ML20059C360

Application for Amends to Licenses DPR-53 & DPR-69,deleting Specific Titles for Members of Plant Operations & Safety Review Committee (Posrc) & to Use Committees or Individuals to Perform Reviews in Lieu of Posrc in Tech Specs

ML20059C360
Person / Time
Site:	Calvert Cliffs
Issue date:	08/23/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059C362	List: ML20059C360 ML20059C363
References
NUDOCS 9008310215
Download: ML20059C360 (11)

Text

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O BALTIMordE OAS AND i ELECTRIC

)

- CHARLES CENTER

• P.O.' BOX 1475 e BALTIMORE. MARYLAND 21203 1475 Gromot C. CatcL VICE PetteDtut .

I NuCat an (e.t eof 400eso ess August 23, 1990 ,

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 & $0-318 Technical Specification Change Request:

M; tat Operations and Safety Review Committee (POSRC)

REFERENCE:

(a) Letter from - Mr. G. C. Creel' (BG&E) to NRC Document Control l Desk, dated November 22, 1989, Request for Additional Information -

!' Plant Operations and Safety Committee Technical Specification Gentlemen:

l 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, ir accordance with 10 CFR " 50.90 and 50.91 to delete specific titles for members of the L Plant Operations and Safety Review Committee (POSRC) and to use committees or individuals to perform selected procedure reviews in lieu of review by POSRC. These changes along with other changes described are being requested to improve the  :

effectiveness of POSRC and the quality of procedure review'. Attachment (1) contains the proposed changes.

DESCRIPTION OF CIIANGES

1. The title of Manager-Calvert Cliffs Nuclear Power Plant (CCNPP) was ; replaced with the title of Plant General Manager throughout the Administrative Section 6.0-of the Trchnical Specification.

2. The title of General Supervisor - Quality Control and Support contained in l Technical Specification 6.4.2 was replaced with the title of General Supervisor - 1 Planning and Support.

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3. Technical Specification 6.5.1.2 was changed to delete specific titles for members of POSRC and in its place denotes areas of expertise. The areas of expertise L

are Nuclear Operations, Electrical and Controls Maintenance, Chemistry, Mechanical Maintenance, Nuclear Engineering, Radiation Safety, Plant Engineering and Design Engineering. The Design Engineering requirement is a new area of expertise not currently required on POSRC. The change also adds a requirement  ;

for the Plant General Manager to appoint members. All members are to have a minimum of eishi years power plant experience of which a minimum of threc years shall _ be nuclear power experience. At least one member shall have an SRO license on Calvert Cliffs Units 1 and 3.

4. A new Technical Specification Section (6.5.1.3) was added to specify that the POSRC Chairman is appointed by the Plant General Manager. The Chairman is to have a minimum of ten years power plant experience of which a minimum of three years shall be nuclear power experience.

5. Technical Specification 6.5.l.3 was renumbered to 6.5.1.4 and the Plant General Manager rather than the POSRC Chairman shall appoint POSRC alternates. The restriction on appointing alternate members on a temporary basis has been removed. Alternate members will have the same experience level as members.

6. Technical Specification 6.5.1.4 was renumbered to 6.5.1.5 and "his designated alternate" was changed to "one of the designated alternates". )

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7. Technical Specification 6.5.1.5 was renumbered to 6.5.1.6 and the ' Chairman or his designated alternate" was changed to the " Chairman or one of the designated alternate Chairmen.

8. Technical Specification 6.5.1.6 was renumbered to 6.5.1.7 and the following exception was taken to POSRC responsibilities, "those items designated for review I by the Procedure Review Committee or Qualified Review Program in accordance with Specification 6.5.2 and 6.5.3, respectively." The phrase "which affect nuclear safety" was added to the sentence, " Review of I) all procedures required by Specification 6.8 which affect nuclear safety . . . ."

