ML20012D350
| ML20012D350 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/13/1990 |
| From: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9003270218 | |
| Download: ML20012D350 (2) | |
Text
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l' MAR 131990 Docket No. 50-317 50-318 Baltimore Gas and Electric Company ATTN: Mr. George C. Creel Vice President Nuclear Energy Calvert Cliffs Nuclear Power Plant MD Rts 2 & 4, P.O. Box 1535 Lusby, Maryland 20657 Gentlemen:
Subject:
10CFR 50.54 QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE REVIEW
Reference:
Letter dated January 31, 1990, G. C. Creel to U.S. Nuclear Regulatory Commission transmitting changes to the Calvert Cliffs Quality Assurance Program We have reviewed the proposed change to Calvert Cliffs quality assurance program as described in the reference letter..The Region I staff has found the temporary changes acceptable since the intent of 10 CFR 50, Appendix B continues to be satisfied.
The proposed changes are approved based on your commitments to:
Perform periodic reviews of procedures; 1) within the two year period, or
- 2) prior to being used, or 3) evaluate and justify continued use until the procedure has been upgraded onder the Procedure Upgrade Program (PUP).
Fully reinstate the two year procedure review interval at the completion of the PUP.
Please be advised that it is important that your scheduled December 1992, PUP completion date be maintained. The effectiveness of your QA program and procedure implementation will continue to be the subject of routine regional inspections.
Sincerely, Original Signed By:
4 Marvin W. Hodges k9003130500g7 90032
$DR Marvin W. Hodges, Director Division of Reactor Safety 0FFICIAL RECORD COPY YEROKUN2/8/90 - 0001.0.0 02/13/90 J
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MAR 131990 Bal'timore Gas & Electric Co.
2 cc w/ enc 1:
W. Lippold, General Supervisor, Technical Services Engineering T. Magette, Administrator, Nuclear Evaluations J. Lemons, Manager, Nuclear Outage Management L. Russell, Manager, Calvert Cliffs Nuclear Power Plant J. Walter, Engineering Division, Public Service Commission of Maryland K. Burger, Esquire, Maryland People's Counsel r
P. Birnie, Maryland Safe Energy Coalition Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Maryland (2) bec w/ enc 1:
Region I Docket Room (with concurrences)
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J. Linville, DRP C. Cowgill, DRP D. Limroth, DRP K. Lathrop, DRP O. Mcdonald, NRR PA0 (24) SALP Reports Only M. Conner, SALP Reports Only J. Dyer, EDO M. Callahan, OCA jl)
RI:DRS RI:DRS RI:DRS RI:DRS prEapen Yerokun Durr Hodges 2/$ /90 2/4/90 3//j/90 3'/3/90 0FFICIAL RECORD COPY YEROKUN2/8/90 - 0002.0.0 02/08/90 j
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- K, BALTIMORE S.'
OAS AND ELECTRI CHARLES CENTER
- P. O. 90X Wrs. BALTlWORE, MARYLAND 31303
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January 31, 1990 v"
ave m a a.ev te.o U. S. Nuolear Regulatory Com=tanton Washington, DC 20$55 ATTENTION:
DocumentControlDesk SUBJECP..
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50 318 Proposed Change to the Quality Assuras se Program Description la the Final Safew Analvain R=a t Gentlemen:
In accordance with 10 CFR 50.54(aX3), we request Nucieni Regulatory Commle*8~
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review and appsoval of a temporary change to-the Baltia ore Oas and Elect
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(BO&E) quality assurance program as described in th> Calvert Cliffs a
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%fety Analysis Report. The proposed change has been reviewed in accordance with o..
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!ity Assurance Procedure QAP-1, ' Control of Procedures,' and has been determined to result in reduction of a quality assurance program commitment In accoris e with 10 CFR -
50.54(aX3Xil). those pages of - the Pinal Safety Analysis Report the are affected by this request have been marked to reflect the proposed change and ' are attached.
I.
