ML25343A252
| ML25343A252 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/09/2025 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25343A250 | List: |
| References | |
| ULNRC-06972 | |
| Download: ML25343A252 (0) | |
Text
Attachment 1 to ULNRC-06972 OQAM REVISION 37a, 37b, 37c, AND 37d DESCRIPTION AND JUSTIFICATIONS This attachment provides a summarization of changes made to the Ameren Missouri Operating Quality Assurance Manual (OQAM) for the Callaway Plant and the onsite independent spent fuel storage facility. Each OQAM Change Notice (OQQAMCN) is separately described, and a basis and justification provided. These changes are also depicted in Attachment 2 by identifying the changes through the use of strikeovers and inserts.
OQAMCNs23-005, 23-004,24-002, 24-003, and 25-001 were previously reviewed internally and determined to not constitute a reduction in commitment.
Note: In the tables to follow, the deleted text is depicted in red strikethrough text, and inserted text is depicted in blue underlined text.
Page 1 of 12
Attachment l to ULNRC-06972 Summary of OQQAMCN 23-005 (OQAM Rev. 37a)
This change extended the internal audit grace period from 90 days to a maximum grace period of 25 percent of the audit interval. The justification for this change was made using the NRC Safety Evaluation provided in Reference 2 of this letter and completing a site evaluation in accordance with 10 CFR 50.54(a)(3)(ii). The evaluation concluded this change is applicable to Callaway Plant and therefore can be adopted.
OQAM
Section 18.7 Current Description Internal audits shall be conducted by the NOS Department and shall be performed with a frequency commensurate with their safety significance. An audit of safety-related functions shall be completed in accordance with formal audit schedules within a period of two (2) years.
A grace period of 90 days may be applied to performance of internal audits provided the two (2) year frequency for the following audit performance is not set forward. Each element of the OQAP, such as design control and document
- control, and each area of Plant operations shall be audited.
Supplementary to the biennial requirements to audit safety-related functions:
e Audits of Unit activities (listed below)
SHALL be conducted on a performance based frequency by the NOS Department, not to
- exceed 24 months
- _ a)
The conformance of Unit operation to provisions contained within the Technical Specifications and applicable license conditions; b)
The performance, training and qualifications of the entire Unit staff; c)
The results of actions taken to correct deficiencies occurring in Unit equipment, structures, systems or method of operation that
. affect nuclear safety; d)
The performance of activities required by the Operational Quality Assurance Program to
' meet the criteria of Appendix B, 10 CFR Part 50, e)
The Radiological Environmental
- Monitoring Program and the results thereof;
- f)
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures; Page 2 of 12 Revised Description Internal audits shall be conducted by the NOS
. Department and shall be performed with a frequency commensurate with their safety significance. An audit of safety-related functions shall be completed in accordance with formal audit schedules within a period of two (2) years.
A maximum grace period of 25 i
percent ofthe audit interval 90-days may be applied to performance of internal audits provided the two (2) year frequency for the following audit performance is not set forward.
Each element ofthe OQAP, such as design control and document control, and each area of
_ Plant operations shall be audited.
l Supplementary to the biennial requirements to
' audit safety-related functions:
e
=©Audits of Unit activities (listed below)
SHALL be conducted on a performance based frequency by the NOS Department, not to exceed 24 months
- a)
The conformance of Unit operation to provisions contained within the Technical Specifications and applicable license conditions; b)
The performance, training and
. qualifications of the entire Unit staff;
¢)
The results of actions taken to correct deficiencies occurring in Unit equipment, structures, systems or method of operation that
, affect nuclear safety; d)
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, e)
The Radiological Environmental Monitoring Program and the results thereof; f)
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures;
Attachment l to
_ULNRC-06972 g)
The PROCESS CONTROL PROGRAM g)
The PROCESS CONTROL PROGRAM and implementing procedures for processing and implementing procedures for processing and packaging of radioactive wastes; and packaging of radioactive wastes;
_h)
The performance of activities required by h)
The performance of activities required by the Quality Assurance Program for effluent and the Quality Assurance Program for effluent and environmental monitoring; and environmental monitoring; and i)
Any other area of Unit operation considered i)
Any other area of Unit operation appropriate by the Senior Vice President and Chief considered appropriate by the Senior Vice Nuclear Officer.
