ML22327A208

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Attachment 1 - Description and Justification for Changes to the Oqam
ML22327A208
Person / Time
Site: Callaway  Ameren icon.png
Issue date: 11/16/2022
From:
Ameren Missouri, Union Electric Co
To:
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML22327A206 List:
References
ULNRC-06777
Download: ML22327A208 (1)
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Text

Attachment 1 to ULNRC-06777 Page 1 of 43 DESCRIPTION AND JUSTIFICATION FOR CHANGES TO THE OQAM This attachment provides a summarization of the changes made to the Operating Quality Assurance Manual (OQAM) for the Callaway Energy Center (CEC) (and the onsite independent spent fuel storage facility). Each OQAM Change Notice (OQAMCN) is separately described, and a basis and justification for the change(s) made per each OQAMCN is provided. These changes are depicted in, OQAM Interim Revision 35a mark-up, identifying changes through the use of strikeovers and inserts.

OQAMCNs21-002, 21-003,22-002, and 22-003 were previously reviewed internally and determined to not constitute a reduction in commitment. The OQAM continues to describe a quality assurance program that complies with the requirements of 10 CFR 50 Appendix B.

to ULNRC-06777 Page 2 of 43 Summary of OQAMCN 21-002 This change revised the title of Director, Nuclear Oversight to Manager, Nuclear Oversight.

The duties, responsibilities, and qualifications of the position remain the same. The reporting chain of command remains the same.

Note: In the tables that follow, the deleted text is depicted in red strikethrough text and inserted text is depicted in blue underlined text.

to ULNRC-06777 Page 3 of 43 Change Descriptions for OQAMCN 21-002 OQAM section Current description Revised Description Justification 1.3 The Director, Nuclear Oversight (NOS)5 reports to the Senior Vice President and Chief Nuclear Officer (CNO) on Quality Assurance Program and administrative matters. The Director, Nuclear Oversight has direct access to the Senior Vice President and CNO on significant Nuclear Oversight matters. The Director, Nuclear Oversight is responsible to the Senior Vice President and Chief Nuclear Officer for assuring the OQAP is being effectively implemented for operating activities; directing the overall Quality Assurance Program for Ameren Missouri including Program development, maintenance, and verification of implementation; and providing a constant independent overview of nuclear plant safety. The Director, Nuclear Oversight has sufficient authority, organizational freedom, and independence to effectively assure compliance with OQAP requirements as they control CEC and offsite quality activities; and shall bear no cost, schedule, or production responsibilities which unduly influence attention to quality matters. A communication path shall exist between the Director, Nuclear Oversight, Supervisors, NOS, and the Senior Vice President and Chief Nuclear Officer, as well as the other Nuclear Generation management, thus providing a direct path to inform management regarding conditions affecting quality and nuclear plant safety. The qualifications of the Director, Nuclear Oversight are at least The Director Manager, Nuclear Oversight (NOS)5 reports to the Senior Vice President and Chief Nuclear Officer (CNO) on Quality Assurance Program and administrative matters. The Director Manager, Nuclear Oversight has direct access to the Senior Vice President and CNO on significant Nuclear Oversight matters. The Director Manager, Nuclear Oversight is responsible to the Senior Vice President and Chief Nuclear Officer for assuring the OQAP is being effectively implemented for operating activities; directing the overall Quality Assurance Program for Ameren Missouri including Program development, maintenance, and verification of implementation; and providing a constant independent overview of nuclear plant safety. The Director Manager, Nuclear Oversight has sufficient authority, organizational freedom, and independence to effectively assure compliance with OQAP requirements as they control CEC and offsite Changing the title "Director, Nuclear Oversight" to "Manager, Nuclear Oversight." The

duties, responsibilities, and qualifications of the position remain the same. The title change from Director, Nuclear Oversight to Manager, Nuclear Oversight reflects a Callaway Energy Center organizational change. The reporting chain of command remains the same.

to ULNRC-06777 Page 4 of 43 equivalent to those specified in ANSI/ANS-3.1-1978, "Selection, Qualification, and Training of Nuclear Power Plant Personnel," Sections 4.2.4 and 4.4.5.

The Director, Nuclear Oversight is located at CEC and provides technical direction and administrative guidance, to the Nuclear Oversight staff.

quality activities; and shall bear no cost, schedule, or production responsibilities which unduly influence attention to quality matters.

A communication path shall exist between the Director Manager, Nuclear Oversight, Supervisors, NOS, and the Senior Vice President and Chief Nuclear Officer, as well as the other Nuclear Generation management, thus providing a direct path to inform management regarding conditions affecting quality and nuclear plant safety. The qualifications of the Director Manager, Nuclear Oversight are at least equivalent to those specified in ANSI/ANS-3.1-1978, "Selection, Qualification, and Training of Nuclear Power Plant Personnel,"

Sections 4.2.4 and 4.4.5. The Director Manager, Nuclear Oversight is located at CEC and provides technical direction and administrative guidance, to the Nuclear Oversight staff.

1.3.1 The Director, NOS directs Supervisors NOS, and Supervisor QC, who have primary duties for assuring implementation of the OQAP and who devote full attention to this effort. They provide for maintenance The Director Manager, NOS directs Supervisors NOS, and Supervisor QC, who have primary duties for assuring implementation of the OQAP and to ULNRC-06777 Page 5 of 43 of the Operating Quality Assurance Manual (OQAM); for audit, surveillance, and evaluation of nuclear supplier quality activities; and for performing those procurement document reviews assigned to their personnel. The activities of the NOS staff assure implementation of the OQAP. The Director, Nuclear Oversight is responsible to evaluate CEC operations from a safety perspective.

who devote full attention to this effort. They provide for maintenance of the Operating Quality Assurance Manual (OQAM); for audit, surveillance, and evaluation of nuclear supplier quality activities; and for performing those procurement document reviews assigned to their personnel. The activities of the NOS staff assure implementation of the OQAP. The Director Manager, Nuclear Oversight is responsible to evaluate CEC operations from a safety perspective.

1.3.2 The Quality Control Group reports to the Director, NOS. They are responsible for work activities, inspections, receipt inspections as described in Section 7.0 and non-destructive examinations.

