ML20082B605
| ML20082B605 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/03/1991 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9107160076 | |
| Download: ML20082B605 (5) | |
Text
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4 B Al.T IMORE GAS AND ELECTRIC 1
CHARLES CENTER
- P 0. DOX 1475
- BALTIMORE. MARYLAND 21203 1475 Gronot C CRttL July 3,1991 vu numiu Nvcit o rogno, w no..n U. S. Nuclear Regulatory Commission Washington, DC 20555 NITENTION:
Document Control Desk SUluECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50-318 Procedures Upgrade Project Status Report REl~ERENCES:
(a)
Letter from G. C. Creel (BO&E) to Document Control De.sk (NRC),
dated January 31,1990, Proposed Change to the Quality Assurance Program Description in the Final Safety Analysis Report.
(b)
Letter from bl. W. Ilodges (NRC) to G. C. Creel (BG&E), dated h1 arch 13, 1990, 10 CFR 50.54 Ouality Assurance Program Description Change Review (c) letter from C. W. Cowgill (NRC) ta G. C. Creel (BO&E). dated October 17,1990, NRC Region 1 Resident inspection Report 50-317 and 50-318/90-23 (d) 1xtter from O. C. Creel (BG&E) to Document Control Desk (NRC),
dated June 11,1991, Proposed Change to Quality Assurance Program Gentlemen:
This letter provides an update on the direction and status of Calvert Cliffs' Procedure Upgn.c Project. Since the inspection of this area documented in Reference (c), we have made substantial progress in procedure revisions. We have also identified several modifications which will serve to improve the project, Attachment (1). While the purpose, extcnt, and methodology are generally consistent with what we previously discussed with your staff, these adjustments are significant enough to warrant a comprehensive discussion.
In the area of technical procedures, we have completed approximately 35% of the 2300 procedures expected to be revised under PUP. We have determined that the limitmg resource for revision is the pool of experienced plant personnel to review the scheduled completion to accommodate this need % procedures. As a result, we have modified the a
e are pleased with the quality of the procedures produced to date, and we feel that adjustment of the schedule to obtain this quality review will result m both improved accuracy and acceptability of the final products.
Q$lS 9107160076 910703 PDR ADOCK 05000317 Fp P
FDR tv u,% O 1 ii g
Document Control Desk
- July 3,1991 Page 2 We have prioritle" the technical procedures to ensure that those most impo: tant to safety are done Erst. %c most important procedures are the Emergency Operating Procedures (EOPs), Abnormal Operating Procedures (AOPs), and Surveillance Test Procedures (STPs). We expect to complete these within the previnusly projected completion date of December 1992. The remaining technical procedures are projected to be complete by December 1991 in the area of administrative procedures, we have made several major improvements. As we proceeded with these procedures, we became aware of the need for a basic restructuring of our administrative procedure hierarchy. We have initiated this clTort, starting with the basic policies upon which the directives and implementing procedures are to be based. These policies were approved in November 1990. We subsequently determined that fullimplementation of this hierarchy would require modincation of our Quality Assurance Program and the Plant Operations Safety Review Committee Technical Specification. These modi 0 cations have been reviewed and approved internally, and are currently being reviewed by NRC staff. The result of these changes will be not only to upgrade the administrative procedures, but to significantly clarify the processes which they govern. One result of this far reachmg impact is that the implementation schedule must be carefully monitored to ensure that we do not exceed the organization's capacity for change _We have given appropriate consideration to change management in our administrative procedure schedule. We currently expect to complete the entire administrative procedure revision by December 1995.
In summary, we have made substantial progress in our procedure upgrade effort. The Writer's Guides which were reviewed by your staff last year have proven effective in producin ; high qual:ty procedures, and the review process which we outlined at that time has proven to be auth efficient and safe. We have performed a major portion of the procedure workload, and in that process have identined some key factors which will help us attain a quality product. While the schedules for procedure upgrades have been extended in some cases, we have prioritized our efforts in a manner which offers the best safety approach. Also, by December 1992, BG&E will fully comply with the requirement for biennial review, discontinuing the option to use the " temporary one-time change to the periodic review interval requested by Reference (a) and granted by Reference (b). We are con 6 dent that our adjustments have effectively incorporated the lessons of our efforts to date, and will continue our major resource commitment to achieve the desired improvement in the plant.
