ULNRC-06602, Response to Request for Addition Information Pertaining to Revision to Technical Specification (TS) 5.3.1 and Deletion of TS 5.3.1.1 and TS 5.3.1.2 -
| ML20246G738 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/02/2020 |
| From: | Wink R Ameren Missouri, Union Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EPID L-2020-LLA-0046, ULNRC-06602 | |
| Download: ML20246G738 (16) | |
Text
rAIIIeIø:eI1 Callaway Plant MISSOURI September 2, 2020 ULNRC-06602 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
RENEWED FACILITY OPERATING LICENSE NPF-30 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO REVISION TO TECHNICAL SPECIFICATION (TS) 5.3.1 AND DELETION OF TS 5.3.1.1 AND TS 5.3.1.2 - EPID L-2020-LLA-0046
References:
1.
Ameren Missouri letter ULNRC-06335, Revision to Technical Specification 5.3. 1 and Deletion of Technical Specifications 5.3. 1. 1 and 5.3.1.2 (LDCN 19-001 3), dated March 10, 2020 (ADAMS Accession Number ML20070R105) 2.
NRC electronic correspondence, Final Request for Additional Information Callaway Plant, Unit 1
- License Amendment Request
- Revision to Technical Specification (TS) 5.3. 1 and Deletion of TS 5.3. 1. 1 and 5.3. 1.2
EPID L-2020-LLA-0046, dated August 4, 2020 (ADAMS Accession Number ML20203M368)
In the letter identified as Reference 1, Union Electric Company (Ameren Missouri) submitted a license amendment request (LAR) for Callaway Plant, Unit 1. The proposed amendment would revise Technical Specification (TS) Administrative Control (AC) 5.3. 1, under TS 5.3, Unit Staff Qualifications, and delete TS AC 5.3. 1. 1 and TS AC 5.3. 1.2 in order to remove details specified for the qualifications of certain positions within the unit staff, since such details are already and appropriately specified in the Operating Quality Assurance Manual (OQAM).
From review of the Reference 1 submittal, the NRC staff issued per Reference 2 a request for additional information (RAI) in electronic form on August 4, 2020, and requested that responses to the RAI questions/requests be provided within 30 days. This letter provides Ameren Missouris response 8315 County Road 459 Steedman MO 65077 AmerenMissouri corn
ULNRC-06602 September 2, 2020 Page 2 of 4 to the RAT. Specifically, Ameren Missouris responses to each of the RAT questions are provided in the enclosure to this letter.
The additional information provided in this RAT response (as a supplement to Ameren Missouris March 10, 2020 LAR) has no impact on the TS changes requested and described in the LAR As such, these changes do not change the No Significant Hazards Consideration conclusions reached in the LAR, nor do they change the conclusion regarding no need for an environmental assessment based on the categorical exclusion provisions of 10 CFR 51.22.
In accordance with 10 CFR 50.9 1, Notice for public comment; State consultation, Section (b)(1), a copy of this RAT response provided in connection with the March 10, 2020 amendment application is being provided to the designated Missouri State official.
This letter does not contain new commitments.
Tf there are any questions, please contact Mr. Tom Elwood at 314-225-1905.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, Roger C. Wink Manager, Regulatory Affairs Executed on:
September 2, 2020 JPK\\mlp
Enclosure:
Ameren Missouri Response to NRC RATs
ULNRC-06602 September 2, 2020 Page 3 of 4 cc:
Mr. Scott A. Morris Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mahesh Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-000 1
ULNRC-06602 September 2, 2020 Page 4 of 4 Index and send hardcopy to QA File A160.0761 Hardcopy:
Certrec Corporation 6500 West Freeway, Suite 400 FortWorth,TX 76116 (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 Responses and Reports ULNRC Distribution:
F. M. Diya B. L. Cox F. J. Bianco S. P. Banker S. G. Kovaleski R. C. Wink T. B. Elwood NSRB Secretary Ms. Melissa Friel, REP Manager (SEMA)
STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)
Ms. Katie Jo Wheeler (DNR)
Enclosure to ULNRC-06602 Ameren Missouri Response to NRC RAIs 11 pages
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 1 of 11 on March 10, 2020, Ameren Missouri (Union Electric Company) submitted a license amendment request (LAR) for Callaway Plant, Unit 1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20070R105). The proposed amendment would revise Technical Specification (TS) Administrative Control (AC) 5.3.1
, under TS 5.3, Unit Staff Qualifications, and delete TS AC 5.3.1.1 and 5.3.1.2 in order to remove details specified for the qualifications of certain positions within the unit staff, since such details are already and appropriately specified in the Operating Quality Assurance Manual (OQAM) for Callaway. The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the application and has determined that the following additional information is required in order to complete the review of the subject OQAM.
