ULNRC-06177, Operating Quality Assurance Manual Revision 31
| ML15035A275 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/04/2015 |
| From: | Diya F Ameren Missouri |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15035A272 | List: |
| References | |
| ULNRC-06177 | |
| Download: ML15035A275 (9) | |
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WAmeren MISSOURI Fadi M. Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center T 573.676.6411 F 573.676.4056 fdiya@ameren.com February 4, 2015 ULNRC-06177 U. S. Nuclear Regulatory Commission Attn: Docwnent Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:
10 CFR 50.54 10 CFR 50.71*
DOCKET NUMBER 50-483 CALLA WAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 OPERATING QUALITY ASSURANCE MANUAL (OQAM) REVISION 31
Reference:
- 1. Ameren Missouri Letter ULNRC-06051, "Operating Quality Assurance Manual (OQAM), Revision 30," dated October 29,2013 Furnished herewith is OQAM Revision 31. 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 31
- 3. OQAM Revision 30 mark-up, identifying changes through the use of strikeovers and inserts The major changes in this revision include:
several title and organizational changes clarification of wording describing NSRB review and NRC approval of certain design changes implementation of Fire Protection Program audit frequency changes previously approved via License Amendment 206 addition of verbiage to comply with 1 OCFR 72 regarding the Independent Spent Fuel Storage Installation Junction CC & Hwy 0 PO Box 620, MC CA-460 Fulton, MO 65251 AmerenMissouri.com
ULNRC-06177 February 4, 2015 Page2 Revision 31 incorporates OQAM Change Notices14-001, 14-002, & 14-003. These changes were reviewed internally and determined to not represent reductions in commitment to the 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, Director, Nuclear Oversight at 314-225-1589.
I declare under penalty of perjury that the foregoing is true and correct.
Sincerely, Executed on: L/4-} 1.DL5 JSGIHDB/nls F. M. Diya 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 31
- 3) OQAM Revision 30 mark-up, identifying changes through the use of strikeovers and inserts
ULNRC-06177 February 4, 2015 Page 3 cc:
Mr. Marc L. Dapas 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. Fred Lyon Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738
ULNRC-06177 February 4, 2015 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:
F. M. Diya D. W. Neterer L. H. Graessle T. E. Herrmann B. L. Cox J. S. Geyer S. A. Maglio T. B. Elwood Corporate Communications NSRB Secretary STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission to ULNRC-06177 OPERATING QUALITY ASSURANCE MANUAL (OQAM) REVISION 30 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 30. OQAM Change Notices were previously reviewed internally and the OQAM continues to meet the requirements of 1 OCFR50, Appendix B. None of the changes constitute a reduction in commitment to the approved Quality Assurance Program, as previously accepted by the NRC. In all cases, previously described functions are still being performed. These include title changes, changes in assignments of responsibilities, removing an OQAM internal conflict and clarification of meeting frequencies, which are not considered reductions in commitment. The change in Section 18.8.1 could be considered a reduction; however, the NRC has previously approved the changes in License Amendment 206.
New functions documented in this revision do not decrease the level of Commitment to the OQAM. They are additional requirements necessary to meet the various requirements identified above from 10 CFR 72, "Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste."
OQAM CN 14-001 Section Change Description Justification Delete paragraph and Reassignment of the Fuel Cycle Management organization is 1.2.2 reassign Fuel Cycle not considered a reduction as this group is still performing its Management organization function and the change is intended to increase efficiency.
to Nuclear Engineering.
Renumbered subject 1.6 and
- 1. 7 to 1.5 and 1.6 to make Changes in numbering are not considered a reduction in 1.6,1.7 room for new position of Senior Director, commitment.
Engineering.
Added new position of Adding a Senior Director, Engineering is considered an 1.7 Senior Director, improvement in the span of control of the Vice President, Engineering.
Engineering and is not considered a reduction in commitment.
Changed direct reports from Vice President, Engineering to Senior Director, See 1. 7 for change in reporting structure. Removal of 1.8 Engineering. Removed Technical Assistant Director is not considered a reduction in Technical Assistant commitment as this position has been eliminated and duties Director, Special Projects as absorbed within the Engineering organization.
that position has been eliminated.
to ULNRC-06177 Section Change Description Justification Change in reporting structure for fire marshal and fuel cycle Added fire marshal and fuel management to Engineering was done to better align functions 1.8 cycle management to list of with Callaway Energy Center organization. The functions technical support activities.
continue to be performed; therefore, this change does not constitute a reduction in commitment.
Changed title of Radiation This title change was done to align the Callaway Energy 1.9.2 Protection Manager to Center with Ameren Missouri Corporate titles. There is no Manager, Radiation change in duties; therefore, this is not considered a reduction Protection in commitment.
Changed title of Assistant Operations Managers and Chemistry Manager to 1.9.3 Managers, Operations and See 1.9.2 and 1.8 above.
Manager, Chemistry.
Removed fire marshal due to reassignment to Engineering.
Changed Shift Assistant 1.9.3.1 Operations Manager to See 1.9.2 above.
Manager, Operations (shift).
Changed Superintendents, 1.9.4 Maintenance to Manager, See 1.9.2 above.
Maintenance.
Changed Outage Manager; Superintendent, Work Management; and 1.9.5 Superintendent, Planning to See 1.9.2 above.
Manager, Outage; Manager, Work Management; and Manager, Work Management Planning.
