ML20198S759

SER Accepting Quality Assurance Program Description Change for Calvert Cliffs Nuclear Power Plant,Units 1 & 2

ML20198S759
Person / Time
Site:	Calvert Cliffs
Issue date:	01/07/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20198S753	List: ML20198S749 ML20198S759
References
NUDOCS 9901110414
Download: ML20198S759 (3)

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s* NUCLEAR REGULATORY COMMISSION o WASHINGTON, D.C. 20655 4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

.QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT '

DOCKET NOS. 50-317 AND 50-31C i

By letter dated March 27,1998, as supplemented by letters dated April 21,1998, and November 24,1998, the Baltimore Gas and Electric Company (BGE) submitted proposed changes in accordance with 10 CFR 50.54(a)(3) to the Calvert Cliffs Nuclear Power Plant (Calvert Cliffs) Quality Assurance Program Description (QAP). The scope of the Quality '

Assurance, Vendor Inspection and Maintenance Branch's (HQMB's) review of these QAP change; was limited to those changes identified as reductions in commitments. BGE has proposed changes regarding the approval authority for procedures listed in Calvert Cliffs Technical Specification 5.4 and the addition of new requirements for processing editorial corrections to these procedures. The fol'owing sections provide the staff's evaluation of these proposed changes. l Proposed QAP Chanoes BGE proposed the following changes for the approval of procedures listed in Technical

_ Specification 5.4 (proposed deletions are shown with a strikeout and additions are in redlined text):

Procedures listed in Technical Specification 6.4 [ currently Technical Specification 5.4] shall be approved by the Plant General Manager or by cognizant Managers, Superinte.ndents, or. General Supervisors (or Directors) and other' supervisory personnel that report directly to a manager, 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 QJalified Reviewer.

_ Temporary changes to procedures of Technical Specification 6.4 [ currently Technical ,

Specification 5.4] may be made provided:

a. The inient of the original procedure is not altered.

b. The change la 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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c. The change is documented, reviewed by the POSRC, the Procedure Review Committee, or by a Qualified Reviewer and approved by the designated authority within 14 days of implementation.

EdiiNI5i'd6EIEIiEFA'l57565ddieTg8ksiniddi65[56fnijIisliih~ted in TAEEhichi Specification SAmay beirnadelprovidedi E Ifie.correctiodIi7ili5weif}yT53EefddliA[sdd  :

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$ 7"as iffshtedbythefprocsildfe ahd a Qdalifisd RsWeserMTh inanagement istaff membef and the1Q6alifiedReviewerlmep be the;same persors hi"0A$d;iri'tElid$35mshEl Edit 5riiihdrr$hilon"Tidifiidd is"a pfoce'siuded t6I566rporali' minor altsrations in an

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approved procedure.iMinor alteration is.' defined as a tarm to ' recognize a procedure 1

alteration that does ~not constitute a change in intent, a change to a Technica! '

Specification, orintroducefari unrevie'wed safety lquestionnThis' term is onlylisid'in conju_nction.withlar[eifitorial correction:

Apolicable Reoulatory Reouirements Criterion IV, "Docun..at Control," of Appendix B to 10 CFR Part 50 requires, in part, that l changes to documents which prescribe activities affecting quality shall be reviewed for l adequacy and approved for release by authorized personnel and that changes to these i documents (e.g., procedures) shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization. Further, in order to ineet the requirements of 50.34(b)(6)(ii) to describe how the requirements of Appendix B to 10 CFR Part 50 will be satisfied, the Calvert Cliffs QAP has committed to the provisions contained in ANSI N 18.7-1976, " Administrative Controls and Quality Assurance for the Operationci Phase of Nuclear Power Plants," as endorsed by Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements (Operations)," Revision 2. The Calvert Cliffs QAP contains provisions for the use of Qualified Reviewers and ANSI N18.7 provisions that describe how the procedure control requirements of Appendix B to 10 CFR Part 50 will be satisfied.

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NRC Evaluation The approval authority has been expanded to include supervisors that report directly to a menager. BGE stated in its March 27,1998, letter that "This proposed change to the QA

Policy will extend the approval authority to all General Supervisors and to other supervisory personnel who are not called General Supervisors, but who report directly to a manager." BGE further stated that " Allowing approval at this level of supervislen helps ensure procedure

ownership is at the level of plant management that is knowledgoable in the areas affected by

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y the approval authority for specific procedures or classes of procedures shall be designated in writing by the Plant General Manager."

The review and approval process for making editorial changes to procedures listed in Technical Specification 5.4 proposed by BGE was detailed in its March 27,1998, letter which stated, in part, that editorial corrections are changes to a procedure that are minor alterations (such as correcting misspellings) not requiring a detailed review and approval process.

Further, in its November 24,1998, !etter, BGE proposed adding text to the QAP to expend the review of editorial corrections to include a Qualified Reviewer.

CONCLUSION The proposed changes to the QAP were reviewed in accordance with Section 17.2, " Quality Assurance During the Operational Phase," Section 17.1 as referenced in Section 17.2, and Section 13.4, " Operational Review," of NUREG-0800 and were found to con' oJe to meet the applicable regulatory requirements and the applicable procedure control provisions contained in RG 1.33.

Principle Contributor Larry Campbell Date: -(lanuary 7,1999 l

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