ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A

Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A

ML23229A538
Person / Time
Site:	Callaway
Issue date:	08/17/2023
From:	Witt T Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ULNRC-06824
Download: ML23229A538 (1)

Text

Callaway Plant

.t August 17, 2023 ULNRC-06824 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.36 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 REGARDING OPERATING QUALITY ASSURANCE MANUAL (OQAM) REVISION 36A

References:

1. Ameren Missouri letter ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual (OQAM) Revision 36a, dated June 5, 2023 (ADAMS Accession No. ML23156A670)

2. Ameren Missouri letter ULNRC-06822, "Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (OQAM) Revision 36a," dated June 14, 2023 (ADAMS Accession No. ML23165A241)

3. NRC Letter, "Callaway Plant, Unit 1 - Final Request for Additional Information (RAI) -

Request for Approval of OQAM, Revision 36a - EPID L-2023-LLQ-0000," dated July 19, 2023 (ADAMS Accession No. ML23200A298)

By letters dated June 1, 2023, and June 14, 2023 (References 1 and 2 respectively), Ameren Missouri (Union Electric) transmitted a request to approve a change to the Operating Quality Assurance Program (OQAP) described in the Operating Quality Assurance Manual (OQAM) for the Callaway Plant. During its review of this request, the NRC staff determined that a request for additional information (RAI) was needed to complete its review. The NRC transmitted an RAI to Ameren Missouri in electronic form on July 19, 2023 (Reference 3) and requested that the response be provided within 30 days of receipt. The response to the RAI is attached to this letter as Attachment 1.

.t 8315 County Road 459 : Steedman, MO 65077 : AmerenMissouri.com

.t

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ULNRCO6824 August 17, 2023 Page 2 of 4 During review ofthe NRCs RAI (Reference 3), it was determined that a change should be made to of Reference 1, which provided a markup of Appendix A to the OQAM. Specifically, the change removes discussion of equivalent and nomequivalent positions regarding the education and experience requirements of ANSI/ANS 3 1-2014 for supplemental contract Radiation Protection personnel. This change, which is attached to this letter as Attachment 2, was made to clarify that when supplemental contract Radiation Protection personnel are used to perform safety-related activities, these personnel shall meet the education and experience requirements ofANSI/ANS 3.1-2014 for the position they are assigned.

This letter does not contain new commitments.

Ifthere are any questions, please contact Mr. Tom Elwood at 314-225-1905.

I declare under penalty ofperjury that the foregoing is true and correct.

Sincerely, Todd A. Witt Manager, Regulatory Affairs Executed on: I Z3 Attachments:

1 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (OQAM) Revision 36a

2. OQAM Appendix A Markup

ULNRC-06824 August 17, 2023 Page 3 of 4 cc: Mr. John Monninger 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 Mr. M. Chawla Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-0001

ULNRC-06824 August 17, 2023 Page 4 of 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6500 West Freeway, Suite 400 Fort Worth, 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 K. C. Scott W. A. Witt G. J. Perry D. E. Farnsworth S.G. Kovaleski B. L. Jungmann T. A. Witt T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Ms. Kathleen McNelis (Public Service Commission)

Ms. Claire Eubanks (Public Service Commission) to ULNRC-06824 Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING OPERATING QUALITY ASSURANCE MANUAL (OQAM) REVISION 36a The following is from the NRC's Request for Additional Information transmitted via e-mail on July 19, 2023 (ADAMS Accession No. ML23200A298).

Background

By letters dated June 5, 2023 and June 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23156A669 and ML23165A241), Ameren Missouri Union Electric Company (Ameren) submitted to the U.S. Nuclear Regulatory Commission (NRC) for review and approval a revision to the Operating Quality Assurance Manual (OQAM) for the Callaway Plant that contains change that is a reduction in commitment in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54(a)(4).