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9. Technical Specification's 6.5.1.6e, 6.5.1.6 f, 6.5.1.6g, 6.5.1.61, 6.5.1.6j, l 6.5.1.6k, 6.5.1.61, 6.5.1.7c, 6.5.1.8 and 6.5.2 were renumbered to 6.5.1.7.h. l 6.5.1.71, 6.5.1.7J, 6.5.1.7e, 6.5.1.7 f, 6.5.1.7 k, 6.5.1.7g, 6.5.1.8d, 6.5.1.9 and l 6.5.4, respectively. Subsequent references to these sections in Technical j Specification 6.5.2 (proposed 6.5.4) also required changing. I

10. Technical .cpecification 6.5. I .6h which required performance of special reviews, l investigaticas or ar lysis and reports thereon as requested the Chairman of j OSSRC was deleted in its entirety. l l

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i 11-. Renumbered Technical Specification 6.5.1.7 to- 6.5.1.8 and added requirements z to q

! submit ' ' recommendationsE for approval to the Plant General Manager for the '

following items: l a.: Plant -Security Plan and implementing procedures

b. Emergency Plan and implementing procedures

c. Process Control Program and the Offsite Dose Calculation Manual u

12. Removed requirement in Technical Specification 6.5.1.7 b (proposed -6.5.1.8c) to render a determination in writing .if Technical Specification Violations constitute an unreviewed safety question.

l l 13. Added requirements in Technical Specification 6.5.1.7 b (proposed 6.5.1.8c) to ,

l render a determination in writing if any of the following items constitutes an unreviewed safety question:

.l I a. Plant Security Plan and implementing procedures I

b. Emergency Plan and implementing procedures l

c. Process Control Program and the Offsite Dose Calculation Manual l l'

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14. A new Technical Specification was created (Technical Specification 6.5.1.8d) to evaluate root causes and recommend actions to prevent recurrence for the l following:

a. Technical Specification Violations

b. Reportable Events I

c. ' Potential Safety Hazards i d. Accidental,^ Unplanned or Uncontrolled Radioactive Release that exceeds 25' L of' the limits of Technical Specification 3.11.1.2, 3.11.2.2 . or 3.11.2.3.

L, 15. The following Technical Specification Sections were added to describe' the Procedure Review Committee and Qualified Review Program.

6J.2 PROCEDURE REVIEW COMMITTEE l-FUNCTIGN 6.5.2.1 The Procedure Review Committee may function to review procedures listed in Specification 6.5.1.7(a)- in lieu of review by POSRC as directed by the Plant l General Manager.

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COMPOSITION ,

l 6.5.2. 2 The Procedure Review Committee .shall be composed of a Chairman =-and i eight individuals who shall collectively have ' expertise in the areas contained in l Technical Specification 6.5.1.2.  ;

Members shall- be appointed . in writing by the Plant General Manager. Members shall have a minimum of eight years power plant experience of which'a. minimum of '

three years shall be nuclear power experience. At least one member shall be a -

POSRC member or alternate. The charter for the Procedure Review Committee shall include a description of membership, qualifications, functions, and reports oc9 shall be' described in plant administrative ' procedures. The Procedure Revhw Committee may be dissolved at the discretion of the Plant General Manager.

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y CilAIRMAN l 6.5.2.3 The Chairman and alternate Chairmen of the Procedure Review Committee shall be appointed in writing by the Plant General Manager Chairmen shall have .j a minimum of eight years power plant experience of which a minimum of three years i shall be nuclear power plant experience.

ALTERNATES 6.5.2.4 All alternate members shall be appointed in writing by the Plant General Manager. Alternate members shall- a minimum of least eight years power plant i experience of which a minimum of three years shall be nuclear power experience. I t- MEETING FREOUENCY

.1 6.5.2.5 The Procedure Review Committee shall meet at least once per calendar l month and as convened by the Chairman or his designated alternates.

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OUORUM 6.5.2.6 A quorum for the Procedure Review Committee shall consist of. the-Chairman or one of the designated alternate Chairmen and three primary or alternate members provided at least four disciplines are represented.

