ULNRC-06626, Supplemental 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

Supplemental 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

ML20357A082
Person / Time
Site:	Callaway
Issue date:	12/22/2020
From:	Wink R Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2020-LLA-0046, ULNRC-06626
Download: ML20357A082 (10)

Text

7 Aiiieren MISSOURI Callaway Plant December 22, 2020 ULNRC-06626 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 SUPPLEMENTAL 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 ofTechnical Specifications 5.3.1.1 and 5.3.1.2 (LDCN 19-0013), dated March 10, 2020 (ADAMS Accession Number ML2007OR1 05)

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 ofTS 5.3.1.1 and 5.3.1.2 EPID L-2020-LLA-0046, dated August 4, 2020 (ADAMS Accession Number ML20203M368)

3. Ameren Missouri letter ULNRC-06602, Revision to Technical Specification 5.3. 1 and Deletion of Technical Specifications 5.3. 1 1 and 5.3. 1 .2 EPID 2020-LLA-0046, dated September 2, 2020 (ADAMS Accession Number ML20246G738)

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 afready and appropriately specified in the Operating Quality Assurance Manual (OQAM).

8315 County Road 459 Steedman MO 65077 AmerenMissoun corn

ULNRC-06626 December 22, 2020 Page 2 of 4 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. The RAT response was submitted to the staff in Reference 3 on September 2, 2020. During a follow-up conversation with the staff reviewers on October 1, 2020, representatives for Ameren Missouri proposed to revise Final Safety Analysis Report (FSAR) sections 1 3 1 3 1 1 8 and 1 3 1 3. 1 1 9 (to clarify text therein related to the LAR) and provide those revisions to the staff. This letter provides the revised FSAR sections (per the enclosure to this letter).

The additional information provided in this supplemental response has no impact on the TS change requested and described in the LAR. As such, these changes do not change the No Significant Hazards Consideration conclusions reached in the EAR, 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 50.91, Notice for public comment; State consultation, Section (b)(l), a copy of this supplemental 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.

Ifthere 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, c:/7& D3%

R gerC. Wink Manager, Regulatory Affairs Executed on: December 22, 2020 JPK\mlp

Enclosure:

Revised FSAR Sections 1 3. 1 .3. 1 1 8 and 13.1.3.1.19

ULNRC-06626 December 22, 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

$201 NRC Road Steedman, MO 65077 Mahesh Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O$B1A Washington, DC 20555-0001

ULNRC-06626 December 22, 2020 Page4of4 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 N$RB Secretary Ms. Melissa Friel, REP Manager (SEMA)

STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Katie Jo Wheeler (DNR)

- W - . .

Enclosure to ULNRC-06626 Revised FSAR Sections 13.1.3.1.18 and 13.1.3.1.19 5 pages

Enclosure to ULNRC-06626 Page 1 of5 SUPPLEMENTAL INFORMATION 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 afready specified in the Operating Quality Assurance Manual (OQAM) for Callaway. The U.S. Nuclear Regulatory Commission (NRC) staff personnel reviewing the application determined that additional information was required to complete the review. The request for additional information (RAI) was electronically transmitted to Callaway on August 4, 2020 (ADAMS Accession No. ML20203M368). The response to the RAI questions was provided to the NRC staff via correspondence dated September 2, 2020 (ADAMS Accession No. ML20246G738).

Following NRC staff review of the RAI response, a phone conversation on October 1 2020, between NRC reviewers and Ameren Missouri representatives explored the meaning of content included in Final Safety Analysis Report (FSAR) section 13. 1 .3, Qualification Requirements of Nuclear Plant Personnel. Specifically, FSAR sections 13.1.3.1.18 and 13.1.3.1.19 each identify three different supervisory or technician positions, and from a literal reading of these FSAR sections, it would appear that they would allow unrestricted substitution of experience requirements between the positions in each section, which is not consistent with the requirements of ANSI/ANS 3.1-1978, Standard for Selection and Training of Personnel for Nuclear Power Plants. During this conversation, Ameren Missouri representatives agreed that changes to these FSAR sections were appropriate to ensure clarity in the manner in which personnel occupying these positions comply with the experience and educational requirements specified in ANSI/ANS 3 1-1978. In addition, to promote clarity and consistency with the remaining portion of FSAR section 13. 1 .3, it was determined that the experience and education requirements for each position identified in FSAR sections 13. 1 .3. 1 1$ and 13.1.3.1.19 should be separately specified.

The attachments to this enclosure show the changes that have now been made to FSAR sections 13.1.3.1.18 and 13.1.3.1.19 per License Document Change Notice (LDCN) 20-0027. This LDCN was processed in accordance with station procedures governing changes to the FSAR. The FSAR changes were evaluated against the requirements of 10 CFR 50.59 and 10 CFR 50.54(a) and were determined to not require prior NRC review and approval. These changes are reflected in FSAR Interim Revision OL-24c. Attachment 1 provides a red-line version of the affected FSAR text depicting the changes made. Attachment 2 provides a clean version of the affected pages.

