ULNRC-05852, Operating Quality Assurance Manual (Oqam) Revision 29
| ML12150A170 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/25/2012 |
| From: | Heflin A Ameren Missouri, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML121500197 | List: |
| References | |
| ULNRC-05852 | |
| Download: ML12150A170 (13) | |
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WAmeren Callaway Plant MISSOURI May 25, 2012 ULNRC-05852 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.54 10 CFR 50.71 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 OPERATING QUALITY ASSURANCE MANUAL (OQAMl REVISION 29
Reference:
- 1. ArnerenUE Letter ULNRC-05742, "Operating Quality Assurance Manual (OQAM), Revision 28," dated November 30, 2010 Furnished herewith is OQAM Revision 29. Pursuant to the requirements of 10 CFR 50.54 and 10 CFR 50.71, the OQAM has been revised to incorporate changes since the last docketed revision transmitted via Reference 1.
We have enclosed one copy of the following documents:
- 1. Description and Justification for Proposed Changes to the OQAM
- 2. Updated pages which constitute OQAM Revision 29
- 3. OQAM Revision 28 mark-up, identifying changes through the use of strikeovers and inserts The major changes in this revision include: several onsite organizational changes, company name change from ArnerenUE to Arneren Missouri, deletion of references to commitments that do not meet the definition of"commitment," deletion ofOnsite Review Committee review of Administrative Procedures (as supported by an NRC Safety Evaluation issued to Exelon), removal of reference to optical disks (for storage of records) and NRC Generic Letter 88-18, and addition of reference to NRC Regulatory Issue Summary 2000-18.
PO Box 620 Fulton, MD 65251 AmerenMissouri.com
ULNRC-05852 May 21,2012 Page2 Revision 29 incorporates OQAM Change Notices10-002, 11-001, and 12-001 which were previously reviewed internally. These changes were determined to not represent reductions in the level of commitment associated with Operating Quality Assurance Program as previously accepted by the NRC. The OQAM continues to maintain focus on activities affecting quality, consistent with importance to safety, including compliance to 10 CFR 50, Appendix B requirements.
If you have any questions, please contact Johann Geyer, Manager, Nuclear Oversight at 314-225-1589.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, Executed on: 'j {z {/rJ,.
f A. C. Heflin Senior Vice President and Chief Nuclear Officer ACH/JSG/MOM/tlw Attachments 1) Description and Justification for Proposed Changes to the OQAM
- 2) Updated pages which constitute OQAM Revision 29
- 3) OQAM Revision 28 mark-up, identifying changes through the use of strikeovers and inserts
ULNRC-05852 May 25,2012 Page 3 cc: Mr. Elmo E. Collins, Jr.
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Mr. Andrew Hon Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738
ULNRC-05852 May 25,2012 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:
Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via QA Program ULNRC Distribution without attachment:
A. C. Heflin F. M. Diya C. 0. Reasoner ill S. A. Maglio R. Holmes-Bobo NSRB Secretary T. B. Elwood Mr. Bill Muilenburg (WCNOC)
Mr. Tim Hope (Luminant Power)
Mr. Ron Barnes (APS)
Mr. Tom Baldwin (PG&E)
Mr. Mike Murray (STPNOC)
Ms. Linda Conklin (SCE)
Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission
Attachment 1 to ULNRC-05852 Page 1 OPERATING QUALITY ASSURANCE MANUAL (OQAM) REVISION 29 DESCRIPTION AND JUSTIFICATION FOR CHANGES The descriptions and justifications listed below refer to OQAM section changes as indicated by the marked-up pages of Revision 28. OQAM Change Notices were previously reviewed internally and determined to not represent reductions in the Operating Quality Assurance Program, as previously accepted by the NRC. The OQAM continues to meet the requirements of 10CFR50, Appendix B.
Change Change Description Justification Notice Rev. 029 OQAM Policy/Introductions - Changed Change of individual assigned as Manager, individual assigned as Manager, Nuclear Nuclear Oversight. No change of duties or Oversight to J. S. Geyer from K. A. Mills qualifications of the Manager, Nuclear for approval ofOQAM Revision. Oversight have been made. The new individual is qualified for the position.
Attachment 1 to ULNRC-05852 Page 2 10-002
- 1. 9. 3, 1. 11. 1 - Moved fire marshal
- The organization changes in Change monitoring from Nuclear Operations to Notice (CN)10-002 and CN 11-001 marked Protective Services. with an asterisk (*) do not affect compliance with the applicable standards
- 1.11, 1. 11.3 - Moved Performance regarding required functions, organizational Improvement reporting from Director, responsibilities, and qualifications, Operations Support to Manager, Plant including compliance with 10 CFR 50 Support. Appendix B. Therefore, they are not considered reductions in commitment.