AUTHORITY The Procedure Review Committee shall:

a. Recommend to the Approval Authority approval or disapproval of procedures considered under 6.5.1.7(a).

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' Page 5 b, ' Render . determinations in writing with > regard to whether _ or not .each procedure considered : under 6.5.17(a) constitutes an unreviewed- safety.

- question.

[ c. Provide - written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice ' President-Nuclear .

L Energy, and the Chairman, Off-Site Safety Review Committee of disagreement

• - between the Procedure Review Committee and the responsible ~ Approval '!

Authority.-

RECORDS.

6.5.2.8 The Procedure Review Committee sha!! maintain written minutes of each meeting and copies shall be provided to the Plant General Manager. ,

OUALIFIED REVIEW PROGR AM '

FUNCTION 6.5.3.1 A Qualified Review Program may be established, implemented, and j maintained. The Plant General Manager may ' designate specific procedures or 1 classes of procedures to be reviewed under the Qualified Review Program in lieu of review by POSRC or the Procedure Review Committee.

l RESPONSIBILITIES 6.5.3.2 The Qualified Review Program shall:

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a. Provide for the review of designated procedures and changes thereto by Qualified Reviewer (s) other than the individual who prepared the procedure  !

or change, i

b. Provide for cross-disciplinary review of procedures and changes when ,

l' organizations other than the preparing organization are ' affected by the '

procedure er change,

c. Ensure cross-disciplinary reviews are performed by Qualified Reviewers in affected disciplines, or by other persons designated by cognizant Managers,  :

Superintendents or General Supervisors as having specific expertise required to assess a particular procedure or chanFa Cross-disciplinary reviewers -may function as a committee.  ;

d. Provide for a screening 'of designated procedures and changes to determine 4 if an evaluation should be performed in accordance wuh the provisions of I 10 CFR Section 50.59 to verify that an unreviewed c.fety question does not exist. This screening will be performed by persons trained and qualified in this specific process and who may or may not be the same person (s) specified above as the Qualified Reviewer.

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AUTHORITY 6.5.3.3 The Qualified Review Program shall:

a. Provide for designation of Qualified Reviewers by the responsible Approval Authority (cognizant Manager. Superintendent or General Supervisor) for each procedure or class of procedures,

b. Provide for written recommendation' by the Qualified Reviewer to the responsible Approval Authority for approval or disapproval ' of procedures considered under 6.5.1.7(a).

RECORDS 6.5.3.4 Review of procedures performed under the Qualified Review Program shall be documented in accordance with administrative procedures.

TR AINING AND OUALIFICATION 6.5.3.5 Training and qualification requirements of personnel designated as Qualified Reviewers under the Qualified' Review Program shall be in accordance with administrative procedures.

16. A new condition was added to Technical Specification 6.8.2 - to allow the Plant General Manager to designate specific procedures or classes of procedures to be reviewed by the Procedure Review Committee or Qualified Review Program in lieu of review by POSRC -in accordance with proposed Technical Specifications 6.5.2 or 6.5.3, respectively.

17. The prior requirements of Technical Specifications 6.8.2 were reorganized into newly created Technical Specifications 6.8.3 and 6.8.4. Changes were made to

-denote that procedures may be approved by cognizant Managers, Superintendents or General Supervisors as opposed to_ only the Plant General Manager, as specified before. The approval authority for each procedure shall be designated by the Plant General Manager and shall be a different individual from the reviewer.

18. Technical Specification 6.8.3 was renumbered to 6.8.5 and a new condition to allow temporary procedural changes to be reviewed under the Procedure Review Committee or the Qualified Review Program was added.' The approval authority was changed from the Plant General Manager, to the designated Approval Authority.

19. Technical Specification 6.10 k was changed to add the requirement to retain records of Procedure Review Committee meetings.