REQUEST FOR ADDITIONAL INFORMATION ARCB-RAI 1 Regulatory Basis 10 CFR 50.120(b)(2) requires thatthe training program must be derived from a systems approach to training as defined in 1 0 CFR 55.4 and must provide for the training and qualification for numerous nuclear power plant positions, including radiation protection and chemistry technicians.
1 0 CFR 55.4, the definition of systems approach to training states that the training program should include five elements, including a systematic analysis of the jobs to be performed and training design and implementation based on the learning objectives.
1 0 CFR 50.54(a)(4) requires that changes to the quality assurance program that reduce commitments must be submitted to the NRC and receive NRC approval prior to implementation.
Background
In the letter dated March 1 0, 2020 (ML2007OR1 05) the licensee proposes to revise Technical Specification (TS) 5.3.1 and delete TS 5.3.1.1 and TS 5.3.1.2. These TSs specify the unit staff qualification requirements. The revised Technical Specification would refer to the Operating Quality Assurance Manual (OQAM) for the minimum qualification requirements of unit staff, which in turn references FSAR Section 1 3.1 In Section 3.2 of the LAR, Deletion of Exceptions to ANSI/ANS 3.1 1 978 from TS, it quotes the OQAM, which states that 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 must meet the qualifications of Regulatory Guide 1 8.
In addition, it states that supplemental Radiation Protection and l&C technicians and QC inspectors shall meet the education and experience requirements of ANSI/ANS 3.1 -1 978 when performing safety-related activities.
However, the term safety-related is normally associated with tasks that ensure reactor safety and protection of the public from significant radiological releases. For example, 1 0 CFR 50.2 indicates that safety-related SSCs are those associated with ensuring: 1) the integrity of the reactor coolant pressure boundary, 2) the capability to shut down the reactor and to maintain the reactor in safe shutdown, and 3) to prevent or mitigate the consequences of accidents which could result in offsite
ULNRC-06602 Ameren Missouri Response to NRC RAPs Page 2 of 11 exposures comparable to the limits in 1 0 CFR 50.34(a)(1) and 1 0 CFR 1 00.1 1
. Many of the tasks performed by radiation protection staff and technicians, such as radiological surveys, radioactive material control, and personnel monitoring, are often not directly associated with ensuring reactor safety or preventing significant releases associated with reactor accidents and therefore are not considered safety related. However, many of these tasks are required in order to meet radiation exposure and radioactivity control requirements and therefore must be performed by appropriately qualified staff.
ARCB-RAI-1 A Please provide additional information to clarify what is meant by safety-related tests and activities, as it relates to radiation protection and radwaste managers, supervisors, and technicians.
Response
The terms safety-related (in regards to activities periormed byjadiation protection and radwaste managers, supervisors, and technicians) and preoperational and startup tests, as described in the OQAM Appendix A commitment to Regulatory Guide (RG) 1.8, Rev. 2 are discussed below.