Criterion II, Quality Assurance Program, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, states, in part, that the Quality Assurance Program shall provide the indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Ameren proposed to change the education and experience qualifications for the positions of Radiation Protection (RP) First Line Supervisors, Technicians, and Supplemental Personnel from Revision 2 of Regulatory Guide (RG) 1.8, Qualification and Training of Personnel for Nuclear Power Plants, to Revision 4 of RG 1.8. Revision 2 of RG 1.8 endorses the American National Standards Institute/American Nuclear Society (ANSI/ANS) 3.1-1978 standard, while Revision 4 of RG 1.8 endorses the ANSI/ANS 3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, standard for these positions. of the submittal letter, dated June 5, 2023, included a markup to Appendix A of the OQAM. The markup states that When supplemental contract Radiation Protection personnel are used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-2014 for equivalent positions or specified education and experience requirements for non-equivalent positions.

Request for Additional Information (RAI)

The NRC staff has reviewed Amerens proposed change to its OQAM and has determined that the following additional information is required to complete its review.

Ameren is requested to clarify the statement specified education and experience requirements for non-equivalent positions. It is unclear to the NRC staff what non-equivalent positions are referenced in this sentence, and how education and experience requirements for positions that are not equivalent to RP can be used for RP personnel.

to ULNRC-06824 Page 2 of 3 Ameren Missouri Response:

The intent of the proposed OQAM change is to indicate that when supplemental contract Radiation Protection personnel are used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-2014 for the position to which they are assigned.

The proposed OQAM change, as proposed per the mark-up provided in Ameren Missouri's June 5, 2023, letter (identified as Reference 1 in the cover letter), refers to "equivalent" and/or "non-equivalent" positions and their associated education/experience requirements. These are terms currently used in the OQAM, and they were included in the text of the proposed OQAM change. In general, some or many of the various positions in different areas of the plant organization, including those within Radiation Protection, are those that are clearly described or clearly relatable to the positions described in the applicable ANSI standard. Such positions are considered "equivalent" positions. Thus, personnel fulfilling "equivalent" positions are subject to the requirements of the applicable standard (with exceptions noted in some cases). For some areas, however, personnel may be fulfilling "non-equivalent" positions, i.e., positions not described in a potentially applicable standard or not seen as equivalent to what is described in the standard (including those positions that do not involve the performance of activities described in the standard). Such positions would not necessarily be subject to ANSI standard (or other standard) requirements. Thus, "equivalent positions" and "non-equivalent positions" are terms used throughout the OQAM, as previously noted.

For the proposed change, which is only concerned with Radiation Protection positions, including when they are fulfilled by contract personnel, the intent was to indicate that for personnel assigned to Radiation Protection positions considered to be "equivalent" positions, such personnel must meet the education and experience requirements of ANSI/ANS 3.1-2014 (in lieu of ANSI/ANS 3.1-1978). Conversely, those assigned to "non-equivalent" positions would not be subject to the qualification and experience requirements of the ANSI standard (either version).

The change proposed to the affected section of OQAM Appendix A per Reference 1 in the cover letter essentially contains two parts. In the first part of the proposed change, the following is stated:

Regulatory Guide 1.8, Rev 4 issued June 2019 which endorses ANSI/ANS 3.1 2014, applies to equivalent positions within the Radiation Protection organization except for the Radiation Protection Manager.

The second part of the change includes the following wording:

When supplemental contract Radiation Protection personnel are used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-2014 for equivalent positions or specified education and experience requirements for non-equivalent positions.

to ULNRC-06824 Page 3 of 3 The second part of the change is the subject of the RAI, since the concern or question expressed in the RAI is for the wording that addresses "non-equivalent" positions. Specifically, it appears confusion was introduced by the phrase "or specified education and experience requirements for non-equivalent positions," as it is not clear what requirements this phrase is referring to.

Upon re-examination of this second part of the proposed change, it has been determined that it is not necessary to address "non-equivalent" positions in the context of this change since the intent is to address the applicability of ANSI/ANS 3.1-2014 requirements to applicable RP positions, particularly for contract supplemental RP personnel, which can be expressed clearly enough by merely specifying that for RP personnel performing safety-related activities, such personnel shall meet the education and experience requirements of ANSI/ANS 3.1-2014.