President and Chief Nuclear Officer.
- A grace period of 90 days may be applied to
- A grace period of 90-days a maximum of 25 the 24 month frequency for internal audits, percent of the audit interval may be applied to
. provided the 24 month frequency for the the 24 month frequency for internal audits, following audit performance is not set forward.
_ provided the 24 month frequency for the following audit performance is not set forward.
End of OQAMCN 23-005 Page 3 of 12
Attachment l to ULNRC-06972 Summary of OQAMCN 23-004 (OQAM Rev. 37b)
This change extended the 24-month internal audit frequency to a 36-month internal audit frequency.
Thejustification for this change was made using the NRC Safety Evaluation provided in Reference 3 of this letter and completing a site evaluation in accordance with 10 CFR 50.54(a)(3)(ii). The evaluation concluded this change is applicable to Callaway Plant and therefore can be adopted.
l Revised Description OQAM Current Description
_ Section ee ee ae 18.7 Internal audits shall be conducted by the NOS Internal audits shall be conducted by the NOS Department and shall be performed with a Department and shall be performed with a frequency commensurate with their safety frequency commensurate with their safety significance. An audit of safety-related functions significance. An-audit-Audits of safety-related shall be completed in accordance with formal audit
© functions shall be completed in accordance with schedules within a period of two (2) years.
A formal audit schedules within a period oftwe+2)
_ maximum grace period of 25 percent ofthe audit years which are separated into three cycles covering interval may be applied to performance of internal
_a period of 36 months. Each cycle includes a set of audits provided the two (2) year frequency for the audits and 24-month reviews. Results of the following audit performance is not set forward.
, completed audits will be reviewed to determine if Each element of the OQAP, such as design control l additional audit activities are necessary prior to and document control, and each area of Plant
. their next scheduled performance. Each functional operations shall be audited.
' area will receive an additional performance analysis (24-month review) within two years of the last performed audit based on internal and external data; functional area changes in responsibility, resources, or management; and consideration of theimpacts, as applicable, to determine if additional audit
" activities arenecessary prior to the 36-month scheduled performance. A maximum grace period of 25 percent of the audit interval may be applied to performance of internal audits provided the +we-@}
year 36 month frequency for the following audit performance is not set forward. Each element of the OQAP, such as design control and document
- control, and each area of Plant operations shall be l
audited.
_ Supplementary to the biennial requirements to l
Supplementary to the biennial requirements to
, audit safety-related functions:
audit safety-related functions:
e
§©Audits of Unit activities (listed below) e
§©Audits of Unit activities (listed below)
SHALL be conducted on a performance SHALL be conducted on a performance based frequency by the NOS Department, based frequency by the NOS Department, not to exceed 24 months
- not to exceed 24-36 months
- The conformance of Unit operation to The conformance of Unit operation to provisions contained within the Technical provisions contained within the Technical Specifications and applicable license Specifications and applicable license conditions; conditions; The performance, training and qualifications b)
The performance, training and qualifications of the entire Unit staff, of the entire Unit staff; The results of actions taken to correct c)
The results of actions taken to correct deficiencies occurring in Unit equipment, deficiencies occurring in Unit equipment, Page 4 of 12
Attachment l to ULNRC-06972 oy) structures, systems or method of operation that affect nuclear safety; The performance of activities required by the Operating Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, The Radiological Environmental Monitoring Program and the results thereof; The OFFSITE DOSE CALCULATION MANUAL and implementing procedures; The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes; The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring; and Any other area of Unit operation considered appropriate by the Senior Vice President and Chief Nuclear Officer.
structures, systems or method of operation that affect nuclear safety; The performance of activities required by the Operating Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, The Radiological Environmental Monitoring Program and the results thereof; The OFFSITE DOSE CALCULATION MANUAL and implementing procedures; The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes; The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring; and Any other area of Unit operation considered appropriate by the Senior Vice President and Chief Nuclear Officer.
End of OQAMCN 23-004 Page 5 of 12
Attachment l to ULNRC-06972 Summary of OQAMCN 24-002 (OQAM Rev. 37b)
Sections 1.7.6 and 16.6 The Onsite Review Committee (ORC) responsibility to review Significant Conditions Adverse to Quality was moved from Section 16.0, "Corrective Action" to Section 1.0, "Organization" which contains all other ORC responsibilities. Therefore, this change was administrative.