The usage of the term safety-related, as it relates to activities periormed by radiation protection and radwaste managers, supervisors, and technicians, predates the definition that was added to 1 0 CFR 50.2 (Ret: 61 FR 651 71 December 1 1
, 1 996). As used in the OQAM commitment to Regulatory Guide (RG) 1.8, Rev. 2, the term was derived from the terminology provided in Section C, Regulatory Position, of RG 1.33, Quality Assurance Program Requirements (Operation), Rev. 2 (1 978), which states in part, The overall quality assurance program requirements for the operation phase that are included in ANSI Ni 8.7-1976IANS-3.2 are acceptable to the NRC staff and provide an adequate basis for complying with the quality assurance program requirements of Appendix B to 1 0 CFR Part 50, subject to the following:
1
. ANSI Ni 8.7-i 976/ANS-3.2 requires the preparation of many procedures to carry out an effective quality assurance program. Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, to this regulatory guide should be used as guidance to ensure minimum procedural coverage for plant operating activities, including related maintenance activities. Appendix A lists typical safety-related [emphasis added] activities that should be covered by written procedures but does not provide a complete listing of needed procedures.
Included within RG i.33, Rev. 2, Appendix A is item 7, Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure). Included within item 7 is bullet item e, Radiation Protection Procedures, which provides a list of activities commonly performed by radiation protection and radwaste managers, supervisors, and technicians. Thus, the safety related characterization is simply an extension of the language used in RG i.33. Safety-related tests and activities, as it relates to radiation protection and radwaste managers, supervisors, and technicians would broadly include the activities listed in item 7.e. Refer to the response to ARCB-RAI-i B for more details.
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 3 of 11 The reference to preoperational and startup tests in the OQAM Appendix A commitment to RG 1.8, Rev. 2 has an historical context that should be explained. During initial licensing of Callaway Plant, the NRC staff asked several questions pertaining to the quality assurance program (originally included in Chapter 1 7 of the Site Addendum to the Final Safety Analysis Report (FSAR)). Some of these questions pertained to training and qualification of the unit staff.
In response to NRC Question 260.52C, Union Electric (Ameren Missouri) added the statement regarding safety-related preoperational and startup tests as a clarification to the OQAM commitment to RG 1.8, Rev. 2. This clarification, which may be found in the sixth paragraph of the commitment (as shown in Attachment 2 to the LAR) pertains specifically to the pre-operational and startup testing that was per(ormed prior to initial licensing of the Callaway Plant.
In regards to certification of personnel, ANSI/ANS 3.1-1978, Standard for Selection and Training of Personnel for Nuclear Power Plants, specifies the following:
Underthe major heading Qualification, Section 4.1 states in pail, The medical requirements for licensed personnel are specified in American National Standard for Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants, N546.1976 (ANS 3.4).
Under the major heading Training, Section 5.2.1.1 allows experience demonstrated by obtaining certification of satisfactory completion of an NRC-approved training program which utilizes a nuclear power plant simulator as part of this program to satisfy the experience requirements for personnel preparing for a cold reactor operator or senior reactor operator license exam (i.e., prior to initial criticality of the unit the individual would be licensed to operate).
Neither of these provisions pertain to non-licensed technical staff, and for licensed operators (i.e., Shift Managers, Operating Supervisors, and Reactor Operators) and Shift Technical Advisors, the current TS 5.3.1.1 and OQAM commitment to RG 1.8, Rev. 2 specify that they shall meet or exceed the qualifications of ANSI/ANS 3.1-1981 as endorsed by Reg. Guide 1.8, Revision 2, with the same exceptions as contained in the current revision to the Operator Licensing Examiner Standards, NUREG-1 021, ES-202, in lieu of the corresponding provisions found in ANSI/ANS 3.1-1978.
In regards to inspection, examination and testing personnel, the OQAM Appendix A commitment to RG 1.8, Rev. 2 states in part that such personnel shall meet the requirements for certification as inspection, examination or testing personnel as set forth in Ameren Missouris commitment to ANSI N45.2.6-1 978 given elsewhere in this Appendix (i.e., in the commitment to RG 1.58, Rev. 1
, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel).