- 1.11.4 - Combined Risk Management with Nuclear Safety Analysis and renamed group as Nuclear Safety Analysis and Probabilistic Risk Assessment.
All Sections - Changed Company name This change is ofthe name only. The from AmerenUE to Ameren Missouri. organization and its upper tier reporting relationships remain unchanged, and no change to the Operating License for Callaway was required. Therefore this change is not considered a reduction in commitment.
All Sections - Deleted references to Certain references identified in parentheses commitments that are not actually as commitments (e.g. COMN 1234) which commitments. purport to identify commitments were identified as simple requirements derived from regulatory guides and ANSI standards and are now considered Obligations. These "commitment" numbers were removed from the OQAM throughout. No requirements are being changed; therefore this is not considered a reduction in commitment.
Editorial changes; removal of erroneous Editorial Changes are not considered underlines and fonts. reductions in commitment.
16.4- Deleted last sentence of 16.4 Redundant sentence. Classification of designating all reportable conditions significant conditions adverse to quality is adverse to quality as significant. covered in 16.3. Therefore, this change is not considered a reduction in commitment.
Attachment 1 to ULNRC-05852 Page 3 Change Change Description Justification Notice 11-001 *1.7, 1.8, 1.21.2, 2.4, 3.8, 3.10, 10.4, 10.5, and 16.6- Engineering Organizational Changes. Creation of 4 Managers:
Engineering Systems, Engineering Design, Engineering Projects, and Engineering Programs. Changed various paragraphs where the appropriate Engineering Group should be referenced.
- 1.11, 1.11.4, 1.11. 5 - Regulatory Affairs Organization Change. Creation of a Regulatory Affairs Manager who reports directly to the Director, Operations Support and is responsible for Regulatory Affairs duties.
- 1. 9. 4 - Maintenance Organization Editorial Minor editorial changes are not considered Change. Changed general term of a reduction in commitment.
Superintendents to Superintendents, Maintenance. Changed name of Facilities organization to Support.
1.11.2 -Protective Services Organization Minor editorial changes are not considered Editorial Change. Changed Supervisor, a reduction in commitment.
Fitness for Duty/Access Authorization to Supervisor, Access Authorization/Fitness for Duty. Editorial change for splitting the third bullet into a third and fourth bullet.
1.20. 7.a); 1.20.8.a), b); 2.6.3); and Deletion of Onsite Review Committee Appendix A page 5 - ORC Procedure review of Administrative Procedures could Review Changes. Deleted the requirement be considered a reduction in commitment.
for the Onsite Review Committee to review However, the NRC has already approved all Administrative Procedure changes. such a change for a number ofExelon plants in a letter dated 9/29/2008 with an attached Safety Evaluation Report (SER).
Attachment 1 to ULNRC-05852 Page4 Change Change Description Justification Notice 11-001 1.20. 7.a); 1.20.8.a), b); 2.6.3); and continued Appendix A page 5 - ORC Procedure The letter was addressed to Mr. Charles G.
Review Changes. Deleted the requirement Pardee, CNO and SVP Exelon Generation for the Onsite Review Committee to review Company, and CNO of AmerGen Energy all Administrative Procedure changes. Company.
Continued.
The approval and SER covers:
- Braidwood Station, Units 1 and 2
- Byron Station, Units 1 and 2
- Clinton Power Station, Unit 1
- Dresden Nuclear Power Station, Units 1, 2, and 3
- LaSalle County Station, Units 1 and 2
- Limerick Generating Station, Units 1 and 2
- Oyster Creek Nuclear Generation Station
- Peach Bottom Atomic Power Station, Units 1, 2, and 3
- Quad Cities Nuclear Power Station, Units 1 and 2
- Three Mile Island Station, Unit I
- Zion Nuclear Power Station, Units 1 and2 Nuclear Oversight has reviewed the above SER and concluded it is applicable to the subject Callaway OQAM change.
Therefore, it is considered a reduction in commitment that has been previously approved by the NRC.