Changed Regulatory Affairs Manager, Security Manager, and Emergency 1.11 Preparedness Manager to See 1.9.2 above Manager, Regulatory Affairs; Manager, Security; Manager, and Emergency Preparedness.
to ULNRC-06177 Section Change Description Justification Changed Security Manager and Emergency Preparedness Manager to 1.11.2 Manager, Regulatory See 1.9.2 above Affairs; Manager; Security; and Manager, Emergency Preparedness.
Changed Performance 1.11.3 hnprovementManagerto See 1.9.2 above Manager, Performance hnprovement.
Changed Regulatory Affairs 1.11.4 Manager to Manager, See 1.9.2 above Regulatory Affairs.
Resolved conflict within the OQAM. OQAM Section 1.3 requires an independent overview of nuclear plant safety by Nuclear Oversight. Section 1.20.1 presents a challenge to 1.20.1, Removed language independence; therefore, removal of this challenge is not 1.20.3,&
identifying Nuclear considered a reduction in commitment. Nuclear Oversight will Appendix Oversight as a member of continue to monitor and assess ORC through meeting A
the Onsite Review attendance, audits, and surveillances.
Committee (ORC).
Additionally, this issue was noted in the 2013 Nuclear Industry Independent Evaluation of the Callaway Quality Assurance Program as a challenge to independence and not generally in agreement with industry practice.
Deleted Nuclear Oversight Clarified expertise required to be present on the Onsite Review and added verbiage to Committee. Requirement is not for Nuclear Oversight 1.20.1 &
1.20.1 regarding collective personnel or expertise but expertise in Quality Assurance 1.20.l.g) competence of ORC in Practices. This clarification is not considered a reduction in Quality Assurance commitment as it clarifies an internal conflict with Practices.
commitment to ANSI N18.7.
Clarified NSRB meeting This change clarifies the frequency of the NSRB to account for frequency from at least once 1.21.7 every 6 months to twice per availability of non-utility members and is not considered a year conducted in each half reduction in commitment as the meetings are conducted twice ofthe year.
per year but may not be every 6 months.
Clarified expertise required to be present on the Nuclear Safety Deleted Nuclear Oversight Review Board. Requirement is not for Nuclear Oversight 1.2l.h) with Quality Assurance personnel or expertise but expertise in Quality Assurance Practices. This clarification is not considered a reduction in Practices.
commitment as it clarifies an internal conflict with commitment to ANSI N18. 7.
2.2 Change position guides to Change in the type of documents covering organization is not job descriptions.
considered a reduction in commitment.
to ULNRC-06177 OQAM CN 14-002 Sections Description Justification Clarification that the NSRB This is not a reduction since it is clarifying current only reviews and the NRC practices and aligns NSRB responsibilities with OQAM approves Section 1.21.
design/configuration changes that require a 3.18 change in the Callaway Plant Technical Specifications or a License Amendment per 1 OCFR50.59 prior to implementation.
Remove the sentence that Regulatory Affairs no longer has a presence at the General Regulatory Affairs is Offices and therefore is no longer responsible for records responsible for assuring generated or temporarily stored there. Records are handled 17.6 handling and maintenance by the responsible departments just as is done at the of quality assurance records Callaway Energy Center. This is not a reduction in generated, received, and commitment since records requirements for temporary temporarily stored at the storage and submittal remain the same for General Office General Offices.
records.
18.8.e Delete Section deleted and moved to 18.8.2. This reorganization is editorial and not considered a reduction in commitment.
18.8.2 Changed Fire Protection This is implementing NRC approved changes to the Fire audit frequency and scope.
Protection Program. See License Amendment 206.
OQAM CN 14-003 Sections Description Justification Added various verbiage to comply with requirements The changes documented in this Change Notice do not of 1 0 CFR 72 regarding the decrease the level of Commitment to the OQAM as they Independent Spent Fuel are additional requirements necessary to meet the various General Storage Installation (In-requirements identified above from 10 CFR 72, "Licensing Ground UMAX System and Requirements for the Independent Storage of Spent Pad). Includes various Nuclear Fuel, High-Level Radioactive Waste, and Reactor-reviews as required by 1 0 Related Greater Than Class C Waste."
CFR 72, 72.48, 72. 70, and Subpart G.
1.20.7.b, Added requirements for See General above. Revised wording to be more generic c, and d; ORC to review changes and focus purpose of the review on identifying items that 1.20.8.c made in accordance with requiring NRC approval prior to implementation.
10CFR72.48. Revised wording to clarify intent of review.
to ULNRC-06177 Sections Description Justification 1.21.10.a, Added requirements for See "1.20.7.b, c, and d; 1.20.8.c" above.
b, c NSRB to review changes made in accordance with 10CFR72.48. Revised wording to clarify intent of rev1ew.
2.1 Added notation that manual See "General" above.
complies with 1 OCFR 72, subpart G and reference to new Appendix B.
2.3 Added reference to See "General" above.
2.6; 2.12; Added reference to See "General" above.
5.1 10CFR72, Subpart G 3.18; 3.19; Added reference to See "General" above.
5.6.2; 10CFR72.48 5.6.4; 11.9; 15.6; 17.11.2 OQAM Added new Appendix B.
See "General" above. This appendix defines quality Appendix programs requirements for Callaway Energy Center's Dry B
Cask Storage System.