However, the Ameren Missouri response to NRC Question 260.72 provides the following additional clarification regarding certification of tech nical staff.
Activities such as surveillance testing, initial startup testing, and l&C, Radiation Protection, and Chemistry group functions are controlled by approved procedures.
They are audited and surveilled by QA, and procedures are reviewed and approved by authorized personnel. The personnel who periorm these activities meet Regulatory
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 4 of 11 Guide 1.8 (ANSI/ANS 3.1-1978) and aretherefore not required to be certified as Inspectors per Regulatory Guide 1.58 (ANSI N45.2.6).
In summary, the subject reference to safety-related preoperational and startup tests refers to activities that were perFormed prior to initial licensing. The personnel who pertorm technical functions (e.g., in the l&C, Radiation Protection, and Chemistry groups) are qualified to ANSI/ANS 3.1-1978 in accordance with the current TS 5.3.1 and the OQAM Appendix A commitment to RG 1.8, Rev. 2, and are not required to be certified as inspectors per RG 1.58.
It can thus be seen that the term safety-related does not itself define the types of tests and activities performed by radiation protection and radwaste personnel for the operating facility.
The types of tests and activities relevant to the qualifications for radiation protection and radwaste managers, supervisors and/or technicians are addressed in the next RAI request and response.
ARCB-RAI-1 B Please provide additional information to clarify what types of activities radiation protection and radwaste managers, supervisors, and technicians are required to be qualified to periorm and what types of radiation protection and waste management activities, if any, can be performed by unqualified individuals.
In addition, please specify if there are any changes to the qualification requirements for radiation protection staff and technicians from what was previously required by the Technical Specifications.
Response
The activities performed by radiation protection (RP) and/or radwaste personnel include those safety-related activities applicable to Callaway Plant that are enumerated in Appendix A to RG 1.33, Quality Assurance Program Requirements, Rev. 2, for which written procedures are required to be established, implemented, and maintained per Technical Specification (TS) 5.4.1 as referenced in OQAM Section 5.2.1
. These procedures include:
Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure)
- a. Liquid Radioactive Waste System (1 ) Collection, Demineralizing, Filtering, Evaporating, and Concentrating, and Neutralizing (Radwaste)
(2) Sampling and Monitoring (Chemistry and RP)
(3) Discharging to Effluents (Radwaste and RP)
- b. Solid Waste System (1 ) Spent Resins and Filter Sludge Handling (Radwaste)
(2) Baling Machine Operation (no longer applicable to Callaway Plant)
(3) Drum Handling and Storage (Radwaste)
- c. PWR Gaseous Effluent System
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 5 of 11 (1) Collection, Storage, and Discharge (Radwaste)
(2) Sampling and Monitoring (RP)
(3) Air Ejector and Stack Monitoring (RP)
(4) Ventilation Air Monitoring (RP)
- d. BWR Air Extraction, Offgas Treatment, and Other Gaseous Effluent Systems (1 ) Mechanical Vacuum Pump Operation (not applicable to Callaway Plant)
(2) Air Ejector Operation (not applicable to Callaway Plant)
(3) Packing Steam Exhauster Operation (not applicable to Callaway Plant)
(4) Sampling (not applicable to Callaway Plant)
(5) Air Ejector, Ventilation, and Stack Monitor (not applicable to Callaway Plant)
- e. Radiation Protection Procedures (1 ) Access Control to Radiation Areas Including a Radiation Work Permit System (RP)
(2) Radiation Surveys (RP)
(3) Airborne Radioactivity Monitoring (RP)
(4) Contamination Control (RP and all Radiation Workers)
(5) Respiratory Protection (RP)
(6) Training in Radiation Protection (Training and RP)
(7) Personnel Monitoring (RP)
(8) Bioassay Program (RP)
(9) Implementation of ALARA Program (RP)
- f. Area Radiation Monitoring System Operation (RP)
- g. Process Radiation Monitoring System Operation (RP)
- h. Meteorological Monitoring (RP)
The listed activities that are perlormed by RP or radwaste personnel are within the scope of the OQAM to the extent that they are governed by these procedures, which are subject to 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, and to corresponding Chapter 5 of the OQAM. Furthermore, as noted in the response to ARCB-RAI 1 A, these activities are subject to quality assurance audit I surveillance. The requirements for periodic auditing ofthese activities are specified in OQAM Sections 18.8 and 18.8.1.
