ML20037D032
| ML20037D032 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/09/1981 |
| From: | Novak T Office of Nuclear Reactor Regulation |
| To: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8105210189 | |
| Download: ML20037D032 (3) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION wAssincrou. o. c. zosss s
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50-317/318 Mr. A. E. Lundvall, Jr.
Vice President - Supply Baltimore Gas & Electric Company P. O. Box 1475 Baltimore, Maryland 21203
Dear Mr. Lundvall:
By letter dated February 18, 1981, you requested an amendment to Section 6.3 of the Technical Specifications relating to qualif.ications of the plant staff members of the Calvert Cliffs Nuclear Power Plant, Units No. I and 2.
As justification for this change, your referenced Draft 1 of the Second Proposed Revision 2 to Regulatory Guide 1.8, dated June 19, 1980.
Section 6.3 o# the existing Technical Specifications refers to staff qualifi-cations as spe.ified by ANSI N18.1-1971 and endorsed by Regulatory Guide 1.8, September 1975. However, both of these referenced documents have been consi-derably revised since,these earlier versions that are referenced in your Technical Specifications.
ANSI N18.1-1971 was revised and issued as ANSI /ANS 3.1-1978, but this 1978 version was never endorsed by a Regulatory Guide. A further revision is now underway and the Standard is to be issued as ANS 3.1.
Meanwhile, Regulatory Guide 1.8 also is in the process of revision. A Second Proposed Revision 2 to Regulatory Guide 1.8 has been circulated for public comment. It endorses, with qualification, a December 6, 1979 draft of the revision to ANS 3.1.
The June 19, 1980 draft of the revision to the Regulatory Guide you referenced in this Technical Specification amendment request was an early version of the Second Proposed Revision 2 to Regulatory Guide 1.8.
The new ANS 3.1 sets :..iaimum qualifications for plant staff members that are considerably hi@er than were specified in its predecessor document, ANSI N18.1-1971. However, it recognizes that licensees may have difficulty finding per-l sonnel who meet these higher minimum requirements, and that there are many well-qualified individuals now serving on plant staffs who may not meet the new requirements. Accordingly, the proposed new Standard includes a caveat that allows licensees to make exceptions for well-qualified personnel who do not literally meet the higher minimum qualifications. The revision to Regulatory Guide 1.8 endorses this concept, but limits the number.of exceptions that can be made at any plant to a small percentage of the plant staff.
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y a-e Mr. A. E. Lundvall, Jr..4 By this request, you are seeking to apply this caveat, as stated in the Second Proposed Revision 2 to Regulatory Guide 1.8, to the existing Technical Specification requirements established by ANSI N18.1-1971.
In so doing, it would provide for an easing of minimum plant staff qualifica-tions that already are less than the desired minimum qualifications as reflected in the draft of the new ANS 3.1 and endorsed by the proposed revision to Regulatory Guide 1.8.
Accordingly, we find this proposed change to the Technical Specifications to be unacceptable and your request of February 18, 1981 is hereby denied.
Instead of attempting to ease the required minimum qualifications of plant staff personnel, you should be attempting to upgrade these qualifications on an expedited basis.
If you have some particular problems with the qualifications of certain individuals, we would be willing to entertain specific exemption requests.
Sincerely, S
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Thomas H. Novak, Assistant Director for Operating Reactors Division of Licensing cc:
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James A. Biddison, Jr.
Ms. Mary Harrison, President Calvert County Board of County Commissioners General Counsel Baltimore Gas and Electric Company Pringe Frederick, MD 20768 P. O. Box 1475 Saltimore, ND 21203 U. S. Environmental Protecticn Agency Region III Office Atta: EIS Coordinator George F. Trowbridge, Esquire Curtis Building (Sixth Floor)
Shaw, Pittman, Potts and Trewbridge 1800 M Street, N. W.
Sixth and Walnut Streets Washington, D. C.
20036 Philadelphia, PA 19106
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Mr. R. C. L. Olson Mr. Ralph E. Architzel Saltimore Gas and Electric Company Resident Reactor Inspector Room 922 - G&E Building NRC Inspection and Enforcement P. O. Box'a37 P. O. Box 1475 Saltimore, MD 21203 Lusby, MD 20657 Mr. Charles 3. Brinkman Mr. Leon 3. Russell Plant Superintendent Manager - Washington Nuclear Operations Calvert Cliffs Nucledar ?ower Plant Conbustion Engineering, Inc.
Baltimore Gas and Electric Company 4853 Cordell Avenue, Suite A-1 Lusby, O 20657 sethesda, MD 20014 3echtel Power Corporation Mr. Bernard Fowler Attn:
Mr. J. C. Judd President, Board of County Comnissicners Chief Nuclear Engineer Prince Frederick, MD 20768 15740 Shady Grove Road Gaithersburg, MD 20760 Director, Criteria and Standards Divisinn Office of Radiation Programs (AHR-450)
Ccchustien Engineering, Inc.
U. S. Environmental Protection Agency Attn: Mr. P. W. Kruse, Manager
'a'ast.ington, D. C.
20460 Engineering Services Mr. W. J. Lippold, Supervisor P. O. Box 500 Windsor, CT 06095 Huclear Fuel Management Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant -
Public Document Roon Calvert County Library P. O. Box la75 Prince Frederick, MD 20673 Baltimore, Maryland 21203 Director, Department of State Planning Quality Assurance Departnent 301 West Preston Street Administrator, Power diant Siting Program 3alticore, MD 21201 Energy and Coastal Zone Administration Department of Natural Resources Mr. R. '4. Douglass, Manager Tawes State Office Buf1 ding Quality Assurance Department Annapolis, MD 21204 Rocm 923 - G&E Building 3altimore Gas and Electric Company P. O. Box la75 3al ti-ore, MD 21203
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