Based on the above determination, the proposed change (i.e., the second part of the proposed change) is being revised to eliminate the text that refers to "non-equivalent positions" and their "specified qualification and experience requirements." This should eliminate the confusion that prompted the RAI. Per the revised text for the proposed change, the change will still make it clear that ANS/ANSI 3.1-2014 is the applicable standard for the qualification and experience requirements for Radiation Protection personnel fulfilling equivalent positions (except for the Radiation Protection manager), as well as for supplemental contract Radiation Protection personnel "used to perform safety-related activities."

To indicate the revised change, and as noted in the cover letter, a revised mark-up of the affected section from OQAM Appendix A is provided in Attachment 2. This mark-up supersedes the mark-up that was provided via the letter identified as Reference 1 in the cover letter.

to ULNRC-06824 Page 1 of 2 OQAM Appendix A Markup The enclosed provides an updated markup of the contents of OQAM Appendix A, i.e.,

the section that addresses Ameren Missouri's compliance with Regulatory Guide 1.8.

One page follows this cover sheet.

OQAM Appendix A Markup REGULATORY GUIDE 1.8 REVISION 2 DATED 4/87 Qualification and Training of personnel for Nuclear Power Plants (Endorses ANSI/ANS 3.1-1981 for Shift Supervisor (Section 4.3.1.1), Senior Operator (Section 4.3.1.2), Licensed Operators (Section 4.5.1.2), Shift Technical Advisor (Section 4.4.8), and Radiation Protection (Section 4.4.4) only, and ANSI/ANS N18.1-1971 for all other positions).

DISCUSSION:

Ameren Missouri complies with the recommendations of this Regulatory Guide with the following clarifications and exceptions:

Revision 1, dated 9/75, applies to the position of Radiation Protection Manager only. For the position of Radiation Protection Manager only, Regulatory Guide 1.8, Revision 1, September 1975 is clarified by USNRC HPPOS-020, Clarification of Regulatory Guide 1.8 on Qualification of Radiation Protection Manager. Regulatory Guide 1.8, Rev 4 issued June 2019 which endorses ANSI/ANS 3.1 2014, applies to equivalent positions within the Radiation Protection organization except for the Radiation Protection Manager.

The experience, training, and education requirements for the positions of Shift Manager, Operating Supervisor, and Reactor Operator, and personnel fulfilling the duties of Shift Technical Advisor shall meet or exceed the requirements and recommendations of ANSI/ANS 3.1-1981 as endorsed by the Regulatory Guide 1.8, Revision 2, with the same exceptions as contained in the current revision to the Operating Licensing Examiner Standards, NUREG-1021, ES-202.

For all other positions, qualification and training shall comply with ANSI/ANS 3.1-1978 as clarified below:

Refer to Callaway-SA FSAR Section 13.1 for a discussion of the qualifications of personnel responsible for plant operation and support.

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 met the qualifications of the Regulatory Guide but were not required to be certified.

Ameren Missouri may use additional Ameren employees or contract personnel to augment the unit staff. These groups include, but are not limited to, Ameren personnel from outside Nuclear Generation as well as supplemental Radiation Protection and I&C technicians and QC inspectors. Except for Radiation Protection, when used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-1978 for equivalent positions or specified education and experience requirements for non-equivalent positions. When supplemental contract Radiation Protection personnel are used to perform safety-related activities, these personnel shall meet the education and experience requirements of ANSI/ANS 3.1-2014. As an alternative, these personnel can be qualified for assigned tasks either by Ameren Missouri through its systematic approach to training or by Vendors with Ameren Missouri approved training and qualification programs. Inspection, examination and testing personnel shall meet the requirements for certification as inspection, examination or testing personnel as set forth in Ameren Missouri s commitment to ANSI N45.2.6-1978 given elsewhere in this Appendix.

With regard to Section 5.6 of ANSI/ANS 3.1 - 1978 titled Documentation: Ameren Missouri shall maintain records in accordance with and to meet the requirements of OQAM Section 17 and ANSI N45.2.9 as specified herein.