ML19253B254
| ML19253B254 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/05/1979 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7910100160 | |
| Download: ML19253B254 (2) | |
Text
0 BALTIMORE GAS AN D ELECTRIC COMPANY GAS AND ELECTRIC DUILDING B ALTl M O R E, M A RYL A N D 21203 October 5, 1979 ARTHun E. LUNDVALL,JR-vic a Paa s.ca=.
Sws*L.
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attn:
Mr. Robert O Reid, Chief Operating Reactors Branch #h Division of Operating Reactors
Subject:
Calvert Cliffs Nuclear Power Planu Units Nos. 1 & 2, Docket Nos. 50-317 & 50-318 Secondarv Water Chemistry
Reference:
NRC letter dated 7/23/T9 from R. W. Reid to A. E. Lundvall, Jr., same subject.
Genthmen:
The referenced letter infor=ed us that the prevention of steca generator tube degradation through the implementation of a chenistry control and surveillance program enforced by the technical scecifications may be accompliched through a more efficient method, the use of a license condition.
The letter also requested that we submit an application with fee for a license amendment to include the proposed license condition. The license condition vould thrt invoke a specific chemistry control and surveillance program, including procedures.
We have discussed the proposed amendment, both within our Company and with your Staff, especially as concerns the potential benefits of the change set against the cost of reauesting and implementing the change, and have determined that it is not fully justifiable at this time. We base this determination on the following:
'.. 'Ihe Calvert Cliffs chemistry program has been in effect since initial fill of the systems involved and is well-documented in plant procedures. Specific parameters have been subject to Technical Specifications since the implementation of the Standard Technical Specifications on February 11, 1977 This arrangement has provided centinuous assurance of a well-maintained chemistrv program.
As ycu nay recall, Baltimore Gas and Electric Company van one of the first companies to cooperate with NRC in the develep-ment of the Standardized secondary chemistry technical specifications.
2.
Cur inservice inspection program has shown that the Calvert Cliffs steam generator tubes have e:thibited a high degree of corrosion resictance.
Thiscanbedirecti~vattributedtoth[a l 2 k j(()
careful implementation of the chemistry control program.
I60+
791005.0 9
~
Mr. R. W. Reid 2-October 5, 1979 3.
The submittal of the proposed application vould require the simultaneous submittal of the appropriate fee ($4,h00) unless it is determined that our previous early request for secondary chemistry technical specifications, submitted on December 20, 1976, qualifies us for e::emption of the fee. We feel that this fee, coupled with the manpower required to implement a modified chemiatry progr 2, if necessary, is in excess of the benefits to be gained in the case of Calvert Cliffs.
h.
Even if the present chemistry program is considered acceptable such that no changes are required, we feel that the fee is in excess of the potential benefits.
Therefore, we propose to submit the requested application combined with several other technical specification changes, which ve are currently developing, so as to make use of the provision which allows the submittal of a blanket fee to cover three or more changes.
We vould be pleased to discuss this matter with you and request that a meeting be scheduled between the appropriate members of our Staffs if you feel that better clarification of your intended program is required.
Very t ly ypurs, 44 cA.m cc:
J. A. Biddison, Esquire G. F. Trowbridge, Esquire Mr. E. L. Conner, Jr. - NRC Mr. P. W.,Kruse - CE F
i124 337 S
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