ML20006D094
| ML20006D094 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/31/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9002120083 | |
| Download: ML20006D094 (7) | |
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F.. l f fl f5 BALTIMO RE - GAS'AND ELECTRI CHARLES CENTER. P. O. BOX 1475. BALTIMOR E, MARYLAND 21203 GEORGE C, CREEL - January 31, 1990 vice entsioc.n NucLean E,senov y 400 peo 4 ass U, S. Nuclear Regulatory' Commission . Washington, DC 20555 - ATTENTION: Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nosc 1 & 2; Docket Nos. 50-317 & 50-318 Proposed Change ~ to the-Quality Assurance Program Description in the Final Safety Analysis Renort Gentlemen: In accordance with 10 CFR 50.54(a)(3), we request Nuclear Regulatory Commission (NRC) -review and' approval of a temporary change to the Baltimore Gas nnd Electric Company , (BG&E) quality assurance program as described in the Calvert Cliffs Final Safety = Analysis ' Report, The - proposed change has been reviewed -in accordance with our Quality Assurance Procedure QAP-1, ' Control of Procedures," and has been determined to result in ' reduction of a quality assurance program commitment. In accordance with 10 CFR 50.54(a)(3)(ii),. those pages of the E Final Safety - Analysis Report - that are affected by .this request have been marked to reflect the proposed change and are attached. ' I. BACKGROUND -The BG&E Quality Assurance Policy, as described in Chapter IB, Table IB-1 of the Final Safety Analysis Report, specifies that plant procedures will be reviewed by a person who is knowledgeable in the area affected by the procedure every two years. This commitment is in response to specific guidance in Regulatory Guide 1.331 and ANS - 3.2/N18.7-1976, Section 5.2.15. Test procedures that are used less often than every two years or that are performed at unspecified frequencies have unique review requirements and are not within the scope of this request. Since early 1989 we have been in the process of implementing a major Procedure Upgrade Program (PUP). During PUP implementation, the periodic review status for some of the procedures covered under the PUP lapsed. in order to address this condition,- we are currently in the process of reviewing our periodic procedure review progr m and the periodic review status relative to-the procedures under this program, it is our intent for each procedure or group of procedures (by type) covered under the PUP to either: (1) complete the required periodic review within its two-year interval, or (2) complete periodic review of the procedure prior to the next use, or (3) evaluate and justify continued use of the procedure until the procedure has been upgraded under the PUP. O Mh0/4/ f; [k,' Ag/ 7 i1 /M8 9002120083 90G131 O / PDR-ADOCK 05000317 P PDC ti
{4' s 3 Document Cintrol Desk. 'J January 31.,1990 Page 2 l II. PROPOSED CHANGE We request NRC approval of a temporary, one-time change to the periodic review interval for those procedures that are scheduled to be addressed under the. PUP, as shown on the attachment. The proposed change would allow, with a documented justification, the periodic review interval to be extended for certain of these procedures until they-can be extensively reviewed and revised under the PUP. Under this change, procedures or groups of procedures (by type) for which the j periodic review has lapsed will either be restricted from use until they can be reviewed, or a justification for their continued use will be documented. After a procedure has been addressed by the PUP the periodic review schedule for-that procedure will be immediately returned to a two-year interval. Following completion of the PUP effort (currently scheduled for December 1992), the quality assurance program commitment to perform periodic procedure reviews on a two-year interval will be fully reinstated. The - administrative process for controlhng implementation of this program change, including the interim criteria for justifying use of a procedure for which the biennial review has lapsed, will be proceduralized. l 111. RE ASON FOR PROPOSED CHANGE . As outlined in our Performance improvement Plan implementation Program, BG&E has dedicated - significant; resources to developing and implementing a comprehensive upgrade of plant procedures under the PUP The PUP goal is to improve management control of plant configuration and udministrative functions through improvements in procedure adequacy, consistency, and human' factors considerations, in order to achieve this goal in the most effective manner, plant ' procedures will be prioritized within each functional discipline (i.e. l operations, maintenance, chemistry, etc.) and will be addressed by the ' PUP l according to several criteria: importance to the safety of plant operations, l frequency of use, and usability in the present condition. L The improvements in procedure' quality that are forthcoming from the Procedure Upgrade Program are considerably greater than those derived from the routine periodic review program. The PUP improvements will lead to reductions in personnel errors and regulatory non-compliances, and greater design and 'L configuration control. The periodic review process competes with the PUP for the same resources. We believe that proper priority and resource allocation should stress improving procedures based upon their importance to safe plant -operations rather than the periodic review schedule alone. The flexibility that would be provided by this change would allow us to dedicate our resources in the most effective manner. We have recently committed to providing the NRC examples of upgraded procedures that are the prefjoct of PUP, and will do so at your convenience.