The Quality Control Group reports to the Director Manager, NOS. They are responsible for work activities, inspections, receipt inspections as described in Section 7.0 and non-destructive examinations.

1.3.3 The Director, Supervisor QC and Supervisors in the Nuclear Oversight Department are authorized by the Senior Vice President and Chief Nuclear Officer to stop work on ongoing quality activities in accordance with approved procedures. During the operating phase they have the authority to stop unsatisfactory work during repair, maintenance, and refueling activities and the authority to recommend to the Senior The Director Manager, Supervisor QC and Supervisors in the Nuclear Oversight Department are authorized by the Senior Vice President and Chief Nuclear Officer to stop work on ongoing quality activities in accordance with approved procedures.

During the operating phase they have to ULNRC-06777 Page 6 of 43 Director, Nuclear Operations stop work affecting the continuation of Plant operation. Other stop work authority shall be delineated in procedures. The continuance of an activity which would cover up a deficiency and preclude identification and correction, or increase the extent of the deficiency is subject to stop work action by the Nuclear Oversight Department. The Director, Nuclear Oversight has no duties or responsibilities unrelated to NOS that would prevent full attention to NOS matters.

the authority to stop unsatisfactory work during repair, maintenance, and refueling activities and the authority to recommend to the Senior Director, Nuclear Operations stop work affecting the continuation of Plant operation. Other stop work authority shall be delineated in procedures. The continuance of an activity which would cover up a deficiency and preclude identification and correction, or increase the extent of the deficiency is subject to stop work action by the Nuclear Oversight Department. The Director Manager, Nuclear Oversight has no duties or responsibilities unrelated to NOS that would prevent full attention to NOS matters.

2.4 The pertinent requirements of the OQAP apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The safety-related structures, systems and components identified in Table 3.2-1 of the Callaway-SP Final Safety Analysis Report (FSAR). This list includes structures, systems, and components identified during the design and construction phase and may The pertinent requirements of the OQAP apply to all activities affecting the safety-related functions of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The safety-related structures, systems and components to ULNRC-06777 Page 7 of 43 be modified as required during operations consistent with their importance to safety.

Modifications to this list require the approval of the Director, Nuclear Oversight and the Director, Engineering Design & Projects and shall be issued and controlled in accordance with Section 6. The development, control, and use of computer programs to be used in safety-related activities are within the scope of the OQAP. The degree of controls applicable to each computer program shall be consistent with the program's importance to safety-related activities. Consumables which could affect the form, fit or function of safety-related structures, systems, and components, although not listed in Table 3.2-1 of the Callaway-SP FSAR, are also under the control of the OQAP.

identified in Table 3.2-1 of the Callaway-SP Final Safety Analysis Report (FSAR). This list includes structures, systems, and components identified during the design and construction phase and may be modified as required during operations consistent with their importance to safety.

Modifications to this list require the approval of the Director Manager, Nuclear Oversight and the Director, Engineering Design & Projects and shall be issued and controlled in accordance with Section 6. The development, control, and use of computer programs to be used in safety-related activities are within the scope of the OQAP. The degree of controls applicable to each computer program shall be consistent with the program's importance to safety-related activities. Consumables which could affect the form, fit or function of safety-related structures, systems, and components, although not listed in Table 3.2-1 of the Callaway-SP FSAR, are also under the control of the OQAP.

to ULNRC-06777 Page 8 of 43 2.6

2) Operating Quality Assurance Manual (OQAM)

The OQAM contains a delineation of the Policy statement, quality assurance requirements, assignment of responsibilities, and a definition of organizational interfaces. The OQAM is the written description of the OQAP. Approval of the OQAM is by the Senior Vice President and Chief Nuclear Officer and the Director, Nuclear Oversight.

2) Operating Quality Assurance Manual (OQAM)

The OQAM contains a delineation of the Policy statement, quality assurance requirements, assignment of responsibilities, and a definition of organizational interfaces. The OQAM is the written description of the OQAP. Approval of the OQAM is by the Senior Vice President and Chief Nuclear Officer and the Director Manager, Nuclear Oversight.

2.11 An audit system shall be established to assure management is advised of Program effectiveness.

The implementation and effectiveness of the OQAP shall be assessed through an audit program of quality activities which includes design, procurement, modification, and operation.

The Director, Nuclear Oversight is responsible for a system of planned audits to assure OQAP An audit system shall be established to assure management is advised of Program effectiveness. The implementation and effectiveness of the OQAP shall be assessed through an audit program of quality activities which includes to ULNRC-06777 Page 9 of 43 compliance, with a frequency commensurate with the Program aspect's safety significance and in accordance with the requirements of Section 18.

This individual is responsible for conducting audits of offsite and onsite activities.

Deficiencies identified during the audit process are reported to responsible management of the organization involved in the resolution and follow-up to assure corrective action.

design, procurement, modification, and operation. The Director Manager, Nuclear Oversight is responsible for a system of planned audits to assure OQAP compliance, with a frequency commensurate with the Program aspect's safety significance and in accordance with the requirements of Section 18. This individual is responsible for conducting audits of offsite and onsite activities.

Deficiencies identified during the audit process are reported to responsible management of the organization involved in the resolution and follow-up to assure corrective action.

5.3.1 Procedures required by OQAM Sections 5.2.1 and 5.2.2, Technical Specification 5.4.1 and 5.5, and other procedures which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved. Each such procedure or procedure change shall 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 Procedures required by OQAM Sections 5.2.1 and 5.2.2, Technical Specification 5.4.1 and 5.5, and other procedures which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved.

Each such procedure or procedure change shall be reviewed by a qualified individual/group other to ULNRC-06777 Page 10 of 43 prepared the procedure or procedure change.

With the exception of Nuclear Oversight procedures, procedures shall be approved by the appropriate Department Head as designated in writing by the Senior Director, Nuclear Operations. The Director, Nuclear Oversight shall approve Nuclear Oversight procedures. The Senior Director, Nuclear Operations shall approve the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL.

