ML20141L745

Operating Quality Assurance Manual Change Revision 34A

ML20141L745
Person / Time
Site:	Callaway
Issue date:	06/08/2020
From:	Mahesh Chawla Plant Licensing Branch IV
To:	Diya F Ameren Missouri
Chawla M
References
EPID L-2020-LLQ-0000
Download: ML20141L745 (6)

Text

June 8, 2020 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Steedman, MO 65077

SUBJECT:

CALLAWAY PLANT, UNIT NO. 1 - OPERATING QUALITY ASSURANCE MANUAL CHANGE REVISION 34A (EPID L-2020-LLQ-0000)

Dear Mr. Diya:

By letter dated January 23, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20028E064), Union Electric Company, dba Ameren Missouri (the licensee), submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to change the Operating Quality Assurance Manual (OQAM) for Callaway Plant, Unit No. 1, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(a)(4). The change involves a reduction in commitment to remove the list of specific conditions that are examples of the definition of significant conditions adverse to quality.

The NRC staff has reviewed the licensees request and concludes that the proposed change to Callaways OQAM, Revision 34A, complies with the applicable quality assurance requirements in 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants; 10 CFR Part 71, Packaging and Transportation of Radioactive Material; and 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, and is, therefore, acceptable.

F. Diya If you have any questions, please contact me at 301-415-8371 or via e-mail at Mahesh.Chawla@nrc.gov.

Sincerely,

/RA/

Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-483 and 72-1045

Enclosure:

Safety Evaluation cc: Listserv

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR CHANGE TO THE OPERATING QUALITY ASSURANCE MANUAL, REVISION 34A, UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NOS. 50-483 and 72-1045

1.0 INTRODUCTION

By letter dated January 23, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20028E064), Union Electric Company, dba Ameren Missouri (the licensee), submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to change the Operating Quality Assurance Manual (OQAM), interim Revision 34a, for Callaway Plant, Unit No. 1 (Callaway) in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.54(a)(4).

The Callaways OQAM provides a top-level overview of the quality program controls applied to quality-related items and activities at Callaway during the operating phase. The OQAM complies with the applicable requirements of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion XIV, Corrective Actions; 10 CFR Part 71, Packaging and Transportation of Radioactive Material, Subpart H, Quality Assurance; and 10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, Subpart G, Quality Assurance.

2.0 REGULATORY EVALUATION

The NRCs regulatory requirements related to Quality Assurance (QA) programs are set forth in 10 CFR Part 50, Appendix B; 10 CFR 50.34(b)(6)(ii), and 10 CFR 50.54(a). In addition, the NRCs regulatory requirements related to QA programs for independent storage of spent nuclear fuel are addressed in 10 CFR Part 72, Subpart G and 10 CFR Part 71, Subpart H.

Appendix B to 10 CFR Part 50 establishes the QA requirements for the design, fabrication, construction, and testing of structures, systems, and components (SSCs) for the Callaway facility. The pertinent quality assurance requirements of Appendix B apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying SSCs.

Enclosure

The regulations in 10 CFR 50.34, Contents of applications; technical information, require that every applicant for an operating license include information in its Final Safety Analysis Report on the managerial and administrative controls to be used to ensure safe operation.

The information on the controls shall also include a discussion on how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

The regulations in 10 CFR 50.54, Conditions of licenses, require each power plant subject to the requirements of Appendix B to implement a QA program and 10 CFR 50.54(a)(4) requires licensees to submit to the NRC changes to their QA program that reduce commitments.

The regulations in 10 CFR Part 72, Subpart G, establish the quality assurance requirements that apply to design, purchasing, fabricating, handling, shipping, storing, cleaning, assembling, inspecting, testing, operating, maintenance, repairing, modifying, and decommissioning that are important to safety.

The regulations in 10 CFR Part 71, Subpart H, establish the quality assurance requirements applying to designing, purchasing, fabricating, handling, shipping, storing, cleaning, assembling, inspecting, testing, operating, maintenance, repairing, and modifying and packaging that are important to safety.

3.0 TECHNICAL EVALUATION

In evaluating the adequacy of the changes to the OQAM, the NRC staff used the guidance in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit, and New License Applicants dated August 2015 (ADAMS Accession No. ML15037A441), which provides acceptance criteria for QA program descriptions. The staff guidance provided in NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, dated March 2000 (ADAMS Accession No. ML003686776).

The changes proposed in the OQAMs Interim Revision 34a revises the wording of Section 16.3 to modify the definition of Significant Conditions Adverse to Quality (SCAQ) and remove the related examples.

The current version of the OQAM states the following in Section 16.3:

A significant condition adverse to quality is a condition adverse to quality that, if uncorrected, could have a serious effect on safety or operability.

Conditions adverse to quality which impede the implementation or reduce the effectiveness of the Operating QA Program shall be considered significant conditions adverse to quality. Significant conditions adverse to quality may include, but are not limited to, noncompliance with procedural requirements which impact nuclear or personnel safety; reportable events, including reportable violations of the Technical Specifications; adverse nonconformance trends; deficiencies identified in the OQAP; recurring conditions for which past corrective action has been ineffective; managerial controls which could result in the failure of a plant system to perform its intended function: National Pollutant Discharge Elimination System (NPDES) violations; accidental, unplanned or uncontrolled radioactive releases; operating abnormalities, deviations from expected

performance of plant equipment and of unanticipated deficiencies in the design or operation of structures, systems, or components which affect nuclear safety; and other conditions found to present potential hazards to nuclear safety.

The change proposes to modify Section 16.3 to state the following:

A significant condition adverse to quality is a condition adverse to quality that, if uncorrected, could have a serious effect on safety or operability.

Conditions adverse to quality which impede the implementation or reduce the effectiveness of the Operating QA Program shall be considered significant conditions adverse to quality.

The NRC staff reviewed the proposed changes to verify that the requirements of Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50 continue to be met.

The Callaway OQAM Section 16.1 continues to require that measures are established to assure conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined, and corrective action is taken to preclude repetition. In addition, the OQAM requires that measures for the identification of significant conditions adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.

4.0 CONCLUSION

The NRC staff used the acceptance criteria in NUREG-0800, Section 17.5 as the basis for evaluating the acceptability of the changes to the Callaway OQAM, in conformance with the applicable portions of 10 CFR Part 50, Appendix B. The NRC staff concludes that the proposed changes to the Callaway OQAM in interim Revision 34a follow the NRC staffs guidance contained within and conforms to the format of NUREG-0800, Section 17.5. Based on the above, the NRC staff concludes that the proposed changes continues to meet the applicable requirements of Appendix B to 10 CFR Part 50 and are, therefore, acceptable.

Principal Contributor: A. Keim, NRR Date: June 8, 2020

ML20141L745 *by memo dated **by email OFFICE NRR/DORL/LPL4/PM** NRR/DORL/LPL4/LA** NRR/DRO/IQVIB* NRR/DORL/LPL4/BC** NRR/DORL/LPL4/PM**

NAME JKlos PBlechman KKavanagh JDixon-Herrity MChawla DATE 05/20/2020 05/21/2020 04/30/2020 06/08/2020 06/08/2020