ML20140D622
| ML20140D622 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/06/1997 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3594, NUDOCS 9706100449 | |
| Download: ML20140D622 (6) | |
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1901 Chouteau kenue Post Othce Bcu 149 St Louis. Missoon 63166 314-621-3222 June 6, 1997
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Umox Etucriac U. S. Nuclear Regulatory Commission g
Attn: Document Control Desk Mail Station PI-137 Washington, D. C. 20555-0001 Gentlemen:
ULNRC-3594 DOCKET NUMBER 50-483 4
CALLAWAY PLANT TECIINICAL SPECIFICATION CIIANGE - SECTION 6.0
Reference:
- 1) ULNRC-3557 dated April 3,1997
- 2) ULNRC-3565 dated April 24,1997
- 3) NRC Letter dated May 2,1997
- 4) ULNRC-3575 dated May 9,1997
- 5) ULNRC-3579 dated May 9,1997 By letter dated April 24,1997 (Reference 2) UE requested an amendment to Facility Operating License NPF-30 for Callaway Plant that revises the title " Senior Vice President, Nuclear" to "Vice President and Chief Nuclear Officer".
The change is necessary due to Donald F. Schnell's : retirement and his replacement by Garry L. Randolph. The evaluation associated with this amendment request addressed locations within Technical Specification Section 6.0 where the senior management position title was used and needed to be revised. The evaluation reflected the fact that the senior management position for the Nuclear Function continues to report to the President and Chief Executive Officer of Union Electric Company.
Although not pan of this amendment request and associated evaluation, an organization change was also involved in the retirement of Mr.
Schnell and his replacement by Mr. Randolph. Prior to May 1,1997 the Vice President Nuclear Operations (Mr. Randolph), the Manager Quality Assurance, the Manager Nuclear Engineering, the Manager Licensing & Fuels, and the Manager Nuclear Services reponed to Mr. Schnell. The Manager Callaway Plant, the g
l Manager Operations Support, the Manager Emergency Preparedness and
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Organizational Support, and the Manager Nuclear Information Services reported to Mr. Randolph. Effective May 1,1997 each of the above listed managers reported directly to the Vice President and Chief Nuclear Officer (Mr. Randolph). This organization change was included in our original notification of Mr. Schnell's retirement by letter dated April 3,1997 (Reference 1) and was described in the update to the OQAM dated May 9,1997 (Reference 4).
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9706100449 970606 PDR ADOCK 05000483 P
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U.S. Nuclear Regulatory Commission Page 2 With respect to elimination of a single layer of senior management oversight, the four managers listed above previously reported to Mr. Randolph as y
the Vice President Nuclear Operations. They now repon to Mr. Randolph as the l
Vice President and Chief Nuclear Officer along with the four managers that s
l previously reponed to Mr. Schnell as the Senior Vice President, Nuclear. Mr.
Randolph has been responsible for operating functions of the Nuclear Division since becoming General Manager, Nuclear Operations in 1987 and, subsequently, Vice President-Nuclear Operations in 1991. He has essentially had the same functional j
. areas reponing to him during that period and has also been intimately involved in all 4
aspects of the Nuclear Function thmugh his interaction with the remainder of the Nuclear Function management team and his membership on the Nuclear Safety l
Review Board. The Manager Callaway Plant, the Manager Operations Support, the Manager Emergency Preparedness and Organizational Support, and the Manager Nuclear Information Services will continue to have sufficient management oversight.
The reporting path and oversite of the Manager Quality Assurance, the Manager Nuclear Engineering, the Manager Licensing & Fuels, and the Manager Nuclear i
Services are the same. They continue to report to senior management position in the Nuclear Function (the Vice President and Chief Nuclear OfGeer) who reports to the
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President & Chief Nuclear Officer of Union Electric.
Amendment 37 (June 21,1988) to the Callaway Plant Facility Operating License removed the offsite and unit organizational charts from the Technical Specifications and added essential aspects of the organizational structure which were previously defined by the organizational charts. Below are excerpts from the NRC SER for Amendment 37 with the corresponding section references from the Callaway Technical Specifications identified in brackets [ ].
