ML20247M524

Forwards Request for Addl Info Re Util 980327 Proposed Changes to Plant QA Policy

ML20247M524
Person / Time
Site:	Calvert Cliffs
Issue date:	05/14/1998
From:	Dromerick A NRC (Affiliation Not Assigned)
To:	Cruse C BALTIMORE GAS & ELECTRIC CO.
References
TAC-MA1474, TAC-MA1475, NUDOCS 9805260290
Download: ML20247M524 (6)

Text

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Mr. Ch rl:s H. Cruse May 14,'1998' Vice President-Nuclear Energy Biltimora G:s cnd Electric CompIny Calvert Cliffs Nuclear Power Plant

'IG50 Calvert Cliffs Parkway-Lusby, MD 20657-4702 i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION, CHANGES TO THE CALVERT CLIFFS NUCLEAR POWER PLANT QUALITY ASSURANCE POLICY (TAC NOS. MA1474 AND MA1475)

Dear Mr. Cruse:

By letter dated March 27,1998, as supplemented April 21,1998, Baltimore Gas and Electric l

Company (BGE) proposed changes to the Calvert cliffs Nuclear Power Plant, Units Nos.1 and 2.

Quality Assurance (QAP) Policy. The NRC staff is currently reviewing your request for these i

changes. Enclosed is a request for additional information which is required in order for the staff to complete its review of your request. The request for additional information also provides our -

preliminary evaluation of certain QAP changes submitted in accordance with 10 CFR 50.54(a)(3) that were identified as reductions in commitments in your March 27,1998, letter.

Based on our need for the additional information, we have not determined if these changes are acceptable pursuant to 10 CFR 50.54 (a)(3)(ii) and you should refrain from implementing them t

l until you have been formally notified otherwise. The staff requests that the additional information be provided within 60 days of receipt of this letter.

If you have any questions regarding this matter, please contact me at (301) 415-3473.

Sincerely, Original Signed by:

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Alexander W. Dromerick, Senior Project Manager Project Directorate I-1 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket Nos. 50-317 i

and 50-318 l

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Mr. Ch:rt:s H. Cruse fiay 14, 1998

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Vice President-Nuclear Energy Baltimore Gas and Electric Company

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Y Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway i

Lusby, MD 20657-4702

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION, CHANGES TO THE CALVERT CLIFFS NUCLEAR POWER PLANT QUALITY ASSURANCE POLICY (TAC NOS MA1474 AND MA1475)

Dear Mr. Cruse:

I l

By letter dated March 27,1998, as supplemented April 21,1999, Baltimore Gas and Electric Company (BGE) proposed changes to the Calvert cliffs Nuclear Power Plant, Units Nos.1 and 2.

l Quality Assurance (QAP) Policy. The NRC staff is currently reviewing your request for these changes. Enclosed is a request for additional information which is required in order for the staff to complete its review of your request. The request for additional information also provides our preliminary evaluation of certain QAP changes submitted in accordance with 10 CFR 50.54(a)(3) that were identified as reductions in commitments in your March 27,1998, letter.

Based on our need for the additional information, we have not determined if these changes are acceptable pursuant to 10 CFR 50.54 (a)(3)(ii) and you should refrain from implementing them until you have been formally notified otherwise. The staff requests that the additional information l

be provided within 60 days of receipt of this letter.

If you have any questions regarding this matter, please contact me at (301) 415-3473.

Sincerely, Original Signed by:

Alexander W. Dromerick, Senior Project Manager Project Directorate 11 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-317 i

and 50-318

Enclosure:

Request for Additional information cc w/ encl: See next page DISTRIBUTION:

Docket File S. Bajwa R. Gramm C. Hehl, Region I PUBLIC S. Little S. Black i

PDl-1 R/F A. Dromerick OGC J. Zwolinski (A)

L.' Campbell ACRS DOCUMENT NAME: G:\\CC1-2\\CCMA1474.RAI To re :lve a copy of this document, indicate in the box: "C" = Copy without attachment'anciosure "E"

= Copy with attachment / enclosure "N" = No copy v

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May 14, 1998 l

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Mr. Charles H. Cruse Vice President-Nuclear Energy Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 l

SUBJECT:

REQUEST FOR ADDIT;ONAL INFORMATION, CHANGES TO THE CALVERT l

CLIFFS NUCLEAR POWER PLANT QUALITY ASSURANCE POLICY l

(TAC NOS. MA1474 AND MA1475)

Dear Mr. Cruse:

By letter dated March 27,1998, as supplemented April 21,1998, Baltimore Gas and Electric Company (BGE) proposed changes to the Calvert cliffs Nuclear Power Plant, Units Nos.1 and 2.