The Senior Director, Nuclear Operations shall approve other Administrative Procedures and Radiological Emergency Response Plan implementing procedures. The Security Manager or designee shall approve the Security Plan implementing procedures. Temporary changes to procedures which 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; 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. With the exception of Nuclear Oversight procedures, procedures shall be approved by the appropriate Department Head as designated in writing by the Senior Director, Nuclear Operations. The Director Manager, Nuclear Oversight shall approve Nuclear Oversight procedures. The Senior Director, Nuclear Operations shall approve the PROCESS CONTROL PROGRAM and the OFFSITE DOSE CALCULATION MANUAL. The Senior Director, Nuclear Operations shall approve other Administrative Procedures and Radiological Emergency Response Plan implementing procedures. The Security Manager or designee shall approve the Security Plan implementing procedures.

Temporary changes to procedures which do not change the intent of the approved procedures shall be to ULNRC-06777 Page 11 of 43 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; 18.3 The Director, Nuclear Oversight shall establish a program which provides for the qualification and training of NOS Department audit and surveillance personnel. Audits shall be directed by an Audit Team Leader (ATL) who is a certified Lead Auditor. A Lead Auditor is an individual certified as qualified to direct an audit, perform an audit, report audit findings, and to evaluate corrective action. Other personnel may assist Lead Auditors in the conduct of audits; namely, technical specialists, management representatives, auditors and other Lead Auditors.

The persons having direct responsibility for performance of the activities being audited shall not be involved in the selection of the audit team.

Personnel selected for NOS auditing or surveillance assignments shall have training or The Director Manager, Nuclear Oversight shall establish a program which provides for the qualification and training of NOS Department audit and surveillance personnel. Audits shall be directed by an Audit Team Leader (ATL) who is a certified Lead Auditor. A Lead Auditor is an individual certified as qualified to direct an audit, perform an audit, report audit findings, and to evaluate corrective action. Other personnel may assist Lead Auditors in the conduct of audits; namely, technical specialists, management representatives, to ULNRC-06777 Page 12 of 43 experience commensurate with the scope, complexity, or special nature of the activities to be reviewed or investigated and shall have no direct responsibility for the area being evaluated.

The NOS personnel training program shall provide general orientation and specific training which develop competence for performing audits or surveillances. Training records shall provide a history of NOS personnel training, evaluations, qualification, certifications, and retraining.

auditors and other Lead Auditors.

The persons having direct responsibility for performance of the activities being audited shall not be involved in the selection of the audit team. Personnel selected for NOS auditing or surveillance assignments shall have training or experience commensurate with the scope, complexity, or special nature of the activities to be reviewed or investigated and shall have no direct responsibility for the area being evaluated. The NOS personnel training program shall provide general orientation and specific training which develop competence for performing audits or surveillances. Training records shall provide a history of NOS personnel training, evaluations, qualification, certifications, and retraining.

18.4 NOS Department personnel who perform audit and surveillance activities shall be qualified in accordance with the requirements prescribed in NOS Department procedures. Lead Auditor qualification requirements shall include education or professional status, previous work experience or training, training received through Ameren NOS Department personnel who perform audit and surveillance activities shall be qualified in accordance with the requirements prescribed in NOS Department procedures. Lead Auditor qualification requirements shall to ULNRC-06777 Page 13 of 43 Missouri, on-the-job performance and participation in surveillances or audits as an auditor, a qualification examination, and other factors applicable to auditing not defined by procedure. The qualification certification of Lead Auditors shall be based on an evaluation of these factors by the Director, Nuclear Oversight. The maintenance of proficiency by Lead Auditors shall be accomplished by active participation in the audit process; a review of program, codes, standards, procedures and other document revisions related to the OQAP; or participation in training programs. The Director, Nuclear Oversight shall provide for annual assessments of each Lead Auditor to determine proficiency. As long as a Lead Auditor is performing satisfactorily and is maintaining proficiency, there is no limit on the period of certification.

However if at any time the Lead Auditor's performance is evaluated as being unacceptable, lead Auditor certification shall be rescinded. In addition the failure to maintain proficiency for a period of two years or more shall be basis for Lead Auditor certification revocation. If certification is rescinded or revoked, requalification shall be required prior to recertification.

include education or professional status, previous work experience or training, training received through Ameren Missouri, on-the-job performance and participation in surveillances or audits as an auditor, a qualification examination, and other factors applicable to auditing not defined by procedure. The qualification certification of Lead Auditors shall be based on an evaluation of these factors by the Director Manager, Nuclear Oversight. The maintenance of proficiency by Lead Auditors shall be accomplished by active participation in the audit process; a review of program, codes, standards, procedures and other document revisions related to the OQAP; or participation in training programs. The Director Manager, Nuclear Oversight shall provide for annual assessments of each Lead Auditor to determine proficiency. As long as a Lead Auditor is performing satisfactorily and is maintaining proficiency, there is no limit on the period of certification.

to ULNRC-06777 Page 14 of 43 However if at any time the Lead Auditor's performance is evaluated as being unacceptable, lead Auditor certification shall be rescinded. In addition the failure to maintain proficiency for a period of two years or more shall be basis for Lead Auditor certification revocation. If certification is rescinded or revoked, requalification shall be required prior to recertification.

18.5 The Director, Nuclear Oversight shall be responsible for assuring the implementation of a comprehensive system of planned audits to verify compliance with the OQAP. The Director, Nuclear Oversight has sufficient authority and organizational freedom to schedule and perform both internal and external audits. This individual has the organizational responsibility to measure and assure the overall effectiveness of the OQAP and is independent of the economic pressures of production when opposed to safety or quality.

The Director, Nuclear Oversight has direct access to the Senior Vice President and Chief Nuclear Officer.

The Director Manager, Nuclear Oversight shall be responsible for assuring the implementation of a comprehensive system of planned audits to verify compliance with the OQAP. The Director Manager, Nuclear Oversight has sufficient authority and organizational freedom to schedule and perform both internal and external audits. This individual has the organizational responsibility to measure and assure the overall effectiveness of the OQAP and is independent of the economic pressures of production when opposed to safety or quality. The Director Manager, Nuclear Oversight has to ULNRC-06777 Page 15 of 43 direct access to the Senior Vice President and Chief Nuclear Officer.

18.6 The audit system shall include internal and external audits. The system shall be planned, documented, and conducted to assure coverage of the applicable elements of the OQAP, and overall coordination and scheduling of audit activities.

Audit results shall be periodically reviewed by the NOS Department for quality trends and results reported to the appropriate management.