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20. In Technical Specification 6.5.1.7a (proposed 6.5.1.8b), ' the word "writte n" has

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been deleted in . the sentence " Recommend to the Plant General Manager written approval of items . . . ."

21. .In Technical Specification 6.5.1.7c (proposed 6.5.1.8e), a typographical error was corrected (i.e., "with" changed to "within") and the words " Chairman of the" were added to: " Provide written notification . . . to the Chairman of the ,

OSSRC . . . ."

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22. The label at the bottom of page 6-13a of the Unit 2 Technical Specifications was.

L changed from Unit I to Unit 2.

1 l 23. Technical Specification 6.5.1.8a was created to denote that POSRC is to recommeld approval of designated procedures to the Approval Authority rather than to the Plant General Manager.

BLiSONS FOR CHANGES l~ Change I is necessary. because effective October 1,1990 the position of Manager-CCNPP l= will no longer. exist due to a reorganization. All previous duties held by the Manager-CCNPP will be assumed by the Plant General Manager.

Change ' 2 was made to correct an error since the position of General Supervisor -

Quality Control .and Support does not exist. The Fire Brigade training is maintained

. under the direction of General Supervisor - Planning and Support.

l Change 3 was made' to allow flexibility in choosing POSRC membership. Because of involvement in POSRC, the current membership' can not devote enough of their time for personal involvement in managing their individual sections. The proposed change would allow other qualified individuals to fill the membership and thus would free the L General Supervisors who comprise the current POSRC~ for their other duties. To be l considered for membership, individuals must have experience levels which meet or exceed o the experience levels required for plant staff per American National Standards L Institute ' (ANSI) N18 l-1971, " Standard for Selection and Training of Personnel for Nuclear Power Plan ts." Desides the experience requirement, individuals will be chosen  ;

, who have a broad perspective on plant c7eration and safety. This experience level plus l 1

the flexibility to appoint individuals who can devote more time to POSRC, will help to improve the overall effectiveness of POSRC, Furthermore, the areas of expertise currently on POSRC continue to be represented. An additional area of expertise has been added (i.e., Design Engineering) so as to broaden the Committee's perspective.

Change 3 will also eliminate the need for a Technical Specification amendment every time an organizational change occurs. The change to- require at least one ' POSRC member to hold a SRO license is a prior commitment contained in Reference (a), which we are meeting, t

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Changes 3 and 4 were made to provide the Plant General Manager, who has ultimate responsibility for' the- safe operation of the plant, with the authority to ensure that -

the best individuals are chosen for POSRC.

A portion of Change 5 is not a real change from the present Technical Specification, since the Plant General Manager will continue to~ appoint POSRC alternates as he currently does under' his present title of POSRC Chairman. By removing the temporary restriction on POSRC alternates, we have eliminated an undefined - restriction.

Furthermore, requiring the same experience level for alter. <tes as permanent members is an additional' restriction intended to improve the overall committee's effectiveness.

Changes 6 and 7 were both made for clarification.

Changes 8, 15, 16, 17, 18, and 19 were made to recognize the establishment of the Procedure Review Committee and- Qualified Review Program. Both of these programs are intended to lessen the POSRC workload by calling upon the expertise of other individuals to perform procedure reviews. This enables POSRC to concentrate on other issues which have a significant impact on plant safety and will also facilitate a more thorough ' review of plant procedures by individuals or groups more familiar with procedure content.

+ Change 9 was necessary because of the addition of new subsections.

Change 10 was made to remove an- unnecessary requirement, since the OSSRC may utilize staff resources to perform special reviews, etc. without recourse to the POSRC. This change also encourages more independence between POSRC and OSSRC.

Changes 11, 13, and 14 were made to incorporate additional requirements (i.e.,

recommend approval of Emergency Plan and Process Ccntrol Program for Change 11, determine if . unreviewed safety question exists for Security Plan, Emergency Plan and Process- Control Program for Change 13, -and evaluate root causes and recommend actions to prevent recurrence for Reportable Events and Potential Safety Hazards for Change 14).

