ML20011E823
| ML20011E823 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/09/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9002220535 | |
| Download: ML20011E823 (3) | |
Text
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'h BALTIMORE GAS AND i
ELECTRI l
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k CHARLES CENTER P.O. BOX 1476 BALTIMORE, MARYLAND 21203 February 9,1990 oconoc c cncet Vice PassiotNT Nucts An cNtn0Y
. (aoi) eso eess
-_U. S. Nuclear Regulatory Commission Washington, _DC 20555 ATTENTION:
Document Control Desk i
SUBJECT:
Calvert. Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Proposed Change to the-Quality Assurance Description in the Final Safety Analysis Report
REFERENCES:
(a) Letter from Mr. G. C. Creel (BG&E) to Document Control Desk (NRC), dated January 31 -1990 Gentlemen:
The attached pages. from our Final Safety Analysis Report (FSAR) supercede those i
' provided in the attachment to reference (a). The revised attachment pages reflect the j
fact that' Technical Support Procedures have been replaced by Engineering Test j
Procedures. This matter has been discussed with Mr. II. I. Gregg of the Region I staff and determined to be acceptable.
A Should 'you 'have any further questions regarding. this matter, we will be pleased to discuss them with you.
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Very truly yours, J
/
GCC/RJP/bjd t
Attachment
= cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire
- R. A.Capra, NRC D. G. Mcdonald, Jr., NRC
- W. T. Russell, NRC J. E. Beall, NRC p1gl[h T.' Magette, DNR
- P. K.Eapen, NRC
.11. I. Gregg, NRC 00k 9002220535 900209 N
- /t DR ADOCK 05000317 p PNU
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TABLE 184 -
Y BALTIMORE GAC AND ELECTRIC COMPANY'S POSITION
{
OW GUIDANCE COWTAINED lh ANSI STANDARDS 1
Revision of Industry Standards Anotleable to th B timore Ces and Electric Quality Assurance M aram Renutrement Some of the Industry Standards liste Section it.2 identify other Standards that are required, and some Regulatory O p define revisions of those Standards that ere-acceptable to the NRC.
Response
BG&f's Program was developed to respond to the specific revision o e documents listed Section 15.2 and is not necessarily responsive to other documents list in the r
renced Industry Standards.
ANS 3.2 197j Ites i E. taw.lr.tasM Section 5.2.15 requires that plant procedures shall be reviewed by an individust knowledgeable in the area affected by the procedure every two years to determine if changes are necessary or desirable.
Response
BG&E applies this requirement of a two year review to att plant procedures except test procedures performed less of ten than every two years or at unspecified frequencies. These are tad u ore than 60 days before performance.
. h "A*
Rea l
Engineering Test Procedures (ETPs) and others like them are written for a one time only performance and kept f or ref erence for f uture - similar tests. If they are used again, they are reviewed and modified to meet condi t ionr, existing at the t ime.. of performance.
Some Surveillance Test Procedures (STPs) bre performed every three to five years.
They too are reviewed before each performance to ensure that they are compatible with.
exicting conditions and responsive to current needs.
9 TY REY. 9 18 35
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'A' (now paragraph)
A one-time extension of the two-year review requirement has been allowed for plant procedures ' until they can be addressed under the Procedure Upgrade Plan (PUP) conditional upon a documented justification. Prewdures or groups of procedures (by type) that have lapsed periodic reviews and that do not have a documented justification for continued use will be restricted from use until they are either reviewed or l
' 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.
Insert "B" (new pungraph)
(
Justification for the one-time extension of two-year review requirements-is provided in our extension request letter frc a G. C. Creel (BG&E) to the USNRC Document Control Desk, dated hauary 31, 1990.
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