Enclosure to ULNRC-06626 Page 2 of 5 Attachment 1 Red-line version of changes made to FSAR sections 1 3 1 .3. 1 1 8 and 13.1.3.1.19 CALLAWAY SA -

years experience shall be related technical training. A maximum of four years of this five years experience may be fulfilled by related technical or academic training.

2. High School education or equivalent.

13.1.3.1.18 Chemistry Supervisor, Radiation Protection Supervisor, and Radwaste Operahons y

.. . S 1 i- mum of four years of experience in applier1 bcatii ph9cs

\

cheiTIIstry Iddiouler J y tic rJ te dutnities (r%l education orequivalent. ---.

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13.1.3.1.19 Radiation Protection Technician, Chemistry Technician, and Radwaste Trainer Operator nse B j__.H+gflShol education or I 3.1 .3.1 20 Supervisor, Quality Control 1 . A total of seven years of power plant experience of which two years shall be nuclear power plant experience. A maximum of four years of the remaining five years of experience may be fulfilled by satisfactory completion of related technical or academic training.

2. High school education or equivalent.

1 3.1 .3.1 .21 Director, Training I Bachelors Degree including courses in educational and technical subjects.

2. 4 years of professional level experience, of which 2 years shall be nuclear power plant experience.

3. Tr&ning in educ&ion& techniques or equivalent, if not included in the Bachelors Degree course material.

If the Director, Training meets the above experience requirements and training in educational techniques, he need not have a Bachelors Degree provided that the Manager, Technical Training or the Manager, Operations Training meets or exceeds the degree requirement.

13.1-18 Rev. OL-24 11119

Enclosure to ULNRC-06626 Page 3 of 5 Insert A:

Chemistry Supervisor

1. A minimum offouryears ofexperience in applied chemistry activities.

2. High School education or equivalent.

Radiation Protection Supervisor

1. A minimum of four years of experience in applied radiation protection activities.

2. High School education or equivalent.

Radwaste Operations Supervisor

1. A minimum of four years ofexperience in applied radwaste activities.

2. High School education or equivalent.

Insert R:

Chemistry Technician 1 . Three years of working experience in chemistry, of which one year should be related technical training.

2. High School education orequivalent.

Radiation Protection Technician I . Three years of working experience in radiation protection, of which one year should be related technical training.

2 High School education orequivalent.

Radwaste Trainer Operator 1 . Three years of working experience in radwaste, of which one year should be related technical training.

2 High School education orequivalent.

Enclosure to ULNRC-06626 Page 4 of 5 Attachment 2 Clean version of changes made to FSAR sections 1 3 1 .3. 1 1 8 and 13.1.3.1.19 CALLAWAY SA -

years experience shall be related technical training. A maximum of four years of this five years experience may be fufilteU by related technical or academic training.

2. High School education or equivalent.

13.1.3.1.18 Chemistry Supervisor, Radiation Protection Supervisor, and Radwaste Operations Supervisor Chemistry Supervisor I . A minimum of four years of experience in applied chemistry activities.

2. High School education or equivalent.

Radiation Protection Supervisor 1 . A minimum of four years of experience in applied radiation protection activities.

2. High School education or equivalent.

Radwaste Operations Supervisor I A minimum of four years of experience in applied radwaste activities.

2. High School education or equivalent.

I 3.1 .3.1 .19 Radiation Protection Technician, Chemistry Technician, and Radwaste Trainer Operator Chemistry Technician I . Three years of working experience in chemistry, of which one year should be related technical training.

2. High School education or equivalent.

Radiation Protection Technician I . Three years of working experience in radiation protection, of which one year should be related technical training.

2. High School education or equivalent.

13.1-18 Rev. OL-24c 12120

Enclosure to ULNRC-06626 Page 5 of 5 CALLAWAY SA -

Radwaste Trainer Operator 1 Three years of working experience in radwaste. of which one year should be related technical training.

2. High School education or equivalent.

13.1.3.1.20 Supervisor, Quality Control 1 . A total of seven years of power plant experience of which two years shall be nuclear power plant experience. A maximum of four years of the remaining five years of experience may be fulfilled by satisfactory completion of related technical or academic training.

2. High school education or equivalent.

13.1.3.1.21 Director, Training

1. Bachelors Degree including courses in educational and technical subjects.

2. 4 years of professional level experience, of which 2 years shall be nuclear power plant experience.

3. Training in educational techniques or equivalent, if not included in the Bachelors Degree course material.

If the Director Training meets the above experience requirements and training in educational techniques, he need not have a Bachelors Degree provided that the Manager, Technical Training or the Manager, Operations Training meets or exceeds the degree requirement.

13.1.3.1.22 Manager, Operations Training 1 . Shall hold or shall have held a Senior Reactor Operators license for Callaway Plant or a similar unit or shall have been certified for equivalent Senior Reactor Operator knowledge.

2. 3 years of nuclear power plant experience.

1 3. 1 .3.1 .23 Technical Training Manager 1 . 3 years of nuclear power plant experience 13.1-19 Rev. OL-24c 12/20