We will continue to look for further ways to improve our procedure upgrade project, and we will keep you informed of any significant changes.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
/
Very truly yours,,9 A
d
/
GCC/rNP/REN/bjd Attachment
Docurnent ControlDesk July 3,1993 Page 3 Cc:
D. A. Brune Ihquite J. E Sillwrg,lhquire R. A. Capra,,NRC T. T. h1attin, NRCD. G. hicDonald, Jr., NRC L E. Nicholson, NRC R.1. hiclean, DNR J.11. Walter, PSC C
s
Document Control Desk July 3,1991 Page 3 cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC 1 E. Nicholson, NRC R.1. Mclean, DNR J. II. Walter, PSC l
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A'ITACIIMENT (1)
PROCEDURES UPGRADE PROJECT STATUS PROJECT CONTROL S In Octobtr,1990, the Nuclear Regulatory Commission documented close out of all Special Tearn inspection Open items related to the Procedures Upgrade Project (PUP) in Reference (c). The report noted that PUP was being managed effectively and stated,in part:
"He licensee had implemented a procedure upgrade project... capabic of producing good quality procedures and would provide adequate controls over procedure review and changes."
During the first quarter of 1991, PUP implemented new scope definition and control processes to enhance project management. The revised Procedures Upgrade Project Plan documents these items and sets direction for the technical and administrative procedure upgrade effor ts.
TECIINICAL PROCEDURES UPGRADE As of July 1,1991, PUP status and accomplistiments are:
+
Over 35% of the 2300 technical procedures upgraded; Approximately_5000 preventive maintenance procedures being converted to repetitive
+
ma ntenance t::sks in the maintenance inanagement system; Control procedures for procedure development, review, approval, and change / revision
+
process upgraded; All procedure related restart Open items resolved, as cited in Reference (c).
+
For technical procedures, priority is given to procedures which are most important to the safe operation of the plant. The upgrade of all Emergency Operating Procedures, Abnormal Operating Procedures, and Surveillance Test Procedures is planned to be complete by December,1992.
Upgrade of the remaining technical procedures is scheduled for December,1994.
ADMINISTRATIVE PROCEDURES UI' GRADE In August,1990, the Vice President-Nuclear Energy established a new administrative procedures hierarchy. This hierarchy is implemented through the development of policies, directives, and procedures to support Calvert Cliffs' major business functions. These procedures are designed to provide clear ownership and accountability at appropriate management levels. This hierarchy j
provides top-down traceability of BG&E management and regulatory requirements, clear interface controls, and well defined processes for consistently producing safe, quality results.
The top level documents in the new administrative procedures hierarchy, Nuclear Program Policies, were approved in November,1990. Administrative procedure upgrade efforts for two policy areas are underway, and the total administrative procedures hierarchy is_ projected to be completed by December 1995. The proposed change from the existing Quality Assurance Procedures to new Nuclear Program Directives is documented in Reference (d).
1
ATTACl1%1ENT H)
PitOCEI)UltES UPQi(AI)E PitO.lECI' STATUS SUhthliBX The 1994 completion for Technical Procedures Upgrades and the 1995 completion of Administrative Procedures Upgrades reflect the total effort necessary to complete PUP. Ilowever. procedure upgrade is a continually evolving process that goes beyond the PUP scope and schedule. PUP activities demonstrate only one part of BO&E's commitment to improving procedures and processes at Calvert Cliffs. Total procedure activity foi developrnent of quahty procedures is a combination of PUP work scope and routine changes to current procedures that will continue throughout plant life.
These combined efforts ensure technically accurate and functional procedures are available to support safe plant operation. As we transition from PUP to a continuing procedures management organitation, adjustments will be considered carefully to achieve the best quality approach for procedure irnprovement and overall safety, 2
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