Change 12 was made to remove a redundant requirement. Because Technical Specification violations are reported as a Reportable Event in which an assessment of safety consequences are required, the unreviewed safety question is encompassed by this assessment. POSRC will continue to revie w all Reportable Events including the adequacy of the safety assessment.

Change 20 eliminates unnecessary documentation since the POSRC meeting minutes will contain this information.

Change 21 was made to clarify that only the Chairman rather than the full OSSRC is to receive written notification. The OSSRC Chairman will direct future distribution at his discretion.

Change 23 allows the Manager or General Supervisor most knowledgeable about a particular procedure to approve the procedure. This allows the Plant General Manager more time to devote to other safety significant issues.

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DETERMINATION OF NO SIGNIFICANT HAZARDS These proposed changes have been evaluated against the standards in 10 CFR 50.92 and have been determined to involve no significant hazards consideration, 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; or i

These proposed changes which will allow for a more efficient - operation of i POSRC, along with more extensive procedural review, will not impact existing accident _ conditions or assumptions and thus, will not increase the probability or consequences of a previously evaluated accident. ,

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(ii) create the possibility of a new or different type of accident from any accident previously evaluated; or 1 Because the proposed changes will not change operation of any plant system nor require physical modification to any equipment, a new or different type accident cannot be created. l (iii) involve a significant reduction in a margin of safety, i

None of the proposed changes will have a direct impact on margin of safety of any Technical Specification; however, the importance of ' maintaining a strong POSRC is fully recognized as being necessary for safe operation.

POSRC will continue to represent the same areas of expertise and to meet the experience and training provision of ANSI N 18.1- 1971. Even though supervisory personnel will no longer be required to serve as POSRC members,  ;

the proposed experience and training' level requirements are the same or ,

greater. Furthermore, individuals will be chosen who have a broad perspective

-on plant operation and safety. These restrictions coupled with am& tem to POSRC being made by the Plant General Manager, who has ultimate responsibility for safe plant operation, will ensure that there will be no degradation of required expertise on POSRC.

Improvements are foreseen in organizational effectiveness by not requiring General Supervisors to serve on POSRC, thus allowing more time for the '

General Supervisors to devote to managing their individual sections.

Furthermore, more emphasis can be placed on other matters of safety significance by the establishment of the Procedure Review Committee and 'a Qualified Review Program to review selected procedures as ' determined by the

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Plant General Manager. The Procedure Review Committee and Qualified Review Program conform to guidance contained in Chapter 13.4 of NUREG-0800, " Standard Review Plan" Both of these programs describe what is to be reviewed and how this determination is made, provide for inter-disciplinary review of subject matter, document the review, and forward the recommendation to the appropriate members of management.

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Page 10- 1 All of the proposed changes are; designed to- strengthen POSRC and make it

- operate more effectively by focusing its attention on significant safety issues, and at the same _ time allow for_a more rigorous.. review of selected -

procedures by committees or individuals most knowledgeable. As such, the proposed changes will not impact on any margin of safety either directly or indirectly.

Accordingly, the proposed changes do not involve a significant hazards considerstion.

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

Very truly yours, b

'h '.

STATE OF MARYLAND  : '

TO WIT :

COUNTY OF CALVERT  :

I hereby certify that on the .N3_ day of Augus 1990, before , the subscriber, a Notary Public of the' State of Maryland in and for i AztrA f, alTIn- .

personally appeared George C Creel, being duly sworn, and. states that #e h 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: 87AJ) -

a Alad Notary Public -.

My Commission Expires: <Moannu, /. /Md f7 Dde GCC/DBO/ dim Attachments

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Page 11.

cc: : D. A Brune, Esquire

- J. - E. Silberg, Esquire R. A.Capra, NRC -

D. G. Mcdonald, Jr.; NRC T.- T. Mariin, NRC L. E. Nicholson, NRC R.1. McLean, DNR 1

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