Section 2.4 The "Director, Engineering Design & Projects" position was replaced with "Director responsible for Design Engineering or designee." This organization change was evaluated per 10 CFR 50.54(a)(3)(vi) due to changes in both functional description and organizational reporting. The evaluation determined this change continues to assure the proper authority and organizational freedom of quality assurance functions.
Sections 2.10, 10.6, 11.10, 12.4, 13.5 The "Director, Maintenance" position was replaced with "Senior Manager or above responsible for Maintenance or designee" and the "Director, Training" position was replaced with "Director responsible for Training or designee." These position title changes were evaluated per 10 CFR 50.54(a)(3)(iii) and determined that the functional description and organizational reporting remain unchanged.
OQAM Current Description Section 1.7.6 a) b)
The ORC shall be responsible for:
Deleted.
Review of 10 CFR 50.59 and 10 CFR 72.48 evaluations! regarding:
procedures, changes to procedures, equipment, systems or facilities, and tests or experiments completed under the provision of 10 CFR 50.59 and 10 CFR 72.48 to verify that such actions did not require prior NRC approval.
Review of proposed procedures and changes to procedures, equipment, systems or facilities which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.485; Review of proposed test or experiments which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.485; Review of proposed changes to Technical Specifications or Operating License; Page 6 of 12 Revised Description The ORC shall be responsible for:
a)
DeletedReview ofsignificant conditions adverse to quality.
b)
Review of 10 CFR 50.59 and 10 CFR 72.48 evaluations! regarding:
e procedures, e
changes to procedures, equipment, systems or facilities, and tests or experiments completed under the provision of 10 CFR 50.59 and 10 CFR 72.48 to verify that such actions did not require prior NRC approval.
Review ofproposed procedures and changes to procedures, equipment, systems or facilities which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.48°;
Review of proposed test or experiments which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.48°;
Attachment 1 to ULNRC-06972 f)
Investigation of all violations of the Review of proposed changes to Technical Technical Specifications including the Specifications or Operating License; forwarding of reports covering evaluation and recommendations to prevent recurrence to the Senior Vice President and Chief Nuclear Officer.
Investigation of all violations of the Technical Specifications including the forwarding of reports covering evaluation and recommendations to prevent recurrence Review of report of operating abnormalities, to the Senior Vice President and Chief deviations from expected performance of Nuclear Officer.
plant equipment and of unanticipated deficiencies in the design or operation of structures, systems or components that affect nuclear safety; Review of report of operating abnormalities, deviations from expected performance of plant equipment and of unanticipated deficiencies in the design or operation of Review of all REPORTABLE EVENTS; structures, systems or components that affect nuclear safety; Review of all REPORTABLE EVENTS; Review of the plant Security Plan; Review of the Radiological Emergency Response Plan; i)
Review of the plant Security Plan; Review of changes to the PROCESS j)
Review of the Radiological Emergency CONTROL PROGRAM, the OFFSITE Response Plan; DOSE CALCULATION MANUAL, and Review of changes to the PROCESS Radwaste Treatment Systems; CONTROL PROGRAM, the OFFSITE Review of any accidental, unplanned or DOSE CALCULATION MANUAL, and uncontrolled radioactive release including the Radwaste Treatment Systems; preparation of reports covering evaluation, recommendations, and disposition ofthe corrective action to prevent recurrence and the forwarding of these reports to the Senior Director, Nuclear Operations.
Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and Review of Unit operations to detect potential the forwarding of these reports to the Senior hazards to nuclear safety; Director, Nuclear Operations.
n)
Investigations or analysis of special subjects Review of Unit operations to detect potential as requested by the Senior Vice President hazards to nuclear safety; and Chief Nuclear Officer.
Investigations or analysis of special subjects 0)
Review of Unit Turbine Overspeed as requested by the Senior Vice President Protection Reliability Program and revisions and ChiefNuclear Officer.
h thereto; Review of Unit Turbine Overspeed p)
Review of the Fire Protection Program.
Protection Reliability Program and revisions thereto; p)-
Review of the Fire Protection Program.
