ULNRC-05852, Callaway, Unit 1, Operating Quality Assurance Manual (Oqam) Revision 29
| ML12150A170 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/25/2012 |
| From: | Heflin A C Ameren Missouri, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML121500197 | List: |
| References | |
| ULNRC-05852 | |
| Download: ML12150A170 (13) | |
Text
WAmeren MISSOURI May 25, 2012 ULNRC-05852 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:
10 CFR 50.54 10 CFR 50.71 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 Callaway Plant 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. Executed on: 'j {z { /rJ,. f ACH/JSG/MOM/tlw Sincerely, A. C. Heflin Senior Vice President and Chief Nuclear Officer 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 monitoring from Nuclear Operations to Protective Services.
- 1.11, 1. 11.3 -Moved Performance Improvement reporting from Director, Operations Support to Manager, Plant Support.
- 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 from AmerenUE to Ameren Missouri.
All Sections -Deleted references to commitments that are not actually commitments.
Editorial changes; removal of erroneous underlines and fonts. 16.4-Deleted last sentence of 16.4 designating all reportable conditions adverse to quality as significant.
- The organization changes in Change Notice (CN)10-002 and CN 11-001 marked with an asterisk (*) do not affect compliance with the applicable standards regarding required functions, organizational responsibilities, and qualifications, including compliance with 10 CFR 50 Appendix B. Therefore, they are not considered reductions in commitment.
This change is ofthe name only. The 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.
Certain references identified in parentheses as commitments (e.g. COMN 1234) which 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 are not considered reductions in commitment.
Redundant sentence.
Classification of significant conditions adverse to quality is covered in 16.3. Therefore, this change is not considered a reduction in commitment.
Attachment 1 to ULNRC-05852 Page 3 Change Change Description 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 Change. Changed general term of Superintendents to Superintendents, Maintenance.
Changed name of Facilities organization to Support. 1.11.2 -Protective Services Organization Editorial Change. Changed Supervisor, 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 Appendix A page 5 -ORC Procedure Review Changes. Deleted the requirement for the Onsite Review Committee to review all Administrative Procedure changes. Justification Minor editorial changes are not considered a reduction in commitment.
Minor editorial changes are not considered a reduction in commitment.
Deletion of Onsite Review Committee review of Administrative Procedures could be considered a reduction in commitment.
However, the NRC has already approved 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 Notice 11-001 1.20. 7.a); 1.20.8.a), b); 2.6.3); and continued Appendix A page 5 -ORC Procedure Review Changes. Deleted the requirement for the Onsite Review Committee to review all Administrative Procedure changes. Continued.
Justification The letter was addressed to Mr. Charles G. Pardee, CNO and SVP Exelon Generation Company, and CNO of AmerGen Energy Company. 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 Notice 12-001 OQAM Sections 17.7 -Removed reference to optical disks and Generic Letter 88-18. Replaced reference to Generic Letter 88-18 with NRC Regulatory Issue Summary 2000-18. Justification Callaway has abandoned optical disk technology and is now using electronic (magnetic) technology.
The new technology was implemented in accordance with the 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).
TG 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 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 Document TG15-1998 5.2.1 Appropriate indexing information for each record should include, as a minimum:
- office of origin (i.e., department),
- title, subject
- file code or record type,
- key words for retrieval,
- addressee (if any),
- signatory, author, date,
- authorized disposition (coded or otherwise), and
- identification of any access restrictions or necessary steps should be included on the labels TG15-1998 4.2.3 (10)-Records Managers should oversee implementation of disposition instructions, including timely transfer of record to off-line storage or permanent archiving Resolution 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." Every field mentioned in this section may not be indexed for every record. ADP-ZZ-DC003, "Indexing Instructions and Record Analysis";
Each indexing instruction for each file type has specific instructions for each field to be indexed. Admin works with originating department to determine critelia for indexing instruction per ADP-ZZ-DC003 documented in Indexing Instruction (Form CA 1552) and file plan updates. The new version ofTG15-2011, 7.1, states: "Appropriate indexing information for each record type may include the following:" (followed by list of suggested indexing information similar to TG15-1998).
Also, in step 7 of TG15-2011, it states that "Sufficient indexing should be done to ensure that each record is uniquely identified and retlievable.
Oliginating organizations should coordinate
.... to ensure appropriate level of indexing is done to support the legal and business needs of the organization." The Ameren Callaway Energy Center's archival storage solution for electronic nuclear quality records does not include an off-line or near-line storage component.
Therefore, the referenced sections in TG-15-1998 regarding off-line or near-line storage are not applicable.
TG Attachment 1 to ULNRC-05852 Page 8 Sections/wording Document 5.3 (4)-An effective electronic records security program should be implemented that: Approved records or quality data are copied to the ofT-line archive facility once they are approved or their status is changed to "record." 6.1.2 (1)-Because of quality assurance/data integrity issues associated with the storage and maintenance of electronic records: The use of removable magnetic or optical disks, or computer tape reels and cartridges by individual employees or organizations for the long-term ofT-line storage of electronic records should not be permitted.
6.2.1(8,11,12,14)-
Facility requirements:
(8) Original records and record media should be maintained ofT-line.
Copies of electronic records may be maintained on-line for use if either: a. properly secured, maintained and verified to ensure their replication of the original record, OR b. used for information only purposes.
(11) If maintained off-line, the duplicate copy of the electronic records/media should be maintained in a facility sufficiently separate from the location of the original to prevent single event destruction ofboth 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 Resolution Storage technology has evolved to provide redundant dual storage at separate geographical locations without one being off-line or near-line.
They are both kept on-line during normal operations.
One or the other can be temporarily taken off-line if necessary (i.e. maintenance), but would be synchronized to have the same set of total files after being brought on-line again. Ameren has implemented Centera brand storage technology from EMC, Inc. that is configured for secure on-line long-term archival storage replacing Write Once Read Many (WORM) optical platters for QA Record storage per NRC Generic Letter 88-18 guidance.
One Centera storage unit is onsite in the protected Callaway data center. A second Centera storage unit is also on-line but located at the Ameren corporate office secure data center in the General Office Building (GOB) in St. Louis. Both storage devices remain on-line and can receive files for storage from the Callaway eB Records Management system. Core eB software functionality maintains awareness of both storage devices as active/on-line "repositories".
The two devices are kept synchronized with the same total files multiple times a day. TG15-2011 (newest revision) does not have the same recommendations.
8.4.4 "Electronic records and record media should be maintained on-line. Copies of electronic records mav be maintained off-line.
n 11.4 "Electronic records may be on off-line media containing records that have mixed retention periods".
13 *Data designated as a backup shall be maintained in case it is needed for recovery from an emergency.
Backup copies should be stored in a different area from the on-line copy to prevent destruction by the same event that destroyed the on-line copy." For Callaway, the second storage unit is stored at the GOB.
TG Attachment 1 to ULNRC-05852 Page 9 Sections/wording 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. Resolution