Regarding the qualifications for personnel who perlorm the activities listed above, the OQAM Appendix A commitment to RG 1.33, Rev.2 states in part:
Initial incumbents or replacements for members of the onsite or offsite technical support organizations shall have appropriate experience, training and retraining to assure that necessary competence is maintained in accordance with the provisions of ANSI/ANS 3.1
- 1978Property "ANSI code" (as page type) with input value "ANSI/ANS 3.1</br></br>- 1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as committed to in the OQAM.
Regarding the activities that are allowed to be performed by unqualified individuals, the activities listed above may be performed by an unqualified individual under the supervision of a qualified individual for the purpose of instruction and qualification. As described in OQAM 2.10.3:
ULNRCO66O2 Ameren MLssouriResponsetoNRCRAls 1 Page 6 of 11 All other training programs [i.e., other than the training programs described in OQAM 2.10.2, for Shift Managers, Operating Supervisors, Reactor Operators, and Shift Technical Advisors] shall meet or exceed the requirements and recommendations of Section 5 of ANSI/ANS 3.1 -1 978.
Per section 5.3.4, Training for Technicians and Maintenance Personnel, of ANSI/ANS 3.1 1978:
Technicians and maintenance personnel shall be trained by on-the-job training; by participation in initial calibration, testing, and equipment acceptance programs; or by related technical training to meet the qualifications set forth in 4.5.
In order to implement the on-the-job training provision of ANSI/ANS 3.1 -1978 section 5, as referenced in OQAM 2.10.3, section 4.5.4 of plant procedure APA-ZZ-00925, Training and Qualification of Plant Personnel, provides that:
Personnel who are not qualified to perform a task or work activity may periorm the activity when the following conditions are met:
An individual who IS qualified for the task or work activity is present and The qualified individual remains in the area and monitors the activity, and The qualified individual ensures the task or work activity is completed correctly through monitoring of the work activity.
Finally, as explained in the response to ARCB-RAI-2A and ARCB-RAI-2B, the LAR does not involve any changes to the qualification requirements for radiation protection staff and technicians from what was previously required by the Technical Specifications.
ARCB-RAI 2 Regulatory Basis 10 CFR 50.120(b)(2) requires thatthe training program must be derived from a systems approach to training as defined in 1 0 CFR 55.4 and must provide for the training and qualification for numerous nuclear power plant positions, including radiation protection and chemistry technicians.
1 0 CFR 55.4, the definition of systems approach to training, states that the training program should include five elements, including a systematic analysis of the jobs to be performed and training design and implementation based on the learning objectives.
1 0 CFR 50.54(a)(4) requires that changes to the quality assurance program that reduce commitments, must be submitted to the NRC and receive NRC approval prior to implementation.
Background
In the letter dated March 1 0, 2020 (ML ML2007OR1 05) the licensee proposes to revise Technical Specification (TS) 5.3.1 and delete TS 5.3.1.1 and TS 5.3.1.2. The current TSs specify unit staff qualification requirements by referring to ANSI/ANS 3.1-1978 and referring to exceptions. The revised Technical Specification would refer to the Operating Quality Assurance Manual (OQAM) for the minimum qualification requirements of unit staff.
The licensee indicates that the reason for the
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 7 of 11 change is to reduce the regulatory burden associated with maintaining duplicate information in licensing documents that are subject to separate change processes.
