ML20043G593
| ML20043G593 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/08/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9006200466 | |
| Download: ML20043G593 (4) | |
Text
-
,Q su
/%
BALTIMORC OAS AND ELECTRIC CHARLES CENTER. P. O. BOX 1475.BALTIMOR E, MARYLAND 21203 Otomot C. Catti Vice Patsiotwv Nycat am r,ethov (300 peo se&S June 8,1990 i
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 UFSAR Revision 10 - Schedular Exemotion Recuest Gentlemen:
The Baltimore Gas and Electric Company (BG&E), pursuant to 10 CFR 50.12(a), requests a one-time exemption from a requirement of 10 CFR 50.7l(e). Specifically, relief is requested to allow a three-month extension to the schedule for submitting the 1990 revision to the Updated Final Safety Analysis Report (UFSAR).
1.
BACKGROUND A.
Reauirement 10 CFR 50.71(e), in part, requires Licensees to submit annual revisions to the UFSAR.
For Calvert Cliffs Nuclear Power Plant (CCNPP) this necessitates submittal of Revision 10 (i.e.,
1990 update) to the Nuclear Regulatory Commission (NRC) by July 20, 1990.
B.
Plant Oneration Contemolated 1
in 1989, an internal Quality Assurance (QA) audit and, later, an NRC Resident inspector Report (Nos. 50-317/89-27; 50-318/89-28) identified weaknesses in the Calvert Cliffs UFSAR update process (NRC Resident Inspector Report Unresolved item 50-317/89-27-03; 50-318/89-28-03). These deficiencies noted weaknesses in the methods for identifying modifications requiring d *>cumentation, and failure to incorporate Safety Evaluation
- Reports, Generic
- Letters, and similar material as described in 10 CFR 50.71(e).
9006200466 900608 W
i PDR ADOCK 0500C,317 l(
\\p P
3 puu
n Document Controi Desk
. J ne 8,1990
'Page 2 These deficiencies were investigated and determined to be the result of a lack of an adequate administrative control process.
Identification of material for incorporation into the UFSAR was left to the individual responsible for the modification, without strong central oversight.
Generic issues and SERs were not systematically included in UFSAR updates, and safety evaluation reviewers were expected to use the source documents (SERs, etc.) in their reviews, Efforts were initiated in early 1990 to correct the weaknesses in the update process.
These efforts included assignment of a
full-time experienced consultant to the
- problem, and increased supervisory involvement. Several areas in the 1990 update (in preparation) which required improvements were identified. Both short-term plans for the 1990 update and long-term plans for establishing a formal update process were established.
In the case of the 1990 update, it was determined that additional interface with responsible design engineers was necessary to ensure completeness of l
the input. Additionally, quality improvements in existing inputs were i
necessary. These efforts are currently underway, and will be incorporated in the 1990 update.
The extent of work of accomplish these changes does not support a July 20,1990 submittal date.
Correction of the process to facilitate future submissions is in progress
-in parallel with the annual update. Lessons learned in developing this submission will be incorporated ' into a draft procedure to govern the i
process. This effort has been secondary to obtaining the current update, but it is being handled by the same responsible individuals.
1 Administrative resources have already been assigned to prepare for the future process. The additional corrections will include:
l L
o implementation of a new procedure for UFSAR changes.
o Development of a database to identify and track UFSAR update candidates.
o Development of a computer database for referencing and maintaining the UFSAR.
C.
Leneth of Exemntion A schedule has been developed for the UFSAR Revision 10 activities, which factors in the above improvements. Three additional months are required to accommodate the incorporation of these improvements in this year's update.
I h
,y Docume:t Control Desk
- J;ne 8,1990 Page 3 If this exemption is granted, the Calvert Cliffs UFSAR Revision 10 would be submitted by October 20, 1990. Since this is a one-time exemption, l
future updates will be submitted by July 20.
II.
CRITERIA OF 10 CFR 50.12 10 CFR 50.12 states that the Commission may grant exemptions from the requirements of regulations contained in 10 CFR 50 provided that the following is satisfied:
A.
The Reauested Exemotion is Authori ed by Law t
No law exists which would preclude the activities covered by this exemption request. Thus, the Commission is authorized to grant this exemption.
B.
The Reauested Exemotion Does Not Present an Undue Risk to the Public Ilealth and Sarcty A formal UFSAR update process will allow us to ensure that all needed information is provided in the update. This wl!! provide the basis for more rapid assessments of safety significance. The delay in submitting the required update does not present an undue risk because source documents are available and currently utilized to assess safety significance.
I C.
The Reauested Exemotion will not Endanner the Common Defense and Security The common defense and security are not at issue in this exemption request.
111.
SPECIAL CIRCUMSTANCES We believe there is a special circumstance present which would justify the granting of this exemption request. 10 CFR 50.12 allows the NRC to grant exemptions if the following special circumstance is present; i.e.,
"The exemption would provide only temporary relief from the applicable regulation and the Licensee or applicant has made good faith efforts to comply with the regulation."
We are requesting temporary relief and are making a good faith effort to comply with the regulation. Our present effort on the UFSAR should substantially enhance the use, maintenance and control of the Calvert Cliffs UFSAR. Our update program will improve the consistency, simplicity, and timeliness of l
activities related to the UFSAR.
I^
L l
L
'gJ
- Document Contiol Desk
,J nc 8,1990 Page 4 Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, 4
y
//
7 f
G. C. Creel Vice President - Nuclear Energy GCC/ PSF / dim ec:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC D. G. M: Donald, Jr., NRC T. T. Martin, NRC L. E. Nicholson, NRC R.1. McLean, DNR 1