...In summary, many of the details shoust on the onsite and ofsite organization charts are not essential to the safe operation of thefacility. Over the years, the staf experience with changes in the details of operating organizations has shown that organization chans can be modified in many ways while maintaining adequate operational safety. This experience has enabled the staf to distill those organizational characteristics which are important to safety.
The staffinds that the only aspects oforganization charts which are important to safety, are not covered by other specifications, and must remain in TS, are those conditions listed below.
(1) A requirement that lines ofauthority, responsibility, and communication shall be established and definedfrom the highest management levels through intermediate levels to and including all operating organization positions. Those 1
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U.S. Nuclear Regulatory Commission Page 3 I
relationships shall be documented and updated, as appropriate, in theform oforganization charts,fimetional j
descriptions ofdepartment responsibilities and relationships,
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andjob descriptionsfor key personnelpositions, or in equivalentfonns ofdocument. "
[ Reference Callaway TS 6.2.1.a and ULNRC-3579 dated May 9,1997 which updated the organization section of the Callaway FSAR]
"(2) Designation of an executive position that has corporate responsibilityfor overallplant nuclear safety and authority to take such measures as may be needed to ensure acceptable performance ofstafin operating, maintaining, and providing technical support to the plant to ensure nuclear safety. "
[ Reference Callaway TS 6.2.1.c and the subject change request.]
"(3) Designation of a management position in the onsite organization that is responsiblefor overall unit operation and has control over those onsite activities necessaryfor safe operation and maintenance of the plant. "
[ Reference Callaway TS 6.2.1.b]
"(4) Designation of those positions in the onsite organization that require a senior reactor operator (SRO) or reactor operator (RO) license. "
[ Reference Callaway TS 6.2.2.g]
"(5) Provisions ofsuficient organizationalfreedom to be independent of operationalpressures to those individuals who perform thefunctions ofhealth physics, quality assurance, and training of the operating staf "
[ Reference Callaway TS 6.2.1.d]
"Since the above conditions will be maintained in the TS, removal j
of the organization charts represents no reduction in current safety requirements. These changes will simply allow licensees to
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i U.S. Nuclear Regulatory Commission Page 4 implement changes in their organization structure without i
obtaining NRC approval... "
References 4 and 5 updated the Operational Quality Assurance f
Manual and the Final Safety Analysis Report (FSAR) to reflect the organization change associated with Mr. Schnell's retirement and replacement by Mr. Randolph.
Based on our current licensing basis, as discussed above, and that the OQAM and FSAR have been updated, we do not believe revision of the significant hazards evaluation is necessary.
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The last paragraph of Reference 3 implies that we had proposed, in an April 22,1997 telecon, sending a letter to the NRC to advise them of the title change and not to submit a technical specification change request. Our call to the Licensing Project Manager for Callaway was to propose a letter notifying NRC of I
the change and that the change would be included in the Improved Technical Specification submitted on May 15, 1997. We did not propose supplanting the Callaway Technical Specification change by a letter.
In summary, we believe the subject change request adequately addresses those areas of the Technical Specification which are being revised. Other portions of our licensing basis are being revised under the. provisions in the applicable regulations, which do not require prior NRC approval. We hope this information is helpful in the processing of the amendment request.
i Please contact us with any further questions.
Very truly yours,
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A. C. Passwater Manager, Licensing & Fuels
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STATE OF MISSOURI
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COUNTY OF CALLAWAY
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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 day of 6 vt e 1997.
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M. H.
Fletcher Professional Nuclear Consulting, Inc.
19041 Raines Drive Derwood, MD 20855-2432 l
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive l
Suite 400 Arlington, TX 7601:.-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commissicn 8201 NRC Road Steedman, MO 65077 Kristine M. Thomas (2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Nuclear Energy Institute 1776 I Street N.W.
Suite 400 Washington, DC 20006-3708