BACKGROUND The BG&E Quality Assumace Policy, as described in Chapter 18. Table 1B-1 of the Final Safety Analysis Report, specifies that plant procedures will be reviewed by a person who is knowledgeable in the area affectcd by the procedure :every two years. This commitment is in response to specific guidance in Regulatory Guide 1.33 and ANS 3.2/N!8.7-1976, Section 5.2.15. Test procedures that are used less often than every two ' years or that are performed at unspecified freque'ncies 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 implementaton, 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 onir periodic procedure review program 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 e. ther: (1) complete the required periodic review within its two-year interval, or (:!) complete periodic ' review of the procedure prior to the next uso or (3) evaluale and justify continued use of A
u the procedure until the procedure has been upgraded under the PUP.
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Document Control Desk Janary 31, 1990 Page 2 H.
PROPOEED 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 vould allow, with a documented justification, the periodic review interval to be. satended for certain of these procedures until they can be extensively reviewed and revised under the PUP.
Under this change, procedures or groups of proce lures (by type) for which the periodic review has lapsed will either be restricta l from use until they can be reviewed, or a justification for their continued te 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 laterval.
Following completion of the PUP effort (currently scheduled for December 1992),
the quality assuranos program commitment to perfori a periodic procedure reviews on a two-year interval will be fully reinstated.
The administrative proossa for controlling implemen.tation of thl program change, including the interim. criteria for justifying use 4 a procedure for ~which the biennial review has lapsed, will be procedur 11:et III.
JtEASON FOR PROPOEED CHANOE As outlined in our Performance Improvement Plan Implementation Program, BO&E-has dedicated significant resources to deve sping and implementing a
comprehensive upgrade of plant procedures under the PUP. The PUP goal. is to d
improve management control of plant configuration and administrative functions through improvements in procedure adequacy, consistency,.and human factors considerations. In order to achieve this goal is the most effective manner, plant procedures will be prioritized within asch functional discipline (i.e.
operations, maintenance, chemistry, etc.) and will be addressed by: the PUP according to several criteria: importance to tha safety of plant > operations, frequency of use, and usability in the present c< ndition.
The improvements in procedure quality that are "orthcoming from the Procedure hose derived from the routine Upgrade Program are considerably greater than 1
periodic review program. The PUP improvemenis will lead to reductions in personnel errors and regulatory non-compliances, and greater design and configuration control. The periodic review procesa competes with the PUP for the same resources. We believe that proper sriority 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 com nitted to providing the NRC examples of upgraded procedures that are the product of PUP, and will do so at your convenience.
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- e Document Control Desk January 31. 1990.
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page 3 IV.
EAem pOR CONCLUDING CONTINUrn coMPLIANC E WITH 10 CFR 50. APPENDIY 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. His o>nfidence comes in part from recent measures we have taken.
Concentrated management efforts have lastilled a slie-wide awareness of, the need for verbatim procedural compliance. Additionally, pant personnel now understand fully that work is to be stopped when procedural dafficulties are encountered, and that work is not to be resumed until tle procedural difficulties are resolved. Both of these work practices were observed and commended by.the NRC Raadlamaa Asesesment Team in November 1989. As O final measure, a step-by-step walk-through of key operations procedures has bem performed to ensure their I
technical adequacy, and weaknesses have been correrted..
l Under the proposed temporary change, procedures.would either be periodically reviewed within the two-year laterval, reviewed pilor to use, or would have a
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documented justification to ' allow their ' use wittout a periodic review..nis approach will ensure. continued compliance with 10 C1R 50, Appendix B, in that the i
program, as temporarily modified, would retain controls that will provide reasonable assurance of quality in procedures important to safety.
l Implementation of the proposed periodic review extension will not require a change to l
l the operating license. The operating license requirement to perform periodic procedure l
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 4
procedures." Since the operating license does not stipuh te a specific periodic review laterval, 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 intter, we will be pleased to discuss them with you.
Very truly yours, 1
l-f i!
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os D. A. Brass, Esquire J. E. Silberg. Esqube R. A.Cora,NRC D. O.ndoDonald,NRC W. T. Russou, NRC '
'J. E.BeeB NRC T. Magotte, DNR P. K.Bapen.NRC d
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Document Control Desk January 31, 1990 Page S
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J. A. Tiernaa/C. J. Frankua, Jr.
C. H. Crose/P. E. Kats Please be save to sosse i
R. E. Denton/R. P. Heibol to year 085EC Ahernate.
R. C. DeYoung R. M. Douglass/R. F. Ash C. C. Lawronos, m/M. J. Miernicki F. J. Muano/M. Osvruas R. B. Food, Jr./8. R. Bombaum T. N. Pritchett/E. L Bauereis L. B. RusseR/J. R. Im J. M. Zapko, Jr.
