ML20237C861
| ML20237C861 | |
| Person / Time | |
|---|---|
| Site: | Callaway |
| Issue date: | 12/15/1987 |
| From: | UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20237C844 | List: |
| References | |
| NUDOCS 8712220230 | |
| Download: ML20237C861 (10) | |
Text
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ULNRC-1693 PROPOSED TECHNICAL SPECIFICATION CHANGES Page 6-3 (Figure 6.2-1)
Page 6-4 (Figure 6.2-2)
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CALLAWAY - UNIT 1
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l ADMINISTRATIVE CONTROLS 6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Superintendent of Training and shall meet or exceed the requirements and recommendations of Section 5 of ANSI /
l ANS 3.1-1978 and Appendix A of 10 CFR Part 55 and the supplemental requirements j
specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter r
to all licensees, and shall include familiarization with relevant industry l
operational experience identified by the ISEG.
6.5 REVIEW AND AUDIT 6.5.1 ON-SITE REVIEW COMMITTEE (ORC)
FUNCTION 6.5.1.1 The ORC shall function to advise the Manager, Callaway Plant on all matters related to nuclear safety.
COMPOSITION
- 6. 5.1. 2 The ORC shall be composed of the:
Chairman:
Manager, Callaway Plant I
Member:
Asst Mgr, Oper and Maintenance Member:
Asst Mgr, Te:h Services Member:
Manager, Operations Support
];
Member:
Supt, Health Physics Member:
Supt, Operations Support, QA Member:
Avs4 Mgr, Nuclear Engineering
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4.wt M p, M A LnmA ALTERNATES 6.5.1.3 All alternate memoers shall be appointed in writing by the ORC Chairman to serve on a temporary basis.**
MEETING FREQUENCY 6.5.1.4 The ORC shall meet at least once per calendar month and as convened by the ORC Chairman or his designated alternate.
OUORUM 6.5.1.5 The quorum of the CRC necessary for the performance of the ORC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and four members of which no more than two shall be alternates.
- Except for the alternate for the Suot, Operations Support, QA, who is appointed by the Manager, Quality Assurance.
CALLAWAY - UNIT 1 6-7
_Amendr:nt 2!c. 16-i
______-_____n
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ULNRC-1693 SAFETY EVALUATION
)
This application requests that Callaway Technical Specification Figures 6.2-1, 6.2-2 and Specification 6.5.1 be revised to reflect organization changes which are designed to l
improve interdepartmental coordination and efficiency.
The changes are described below:
3 Figure 6.2-1 is revised to:
)
(1)
Consolidate the Licensing and Fuels Department under the newly created position, Manager, Licensing and Fuels.
This consolidated department reports directly to the General Manager, Engineering.
(2)
The Manager, Nuclear Engineering position is now located at the Callaway Site.
(3)
The Assistant Manager, Nuclear Engineering posi' ion is eliminated and the Superintendent, Design Control and the Superintendent, Systems Engineering report directly to the Manager Nuclear Engineering.
(4)
A new position, Superintendent, Project Engineering, is established which will report directly to the Manager, Nuclear Engineering.
(5)
Quality control (OC) inspectors, responsible for Non-Destructive Examination (NDE) and In-Service i
Inspection (ISI), will report through the Supervisor, Performance and ISI to the Superintendent, Systems Engineering.
(6)
The Superintendent, Administration Services will no longer report to the Assistant to the Vice President, but will report to the Manager, Operations Support.
This change is also shown on revised Figure 6.2-2.
These changes are designed to improve interdepartmental responsiveness and efficiency by providing better coordination of the engineering staff and enhancing the engineering support of Callaway Plant.
These changes do not reduce the overall experience base nor reduce commitments to minimum qualifications.
]
Figure 6.2-2 is revised to:
(1)
Establish the position of Assistant Manager, Work Control, which reports to the Manager, Callaway Plant.
Reporting to the Assistant Manager, Work Control is the Superintendent, Planning and Scheduling, the Supervisor, Quality Control (QC), and the Supervisor, f
Page 1 of 3
p ULNRC-1693 Outages.
Consolidation of Planning and Scheduling with l
the Outages Department provides for enhanced coordination of plant testing and modification activities.
The QC Department is being reassigned from the Compliance Department which is addressed below.
(2)
Consolidate the Chemistry and Radwaste organization under the Superintendent, Chemistry and Radwaste, which i
will continue to report to the Assistant Manager, Technical Services.
(3) _ Establish the position of Supervisor, Safety, which reports to the Assistant Manager, Technical Services.