The Director, Nuclear Oversight shall monitor the OQAP audit program to assure audits are being accomplished in accordance with the requirements described herein and for overall Program effectiveness. The Director, Nuclear Oversight shall ensure an independent review of the onsite audit program is conducted periodically, to assure that audits are being performed in accordance with the OQAP.

Appropriate levels of management shall be provided copies of internal and external audit reports.

The audit system shall include internal and external audits. The system shall be planned, documented, and conducted to assure coverage of the applicable elements of the OQAP, and overall coordination and scheduling of audit activities.

Audit results shall be periodically reviewed by the NOS Department for quality trends and results reported to the appropriate management. The Director Manager, Nuclear Oversight shall monitor the OQAP audit program to assure audits are being accomplished in accordance with the requirements described herein and for overall Program effectiveness. The Director Manager, Nuclear Oversight shall ensure an independent review of the onsite audit program is conducted periodically, to assure that audits are being performed in accordance with the OQAP.

Appropriate levels of management shall be provided to ULNRC-06777 Page 16 of 43 copies of internal and external audit reports.

Appendix A Regulatory Guide 1.146 Initial Issue Dated 8/80 Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Endorses ANSI N45.2.23-1978)

DISCUSSION:

With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Organizational Responsibility: Ameren Missouri shall comply with this Section with the substitution of the following sentence in place of the last sentence in the Section:

The Director, Nuclear Oversight; Supervisor, NOS; or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited.

With respect to Section 5.3 of ANSI N45.2.23 - 1978 titled Updating of Lead Auditor's Records: Ameren Missouri shall substitute the following sentence for this Section:

Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified).

Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (Endorses ANSI N45.2.23-1978)

DISCUSSION:

With respect to Section 4.1 of ANSI N45.2.23 - 1978 titled Organizational Responsibility: Ameren Missouri shall comply with this Section with the substitution of the following sentence in place of the last sentence in the Section:

The Director Manager, Nuclear Oversight; Supervisor, NOS; or Lead Auditor shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited.

With respect to Section 5.3 of ANSI N45.2.23 - 1978 titled Updating of Lead Auditor's Records: Ameren Missouri shall substitute the following sentence for this Section:

to ULNRC-06777 Page 17 of 43 End of Table of Change Descriptions for OQAMCN 21-002 With respect to Section 5.4 of ANSI N45.2.23 - 1978 titled Records Retention: Ameren Missouri shall substitute the following sentence for this Section:

Qualification records shall be generated and maintained as required by OQAM Section 17 and by commitment to Regulatory Guide 1.88 (ANSI N45.2.9) as clarified in this Appendix.

In every case either identical or equivalent controls are provided in the sections of the referenced Standards and documents.

Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Section 3.2 (as clarified).

With respect to Section 5.4 of ANSI N45.2.23 - 1978 titled Records Retention: Ameren Missouri shall substitute the following sentence for this Section:

Qualification records shall be generated and maintained as required by OQAM Section 17 and by commitment to Regulatory Guide 1.88 (ANSI N45.2.9) as clarified in this Appendix.

In every case either identical or equivalent controls are provided in the sections of the referenced Standards and documents.

Appendix B 1.3 The Director, Nuclear Oversight, has the responsibility for verifying, by procedures such as checking, auditing, and inspection, that activities affecting the functions that are important to safety have been correctly performed.

The Director Manager, Nuclear Oversight, has the responsibility for verifying, by procedures such as checking, auditing, and inspection, that activities affecting the functions that are important to safety have been correctly performed.

to ULNRC-06777 Page 18 of 43 Summary of OQAMCN 21-003 This OQAMCN changed commitment from Regulatory Guide 1.8, Revision 2, dated April, 1987 to Regulatory Guide 1.8, Revision 4, dated June 2019 only for Radiation Protection (RP) positions of First Line Supervisors, Technicians, and Supplemental Personnel.

to ULNRC-06777 Page 19 of 43 Change Descriptions for OQAMCN 21-003 OQAM section Current description Revised Description Justification 2.10.3 Appendix A Reg Guide 1.8 All other training programs shall meet or exceed the requirements and recommendations of Section 5 of ANSI/ANS 3.1-1978.

DISCUSSION:

Ameren Missouri complies with the recommendations of this Regulatory Guide with the following clarifications and exceptions:

Revision 1, dated 9/75, applies to the position of Radiation Protection Manager only. For the position of Radiation Protection Manager only, Regulatory Guide 1.8, Revision 1, September, 1975 is clarified by USNRC HPPOS-020, Clarification of All other training programs with the exception of the Radiation Protection program shall meet or exceed the requirements and recommendations of Section 5 of ANSI/ANS 3.1-1978.

Radiation Protection program shall meet the requirements of ANSI/ANS 3.1-2014 as endorsed by Regulatory Guide 1.8, Rev.4 with the exception of the Radiation Protection Manager which shall continue to meet the requirements of Regulatory Guide 1.8, Rev 1, September, 1975 as clarified by USNRC HPPOS-020.

DISCUSSION:

Ameren Missouri complies with the recommendations of this Regulatory Guide with the following clarifications and exceptions:

Revision 1, dated 9/75, applies to the position of Radiation Protection Manager only. For the position of Radiation Protection Manager only, Regulatory Guide 1.8, Revision 1, September, 1975 is clarified by USNRC HPPOS-020, Clarification of Regulatory Guide 1.8 on Qualification of For the Radiation Protection personnel positions of First Line Supervisor, Technician, and Supplemental Personnel Callaway Energy Center (CEC) is changing conformance from Regulatory Guide 1.8, Rev 2 to Regulatory Guide 1.8, Rev 4 issued June 2019 (which endorses ANSI/ANS 3.1 2014).

Regulatory Guide 1.8, Rev 4 was issued by the NRC as ADAMS Accession Number ML19101A395.

The Radiation Protection Manager will continue to meet the requirements of Regulatory Guide (RG) 1.8, Rev 1 dated September, 1975 as clarified by USNRC Health Physics Positions based on 10 CFR Part 20 (HPPOS-020). The qualifications for the Radiation Protection Manager of ANSI/ANS 3.1 2014 were compared to CEC's current commitment of Regulatory Guide 1.8 Rev 1 1975 as clarified by NRC HPPOS-020. For the Radiation Protection Manager position, ANSI/ANS 3.1 2014 and RG 1.8 Rev 1 1975 as clarified by to ULNRC-06777 Page 20 of 43 Regulatory Guide 1.8 on Qualification of Radiation Protection Manager.