{c Document C:ntr:1 Desk p"~ ~ January 31,-1990 Page 3: i. IV. BASIS FOR CONCLUDING CONTINUED COMPLIANCE WITH 10CFR 50. APPENDIX B We believe that the procedures governing plant operational activities at Calvert Cliffs are adequate as currently written and that the requested extension will. not result in an operational safety concern. This confidence comes in part from recent measures we have taken. Concentrated management efforts have instilled a site-wide awareness of the need for verbatim procedural compliance. Additionally, plant personnel now understand fully that work is to be stopped when procedural-difficulties are encountered, and that work is not-to be resumed until the procedural difficulties are resolved. Both of these work practices-were observed and commended Ly the NRC Readiness Assessment Team.in November 1989. As a final measure, a step-by-step L walk-through of key operations procedures has been performed to ensure their technical adequacy, and weaknesses have been corrected. l-Under the proposed temporary change, procedures would either be periodically reviewed within the two-year, interval, reviewed prior to use, or would have a documented justification to allow their use without a periodic review. This approach will ensure continued compliance with 10 CFR 50, Appendix B, in that the L program, as -. temporarily - modified, would retain controls that will provide reasonable assurance of quality in procedures important to safety. 1 ) Implementation of 'the proposed periodic review extension will not require a change to l the operating license. 'The operating license requirement to perform periodic procedure reviews is established in Technical Specification 6.8.2. Technical Specification 6.8.2 states that-procedures will be " reviewed periodically as set forth in administrative L procedures." Since the operating license does not stipulate a specific periodic review 't interval, compliance with Technical Specification periodic review requirements would.be . maintained by implementation of the applicable administrative procedures, as revised to reflect the temporary - change in the quality assurance program that is the subject of this request. Should you have any further questions regarding this matter, we will be pleased to discuss them with you. Very truly yours, I GCC/RJP/miv Attachments
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'.f'. -'... e i,. ' 1 rl Nh F 'k - Doctment Contr21 Desk . January 31,l1990 Page 4; 3 .b cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra.NRC D. G. Mcdonald,NRC ~ W. T. Russell, NRC ? J. - E. Beall, NRC , T. Magette, DNR. 7 P. K. Eapen, NRC ' E 1 l. L 1 I 1.: r l l l 1 l
(;. - x TABLE IB-! ]
- BALTIMORE GAS AND ELECTRIC COMPANY'S POSITION
-{i ON GUIDANCE CONTAINED IN ANSI STANDARDS Revision of Industry Standards Applicable to the - Baltimore Gas and Electric Quality Assurance Program Requirement i Some'of the Industry St ds listed in Secti .2 identify other Standards that are required, and some Regulatory es d the revisions of those Standards that i are acceptable to the NRC. Response -
- I BG &E's Program was developed to respond to the spec evision of the docum isted in Section IB.2 and is not necessarily rer,ponsive to other uments in the referenced Industry Standards.
ANS 3.2 - 1976 Item 1 Requirement (. Section 2.0 defines "Onsite Operation Organization" and " Operating Activities." Both definitions imply that the same organization performs both operations activities and maintenance activities.
Response
BG&E's NMD per' forms mechanical maintenance and modification and maintenance l ) on electrical equipment and on instrument and control equipmentt item 2 ' Requirement Section 5.2.15 requires that plant procedures shall be reviewed by an Individual- [. knowledgeable in the area affected by the procedure every two years to determine if' changes are necessary or desirable. c 1
Response
j BG&E applies this requirenwnt of a two-year review to all plant procedures except L test procedures performed less often than every two years or at unspecified L frequencies. These are reviewed no more than 60 days before performance. k EEgr T g REV. 5 IB-35 l-l. l
.g .z b Reas5n - b Technical Support Procedures (TSPs) and others like them'are ltten for a.one-R < time-only performance and kept for reference for. future similar tests if they are used again, they are reviewed _ and modified to meet conditions existing at the time' of. _ perf ormance. Some Surveillance Test, Procedures (STPs) are performed every three to five They too are. reviewed before each performance to ensure that they are years.- compatibl
- l h existing conditions and responsive to current needs.
> j g.,. ANSI N45.il - 1973 - Reo ' ement Sub ction 3.2 outlines requirements for demineralized water.
Response
BG&E specif t tions for demineralized water are different an the specifications outlined in the standa I Reason. BG&E specifications -fo demineralized wate are consistent ' with guidelines .provided by the. Nucle'ar Steam Supply System - pplier. lBG&E specifications are _f. generally more restrictive than thos specified b - NSI N45.2.1. ~ 1 ANSI N 2.2'- 1972 I Item 1 Reautrement o site and off-site personnel Subsection 2.4 cou be interpreted to.mean that who. perform any insp tion, examination, or testing activita related to the packing, shipping, receiving, torage,.and handling of items for nuclea wer plants shall be . qualified in accor nce with ANSI N45.2.6. i l Response - requires that only persons who are responsible for approvin items for BQ ndorses nee shall be qualified in accordance with Regulatory Guide 1.58 (whic 1 accep N45.2.6)' and that personnel who verify that storage areas meet requireme s will i AN SI qualified to either Regulatory Guide 1.58-(which endorses - ANSI N45.2.6) or 45.2.23. ((_ REV.4 IB-36 V ,r
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f_ Insert "A" (new paragraph) A one-time extension of the two-year review requirement has been allowed for plant proceduces until they can be addressed under the Procedure Upgrade - Plan (PUP) conditional upon a documented justification. Procedures or groups of procedures.(by type) that have lapsed' periodic reviews and that do not have a documented justification I for continued use will be restricted from use until they are either reviewed or justification is provided. The extension will expire for each procedure on an individual basis once it has been revised under PUP. The PUP is described in the Performance improvement Plan transmittal letter from G. V, McGowan (BG&E) to J. M. Taylor (NRC) dated July 31, 1989, and is expected to be complete in December 1992. 1 Insert "B" (new paragraph) j Justification for the one-time extension of two-year review requirements is provided in our extension request letter from G. C. Creel (BG&E) to the USNRC Document Control - Desk, dated January 31, 1990, i I' l I i m}}