ML20246D266
| ML20246D266 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/18/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8908250307 | |
| Download: ML20246D266 (3) | |
Text
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.o BALTIMORE GAS AND ELECTRIC CHARLES CENTER
- P. O. BOX 1475 BALTIMORE, MARYLAND 21203 GEORGE C. CREEL Vict Persiotut NucLcAn turnov August 18, 1989
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U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 3; Docket Nos. 50-317 & 50-318 Combined Insnection Reoort Noe 50-317/89-06: 50-318/89-06
REFERENCE:
(a) Letter from Mr. J. P. Wiggins (NRC) to Mr. G. C. Creel (BG&E) dated July 21, 1989, same subject Gentlemen:
Reference (a) forwarded NRC Region I Combined Inspection Report 89-06/06. Appendix A to Reference (a) is a Notice of Violation which cites a violation of requirements of 10 CFR 50.59 and Technical Specification 6.5.1.6. Specifically, a change of intent to one of our Operating Instructions was made without a written safety evaluation in accordance with 10 CFR 50.59 and without the review and approval of our Plant Ope ations and Safety Review Committee (POSRC) as required by Technical Specifica-tion 6.5.1.6.
Enclosure (1) provides our response to the Notice of Violation, as required.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very :ruly yours,
/
b Do 88 S8 GCC/CDS/dlm g.g oo cc:
D. A. Brune, Esquire gc J. E.
Silberg, Esquire R. A.Capra,NRC a-;
S A.McNeil, NRC
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'La G W. T. Russell, NRC V. L. Pritchett, NRC I
T. Magette, DNR
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ATTACHMENT (1)
REPLY TO A NOTICE OF VIOLATION j
INSPECTION REPORT 50-317/89-06; 50-318/89-06 i
Apperdix A of NRC Region I Combined Inspection Report 50-317/89-06; 50-318/89-06'is a Notice of Violation -(NOV) regarding 10 CFR 50.59 and Technical Specification require-meats. Specifically, a change of intent to one of. our Operating Instructions (OI) was made without a written safety evaluation in accordance with 10 CFR 50.59 and without J
the review and approval of our POSRC in accordance with Technical Specifica-tion 6.5.16. Below. is our response to the NOV.
1.
CORRECTIVE STEPS TAKEN AND RESULIIS ACJilEVED We have revised the definition of " change of intent" in Calvert Cliffs Instruction (CCI)-101, "Calvert Cliffs Implementing Procedure Development and 3
Control." Changes to all procedures are being performed in accordance with CCI-101. " Change of intent ~ is currently defined as "any change to a procedare beyond correction of an obvious typographical error "
Changes to all procedures must be approved by two members of Plant Management Staff pt.or to review by POSRC. One of these persons must be a BG&E Supervisor from the affected discipline. The procedure change must then be reviewed by POSRC and approved by the Manager - CCNPP prior to implementation. The change to CCI-101 was intended as an interim change until a more detailed definition of I
" change of intent" was developed. The change was purposely intended to be overly conservative to assure that no additional violations of the Technical Specification requirement occurred.
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2.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS We have developed a detailed set of screening criteria for " change of intent" and are presently in the process of incorporating this screening criteria into CCI-101. Those screening criteria are not as restrictive as the current, conservative definition, but stil! assure that procedural changes of intent. are not allowed without the required POSRC review and approval. The new CCI-101 revision has obtained POSRC approval. We will train personnel on the new
" change of intent" screening criteria prior to implementation of the revised CCI-101.
We are aware that a mcre rigorous safety assessment process is needed at Calvert Cliffs. As part of our Performance improvement Plan, we are implement-ing an Action Plan to enhance and widen the safety evaluation / assessment l-process. The intent of this Action Plan is to instill a site-wide culture
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l change to improve safety awareness and ensure written safety evaluations are completed, as appropriate. An expanded safety assessment screening process is l
being formalized as part of the Action Plan and will be proceduralized in the future.
Use of the expanded screening process will assure that safety assessments focused on nuclear safety have been performed when necessary and adequately documented. The process will require the use of progressive screening criteria by personnel at different organizational levels. L_______----__
AITACllMENT (1)
REPI.Y TO A NOTICE OF VIOLATION INSPECTION REPORT 50-317/89-06; 50-318/89-06
't We expect these initiatives will:
o lead to further improvements in our safety assessment methods; o
improve the safety consciousness of employees involved in plant activities; and, o
lead to improved training on the performance of safety assessments.
3.
DATE WilEN COMPLIANCE WAS ACIIIEVED Compliance was achieved when the POSRC review and 10 CFR 50.59 safety rp.
evaluation were completed for the noted configuration changes on May 11, 1989.
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a 2-
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