The experience, training, and education requirements for the positions of Shift Manager, Operating Supervisor, and Reactor Operator, and personnel fulfilling the duties of Shift Technical Advisor shall meet or exceed the requirements and recommendations of ANSI/ANS 3.1-1981 as endorsed by the Regulatory Guide 1.8, Revision 2, with the same exceptions as contained in the current revision to the Operating Licensing Examiner Standards, NUREG-1021, ES-202.

For all other positions, qualification and training shall comply with ANSI/ANS 3.1-1978 as clarified below:

Refer to Callaway-SA FSAR Section 13.1 for a discussion of the qualifications of personnel responsible for plant operation and support.

Radiation Protection Manager. Regulatory Guide 1.8, Rev 4 issued June 2019, which endorses ANSI/ANS 3.1 2014, applies to equivalent positions within the Radiation Protection organization except for the Radiation Protection Manager.

The experience, training, and education requirements for the positions of Shift Manager, Operating Supervisor, and Reactor Operator, and personnel fulfilling the duties of Shift Technical Advisor shall meet or exceed the requirements and recommendations of ANSI/ANS 3.1-1981 as endorsed by the Regulatory Guide 1.8, Revision 2, with the same exceptions as contained in the current revision to the Operating Licensing Examiner Standards, NUREG-1021, ES-202.

For all other positions, qualification and training shall comply with ANSI/ANS 3.1-1978 as clarified below:

Refer to Callaway-SA FSAR Section 13.1 for a discussion of the qualifications of personnel responsible for plant operation and support.

NRC HPPOS-020 are compatible for qualification requirements.

RG 1.8 Rev 4 issued June 2019, Section D Implementation, Use by Applicants and Licensees, states that current licensees may continue to use guidance the NRC found acceptable for complying with the identified regulations as long as their current licensing basis remains unchanged.

In this case, CEC will continue to qualify the Radiation Protection Manager to the NRC acceptable guidance in Regulatory Guide 1.8 Rev 1 1975 as clarified by HPPOS-020.

RG 1.8 Rev 4 issued June 2019 further states that Licensees may use the information in Regulatory Guide 1.8 Rev 4 or applicable parts to resolve regulatory or inspection issues. In this case, CEC will conform to ANSI/ANS 3.1 2014 for the parts of Section 4.4.6 Radiation Protection First Line Supervisor Level and Section 4.5.3.2 Radiation Protection Technicians.

to ULNRC-06777 Page 21 of 43 Personnel responsible for directing or supervising the conduct of safety-related preoperational and startup tests and for review and approval of safety-related preoperational and startup test procedures or results met the qualifications of the Regulatory Guide, but were not required to be certified.

Ameren Missouri may use additional Ameren employees or contract personnel to augment the unit staff.

These groups include, but are not limited to, Ameren personnel from outside Nuclear Generation as well as supplemental Radiation Protection and I&C technicians and QC inspectors. When used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-1978 for equivalent positions or specified education and experience requirements for non-equivalent positions. As an alternative, these personnel can be qualified for assigned tasks either by Ameren Missouri through its systematic approach to training or by Personnel responsible for directing or supervising the conduct of safety-related preoperational and startup tests and for review and approval of safety-related preoperational and startup test procedures or results met the qualifications of the Regulatory Guide, but were not required to be certified.

Ameren Missouri may use additional Ameren employees or contract personnel to augment the unit staff. These groups include, but are not limited to, Ameren personnel from outside Nuclear Generation as well as supplemental Radiation Protection and I&C technicians and QC inspectors.

Except for Radiation Protection, when used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-1978 for equivalent positions or specified education and experience requirements for non-equivalent positions. When supplemental contract Radiation Protection personnel are used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-2014 for equivalent positions or specified education and experience to ULNRC-06777 Page 22 of 43 Vendors with Ameren Missouri approved training and qualification programs. Inspection, examination and testing personnel shall meet the requirements for certification as inspection, examination or testing personnel as set forth in Ameren Missouri s commitment to ANSI N45.2.6-1978 given elsewhere in this Appendix.

With regard to Section 5.6 of ANSI/ANS 3.1 - 1978 titled Documentation: Ameren Missouri shall maintain records in accordance with and to meet the requirements of OQAM Section 17 and ANSI N45.2.9 as specified herein.

requirements for non-equivalent positions.

As an alternative, these personnel can be qualified for assigned tasks either by Ameren Missouri through its systematic approach to training or by Vendors with Ameren Missouri approved training and qualification programs. Inspection, examination and testing personnel shall meet the requirements for certification as inspection, examination or testing personnel as set forth in Ameren Missouri s commitment to ANSI N45.2.6-1978 given elsewhere in this Appendix.

With regard to Section 5.6 of ANSI/ANS 3.1 - 1978 titled Documentation: Ameren Missouri shall maintain records in accordance with and to meet the requirements of OQAM Section 17 and ANSI N45.2.9 as specified herein.

End of Table of Change Descriptions for OQAMCN 21-003 to ULNRC-06777 Page 23 of 43 Summary of OQAMCN 22-002 This OQAMCN changed the wording of the first sentence of OQAM 1.2.2 that describes the frequency of the review performed by the Senior Vice President and Chief Nuclear Officer for the independent review of matters involving safe operation of the plant from "at least once per twelve months" to "at least once each calendar year."

to ULNRC-06777 Page 24 of 43 Change Description for OQAMCN 22-002 OQAM section Current description Revised Description Justification OQAM 1.2.2 The Senior Vice President and Chief Nuclear Officer is responsible for ensuring an independent review of matters involving safe operation of the plant is conducted at least once per twelve months. The review addresses matters that management determines warrant special attention, such as plant programs, performance trends, employee concerns, or other matters related to safe plant operations. The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent (from cost and schedule considerations) from the organizations responsible for those activities. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence.

Results are documented and reported to the Senior Vice President and Chief Nuclear Officer.

The Senior Vice President and Chief Nuclear Officer is responsible for ensuring an independent review of matters involving safe operation of the plant is conducted at least once per twelve months each calendar year.

