ML20065G714
| ML20065G714 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/03/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010230071 | |
| Download: ML20065G714 (6) | |
Text
-.
=
BALTIMORE
" ~
GAS AND ELECTRIC CHARLES CENTER e P.O. BOX 1 3
- BALTIMORE, MARYLAND _ 21203-1475 J
GEORGE C. CREEL Viet PntslOENT Nvettan CNgno, 0o0 aeouass October 3,1990 a
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert - Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Etooosed Channe to Ouality Assurance Pronram Descriotion Gentlemen:
}
Pursuant to 10 CFR' 50.54(a)(3), please provide ispproval-for the attached changeL to the Quality Assurance Program. description -contained in, the Updated ; Final Safety Analysis Report (UFSAR) and the Quality Assurance (QA) Manual. We propose to change' Table IB-1,'
" Baltimore Gas and Electric ' Company's Position' on Guidance Contained in ' ANSI -
Standards" from the tUFSAR' [ Attachment (1)] Sand the. QA--ManualL[ Attachment- (2)). The I
proposed change will; give Senior ' Reactor " Operators the authority for approving: certain temporary changes to procedures (i.e., changes which owill not, change the : intent of the original procedure) while i he Shift Supervisor'sy approval will-no; longer ' b'e required.
t Item 2 is added to this ~ Table toidenote our' revised position concerning ANS 3.2-1976.
i Nuclear Regulatory Commission. approval" is x required - pursuant ' to 10' CFR : 50.54(a)(3) because the proposed change constitutes' a reduction in a qualityf assurance program commitment.-
The proposed change will relieve the administrative burden on the Shift-Supervisors: by eliminating the need for' them, to. approve temporary changes _which do not -_ impact the j
intent _ of the approved procedure. More of tte Shift Supervisors' Ttime i can thus ' be l
devoted to ' more significant ' shift - management responsibilities. Also,1 i he proposed -
t j.
change ; brings._ consistency between : the Quality : Assurance - Program description and: the l
~
l Technical Specification requirements, _ since = Technical ~ Specification J 6.8.3.b requires that ~ temporary changes to procedures be approved -by someone who ' holds' a senior. reactor L
operator's license, not necessarily..'the ' Shift Supervisor.
F If-this change is - approved, our quality assurance ' program would continue E to ' satisfy d
Appendix B of 10 CFR Part '50. Reviews and ' approvals wouldl be performed'.by -individuals holding a
senior reactor operator's license.
These.. individuals' possessi the qualifications to ensure '. that changes do not: affect the. intent - of the original procedure or have an adverse impact on plant safety. The. reviews will ; benefit from the -
4 jff
?
2.. Ti3 Lij; g.Mt/p /did L
rI ADOCK 0 % %7 [
001 9010230071 901003 DR
'"#e"
,.4
' +.
lj
., j l
4 I
f
- p
[
e 1
4 w
e ss k
'i I
.: y in.
'i
- 1 1
i
-t ag i
V o
'T i
e C
+...,
1, 4
'> t,.
p
~_ $ lI.
b 3
it 4
gu i
J I
i h i
- e2 c.j!
~
s.
3:
.,'1' 9
\\
- .0 ;
>P p
' { I
-.h$
g I
g '.-'
i
-[
t m
)
f i;
't tb i
<.it' r..
-i E
s'b a
.e
. )
i' j
-.i
-)
e J
i
'M b
e AI.th-d.-t P<EN c-^iMb'.T'-'
eb'J.:NA$
f7 4
79+
2' x-'DurfNFikV iimf d 86 T"9CM';J-'
M'?MO h M T
l
'I 7
_4 fF h 1*'*
Y 1
M'
.l
-l
. Document Control Desk October 3,1990 Page 2 4
larger pool of qualified individuals available to perform the review in that the review burden will be shared and the experience of additional operators will be included in the process. An additional benefit is - that the Shift Supervisor will have fewer -
distractions and accordingly be able to devote more time to the ' supervision of safe plant operations.
Considering the 'above arguments, we conclude that the proposed change to our Quality -
Assurance Program will maintain the effectiveness of the procedure review proces. We i
will be pleased to answer any questions you may have.
Very truly yours,
/
D GCC/DBO/ dim Attachments (1)
Table IB-1 from UFSAR (2 pages)
(2)
Table IB-1 from QA Manual (2 pages) cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra,NRC D. G. Mcdonald, Jr., NRC.
T. T. Martin, NRC L. E. Nicholson, NRC R. I. McLean, DNR l
l i
I l
1 1
b $. fA.C. b **f t e j 1
PApo / ofi TABLE-10 1
)
BALTIMORE GAS AND ELECTRIC COMPANUS POSITION ON GUIDANCE CONTAINED IN AN$1 $IANDARDS
}
Revision of Industry Standards Anoticable to the Baltimore Gas and Electrie Quality Assurance Proncam Recutrement some of the Industry Standards ilsted in Section 15.2 Identify other Standards that are required, and some Regulatory Guides define the revisions of those Standards that ' are acceptable to the NRC.