The pertinent requirements ofthe OQAP apply to The pertinent requirements of the OQAP apply to all activities affecting the safety-related functions all activities affecting the safety-related functions of those structures, systems, and components that of those structures, systems, and components that prevent or mitigate the consequences of postulated
_ prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health accidents that could cause undue risk to the health and safety of the public. The safety-related and safety of the public. The safety-related structures, systems and components identified in structures, systems and components identified in Table 3.2-1 of the Callaway Final Safety Analysis l Table 3.2-1 of the Callaway Final Safety Analysis
- Report-Standard Plant (FSAR SP). This list includes structures, systems, and components includes structures, systems, and components
_ identified during the design and construction phase
__ identified during the design and construction phase Page 7 of 12
Attachment l to ULNRC-06972 and may be modified as required during operations consistent with their importance to safety.
Modifications to this list require the approval of the 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 theOQAP. 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 FSAR SP, are
_ also under the control of the OQAP.
General indoctrination and training programs shall be developed for personnel performing safety-related activities to assure that responsible functions, departments, and individuals are knowledgeable regarding quality policy and
- requirements of applicable manuals and procedures. The requirements for training of CEC personnel are described in Section 13.2 of the Callaway FSAR Site Addendum (FSAR SA). The training of permanent Plant personnel is the responsibility of the Director, Training. Personnel performing complex, unusual, or hazardous work shall be instructed in special indoctrination or briefing sessions. Emphasis shall be on special
- requirements for safety of personnel, radiation control and protection, unique features of equipment and systems, operating constraints, and control requirements in effect during performance of work. Training shall be conducted as required to, as a minimum, meet the requirements of Ameren Missouri's commitment to Regulatory
- Guide 1.8 (ANSI/ANS 3.1), Regulatory Guide 1.33 (ANSI N18.7), other Regulatory Guides as endorsed in OQAM Appendix A, and other regulatory requirements. Records of training shall be maintained as described in Section 17. Where required by code or standard, personnel are trained or qualified according to written procedures in the principles and techniques of performing specific activities. Special equipment, environmental conditions, skills, or processes shall be provided as necessary for the effective implementation of the OQAP.
_ OQAP.
An inspection personnel qualification program shall be established to assure inspection activities
- are being performed bypersonnel trained and Page 8 of 12 responsible for Training or ¢ "and may be modified as required duringoperationsl consistent with their importance to safety.
Modifications to this list require the approval of the Manager, Nuclear Oversight and the Director; Engineerine-Desien-& Projects responsible for Design Engineering or designee 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 FSAR SP, are also under the control ofthe OQAP.
General indoctrination and training programs shall
' be developed for personnel performing safety-related activities to assure that responsible
- functions, departments, and individuals are knowledgeable regarding quality policy and requirements of applicable manuals and procedures. The requirements for training of CEC personnel are described in Section 13.2 of the Callaway FSAR Site Addendum (FSAR SA). The training of permanent Plant personnel is the responsibility of the Director, Training Director ee. Personnel performing complex, unusual, or hazardous work shall be instructed in special indoctrination or briefing sessions. Emphasis shall be on special requirements for safety of personnel, radiation control and protection, unique features of
' equipment and systems, operating constraints, and control requirements in effect during performance of work. Training shall be conducted as required
- to, as a minimum, meet the requirements of Ameren Missouri's commitment to Regulatory Guide 1.8 (ANSI/ANS 3.1), Regulatory Guide 1.33 l
(ANSI N18.7), other Regulatory Guides as
- endorsed in OQAM Appendix A, and other regulatory requirements. Records oftraining shall be maintained as described in Section 17. Where required by code or standard, personnel are trained or qualified according to written procedures in the principles and techniques of performing specific activities. Special equipment, environmental conditions, skills, or processes shall be provided as necessary for the effective implementation of the An inspection personnel qualification program a
shall be established to assure inspection activities are being performed by personnel trained and
Attachment l to ULNRC-06972 qualified to a capability necessary for performance l qualified to a capability necessary for performance of the activity. Plant procedures shall prescribe the of the activity. Plant procedures shall prescribe the qualification requirements of inspection personnel.
_qualification requirements of inspection personnel.
The Director, Training shall be responsible for The Director, Training Director responsible for providing related technical and quality training Trainingor designee shall be responsible for appropriate to the certification/qualification of l providing related technical and quality training Ameren Missouri personnel.
appropriate to the certification/qualification of l
_ Ameren Missouri personnel.