The review addresses matters that management determines warrant special attention, such as plant programs, performance trends, employee concerns, or other matters related to safe plant operations.

The review is performed by a team consisting of personnel with experience and competence in the activities being reviewed, but independent (from cost and schedule considerations) from the organizations responsible for those activities. The review is supplemented by outside consultants or organizations as necessary to ensure the team has the requisite expertise and competence.

Results are documented and reported to the Senior Vice President and Chief Nuclear Officer.

Clarifying the frequency of review by using approved wording in the NRC SER for NMC (

Reference:

ADAMS accession number ML050210276).

CEC adopted the change in 2017 under OQAMCN 17-002 but paraphrased the wording. This change, OQAM CN 22-002, is replacing the paraphrased wording with wording from the NRC SER for NMC.

End of Table of Change Descriptions for OQAMCN 22-002 to ULNRC-06777 Page 25 of 43 Summary of OQAMCN 22-003 Section 1.3.2 was revised to clarify existing text regarding QC inspection activities.

Section 1.7.1 was revised to make an editorial change to reflect the renaming of the Health Physics department to Radiation Protection.

Sections 4.9.1).a, 4.9.2).a, 4.9.3).a, 7.16.1).a, 7.16.2).a, 18.10.1.1.a, 18.10.1.2.a, and Appendix A Regulatory Guide 1.123 and Regulatory Guide 1.144 were revised to reflect an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017".

Sections 10.7, 10.8, 10.8.1, 11.11, 11.12, Appendix A Regulatory Guides 1.38, 1.74, and 1.123 were revised for clarification by adding the year "1978" after ANSI N45.2.6 to be consistent with OQAM section 7.18 and ANSI/ANS-3.1 to be consistent with OQAM section 2.10.3.

to ULNRC-06777 Page 26 of 43 Change Descriptions for OQAMCN 22-003 OQAM section Current description Revised Description Justification 1.3.2 The Quality Control Group reports to the Director, NOS. They are responsible for work activities, inspections, receipt inspections as described in Section 7.0 and non-destructive examinations.

The Quality Control Group reports to the Director, NOS. They are responsible for work activities such as preparation of inspection procedures and/or checklists to support maintenance and modification activities as described in Section 6, work activities, activity inspections as described in Section 10, receipt inspections as described in Section 7.0, and non-destructive examinations as directed by Engineering.

Clarification of Quality Control work activities.

1.7.1 ORC membership shall include a minimum of six additional members appointed by the Chairman. Selected members shall include, at a minimum, management responsible for the following areas of expertise and who collectively possess competence in Quality Assurance Practices:

a) Operations b) Maintenance c) Chemistry d) Radwaste e) Health Physics f) Nuclear Engineering ORC membership shall include a minimum of six additional members appointed by the Chairman. Selected members shall include, at a minimum, management responsible for the following areas of expertise and who collectively possess competence in Quality Assurance Practices:

a) Operations b) Maintenance c) Chemistry d) Radwaste e) Health Physics Radiation Protection f) Nuclear Engineering Editorial change to reflect that the name of the Health Physics department was changed to Radiation Protection.

to ULNRC-06777 Page 27 of 43 4.9 Commercial grade calibration and/or testing services may be procured from commercial laboratories based on the laboratory's accreditation to ISO/IEC-17025 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation Cooperation (ILAC)

Mutual Recognition Arrangement (MRA) provided all of the following are met:

1) A documented review of the supplier's accreditation is performed and includes a verification of the following:
a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

Commercial grade calibration and/or testing services may be procured from commercial laboratories based on the laboratory's accreditation to ISO/IEC-17025 by an Accreditation Body (AB) which is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) provided all of the following are met:

1) A documented review of the suppliers accreditation is performed and includes a verification of the following:
a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 28 of 43 4.9

2) The purchase documents require that:
a. The service must be provided in accordance with their accredited ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program and scope of accreditation.
2) The purchase documents require that:
a. The service must be provided in accordance with their accredited ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program and scope of accreditation.

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

4.9

3) It is validated, at receipt inspection, that the laboratory's documentation certifies that
a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and
b. The purchase order's requirements are met.
3) It is validated, at receipt inspection, that the laboratory's documentation certifies that
a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and
b. The purchase order's requirements are met.

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 29 of 43 7.16.1 When purchasing commercial grade calibration or testing services from a laboratory holding accreditation by an accrediting body recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA),

commercial grade surveys need not be performed provided all of the following conditions are met:

1) A documented review of the supplier's accreditation is performed and includes a verification of the following:
a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

When purchasing commercial grade calibration or testing services from a laboratory holding accreditation by an accrediting body recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA), commercial grade surveys need not be performed provided all of the following conditions are met:

1) A documented review of the supplier's accreditation is performed and includes a verification of the following:
a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 30 of 43 7.16.1

2) It is validated, at receipt inspection, that the laboratory's documentation certifies that:
a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and
b. The purchase order's requirements are met.
2) It is validated, at receipt inspection, that the laboratory's documentation certifies that:
a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and
b. The purchase order's requirements are met.

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 31 of 43 10.7 Quality Control inspection personnel or other personnel who perform "inspection" activities shall be qualified within their respective areas of responsibility. The qualification of QC inspection personnel shall be defined in three levels of capability as described in ANSI N45.2.6. Other personnel performing "inspection" activities shall have appropriate experience, training, and retraining to assure competence in accordance with ANSI/ANS-3.1 and applicable codes and standards. Inspection assignments shall be consistent with the qualification of an individual. In instances where the education and experience recommendations are not met by QC inspection personnel who are to be certified to ANSI N45.2.6, Ameren Missouri shall demonstrate by documented results of written examinations and evaluations of actual work proficiency that individuals possess comparable or equivalent competence.

Quality Control inspection personnel or other personnel who perform "inspection" activities shall be qualified within their respective areas of responsibility. The qualification of QC inspection personnel shall be defined in three levels of capability as described in ANSI N45.2.6-1978. Other personnel performing "inspection" activities shall have appropriate experience, training, and retraining to assure competence in accordance with ANSI/ANS-3.1-1978 and applicable codes and standards. Inspection assignments shall be consistent with the qualification of an individual. In instances where the education and experience recommendations are not met by QC inspection personnel who are to be certified to ANSI N45.2.6-1978, Ameren Missouri shall demonstrate by documented results of written examinations and evaluations of actual work proficiency that individuals possess comparable or equivalent competence.