Attachment 1 to ULNRC-05852 Page 5 Change Change Description Justification Notice 12-001 OQAM Sections 17.7 -Removed reference to Callaway has abandoned optical disk optical disks and Generic Letter 88-18. technology and is now using electronic Replaced reference to Generic Letter 88-18 (magnetic) technology. The new technology with NRC Regulatory Issue Summary 2000- was implemented in accordance with the
- 18. NIRMA Technical Guides (with some minor exceptions) endorsed by NRC Regulatory Issue Summary (RIS) 2000-18 to account for new technologies. PerRIS 2000-18, the standards and controls applicable to the new technology ensure that appropriate controls and requirements will continue to be imposed on the collection, storage and maintenance of quality assurance records in accordance with 10 CFR 50 Appendix B (Criteria VI and XVII) and other applicable regulatory requirements and guidance. Therefore, this is not considered a reduction in commitment.
Additional details are found in OQAM CN12-001 justification (attached).
Attachment 1 to ULNRC-05852 Page6 OQAM CN 12-001 Justification Continued RIS 2000-18 endorses the following NIRMA Technical Guides (TG):
- 1. NIRMA Technical Guide (TG) 11-1998, .. Authentication ofRecords and Media 11
- 2. NIRMA TG 15-1998, .. Management ofElectronic Records ..
- 3. NIRMA TG 16-1998, 11 Software Configuration Management and Quality Assurance ..
- 4. NIRMA TG 21-1998, 11 Electronic Records Protection and Restoration ..
The NRC states in RIS 2000-18 that, "When implemented together, these guidelines provide an acceptable basis for complying with the recordkeeping requirements of 10 CFR Part 31, Part 32, Part 34, Part 40, Appendix B to 10 CFR Part 50, Part 60(2), Part 70, Part 71, Part 72, or Part 76.
The scope of the NRC's acceptance of these four NIRMA technical guidelines is only for managing electronic quality assurance records."
The Callaway Energy Center is implementing the requirements of the Technical Guides.
However, in many cases the Technical Guides are not prescriptive and may only provide suggested methodologies. In some instances Callaway Energy Center is implementing slightly different methodologies. Nuclear Oversight has reviewed these instances and has concluded these differences comply with the intent of the Technical Guides and are not considered a reduction in commitment to RIS 2000-18. TG15 makes reference to on-line and off-line copies of records and implies the "off-line" copy is the QA record. In Callaway's implementation there is no off-line record. Two on-line copies are maintained and QA records in either repository are considered equivalent. TG 15 Section 6.2.1.12 states not to use the "original" for work purposes.
However in the Callaway implementation both on-line copies of records are equally "original" therefore the discussion of off-line records is not germane. Note: Each of the on-line systems are geographically remote from each other; one system at Callaway Energy Center and one at the Ameren General Office Building in St. Louis, MO.
Exceptions to Recommendations of Technical Guides TG Sections/wording Resolution Document TGll-1998 5.6.2 The scanner and images are sufficiently checked by the Equipment testing should be process used at Callaway, as summarized below:
conducted in accordance with the ADP-ZZ-RM001, "Receipt, Processing, Image capture, criteria established in the ANSI/AIIM Storage and maintenance of Records," Rev.013, step 4.7 Recommended Practice MS44. contains instructions on use of a test target to check the scanner. Scanned images are checked/verified 100% either at point of scanning or after attaching to the document entry.
4.7. Scanning At All Locations 4.7.1. SCAN a Resolution Test Target (Attachment 7).
- a. INSPECT image for legibility.
- b. INSPECT image to ensure edges of document are legible and no information has been cut off.
4.7.2. SCAN documents in their entirety utilizing appropriate
Attachment 1 to ULNRC-05852 Page7 TG Sections/wording Resolution Document desktop instruction for equipment used.
- a. Continuously MONITOR each sheet as it goes through scanner.
- b. WATCH for legibility, skewed documents, edges, etc.
Images are then verified:
4.8. Image lnspectionNelification 4.8.1. CHECK 10% of all records scanned.
- a. After records have been scanned, ENUSRE the hard copy is velified by another knowledgeable clerk either in the same work area or a clerk in the Admin Records' group.
- 1. CHECK legibility.
- 2. CHECK image to ensure edges of document are legible and no information has been cut off.
- 3. CHECK that image belongs to the indexed record i.e., by matching barcode number, record identifier, etc.
- 4. DETERMINE course of action needed to resolve any issues.
Also, the newer versions of this TG no longer reference this standard.
In addition, per AIIM, "This standard is out of date ... The only test target that is still valid is the AIIM Scanner Test Target."