W. J. Lippold/B. 5. Montgomery J. H. Walter C. M. Rios R. O. Staker J. J. Coanouy O. J. PnHbota J. B.Baum L. D. Oraber G. L. Bell /T. E. Noard M. L. Stons 4 R. J. Poche' D. Latham/H. Gammage J. T. Carrull A. B. Anujo
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4 TABLEIB-1
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BALTIMO E' GAS AND ELECTRIC CO.W ANY'S P.051T10N ON GUIDANCE CONTAINED IN ANSI STANDARD 5 Revision of Indu sury 5tandar<is Apoll cable to the.
Baltimore Gas and F, ectric Qua ity Ass trance Program Resulrement Some of the industry ds listed in.5ect
.2 Identify other Standards that are required, and some Regulatory a
the nevisions of those Standards that are acceptable to the NRC.
Renannan Y
BG&E'n ogram 'was developed to respond to the spec lalon of 'he t
docum sted in Section 18.2 and is not necessarilp responsive to oth ments n the referenced ladustry Standards.
l V
ANS 3.2 - 1976 m
Ite m 1
.?
Reculrement y'
5ection 2.0 defines "Onsite operation organisallon" and " operating'Activltles."
Both definitions imply that the same organization performs both operations activities and maintenance activities.
_Raantif BGkE's NMD performs mechanical maintenance aid modification and maintenance l
on electrical equipment and on instrument and control e gulpmente-Item 2 Reeutrement Section1.2.15 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.
Response
BG&E applies this requirement of a two-year review.to all plant procedurn except test procedures performed less often than every two years or. at unspecified frequencies. These are reviewed no more than 60 days before performance.
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' REY.S 15-35 l
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ASS!*D.
l Technical Support Procedures (TSPs) and others Bhe them.'are written for a one-(
i time-only performance and kept for reference for. futura similar tests. If they are used f
,again, they are reviewed and modified to meet cond tions existing at the time o performance.
Some Surveillance Test. Procedures (STPs) are lerforrned every three to five The'y too are reviewed before each perform mos to ensure that they.are l
r years.
ting conditions and responsive to cur'ent needs, compa i
n AN53 N45Jh.I - lid
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6 R
ement S
tion 5.2 outlines requirements for deminer'at med water.
I Reanenet n the sp' cifications BG&E speelf tions for deminerallaed water are different e
outlined in the stand s
ESSIEL SC&E specifications f dominerallaed we are consistent with deunes
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provided by the Nucle'ar Stear;.
upply System-lier.
BC&E speciti ens are generally more restrictive than fled 1 M45.2.1 l.
-l ANSI
_ * * - 1972
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4 Reevirement Subsection 2.4 co be ' interpreted to mesh thet to' and offdtte personnel whoDrform any ins tion, examination, or testing actlel related to the packing, shipping, receivl orage, and handling of items f r nucle wer plants shall.be quaufled in accor with ANSI N45.2.6.
- 3333333, B
requires that only persons who are' responsible for approvin items for nee 'shall be_quallfled in accordance with Regulatory Guide 138 (wh.
root sece p A
. N45.2.6) and that personnel who verify that storage areas meet' require will ed to eithet ' Regulatory Guide 1.58 (which endorses ANSI N.45.2 6) or
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- 45. 25.
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REY.4 15 56
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lasert
'A' (now paragraph)
A one-thne extoosion of the two-year review requiteenat has been allowed for plant procedures until they ces be addromed under the 1tocedure 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 for continued use will be restricted from use until they are either reviewed or justirnostion la provided. The extension will expire for each procedure on an individual basis ones It has been revised under PUP. De PUP is described in the Performanos haprovement Plan transmittal letter from O. V. McGowan (BO&E) to J. M.
Taylor (NRC) dated July 31, 1989, and is expected to be complete in December 1992.
Insert '5P (now paragraph',
Justifloation for the one-time extension of two-year rev ew requirements is provided in our extension request letter from G. C. Creel (BG&E) tc the USNRC Document Control Desk, dated January 31, 1990.
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