Add "-1978" after ANSI N45.2.6 and after ANSI/ANS-3.1 to clarify the applicable issue year.

to ULNRC-06777 Page 32 of 43 10.8 Personnel from outside organizations performing QC inspection activities associated with safety-related items at the CEC shall be certified as required by ANSI N45.2.6.

Personnel from outside organizations performing QC inspection activities associated with safety-related items at the CEC shall be certified as required by ANSI N45.2.6-1978.

Add "-1978" after ANSI N45.2.6 to clarify the applicable issue year.

10.8.1 Personnel from outside organizations or Ameren personnel who are not Nuclear Generation personnel selected to perform other activities associated with safety-related items at the CEC shall meet one or more of the following for the activities which they are performing:

  • meet the education and experience requirements applicable to the
position,
  • be qualified through Ameren Missouris systematic approach to training,
  • be qualified through a vendors training and qualification program, which has been approved by Ameren Missouri.

Personnel from outside organizations or Ameren personnel who are not Nuclear Generation personnel selected to perform other activities associated with safety-related items at the CEC shall meet one or more of the following for the activities which they are performing:

  • meet the education and experience requirements applicable to the position,
  • be qualified through Ameren Missouris systematic approach to training,
  • be qualified through a vendor's training and qualification program, which has been approved by Ameren Missouri.

Add "-1978" after ANSI N45.2.6 to clarify the applicable issue year.

to ULNRC-06777 Page 33 of 43 11.11 Personnel within the various Ameren organizations may perform testing activities including implementing test procedures and the evaluation and reporting of test results. The assignment of Plant testing personnel shall be under the direction and control of the Senior Vice President and Chief Nuclear Officer. The qualification of QC testing personnel shall be defined in three levels of capability as described in ANSI N45.2.6. Other personnel performing "testing" activities shall have appropriate experience, training, and retraining to assure competence in accordance with ANSI/ANS-3.1 and applicable codes and standards.

Testing assignments shall be consistent with the qualification of an individual. In instances where the education and experience recommendations are not met by QC testing personnel who are to be certified to ANSI N45.2.6, Ameren Missouri shall demonstrate by documented results of written examinations and evaluations of actual work proficiency that individuals possess comparable or equivalent competence.

Personnel within the various Ameren organizations may perform testing activities including implementing test procedures and the evaluation and reporting of test results.

The assignment of Plant testing personnel shall be under the direction and control of the Senior Vice President and Chief Nuclear Officer. The qualification of QC testing personnel shall be defined in three levels of capability as described in ANSI N45.2.6-1978. Other personnel performing "testing" activities shall have appropriate experience, training, and retraining to assure competence in accordance with ANSI/ANS-3.1-1978 and applicable codes and standards. Testing assignments shall be consistent with the qualification of an individual. In instances where the education and experience recommendations are not met by QC testing personnel who are to be certified to ANSI N45.2.6-1978, Ameren Missouri shall demonstrate by documented results of written examinations and evaluations of actual work proficiency that individuals possess comparable or equivalent competence.

Add "-1978" after ANSI N45.2.6 and after ANSI/ANS-3.1 to clarify the applicable issue year.

to ULNRC-06777 Page 34 of 43 11.12 Personnel from outside organizations or Ameren personnel who are not Nuclear Generation personnel selected to perform other testing activities associated with safety-related items at the CEC shall meet one or more of the following for the activities which they are performing:

  • meet the education and experience requirements applicable to the
position,
  • be qualified through Ameren Missouris systematic approach to
training,
  • be qualified through a vendors training and qualification program, which has been approved by Ameren Missouri.

Personnel from outside organizations or Ameren personnel who are not Nuclear Generation personnel selected to perform other testing activities associated with safety-related items at the CEC shall meet one or more of the following for the activities which they are performing:

  • meet the education and experience requirements applicable to the position,
  • be qualified through Ameren Missouri's "systematic approach to training,"
  • be qualified through a vendor's training and qualification program, which has been approved by Ameren Missouri Add "-1978" after ANSI N45.2.6 to clarify the applicable issue year.

to ULNRC-06777 Page 35 of 43 18.10.1.1.a When purchasing commercial grade calibration or testing services from a laboratory holding accreditation by an accrediting body recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA),

commercial grade surveys need not be performed provided all of the following conditions are met:

1. A documented review of the supplier's accreditation is performed and includes a verification of the following:
a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

When purchasing commercial grade calibration or testing services from a laboratory holding accreditation by an accrediting body recognized by the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA), commercial grade surveys need not be performed provided all of the following conditions are met:

1. A documented review of the supplier's accreditation is performed and includes a verification of the following:
a. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 36 of 43 18.10.1.2.a

2. It is validated, at receipt inspection, that the laboratory's documentation certifies that:
a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and
b. The purchase order's requirements are met.
2. It is validated, at receipt inspection, that the laboratory's documentation certifies that:
a. The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and
b. The purchase order's requirements are met.

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 37 of 43 Appendix A Regulatory Guide 1.38, Revision 2 Dated 5/77 DISCUSSION:

With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shipping Damage Inspection: Stores personnel shall normally visually scrutinize incoming shipments for damage of the types listed in this Section; this activity is not necessarily performed prior to unloading. Since required items receive the Item Inspection of Section 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the transport agent after unloading and the signing for receipt of the shipment may be all of the only action taken to document completion of the Shipping Damage Inspection. Any nonconformance noted shall be documented and dispositioned as required by OQAM Section 15. The person performing the visual scrutiny during unloading is not considered to be performing an inspection function as defined under Regulatory Guide 1.74; therefore, while this person shall be trained to perform this function, this person may not necessarily be certified to Regulatory Guide 1.58 (ANSI N45.2.6) as an Inspector.

