ML20155A205
| ML20155A205 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/03/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806090282 | |
| Download: ML20155A205 (4) | |
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o B ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 RALTIMORE, MARYLAND 21203 JosrPH A.TIERNAN Vict PatssotNT NucLtAn ENERGY June 3,1986 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 Request for Additional Information - Proposed Changes to Technical Specification Oreanizational and Trainine Reauirements
REFERENCE:
(a) Letter from Mr. S. A. McNeil (NRC) to Mr. J. A. Tiernan (BG&E),
dated May 19, 1988, same subject Gentlemen:
This is in reply to Reference (a). The additional information you requested is provided in Enclosure (1).
Should you have any further questions regarding this matter, we will be pleased to dacust them with you.
Very truly yours,
[
(f //A L JAT/JRL/DLS/ dim Enclosure cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC S. A.McNeil,NRC W. T. Russell, NRC D. C. Trimble, NRC oO\\
T. Magette, DNR
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8806090282 880603 PDR ADOCK 05000317 s.
P DCD
ENCL,OSURE (1)
RESPONSE to REQUEST for ADDITIONAL INFORMATION -
PROPOSED CIIANGES to TECilNICAL SPECIFICATION ORGANIZATIONAL and TRAINING REQUIREMENTS EltC Coneern I.a.
Please provide a detailed description of how you currently meet the requ rements of ANSI N18.1 including a correlation of individual BG&E treT positions and responsibility to those described in ANSI ? :18.1 for the Plant Mana.;er, Operations Manager and Operations Supervisor.
BG&E Response
.e orgarizGicnt: structure currently in the Technical Specifica..ons aligns with ANSI hI8.1 as followr Pi nt Manager - Mant.gec, Nuclear Operations Department (MNO). While maintenance and some tech. Mal support functions are not urAr his direct supervisory control, he does have the overall responsibility for ensuring the p' a.t is operated and maintained safely, reliably, and efficiently. This is clearly stated in Section 12.1.1 of the FSAR. For those activities not under his direct supervisory control, he has control through budgeting, scheduling, procedure approval, etc. The present MNO held an SRO license at Calvert Cliffs for six years.
OperaHons Manager - General Supervisor, Operations (GSO). With the current structure,
,Se GSO directly supervises the Operations Shift Supervisors and is responsibl( for the day-to-day cperation of the plant. The preseni GSO holds a current SRO license.
Operr., ions Supervisors - Shift Supervisors (SS). The SS is responsible to the GSO for the operation of the plant during his shift. Each SS holds a entrent SRO license.
NRC Concern I.b.
Please provide a detailed description of how ye n, will mect the requirements of ANSI N18.1, including a correlation of BG&E staff positions and responsibilities to those described la ANSI N18.1 for the Plant Manager, Operations Manager aa.: Operations Supervisors, if the tive 3RO license requirement of the GSO is deleted as proposed in your
- h 19b8 sr' mittal.
IlG A F 1 -
Unds
'o
'e proposed in our March 15, 1988 submittal, the MNO
,er and the SSs continue to be the Operations Supervisors
}
continues to
..t esition, Assistant General Supervisor of Operations (AGSO),
as describu
-e t
ir ~"iblishea oe:,u n SO and the SSs. With this structure, the AGSO assumes r.lity for the
.ect supervisica of the SSs and the responsibility for the t
-day operation of the plant, lie, therefore, becomes the "Operations Manager" l - - - w - mwwe
ENCLOSURE (li RESPONSE to REQUEST for ADDITIONAL INFORMATION -
PROPOSED CIIANGES to TECilNICAL SPECIFICATION ORGANIZATIONAL and TRAINING REQUIREMENTS described in ANSI N18.1. The GSO becomes much less involved in directing the operation of the plant and more involved in budgeting for and coordinating the maintenance and engineering resources used to maintain and n:0dify the plant. In the context of ANSI N18.1, the GSO is basically an Assistant Plant Manager. To eneure thst the GSO does have an excellent understanding of plant operations, we have specified that he must have held on SRO license at Calvert Cliffs.
NRC Concern 1.c.
Please provide an application in accordance with the requirements of 10 CFR 50.54(a)(3), if you determine that you are reducing the current commitments in the QA program, otherwise, a clear and unequivocal statement that this change does not in any way reduce any current coramitments provided in the QA progrr.m.
BG&E Response This change does not in any way reduce any current commitments provided in the QA program. The individual who supervises the SSs and has responsibility for the day-to-day operation of the plant holds an SRO license under bcth the current and proposed structure. In fact, this proposal strengthens the organization because it requires that the supervisor of the ' Operations Manager" must have held an SRO license.
NRC Concern 2 Currently, Technical Specification 6.5.1, "Plant Operations and Safety Review Committee (POSRC)," requires that the GSO be a voting member rf the POSRC. And as previsusly described, Technical Specification 6.2.2, "Facility Staff," requires that the GSO, as provided in Figure 6.2-2, shall have an active SRO license. As your submittal of March 15, 198?,
proposes to delete tne active SRO license requirement for the GSO, please justify, through a safety evaluation and a determination of significant hrzards, the effect of deleting the only active SRO license from the POSRC.
BG&E Response The deletion of the only active SRO lice 1se from the POSRC by relaxing the requirement for the GSO to hold such a license has been evaluated against ae standards in 10 CFR 50.92 and has been deterrained to involve no significant hrzards considerations, in that operation of the facility in accordaace with the proposed amendment would not:
I =
D,,
ENCLOSURE (1)
RESPONSE to REQUEST for ADDITIONAL INFORMATION -
PROPOSED CIIANGES to TECIINICAL SPECIFICATION ORGANIZATIONAL and TRAINING REQUIREMENTS (i) involve a significant increase in the probability or consequences of an accident previously evaluated; No modification to plant equipment is made by this proposed change. This change is administrativc in nature and, therefore, does not affect those accidents evaluated in the Updated FSAR.
or (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, or (iii) involve a significant reduction in a margin of safety.
Not having a pereon holding a current SRO license on POSRC will not reduce the effectiveness of POSRC. As a minimum, there will always be at least one member who has held an SRO license. With the present membership, there are four people who have held an SRO license. It is important to have members who have a good fundamental understanding of the operation of the plant, but it is not important that any have the detailed knowledge level which must be maintained to keep an SRO license current. All procedures which directly affect the operation of the plant rece!/e a detailed review by a nerson holding a current SRO license. If questions are raised during POSRC review which require detailed operational knowledge, then an SRO license holder can be called iruo the meeting. l