TG15-1998 5.2.1 Every field mentioned in this section may not be indexed for Appropriate indexing information for every record.
each record should include, as a ADP-ZZ-DC003, "Indexing Instructions and Record minimum: Analysis"; Each indexing instruction for each file type has
- office of origin (i.e., specific instructions for each field to be indexed. Admin works with originating department to determine critelia for department),
indexing instruction per ADP-ZZ-DC003 documented in
- title, subject Indexing Instruction (Form CA 1552) and file plan updates.
- file code or record type,
- key words for retrieval, The new version ofTG15-2011, 7.1, states: "Appropriate indexing information for each record type may include the
- addressee (if any),
following:" (followed by list of suggested indexing
- signatory, author, date, information similar to TG15-1998).
- authorized disposition (coded or otherwise), and Also, in step 7 of TG15-2011, it states that "Sufficient indexing should be done to ensure that each record is
- identification of any access uniquely identified and retlievable. Oliginating organizations restrictions or necessary steps should coordinate ....to ensure appropriate level of indexing should be included on the labels is done to support the legal and business needs of the organization."
TG15-1998 4.2.3 (10)- Records Managers The Ameren Callaway Energy Center's archival storage should oversee implementation of solution for electronic nuclear quality records does not include an off-line or near-line storage component.
disposition instructions, including Therefore, the referenced sections in TG-15-1998 regarding timely transfer of record to off-line off-line or near-line storage are not applicable.
storage or permanent archiving
Attachment 1 to ULNRC-05852 Page 8 TG Sections/wording Resolution Document 5.3 (4)- An effective electronic Storage technology has evolved to provide redundant dual records security program should be storage at separate geographical locations without one being off-line or near-line. They are both kept on-line during implemented that: Approved records normal operations. One or the other can be temporarily or quality data are copied to the ofT- taken off-line if necessary (i.e. maintenance), but would be line archive facility once they are synchronized to have the same set of total files after being approved or their status is changed to brought on-line again.
"record."
Ameren has implemented Centera brand storage technology 6.1.2 (1)- Because of quality from EMC, Inc. that is configured for secure on-line long-assurance/data integrity issues term archival storage replacing Write Once Read Many associated with the storage and (WORM) optical platters for QA Record storage per NRC maintenance of electronic records: Generic Letter 88-18 guidance. One Centera storage unit is The use of removable magnetic or onsite in the protected Callaway data center. A second Centera storage unit is also on-line but located at the optical disks, or computer tape reels Ameren corporate office secure data center in the General and cartridges by individual Office Building (GOB) in St. Louis.
employees or organizations for the long-term ofT-line storage of Both storage devices remain on-line and can receive files for electronic records should not be storage from the Callaway eB Records Management system. Core eB software functionality maintains permitted. awareness of both storage devices as active/on-line 6.2.1(8,11,12,14)- Facility "repositories". The two devices are kept synchronized with requirements: the same total files multiple times a day.
(8) Original records and record media should be maintained ofT-line. TG15-2011 (newest revision) does not have the same recommendations.
Copies of electronic records may be maintained on-line for use if either: a. 8.4.4 "Electronic records and record media should be properly secured, maintained and maintained on-line. Copies of electronic records mav be verified to ensure their replication of maintained off-line. n the original record, OR b. used for 11.4 "Electronic records may be on off-line media containing information only purposes. records that have mixed retention periods".
(11) If maintained off-line, the duplicate copy of the electronic 13 *Data designated as a backup shall be maintained in records/media should be maintained case it is needed for recovery from an emergency. Backup in a facility sufficiently separate from copies should be stored in a different area from the on-line copy to prevent destruction by the same event that the location of the original to prevent destroyed the on-line copy." For Callaway, the second single event destruction ofboth storage unit is stored at the GOB.
cop1es.
(12) In no case should the original records/media be used for work purposes or maintained on-line.
(14) Where original data (i.e.
database data, email systems) is maintained on-line for business purposes, the record data should be
Attachment 1 to ULNRC-05852 Page 9 TG Sections/wording Resolution Document copied to separate media and maintained off-line for archival purposes.
7.2 (2, 7)- Retention processes: (2)
Coordinate the retrieval of near-line or off-line copies of electronically stored records. (7) Additional information needed to establish electronic record retention requirements and retention periods for records produced, contained in or maintained by the information system are: a. How long information is needed on-line and if on-line retention requirements can be met by the computer operating system or application software. b. Should information be retained near-line or off-line, in what storage media, and for how long after the originating department no longer needs the on-line data. c. The identification of off-line archival storage for life of plant retention.
- 7. 4 (6) - repeat of section 7. 2 (7) above.