DISCUSSION:

With regard to Section 5.2.1 of ANSI N45.2.2 - 1972 titled Shipping Damage Inspection: Stores personnel shall normally visually scrutinize incoming shipments for damage of the types listed in this Section; this activity is not necessarily performed prior to unloading. Since required items receive the Item Inspection of Section 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the transport agent after unloading and the signing for receipt of the shipment may be all of the only action taken to document completion of the Shipping Damage Inspection. Any nonconformance noted shall be documented and dispositioned as required by OQAM Section 15. The person performing the visual scrutiny during unloading is not considered to be performing an inspection function as defined under Regulatory Guide 1.74; therefore, while this person shall be trained to perform this function, this person may not necessarily be certified to Regulatory Guide 1.58 (ANSI N45.2.6-1978) as an Inspector.

Add "-1978" after ANSI N45.2.6 to clarify the applicable issue year.

to ULNRC-06777 Page 38 of 43 Regulatory Guide 1.74 Initial Issue Dated 2/74 Quality Assurance Terms and Definitions (Endorses ANSI N45.2.10-1973)

DISCUSSION:

Ameren Missouri complies with the recommendations of this Regulatory Guide with the following clarifications.

Ameren Missouri reserves the right to define additional words or phrases which are not included in this Standard.

Such additional definitions shall be documented in appropriate procedures or in Sections of the Operating QA Manual.

In addition to the Standard's definition of "Inspection," Ameren Missouri shall use the following: "Inspection (when used to refer to activities that are NOT performed by NOS or QC personnel) - Examining, viewing closely, scrutinizing, looking over or otherwise checking activities.

Personnel performing these functions are not necessarily certified to Regulatory Guide 1.58 (ANSI N45.2.6)." These activities are controlled by the CEC Operating Procedures.

Quality Assurance Terms and Definitions (Endorses ANSI N45.2.10-1973)

DISCUSSION:

Ameren Missouri complies with the recommendations of this Regulatory Guide with the following clarifications.

Ameren Missouri reserves the right to define additional words or phrases which are not included in this Standard. Such additional definitions shall be documented in appropriate procedures or in Sections of the Operating QA Manual.

In addition to the Standard's definition of "Inspection," Ameren Missouri shall use the following: "Inspection (when used to refer to activities that are NOT performed by NOS or QC personnel) - Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Personnel performing these functions are not necessarily certified to Regulatory Guide 1.58 (ANSI N45.2.6-1978)." These activities are controlled by the CEC Operating Procedures.

Add "-1978" after ANSI N45.2.6 to clarify the applicable issue year.

to ULNRC-06777 Page 39 of 43 Regulatory Guide 1.123 Revision 1 Dated 7/77 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION:

1) A documented review of the supplier's accreditation is performed and includes a verification of the following:

a) The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION:

1) A documented review of the supplier's accreditation is performed and includes a verification of the following:

a) The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 40 of 43 Regulatory Guide 1.123 Revision 1 Dated 7/77 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION:

2) The purchase documents require that:

a) The service must be provided in accordance with their accredited ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program and scope of accreditation.

Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION:

2) The purchase documents require that:

a) The service must be provided in accordance with their accredited ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program and scope of accreditation.

This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 41 of 43 Regulatory Guide 1.123 Revision 1 Dated 7/77 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION:

3) It is validated, at receipt inspection, that the laboratory's documentation certifies that:

a) The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorses ANSI N45.2.13-1976)

DISCUSSION:

3) It is validated, at receipt inspection, that the laboratory's documentation certifies that:

a) The contracted calibration or test service has been performed in accordance with their ISO/IEC-17025:2005 or ISO/IEC-17025:2017 program, and has been performed within their scope of accreditation, and This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

Regulatory Guide 1.123 Revision 1 Dated 7/77 With regard to Section 7.5 of ANSI N45.2.13 - 1976 titled Personnel Qualifications: The phrase: "Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6 as applicable", is subject to the following clarification: Qualification of personnel performing verification activities for the CEC shall be in accordance with Ameren Missouri's position on Regulatory Guide 1.58.

With regard to Section 7.5 of ANSI N45.2.13 - 1976 titled Personnel Qualifications: The phrase: "Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.6-1978 as applicable", is subject to the following clarification:

Qualification of personnel performing verification activities for the CEC shall be in accordance with Ameren Missouri's position on Regulatory Guide 1.58.

Add "-1978" after ANSI N45.2.6 to clarify the applicable issue year.

to ULNRC-06777 Page 42 of 43 Regulatory Guide 1.144 Revision 1 Dated 9/80 Auditing of Quality Assurance Programs for Nuclear Power Plants (Endorses ANSI N45.2.12-1977)

DISCUSSION:

In lieu of performing commercial grade survey or accepting a commercial grade survey performed by another licensee, a documented review of the laboratory's accreditation is performed which includes a verification of the following:

1. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA.

The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."

2. For procurement of calibration services, the published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.
3. For procurement of testing services, the published scope of accreditation for the test Auditing of Quality Assurance Programs for Nuclear Power Plants (Endorses ANSI N45.2.12-1977)

DISCUSSION:

In lieu of performing commercial grade survey or accepting a commercial grade survey performed by another licensee, a documented review of the laboratory's accreditation is performed which includes a verification of the following:

1. The calibration or test laboratory holds accreditation by an accrediting body recognized by the ILAC MRA. The accreditation encompasses ISO/IEC-17025:2005 or ISO/IEC-17025:2017, "General Requirements for the Competence of Testing and Calibration Laboratories."
2. For procurement of calibration services, the published scope of accreditation for the calibration laboratory covers the needed measurement parameters, ranges, and uncertainties.
3. For procurement of testing services, the published scope of accreditation for the test laboratory covers the needed testing services including test methodology and tolerances/uncertainty.
4. The laboratory has achieved accreditation based on an on-site accreditation This represents an editorial change by changing the phrase "ISO/IEC 17025:2005 or ISO/IEC 17025:2017" to "ISO/IEC 17025:2017". The 2005 revision was superseded when the 2017 revision was approved by the NRC June 2021.

to ULNRC-06777 Page 43 of 43 laboratory covers the needed testing services including test methodology and tolerances/uncertainty.

4. The laboratory has achieved accreditation based on an on-site accreditation assessment by the selected AB within the past 48 months. The laboratory's accreditation cannot be based on two consecutive remote accreditation assessments.

assessment by the selected AB within the past 48 months. The laboratory's accreditation cannot be based on two consecutive remote accreditation assessments.

End of Table of Changes for OQAMCN 22-003

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