ML20148C898

Application for Amends to Licenses DPR-53 & DPR-69,changing Tech Specs,Adding Newly Created Position,Assistant General supervisor-operations & to Modify Requirement for General supervisor-operations.Fee Paid

ML20148C898
Person / Time
Site:	Calvert Cliffs
Issue date:	03/15/1988
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20148C899	List: ML20148C898 ML20148C903
References
NUDOCS 8803230181
Download: ML20148C898 (5)

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l B ALTIMORE f GAS AND l

ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE. MARYLAND 21203 JostPH A.TIERNAN Vict PatsIDENT NUCLEAR ENEROV hiarch 15, 1988 U. S. Nuclear Regulatory Commission Washington, DC 20555 A'l'TENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Reauest for Amendment Gentlemen:

The Baltimore Gas and Electric Company hereby requests an Amendment to its Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Unit Nos.1 & 2, respectively, with the submittal of the proposed changes to the Technical Specifications.

Cil ANGE NO.1 (BG&E FCR 88-28)

Change page 6-3 of Unit Nos. I and 2 Technical Specifications as shown on the marked-up copies attached to this submittal.

DISCUSSION The proposed change is to add a newly created position, Assistant General Supervisor-Operations (AGS-Operations) to the organization chart of Figure 6.2-2 and to modify the requirement for the General Supervisor-Operations (GS-Operations) to hold a Senior Reactor Operator (SRO) License to require that the GS-Operations holds or has held an SRO license at Calvert Cliffs.

The AGS-Operations position has been created to provide supervision of the Operations Unit, which operates the plant. The AGS-Operations is required to hold and maintain an SRO License.

The GS-Operations presently spends 21 full days a year in classroom, simulator requalification, and preparation for NRC testing to inaintain an SRO license. Creation of the AGS-Operations position and modification of the GS-Operations SRO License requirements would allow the GS-Operations more time to effectively supervise the Ooerations Section, which includes the Procedures Development and hiodifications Acceptance Unit and the hiaintenance Coordination Unit along with the Operations Unit.

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. 's-Document Control Desk March 15,1988 Page 2 This level of supervision does not require the current, in-depth, plant-specific knowledge which results from maintaining an SRO license.

Selection of individuals for the GS-Operations position would be enhanced since more candidates could be considered for the job. The status of a candidate's SRO license is presently a major consideration, since those whose license is not current require many months of training to get it renewed.

Together, the GS-Operations and the AGS-Operations positions maintain compliance with the intent of American National Standard N18.1 of 1971, Selection and Training of Nuclear Power Plant Personnel, which the Technical Specifications commit to.

DETE R MIN ATION OF SIG NIFICA NT II A Z A R DS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility ir. accordance with the proposed amendment would not:

(i) involve a significant increase in the probability or consequences of an accident previously evaluated in the Updated Final Safety Analysis Report (FSAR).

No modification te plant equipment is made by this proposed change. This change is administrative in nature and, therefore, does not affect those accidents evaluated in the Updated FSAR.

(ii) create the possibility of a new or different type of accident from any accident previously evaluated.

No new or different kind of accidents from those previously evaluated in the Updated FSAR are created by this change.

(iii) involve a significant reduction in a margin of safety.

Adding the AGS-Operations position to the plant organization does not reduce the margin of safety. It provides an additional level of supervision over the operating shift organization.

Deleting the requirement for the GS-Operations to hold and maintain an SRO license does not reduce the margin of safety in the direct line of supervision between the GS-Operations and the operating shift organization because of the addition of the AGS-Operations, who provides direct supervision in this area and holds and maintains an SRO license.