In Section 3.2 of the LAR, Deletion of Exceptions to ANSI/ANS 3.1 -1 978 from TS, it copies text from the OQAM. The text, in part, refers to FSAR Section 131. FSAR Section 13.1 appears to provide different qualification requirements than are required by the current TS, as described as follows:
TS 5.3.1.1 specifies that operating supervisors should be qualified to ANSI/ANS 3.1-1981, as endorsed by RG 1.8, Revision 2, with the exceptions listed in the TS. ANSI/ANS 3.1-1981 specifies that the supervisors should have four years of experience in the craft or discipline they supervise. Elsewhere in ANSI/ANS 3.1-1981, it distinguishes between chemistry (including radiochemistry) and radiation protection, both of which have different supervisors and management qualification requirements. Yet FSAR Section 13.1, Section 131.3.1.18, specifiesthatthe radiation protection supervisor and radwaste operations supervisor must have a minimum of four years of experience in applied health physics, chemistry, radiochemistry, or radwaste activities. This implies that four years of experience working in chemistry is sufficient qualification to be radiation protection supervisor or radwaste operations supervisor and vice versa.
Similarly, the original TS 5.3.1 required that radiation protection technicians be qualified in accordance with ANSI/ANS 3.1 -1 978. ANSI/ANS 3.1 -1 978, Section 4.5.2, indicates that technicians shall have three years of working experience in their specialty, of which one year should be related technicaltraining. Elsewhere in ANSI/ANS 3.1-1978, it distinguishes differences between chemistry (and radiochemistry) and radiation protection, both of which have different supervisors and management qualification requirements. However, in FSAR Section 13.1.3.1.19 it specifies that radiation protection technicians and radwaste trainer operator must have three years of radiation or chemistry experience. This implies that three years of chemistry experience is sufficient qualification for a radiation protection technician and radwaste trainer operator and vice versa.
In addition, there is no mention of one year of related technicaltraining in Section 13.1.3.1.19.
In Section 13.1.3.1 ofthe FSAR, other unique specialty qualifications are provided individually and not grouped together like radiation protection and chemistry.
As described in the examples above, revising TS 5.3.1
, deleting TS 5.3.1.1 and 5.3.1.2, appear to not only eliminate duplicative requirements, but also appear to alter the qualification requirements for the positions described above.
ARCB-RAI-2A Please provide additional information to clarify if there are any changes to qualification requirements from the current TS for the positions of radwaste supervisor and radwaste technicians.
Response
The subject LAR does not involve any changes to personnel qualification requirements as currently described in the TS. The current TS 5.3.1 requires each member of the unit staff to meet or exceed the minimum qualifications of ANSI/ANS 3.1 -1 978, with the following exceptions:
Per the current TS 5.3.1.1
, Shift Managers, Operating Supervisors, Reactor Operators, and Shift Technical Advisors shall meet or exceed the qualifications of
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 8 of 11 ANSI/ANS 3.1 -1 981 as endorsed by Reg. Guide 1 8, Revision 2, with the same exceptions as contained in the current revision to the Operator Licensing Examiner Standards, NUREG-1021
, ES-202. As noted in the LAR, this exception to ANSI/ANS 3.1-1978 was added per License Amendment 60, and pertains to persons who serve as Shift Technical Advisors and/or hold an NRC Reactor Operator or Senior Reactor Operator license.
Per the current TS 5.31.2, The Radiation Protection Manager shall be a supervisor with line responsibility for operational health physics who meets or exceeds the qualifications of USNRC Regulatory Guide 1.8, September 1 975, for a Radiation Protection Manager. The Radiation Protection Manager will be designated by the plant manager. (Note that the provision for the Radiation Protection Manager to be designated by the plant manager is not a qualification requirement, but was added (per License Amendment 92) in order to provide organizational flexibility.)
The qualification requirements for Shift Managers, Operating Supervisors, Reactor Operators, Shift Technical Advisors, the Radiation Protection Manager, and each of the other members of the unit staff, as currently specified in TS 5.3.1, TS 5.3.1.1, and TS 5.3.1.2 are duplicated in Ameren Missouris commitment to RG 1.8, Rev. 2 as presented in OQAM sections 2.1 0.2 and 2.10.3, and OQAM Appendix A.
