ML20196A586

Informs That Util Is Adding Text to Proposed QA Policy to Define Minor Alteration & Editorial Correction & to Expand Review of Editorial Corrections to Include Qualified Reviewer

ML20196A586
Person / Time
Site:	Calvert Cliffs
Issue date:	11/24/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9811300067
Download: ML20196A586 (5)

Text

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Cuctos II. Cau:E Baltimore Gas and Electric Compar.y Vice President Calvert Cliffs Nuclear Power Plant

. Nuclear Energy 1650 Calven Cliffs Parkway Lusby. Maryland 20657

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410 495-4455 1

November 24,1998 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 Prooosed Changes to the Ouality Assurance Policy. Reduction in Commitment

REFERENCE:

(a)

Letter from Mr. C. H. Cruse (BGE) to Document Control Desk (NRC) dated March 27,1998, Proposed Changes to the Quality Assurance Policy, Reduction in Commitment (b)

Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated July 17,1998, Changes to the Quality Assurance Policy i

In Reference (a), Baltimore Gas and Electric Company proposed two changes to the Quality Assurance Policy that were deemed to be reductions in commitment. Since the submittal of that letter, there have been several telephone conference calls between Baltimore Gas and Electric Company personnel and the Nuclear Regulatory Commission project manager and technical reviewer. During those conference calls, the technical reviewer felt that the terms " minor alteration" and " editorial correction" needed to be defined in the Quality Assurance Policy and expressed concern that some minor alterations should be f

reviewed by a Qualified Reviewer.

Accordingly, we are adding text to the proposed Quality Assurance Policy to define minor alteration and editorial correction and to expand review of editorial corrections to include a Qualified Reviewer. These l

changes are noted on the attached markup. We understand that making these changes will result in the l

NRC technical reviewer's acceptance of the list of editorial corrections submitted as an attachment to l

Reference (b).

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l DocumInt Control Desk November 24,1998 Page 2 Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

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h-l for C. H. Cruse Vice President -Nuclear Energy CHC/EMT/bjd Attachment cc:

R. S. Fleishman, Esquire Resident Inspector, NRC j

J. E. Silberg, Esquire R.1. McLean, DNR 1

S. S. Bajwa, NRC J. H. Walter, PSC A. W. Dromerick, NRC N. J. Blumberg, NRC H. J. Miller, NRC i

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QUALITY ASSURANCE POLICY Revision 49 18.5 INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS Controls delineate the sequence of actions to be performed in the preparation, review, approval, and control of instructions, procedures, and drawings.

Controls require that:

1.

Methods for complying with each of the applicable criteria of 10 CFR 50, Appendix B, must be specified in instructions, procedures, and drawings.

2.

Instructions, procedures, and drawings must specify appropriate quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workmanship samples) acceptance criteria for verifying that important activities have been satisfactorily accomplished.

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Controls ensure that:

1.

The QA Policy is approved by the Vice President Nuclear Energy Division. (1) 2.

Nuclear Program Directives are prepared under the direction of the Department Manager assigned as the Program Sponsor. Affected Department Managers review directives and their l

revisions. The Manager-NPAD ensures directives are reviewed by NPAD personnel and approval recommended to the Program Sponsor. The responsible Program Sponsor approves directives and their revisions. Directives are prepared, reviewed, and approved according to an appendix to the Nuclear Program Directives Manual. (19) c.o r t w +

3.

Procedures are prepared, approved, and controlled accordi g to the Control Procedures. Control Procedures establish review, approval, revision, change, and periodic review requirements for i

applicable procedures. If format and content requirements are not contained in Control i

Procedures. they shall specify the document to be used to determine format and content requirements. Control Procedures are reviewed by NPAD personnel to ensure compliance with

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regulatory requirements and industry standards. Other procedures are reviewed by NPAD on a requested basis.

l 4.

Basis items added duritig procedure revisions or changes will be recorded. (1) l The Plant General Manager may designate specific procedures or classes of procedures in writing to be reviewed by the Procedure Review Committee or by Qualified Reviewers in lieu of review by the POSRC. Review by the Procedure Review Committee and by Qualified Reviewers shall be in accordance with Addendum IB-1. (19)

Procedures listed in Technical Specificatijo 6.4 shall be approved by the Plant General Manager or by up cognizant Managers, Superintendents, efGeneral Supervisors (or Directors)Mh::fyva Occ:!y :s a 3 l

W;;r prior to implementation as specified by administrative requirements. The approval authority for specific procedures or classes of procedures shall be designated in writing by the Plant General Manager and shall be a different individual from the Qualified Reviewer. (19)

Temporary changes to procedures of Technical Specification 6.4 may be made provided:

The intent of the original procedures is not altered.

a.

b.

The change is approved by two members of the plant management staff knowledgeable in the areas affected by the procedures, at least one of whom holds a Senior Reactor Operator's License on the unit affected.

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ja.l QUALITY ASSURANCE POLICY Revision 49 The change is documented, reviewed by the POSRC, the Procedure Review Committee, or by a i

c.

- Qualified Reviewer and approved by the designated approval authority within 14 days of i

• implerhentation. (19) i i

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ATTACHMENT (1)

Insert A:

and other supervisory personnel that report directly to a manager.

Insert B:

Editorial corrections to procedures governing the activities listed in Technical Specification 5.4 may be made provided:

The correction is allowed by control procedures, and a.

b.

The correction is approved by a member of plant staff knowledgeable in the areas affected by the procedure and a Qualified Reviewer.

The plant management staff member and the Qualified Reviewer may be the same person.

As used in this document:

Editorial Correction is defined as a process used to incorporate minor alterations in an approved procedure.

Minor Alteration is defined as a term uced to recognize a procedure alteration that does not constitute a change ofintent, a change to a Technical Specification, or introduce an unreviewed safety question. This term is used only in conjunction with an editorial correction.

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