fire protection equipment and program implementation at least once per 12 months utilizing either qualified offsite licensee fire protection engineer or an outside independent fire protection consultant (non-Union Electric). An outside independent fire protection consultant (non-Union Electric) shall be used at least every third year (Current requirements j

of TS 6.5. 2.9.1).

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Should'you choose to supplement your June 21, 1994, application and"

'l incorporate the above changes, the staff will be able to complete its review.

Any changes.to the relocated review and audit requirements following issuance of the amendment would be performed in accordance with 10 CFR 50.54(a),

inc'luding any revisions that result from the NEI petition for rulemaking..

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c D. F. Schnell v If Union Electric does not wish to incorporate these changes, please submit a

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letter withdrawing all or portions of the original application.

If a supplement or a letter of withdrawal is not received within 45 days of receipt of this letter, the staff plans to issue an amendment addressing the administrative changes contained in the June 21, 1994, application' and deny the portion related to the relocation of review and audit requirements.

)

Sincerely, L. Raynard Wharton, Project Manager Project Directorate III-3 Division of Reactor Projects - III/IV Office of Nuclear Reactor Regulation Docket No. 50-483

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e MEMORANDUM OF TELECONFERENCE WITH THE NRC DATED OCTOBER 10,1995

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s TELECON R. Wharton - NRC-FM i

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D. Shafer - UE Date: 10/10/95 i

Subject:

TS Section 6. Amendment Request (OL 1156) 1 Ray informed me that he had gotten a message from the technical reviewer for this change (Bill Reckley) that the NRC fire protection group has revised its position on audit frequency. Instead of the 12 month frequency for fire protection equipment and profram implementation, they will now accept a 24 month performance based audit frequency. They still require the triennial outside independent fire protection consultant (non-Union Electric) audit. Ray wanted to get this information to us prior ta our responding to the September 1, i

1995 letter from NRC.

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