Quality Assurance Policy (QAP), The NRC staff is currently reviewing your request for these changes. Enclosed is a request for additionalinformation which is required in order for the staff to complete its review of your request. The request for 6dditionalinformation also provides our preliminary evaluation of certain QAP changes submitted in accordance with 10 CFR 50.54(a)(3) that were identified as reductions in commitments in your March 27,1998, letter.

Based on our need for the additional information, we have not determined if these changes are acceptable pursuant to 10 CFR 50.54 (a)(3)(ii) and you should refrain from implementing them until you have been formally notified otherwisa. The staff requests that the additionalinformation be provided within 60 days of receipt of this letter.

If you have any questions regarding this matter, please contact me at (301) 415-3473.

Sincerely, Alexander W. Dromerick, Senior Project Manager Project Directorate 1-1 l

Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

Request for Additional Information cc w/ encl: See next page

,o 1:

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Mr. Charles H. Cruse Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant cc:

President.

Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 l

James P. Bennett, Esquire i

Counsel Kristen A. Burger, Esquire

. Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre

- Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and Trowbridge Patricia T. Bimie, Esquire 2300 N Street, NW Co-Director i

Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 i

Mr. Thomas N. Pritchett, Director Baltimore, MD 21218 l

l NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell l

1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. Richard I. McLean, Manager Nuclear Programs Power Plant Research Program,

Maryland Dept. of Natural Resources Tawes State Office Building, B3

. Annapolis, MD 21401 Regional Administrator, Region i U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 I

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.___-__________________-_-________A

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REQUEST FOR ADDITIONAL INFORMATION BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS.1 AND 2 DOCKET NOS. 50-317 AND 50-318 By letter dated March 27,1998, as supplemented April 21,1998, Baltimore Gas and Electric Company (BGE) submitted proposed changes in accordance with 10 CFR 50.54(a)(3) to Calvert l

Cliffs Nuclear Power Plant, Unit Nos.1 and 2, Quality Assurance Policy (QAP). The scope of the NRC staff's review of these QAP changes was limited to those changes identified as reductions in commitments in BGE's March 27,1998, letter.

BGE proposed to add the following to Section 18.5, " Instructions, Procedures, and Drawings," on Page 25 of Revision 49 to its QAP:

• Editorial corrections to procedures of Technical 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."

NRC Comments:

1. The terms " editorial correction" and " minor alterations" as related to procedure changes are not addressed in the QAP. Please define these terms.

2. The BGE March 27,1998, letteridentified correcting a spelling error as a type of an editorial correction covered by the scope of the proposed QAP change. However, it appears from the text of the March 27,1998, letter that the scope of the change is for minor alterations. Please provide other examples of minor alterations.

Because the proposed change affects TS Section 6.4 procedures, the staff questions the extent of review performed to ensure that the editorial change would not change the intent of the procedure. The BGE QAP provisions for controlling temporary changes to procedures (changes that do not change the intent of the procedures) controlled by TS Section 6.4 require certain reviews and approvals prior to implementation and full review and approval of the changes within 14 days ofimplementation. Unlike the QAP provisions for Temporary Changes, there appears to be no independent reviews or overchecks to ensure that the editorial change or minor alteration would not change the intent of the procedure.

Please provide additional discussion on the differences between changes made as temporary changes (that do not change the intent of the procedure) and changes that are minor alterations. Should the scope of minor alterations be similar to certain changes controlled as temporary changes, the staff believes that the temporary change controls should apply to such changes.

3. Would editorial changes to procedures for TS Section 6.4 procedures be subjected to some type of independent review such as a limited scope review by a qualified reviewer or the Procedures Review Committee (PRG)(see comment below) to ensure that the intent of the procedure is not changed by the editorial change before being approved? If not, please provide additional discussion and identify the contrcIs that would provide assurance that the editorial change would not change the intent of the procedure.

Enclosure

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t 4. Reference is made to designating certain classes of procedures in writing to be reviewed by the PRG. Would any of the TS Section 6.4 procedures be designated as being subject to review by the PRG7 What are the requirements for the individuals in the PRG performing procedure review? Are the qualification requirements the same as those for a qualified reviewer?

5. Because of the safety significance of certain TS Section 6.4 procedures and the fact that l

certain editorial changes / minor alterations may change the intent of a procedure, the staff l

believes these administrative controls, as well as additional controls for ensuring that the i

editorial change does not change the intent of the procedure, need to be addressed in the QAP.

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