It should be noted that ANSI/ANS 3.1 -1 978 does not specifically describe the positions or associated responsibilities of RP, radwaste, chemistry, or operations technicians (formerly equipment operators), or of the non-licensed first-line supervisors who supervise the performance of their activities. Instead, the ANSI/ANS 3.1 -1 978 qualification requirements for non-licensed first-line supervisors are generically described in section 4.3.2, Supervisors Not Requiring NRC Licenses, and for technicians, they are described in section 4.5.2, Technicians. Neither the current TS 5.3.1 nor the OQAM Appendix A commitment to RG 1.8, Rev. 2 take exception to ANSI/ANS 3. 1 -1 978 sections 4.3.2 or 4.5.2.
In summary, replacing the details of personnel qualification requirements from TS and replacing them with a requirement that each member of the unit staff shall meet or exceed the minimum qualifications for the comparable position(s) addressed in the standard(s) that is referenced in the Callaway Plant Operating Quality Assurance Manual (OQAM), with exceptions specified in the OQAM does not change any qualification requirements for members of the unit staff that are currently specified in TS.
ARCB-RAI-2B As described above, [FSAR Site Addendum] Sections 13.1.3.1.18 and 13.1.3.1.19 appear to indicate that experience in chemistry can be credited for radiation protection qualifications and that radiation protection experience can be credited for chemistry qualification. Please clarify if this is the intent.
If so, please provide additional information as to how experience in the area of chemistry is adequate to qualify for radiation protection positions and vice versa.
Response
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 9 of 11 As explained below, justification that has allowed experience in chemistry to be credited for radiation protection qualifications, and vice versa, consistent with ANSI/ANS 3.1-1978, has been reviewed and accepted by the NRC staff, but additional training and qualification requirements may be imposed on these positions in order to satisfy other regulatory and accreditation requirements.
ANSI/ANS 3.1 -1 978, as referenced by the current TS 5.3.1 and the OQAM Appendix A commitment to Regulatory Guide 1.8, specifies requirements for qualification of the responsible individual in charge of chemistry and radiochemistry in Section 4.4.3, and for the responsible individual in charge of radiation protection in Section 4.4.4. The specified qualification requirements in Section 4.4.3 include experience in chemistry and radiochemistry, while the specified qualification requirements in Section 4.4.4 include experience in applied radiation protection.
However, the generic qualification requirements for technicians that are provided in ANSI/ANS 3.1-1978 Section 4.5.2 specify that:
Technicians shall have three years of working experience in their speciality, of which one year should be related technical training. They should possess a high degree of manual dexterity and ability and should be capable of learning and applying basic skills.
For first-line supervisors, including those who supervise the work of technicians, the generic qualification requirements that are provided in ANSI/ANS 3.1 -1 978 Section 4.3.2 specify that:
At the time of initial core loading or appointment to the position, whichever is later, a supervisor in this category shall have a high school diploma or equivalent, and four years experience in the craft or discipline he supervises.
ANSI/ANS 3.1 -1 978 does not provide a definition of the term speciality. Instead, Section 3.1 of ANSI/ANS 3.1 -1 978 states in part The establishment of functional levels and assignment of responsibility require establishing various levels of qualified individuals that must be a part of the organization licensed to operate nuclear power plant. The functional levels used below are not intended to define the specific organization that must be established for nuclear power plants, or to completely define the responsibilities of each level of an organization. Based on the above, ANSI/ANS 3.1 -1978 does not specifically prohibit crediting of chemistry experience for radiation protection positions, or radiation protection experience for chemistry positions.