Response
BG&E's QA Program'was developed to respond to the specific revision of the documents I
Listed in Section 18.2 and is not necessarily responsive to other documents,tisted in the referenced Industry Standards.
t ANS 3.2 1976 Item 1 Reautrement Section 5.2.15 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.
l' i
I eesponse i
i 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 f requencies. These are reviewed no more than 60 days before performance.
Reason i
l Engineering Test Procedures (ETPs) and others like them are wr'itten for a one time only perf ormance and kept for ref erence f or. future 'similar tests. If they are used again, they are reviewed and modified to meet conditions existing-at. the time of
~
performance.
Some Survel tlance Test _ Procedures (STPs) are performed. every three ; to five years.
'I
~
They too are reviewed before each perf ormance to ensure that they are compatible with existing conditions and responsive to current needs.
I
.)
e
'REV.
9.
18 35 i
h i fAc. ll me n f, =.1 INSERT 84y e,,2 of 2 -
l.
Item 2 Reaulrement Section 5.2.2 specifies that temporary procedure changes that clearly do not change the intent of the approved procedure shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedure; and' at :least one of these individuals shall-be the ' supervisor in-charge of the shift. and ' hold a senior -.
operators' license on the unit affected.
i l
Resoonse BG&E does not require the Shift Supervisor' to be the Senior Reactor Operator (SRO) l approving temporary changes to ' procedures; any active SRO (either on-shift or on-staff) may provide the SRO approval for procedure changes.
Reason Shift ' Supervisor's b
Many proposed temporary procedure changes do not require ' the immediate attention or knowledge -of the change since they do not affect plant safety.
~
Other SROs are available and qualified to perform this task-since the Shift Supervisor's detailed review of. the proposed change is not necessary to - ensure plant safety.
i l
Requiring the Shift Supervisor to review gli : changes is. burdensome - and contrary to
{
l plant safety in light of the total number of procedures that exist ' and' the time the Shift Supervisor must dedicate to ensuring the plant 'is safely operated : and maintained.
Additionally, our Technical Specification requires -this approval be from. someone holding an SRO license (not necessarily the-Shift Su'pervisor),
l i
4 i
I 4
AtWhedi QUAD TY ASSURANCE POLICY-Revision 21 TABLE 1B 1 BALTIMORE GAS AND ELECTRIC COMPANY'S: POSITION ON GUIDANCE CONTAINED IN ANSI STANDARDS Revision of Industry Standards Anolicable to the Baltimore Gas and Electric Quality Assurance Prorram Recuirement Some of the Industry Standards listed in Section 18.2 identify other Standards that are required, and some Regulatory Guides define the revisions i
of those Standards that are acceptable to the NRC.
Resoonse BC&E's QA Program was developed to respond to the, specific' revision of j
the documents' listed in Section 1B.2 and is not necessarily responsive to-other documents listed in the referenced Industry Standards.
ANS 3.2 - 1976 Item 1 i
Recuirement Section 5.2.15 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;.,
Fesconse-BG&E applies this requirement of a two year review:to alliplant procedures except test procedures performed less often than every two. years or
._1 at unspecified frequencies.
These are reviewed no'more than 60: days before a
pe rfo rmance.
Reason i
Engineering Test Procedures (ETPs) and others like them are written for~a one time only performance and kept for' reference for future similar tests; If they are used again, they are reviewed and modified'to meet conditions existing at the time of performance.
Some Surveillance Test Procedures (STPs) are' performed every three to
- five years.
They too are reviewed before each performance to ensure:that they:
are compatible with existing conditions and responsive to current needs.
1 044Lsu)7 s
I Page'43 of 60 1
4
-,we e
r j t fA c. h me.r'l 2.,
pop p,,f y INSERT 1
Ite m 2
.i Reauirement
~f i
Section 5.2.2 specifies that temporary procedure changes. that clearly do not change the intent of the approved procedure shall as a minimum be. approved by two members of the l
plant staff knowledgeable in the areas affected by the procedure; and at least one of i
these individuals shall be the : supervisor in charge of the shift and hold a senior operators' license on the unit affected.
j Resoonse BG&E does not require the Shift Supervisor to be the '. Senior Reactor Operator (SRO) -
l I
approving temporary changes to procedures; any-active SRO (either - on-shift or on-staff) rnay provide the SRO approval for procedure changes.
t Reason i
Many proposed temporary procedure changes do not require the Shift Supervisor's -
immediate attention or knowledge of the change since. they do not affect plant safety.-
Other SROs are available and qualified to perform this task since the Shift.
Supervisor's detailed review of the proposed change is not necessary: to ensure plant
- safety, j
l Requiring the Shift Supervisor to review - all changes is burdensome and contrary to i
plant safety in light of the total number of procedures that exist and the time the; Shift Supervisor must dedicate to ensuring the plant is safely. operated and maintained.
Additionally, our Technical Spc:ification requires this - approval be from someone holding an SRO license (not necessarily the. Shift Supervisor).
j
.l 1
1
-1 i
i l
1 1
1 I
i 4
'I