11.10 A program shall be established to assure testing A program shall be established to assure testing activities are performed by personnel trained and activities are performed by personnel trained and qualified to a capability necessary for performance qualified to a capability necessary for performance of the activity. Plant procedures and procurement l of the activity. Plant procedures and procurement documents shall prescribe the qualification documents shall prescribe the qualification requirements for testing personnel. Provisions may requirements for testing personnel. Provisions may be made for on-the-job training of individuals not
' be made for on-the-job training of individuals not
. qualified to the program provided they are qualified to the program provided they are supervised or overseen by qualified individuals for l supervised or overseen by qualified individuals for the activities being performed. The Director,
. the activities being performed. The Direeter, Training shall be responsible for providing related Fraining Director responsible for Trainingor technical and quality training for Ameren Missouri designee shall be responsible for providing related
_ personnel who perform testing.
technical and quality training for Ameren Missouri
[
l personnel who perform testing.
The calibration and control program established at The calibration and control program established at the CEC shall assure that M&TE, reference the CEC shall assure that M&TE, reference standards, and PI maintain their required accuracy.
standards, and PI maintain their required accuracy.
The Director, Maintenance is responsible for The Direeter;Senior Manager or above responsible
- assuring the program establishment. Program for Maintenance or designee is responsible for implementation is the responsibility of the assuring the program establishment. Program appropriate Department Heads.
_ implementation is the responsibility of the
' appropriate Department Heads.
The Director, Maintenance shall establish an The Direeter; Senior Manager or above responsible inspection program for Plant material handling for Maintenance or designee shall establish an
_ equipment that provides for routine maintenance inspection program for Plant material handling and inspection in accordance with documented equipment that provides for routine maintenance procedures which specify acceptance criteria.
and inspection in accordance with documented Routine inspections shall determine the procedures which specify acceptance criteria.
i acceptability of equipment and rigging. Routine Routine inspections shall determine the inspections shall be supplemented by acceptability of equipment and rigging. Routine nondestructive examinations and proof tests as inspections shall be supplemented by delineated in procedures for items requiring special nondestructive examinations and proof tests as handling. Personnel performing nondestructive delineated in procedures for items requiring special examination and prooftesting shall be qualified.
handling. Personnel performing nondestructive oo.
_examination and proof testing shall be qualified.
Engineering Design or Projects personnel shall Engineering Design or Projects personnel shall review conditions adverse to quality which involve review conditions adverse to quality which involve l
design deficiencies or which involve design deficiencies or which involve recommending design/configuration changes as recommending design/configuration changes as corrective action. Fuel Cycle Management should corrective action. Fuel Cycle Management should
- review conditions adverse to quality for fuel related review conditions adverse to quality for fuel related issues. The ORC shall review significant conditions issues. Fhe-ORC shalt reviewsignificant conditions adverseto quality.
_ adverse te-quality.
oo End of OQAMCN 24-002 Page 9 of 12
Attachment l to ULNRC-06972 Summary of OQAMCN 24-003 (OQAM Rev. 37c)
Policy/Introduction The reference to "10 CFR Part 100" was changed to "10 CFR 50.67 and Regulatory Guide 1.183" as it relates to the consequences of accidents which could result in off-site exposures. This change was based on issuance of Amendment 233 provided in Reference 4 of this letter and was evaluated per 10 CFR 50.54(a)(3)(i).
Sections 1.7.6 and 3.18 The OQAM was clarified to better align with language stated in ANSI N18.7-1976 (ANS3.2).
Policy/Introduction, Section 18.8, Appendix A Several typographical errors were corrected that were made from previous OQAM changes. These changes were determined to be administrative and/or editorial.
' Revised Description 3)
The capability to prevent or mitigate the l Current Description The capability to prevent or mitigate the OQAM Section Policy/Introduction 3) consequences of accidents which could result in off-site exposures comparable to the guideline exposures of NRC consequences of accidents which could result in off-site exposures comparable to the guideline exposures ofNRC Regulation 10 CFR Part 100.
Regulation 10 CER-Part106 10 CFR Policy/Introduction Callaway Energy Center has been licensed to use 10CFR50.60 "Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors.l The ORC shail be responsible for:
a) Review of significant conditions adverse Callaway Energy Center has been licensed to use 10CFR50-6950.69 "Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power l Reactors."