This group addresses occupational safety and health issues, which were previously a responsibility of the Compliance Department.
(4)
The Assistant Manager, Support Services position is eliminated and the Superintendent, Training and the Superintendent, Security report directly to the Manager, Operations Support.
(S)
As previously discussed in relationship to Figure 6.2-1, the Superintendent, Administration Services reports to the Manager, Operations Support rather than the Assistant to the Vice President.
(6)
The Compliance Department is eliminated, and its responsibilities are re-assigned as follows:
(a)
The Compliance Group reports to the Manager, Licensing and Fuels as a Site Licensing Group.
(b)
The Quality Control group, responsible for plant modification / maintenance work, reports to the Assistant Manager, Work Control.
(c)
The Quality Control personnel, responsible for NDE/ISI, report to Nuclear Engineering as discussed in relationship to Figure 6.2-1.
(d)
Surveillance Tracking is performed within Nuclear Operations.
(e)
Fire Protection reports to Nuclear Engineering.
(f)
Personnel Safety reports to the Assistant Manager, Technical Services as previously discussed.
These changes are designed to improve interdepartmental responsiveness and efficiency by providing better coordination and communication.
These changes do not reduce the overall experience base nor reduce commitments to minimum qualifications.
Page 2 of 3
ULNRC-1693 Specification 6.5.1 is revised to include the Manager, Nuclear Engineering and the newly created position, Assistant Manager, Work Control, as members of the On-Site Review Committee.
The addition of the Manager, Nuclear Engineering provides a higher level of management attention and engineering perspective to the On-Site Review Committee.
The Assistant Manager, Work Control is responsible for planning and scheduling of outages, surveillance testing, and plant modifications and therefore provides a valuable role in reviews conducted by the On-Site Review Committee.
This proposed Technical Specification change, which reflects the revised organization, provides enhancements in the effectiveness and capabilities of the Nuclear Function management for the operation of Callaway Plant and does not adversely affect or endanger the health or safety of the general public nor involve an unreviewed safety question.
I Page 3 of 3
ULNRC-1693 SIGNIFICANT HAZARDS CONSIDERATION i
This amendment request revises Callaway Technical Specification Figure 6.2-1, Figure 6.2-2 and Section 6.5.1 to l
reflect Nuclear Function organizational changes associated with I
the establishment of the positions of Manager, Licensing and Fuels, and Assistant Manager, Work Control and the elimination of the Assistant Manager, Support Services position and the i
resulting changes in the operating organization, engineering-organization, and On-Site Review Committee.
The details of the new organization are presented in the Safety Evaluation to this amendment request.
The results of the Safety Evaluation conclude that while personnel assignments are revised and reporting relationships are changed, the commitments to minimum qualifications and basic organizational reporting requirements are unchanged.
These changes are administrative in nature and provide additional management strength and definition over that l
presently included in the Technical Specifications.
1)
The proposed amendment does not involve a significant increase in the probability or consequences of an accident perviously evaluated.
This is based on the fact that the organization changes improve the interdepartmental responsiveness and efficiency by providing better coordination and communication.
The changes do not reduce the overall experience base nor reduce commitments to minimum qualifications.
2)
The proposed amendment does not create the possibility of a new or different kind of accident than previously evaluated because the proposed change is administrative in nature, and no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.
3)
The proposed amendment does not involve significant reduction in a margin of safety.
Through Union Electric's strong Quality Assurance programs and its commitment to maintain only qualified personnel in positions of responsibility, it is assured that safety functions performed by the On-site and the Corporate organizations will continue to be performed at a high level of competence.
In addition, the Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (48 FR 14870).
One of the examples of actions involving no significant hazards consideration relates to a purely administrative change to Technical Specifications.
Another example involving no significant hazards consideration is a change which constitutes an additional limitation, restriction Page 1 of 2
l ULNRC-1693 i
or control not presently included in the Technical Specifications.
These proposed changes are administrative in nature and introduce additional management controls not presently in the Technical Specifications and, therefore, involve no significant hazards.
These requests do not involve a significant increase in the probability or consequence of an accident or other adverse condition over previous evaluations; or create the possibility of a new or different kind of accident or condition ever previous evaluations; or involve a significant reduction in a margin of safety.
Based on this information, the requested license amendment does not present a significant hazard, i
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l Page 2 of 2
i ULNRC-1693
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.l Application Fee UNION ELECTRIC COMPANY Sr. Lours,Missoual 232478 sis 10 cesreaae sAux or xenserr. uissouar 2313 i
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