ML20217H474
| ML20217H474 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/27/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9804030362 | |
| Download: ML20217H474 (6) | |
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CH A*tLES It. C:l;USE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495-4455 March 27,1998 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 h 50-318 Proposed Changes to the Ouality Assmance Poliev. Reduction in Commitment Pursuant to 10 CFR 50.54(a)(3), Baltimore Gas and Electric Company hereby requests approval of two reductions in commitment to the Quality Assurance (QA) Policy. We propose to change the level of approval authority and to establish minimum requirements for processing editorial corrections to the procedures listed in Technical Specification 6.4 Attachment (1) is the marked-up pages of the Quality Assurance Policy showing these proposed changes.
Technical Specification 6.4 describes activities that must be governed by written procedures. The QA Policy states that the approval authorities for those procedures are Managers, Superintendents, or General Supervisors (or Directors) who report directly to Managers. This proposed change to the QA Policy will extend approval authority to all General Supervisors and to other supervisory personnel who are not called General Supervisors, but who report directly to a Manager.
Most General Supervisors at Calvert Cliffs report directly to a Manager, but some departments have a positirn of Superintendent between the Manager and General Supervisor. The level of responsibility of a General Supervisor is the same whether reporting to a Manager or Superintendent, and the General Supervisor level is the appropriate level for approving procedures listed in Technical Specification 6.4.
Therefore, deleting the requirement that an approving General Supervisor must report directly to a Manager will include some General Supervisors who were previously excluded. Additionally, there are other supervisory positions reporting directly to Managers. Allowing approval at this level of supervision helps ensure procedure ownership is at the level of plant management that is knowledgeable in the areas affected by the procedures being reviewed. Therefore, we are proposing a change to the QA Policy to allow people in these positions to also approve procedures described in Technical Specification 6.4 The other reduction in commitment we are requesting is to establish an editorial correction process when changing prxedures required by Technical Specification 6.4. Editorial corrections are changes to a a.
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procedure that are minor alterations (such 'as correcting misspellings or movement of text within the QA i:
Policy) not requiring e detailed review and approval process. Therefore, we are proposing a change to i
the QA Policy that will allow editorial corrections to be made to the procedures required by Technical L
Specification 6.4.
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. As expressed in the above discussions, approval of these proposed changes will give approval authority.
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- for changes of procedures required by Technical Specification 6.4 to people at the appropriate level of
- plant management, and will maintain the effectiveness of the procedure review and approval process.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, 1
1 A
g/
1M"
~ CHC/EMT/ dim l
R. S. Fleishman,l'. squire H. J. Miller, NRC cc:
J. E. Silberg, Esquire Resident Inspector,NRC
{
A. W. Dromerick, NRC R. I. McLean, DNR '
l Director, Project Directorate I-1, NRC J. H. Walter, PSC l
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ATTACHMENT (1) i l
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MARKED-UP QUALITY ASSURANCE POLICY CHANGE PAGES l
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Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant March 27,1998
i QUALITY ASSURANCE POLICY Revision 49 Ih.5 INSTRUCTibNS_ PROCEDURF5: AND DRAWINGS Controls delineate the sequence of actions to be performed in the preparation, review, approval, and h
control ofinstructions, 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.
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
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revisions. The Manager-NPAD ensures directives are reviewed by NPAD personnel and 1
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) 3.
Procedures are prepared, approved, and controlled according to the Control Procedures. Control Procedure -ctablish review, approval, revision, change, and periodic review requirements for applicable proce.dures. If format and content requirements are 'not contained in Control
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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 regulatory requirements and industry standards. Other procedures are reviewed by NPAD on a requested basis.
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Basis items added during procedure revisions or changes will be recorded. (1)
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) l Procedures listed in Technical Specification 6.4 shall be approved by the Plant General Manager or by cognizant Managers, Superintendents, er#deneral Supervisors (or Directors)*" rp S:: !y : : y)_ F Manages 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:
a.
The intent of the original procedures is not altered.
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The change is approved by two members of the plant management staff knowledgeable in the areas affected by the precedures, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
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QUALITY ASSURANCE POLICY Revision 49 d.
The change is documented, reviewed by the POSRC, the Procedure Review Committee, or by a Qualified Reviewer and approved by the designated approval authority within 14 days of implementation. (19)
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' Insert A:
and other supervisory personnel that report directly to a manager, 5
Insert B:
Editorial corrections to procedures of Technict.1 Specification 6.4 may be made provided the editorial correction is processed according to administrative procedures that include approval by a member of the plant management staff knowledgeable in the areas affected by the procedures.
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