ML20059J257
| ML20059J257 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs |
| Issue date: | 01/18/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20059J261 | List: |
| References | |
| NUDOCS 9401310416 | |
| Download: ML20059J257 (2) | |
Text
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B ALTIMORE GAS AND ELECTRIC 1650 CALVERT ClJFFS PARKWAY. LtJSBY, MARYLAND 20657-4702 ROBERT E DCNTON January 18,1994 vict Pacsiot~r NucLT Aa ENIRO V L eg. MO 44$
U. S. Nucleai 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 Prooosed Change to Quality Assurance Program In accordance with 10 CFR 50.54(a)(3), Baltimore Gas and Electric Company (BG&E) hereby requests approval of a proposed change to the Quality Assurance (OA) Program for Calvert Cliffs Units I and 2. The proposed change would add a new exception to the qualification requirements of ANSI N18.1-1971 for personnel sening as intermediate supervisors. Specifically, this proposal would change the requirement for intermediate supenisors to have four year; experience in the craft or discipline supervised. The changes to the program are shown on the attached markup from Table 1B-1 (see section entitled A.NSI N18.1-1971, new Item 2). Nuclear Regulatory Commission (NRC) approval is required prior to implementation of this change since this change is deemed to constitute a reduction in a OA Program commitment previcasty accepted by the NRC.
The QA Program contains a commitment to follow the guidance of NRC Regulatory Guide 1.8 (September 1975), which in turn references ANSI N18.1-1971. Baltimore Gas and Electric Company exceptions to this guidance are noted in Table 1B-1 of the QA Program. ANSI N18.1-1971, Paragraphs 3.2.2 and 4.3.2, taken together, require intermediate-level as well as first-line supenisors of repairmen / technicians to have at least four years experience in the craft / discipline supervised.
Baltimore Gas and Electric Company has three levels of supenision in its " repairman / technician" organizations: i.e.; Supenisors, Assistant General Supcrvisors (AGS) (in some cases), and General Supenisors (GS). All of these positions correspond to the positions defined in Paragraph 3.2.2. The AGS and GS are intermediate-level positions. However, we do not believe that all these individuals need to have the four years of craft / discipline experience required by Paragraph 4.3.2. Instead, we propose that as a minimum, first-line supenisors shall possess four years experience in the craft / discipline supervised, while intermediate level supenisors in the " repairman / technician" organization may be selected to fill supenisory positions based on a minimum of four years related academic / technical training or experience, and demonstrated supervisony capability. All first-line and intermediate-!cvel supervisors shall have at least a high school diploma or equivalent.
To illustrate, this change would allow an experienced degreed engineer with supervisory experience in design engineering to fill an intermediate-level supervisory position in maintenance.
Plant operation m accordance with this proposed change would continue to satisfy 10 CFR Part 50, Appendix B, Criterion 1, " Organization." Supenisors with responsibilities for implementing clements of the QA Program will continue to be qualified to carry out their resp (msibilities. In addition, the proposed change will allow BG&E to provide a balanced and broad base of supenisory 9401'310416 940118 f
1 PDR ADDCK 05000317 00 P
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h iDocument Control Desk i
-January 18,1994 l
Page 2 capability comprised of individuals with extensive craft / discipline experience accrued through field work, and individuals with related education and experience who have demonstrated the ability to effectively supervise.
j Should you have a'ny further questions regarding this matter, we will be pleased to discuss them with you. Our contact is Mr. Bruce S. Montgomery, Principal Engineer - Licensing (410 260-4929).
ruly yours, -
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RED /BSM/ dim
Attachment:
Markup of BG&E OA Policy, Commitment to ANSI N18.1-1971 cc:
D. A. Brune, Esquire J. E. Silberg, Esquire i
't A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC 3
R. I. McLean, DNR J. II. Walter, PSC 1
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