The Maintenance Coordination Unit does not directly affect the operation i of the plant. One of the principal responsibilities of the AGS-Operations is to provide the on-shift operational control for on-line and outage maintenance and operational activities. Therefore, regarding this

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Document Control Desk March 15,1988 Page 3 direct line of supervision, the relaxation of the requirement for the GS-Operations to maintain an SRO license does not involve a significant reduction in a margin of safety.

e The Procedures Development and Modifications Acceptance Unit does directly affect how the plant is operated. Accordingly, the Supervisor of this unit must hold and maintain an SRO license. The GS-Operations will have to hold or have held an SRO license and, therefore, will have a detailed base knowledge of the plant and its operation. Therefore, regarding this direct line of supervision, the relaxation of the requirement for the GS-Operations to maintain an SRO license does not involve a significant reduction in a margin of safety.

In general, eliminating the time which the GS-Operations is currently spending in classroom, simulator, and NRC test preparation to maintain an SRO license would allow him to dedicate that time to performing his principal responsibilities. The benefits of this actually would enhance overall nuclear safety which would increase the margin of safety.

The added flexibility management will have in selecting a new GS-Operations (without regard to the current status of his SRO license) will provide an individual from a larger field of selection. This will also increase the margin of safety.

CII ANGE NO. 2 (BG&E FCR 88-28)

Change pages 6-6 and 6-7 of Unit Nos. I and 2 Technical Specifications as shown on the marked-up copies attached to this submittal.

DISCUSSION The proposed change is to increase the number of Plant Operations and Safety Review Committee (POSRC) members from eight to ten and to increase the POSRC quorum requirement from five to six total members.

At the request of the POSRC Chairman, the General Supervisor-Design Engineering and the General Supervisor-Quality Assurance regularly attend POSRC meetings as non-voting members. Knowledge and experience in these two areas contribute significantly to sound POSRC decisions. Adding these two positions to POSRC membership provides a more comprehensive review of key plant safety issues.

The present POSRC quorum consists of "the Chairman or his designated alternate and four members including alternates." By adding two positions to the POSRC membership, it i logically follows to change the quorum to "the Chairman or his designated alternate and five members including alternates."

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. Document Control Desk March 15,1988 Page 4 DETE R MIN ATION OF SIGNIFICANT II A Z A R DS This proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to involve no significant hazards considerations, in that operation of the facility in accordance with the proposed amendment would not:

(i) involve a significant increase in the probability or consequences of an accident previously evaluated in the Updated Final Safety Analysis Report (FSAR).

No modification to plant equipment is made by this proposed change. This change is administrative in nature, and therefore, does not affect those accidents evaluated in the FSAR.

(ii) create the possibility of a new or different type of accident from any accident previously evaluated.

Adding two members to the POSRC membership and increasing the quorum from five to six does not create the possibility of a new or different kind of accident.

(iii) involve a significant reduction in a margin of safety.

This proposed change does not involve any reduction in the margin of safety. The addition of two positions to the POSRC membership and increasing the quorum from five to six will provide a more comprehensive

< and effective review of key plant safety issues. The margin of safety will increase due to the increased expertise.

SAFETY COMMI'ITEE REVIEW These proposed changes to the Technical Specifications and our determination of significant hazards have been reviewed by our Plant Operations and Off-Site Safety Review Committees, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.

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. Document Control Desk March 15,1988 Page 5 FEE DETERMINATION Pursuant to 10 CFR 170.21, BG&E Check No. (1211143) in the amount of $150.00 was mailed to the NRC on February 24, 1988, to cover the application fee for this request.

Very truly yours, (fC4fa -

STATE OF MARYLAND  :

TO WIT:

COUNTY OFCALVERT  :

I hereby certify that on the /8tt day of WIl ,19 f( before me, the subscriber, a Notary Public of the State of Maryland in and for /# IuaL AL

[/ //ud personally appeared Joseph A. Tiernan, being duly swofn, and stat:s that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.

WITNESS my Hand and Notarial Seal: __J ID W 7c. AD Notary Public My Commission Expires: Al 9/, /hYd F (Date JAT/DLS/ dim Attachments cc: D. A. Brune, Esquire J. E. Silbesg, Esquire R. A.Cepra, NRC S. A. McNeil. N RC W. T. Russell, NRC D. C. Trimble, NRC T. Magette, DNR

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