In fact, at the time Callaway Plant was initially licensed, the radwaste, radiation protection and chemistry functions were assigned to personnel (including Radiation-Chemical Supervisors and Radiation-Chemical Technicians (RCTs)) organized in a single Radiation-Chemistry department. As noted by the NRC staff in NUREG-0830, section 12.5.1:
The applicant proposes to have a combined health physics and chemistry technician (ROT). Because of the difficulty in maintaining individuals qualified in both specialties, the staff recommends that radiation protection personnel should not be assigned multiple specialties unless they are fully qualified in each specialty, including training, experience, testing, and retraining. During an Inspection and Enforcement staff
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page lOof 11 inspection of the Callaway organization, the inspector determined that the applicant has hired RCTs with 3 to 8 years experience as engineering laboratory technicians (ELT5) in the Navy Nuclear Power Program. Several of them have additional nuclear power plant experience and have a college degree. The staff reviewed the ROT training program at Oallaway and found it is designed to maintain technician competency in both radiation protection and chemistry. To complete the radiation protection training, employees must pass written examinations given throughout the program.
The qualification requirements specified in the FSAR Site Addendum Sections 1 3.1.3.1.18 and 13.1.3.1.19, which has allowed chemistry experience to be credited for radiation protection first-line supervisor and technician positions and vice versa, are consistent with the requirements in sections 4.3.2 and 4.5.2 of ANSI/ANS 3.1 -1 978, as referenced by the current TS 5.3.1 and the OQAM Appendix A commitment to Regulatory Guide 1.8.
In order to satisfy the NRC staff recommendation that radiation protection personnel should not be assigned multiple specialties unless fully qualified in each specialty, Oallaway has employed a combination of assigning appropriate creditfor past experience (e.g., by crediting Navy ELT experience as applicable for either chemistry or radiation protection experience) and on-the-job experience obtained as part of the training program.
It should also be noted that the qualification requirements for non-licensed first-line supervisors and technicians that are provided in the current TS 5.3.1 and the OQAM Appendix A commitment to RG 1.8, Rev. 2 pre-date the requirements that are outlined in 1 0 CFR 50.1 20(b)(2). As such, additional qualification requirements may be imposed, as applicable, for the positions enumerated in 10 CFR 50.120(b)(2), including Non-licensed operator, Radiological protection technician, and Ohemistry technician, through the periodic training program evaluation and revision process that is established to satisfy 10 CFR 50.120(b)(3).
Such additional qualification requirements would not be within the scope of the current TS 5.3.1 or the OQAM Appendix A commitment to RG 1.8, Rev. 2, and would not be affected by the requested license amendment.
As noted above, ANSI/ANS 3.1 -1 978 section 4.5.2 contains a provision that one year of technician experience be related technical training. This requirement has been satisfied in accordance with the guidance of ANSI/ANS 3.1 -1 978 section 5 under the training program that is described in OQAM 2.1 0.3 (as referenced in the response to AROB-RAI-1 B above),
and which is also intended to satisfy 10 CFR 50.120(b)(2), and to maintain accreditation under the Institute of Nuclear Power Operations (INPO) National Academy for Nuclear Training (which supports the periodic training program evaluation and revision process that is established to satisfy 10 CFR 50.120(b)(3)).
Finally, while not required to support the subject LAR, in order to avoid further confusion over how ANSI/ANS 3.1 -1 978 and 1 0 CFR 50.1 20(b)(2) are being satisfied, Ameren Missouri intends to add clarifications (shown as underlined text) to FSAR Site Addendum sections 13.1.3.118 and 13.1.3.1.19, as follows.
1 3.1.3.1.18 Chemistry Supervisor, Radiation Protection Supervisor, and Radwaste Operations Supervisor
ULNRC-06602 Ameren Missouri Response to NRC RAIs Page 1 1 of 11 1
A minimum of four years of experience in applied health physics, chemistry, radiochemistry or radwaste activities, as appropriate to the position.
2.
High School education or equivalent.
13.1.3.1.19 Radiation Protection Technician, Chemistry Technician, and Radwaste Trainer Operator 1
Three years of radiation or chemistry experience, as appropriate to the position, of which one year should be related technical training.
2.
High School education or equivalent.