The ORC shall be responsible for:
a) Review of significant conditions adverse b) 9)
to quality.
Review of 10 CFR 50.59 and 10 CFR 72.48 evaluations regarding:
e¢ procedures, e
changes to procedures, equipment, systems or facilities, and tests or experiments completed under the provision of 10 CFR 50.59 and 10 CFR 72.48 to verify that such actions did not require prior NRC approval.
Review of proposed procedures and changes to procedures, equipment, systems or facilities which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.48.
Review of proposed test or experiments which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.48°;
Page 10 of 12 to quality to ensure causes of the condition have been determined_and adequate corrective action has been taken.
Review of 10 CFR 50.59 and 10 CFR 72.48 evaluations regarding the following and to verify that such actions did not require prior NRC approval:
procedures, e
changes to procedures, equipment, systems or facilities, and tests or experiments completed under the provision of 10 CFR 50.59 and 10 CFR 72.48 te verify that such-actions did-net require prior NRC approval.
)
Review of proposed procedures and changes to procedures, equipment, systems or facilities which may involve prior NRC approval as defined in 10
Attachment l to ULNRC-06972 l AppendixA le) Review of proposed changes to Technical Specifications or Operating License; f)
Investigation of all violations of the Technical Specifications including the forwarding of reports covering evaluation and recommendations to prevent recurrence to the Senior Vice President and Chief Nuclear Officer.
Review of report of operating abnormalities, deviations from expected performance of plant equipment and of unanticipated deficiencies in the design or operation of structures, systems or components that affect nuclear safety;
_h) Review of all REPORTABLE EVENTS; i)
Review of the plant Security Plan; J) Review of the Radiological Emergency Response Plan; k) Review of changes to the PROCESS CONTROL PROGRAM, the OFFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems; p)Review of the Fire Protection Program.
Safety Related Design changes shall be reviewed by the ORC and approved by the Senior Director, Nuclear Operations.
- A prace period of a maximum of 25 percent of the audit interval may be applied to the 24 month frequency for internal audits, provided the 24 month frequency for the following audit performance is not set forward.
_ Every instanceofANSI N18.7-1976 CFR 50.59 and 10 CFR 72.48, or involves_a change in Technical Specifications, Review of proposed test or experiments which may involve prior NRC approval as defined in 10 CFR 50.59 and 10 CFR 72.48°;
Review of proposed changes to Technical Specifications or Operating License; Investigation of all violations of the Technical Specifications including forwarding of reports covering evaluation and recommendations to prevent recurrence to the Senior Vice President and Chief Nuclear Officer.
Review of report of operating abnormalities, deviations from expected performance of plant equipment and of unanticipated deficiencies in the design or operation of structures, systems, or components that affect nuclear safety; Review of all REPORTABLE EVENTS; Review of the plant Security Plan and the Cyber Security Plan and revisions thereto; j) Review of the Radiological Emergency Response Plan and revisions thereto;
. k) Review of changes to the PROCESS CONTROL PROGRAM, the OFFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems and revisions thereto; p)Review of the Fire Protection Program and revisions thereto.
Safety Related-Desien evaluations for design changes shall be reviewed by the ORC and approved by the Senior Director, Nuclear Operations.
l
' *A grace period of a maximum of 25 percent of the audit interval may be applied to the 24-36 month frequency for internal audits, provided the 24-36 month frequency for the following audit performance is not set forward.
ANSI NI8.7-1976/ANS 3.2 End of OQAMCN 24-003 Page 11 of 12 to ULNRC-06972 Summary of OQQAMCN 25-001 (OQQAM Rev. 37d)
This change replaced "each Callaway Energy Center Director" with "Director or above" in Appendix B, "Dry Cask Storage System Quality Assurance Program." This position title change was evaluated per 10 CFR 50.54(a)(3)(iii) and determined that the functional description and organizational reporting remain unchanged.
OQAM Current Description Revised Description
_Section Appendix Overall implementation of the quality program Overall implementation of the quality program B, 1.2 requirements for the Dry Cask Storage System requirements for the Dry Cask Storage System and and spent fuel dry cask loading operation resides spent fuel dry cask loading operation resides with with each Callaway Energy Center Director for each Callaway Energy Center Director and above l
_ their area of responsibility.
_ for their area of responsibility.
End of OQAMCN 25-001 Page 12 of 12