ML19332C215
| ML19332C215 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/13/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911270012 | |
| Download: ML19332C215 (2) | |
Text
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t BALTIMORE GAS AND ELECTRIC t
P CHARLES CENTER. P. O. BOX 1475
- BALTIMORE, MARYLAN D 21203
.l Geomoc C CREcL -
l Vact Passiotut NucLesu Cutmos b oO
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- November 13,1989 i
U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant i
Unit Nos.1 & 2: Decket Nos. 50-317 A 50-318 Reauest for Relief frem ASME Code Section XI Reauirements
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REFERENCE:
(a) Letter to Document Control Desk from G.
C.
Creel,. dated j
October : 26, 1989,. same subject Gentlemen:
This letter replaces Reference (a) in its entirety, which should be disregarded.
This letter references 10 CFR 50.55a(g)(5)(iv).
Reference (a) referenced 10 CFR 50.55a(a)(3).
1 In accordance with 10 CFR 50.55a(g)(5)(iv),' we are requesting partial relief from an
. ASME Code Section XI requirement.
On February 26, 1987, we submitted our 10-year ASME Section XI Pump and Valve Test H
Program. Page C-50, Rev.
1, September 26, 1988, of that submittal contains Relief l-
-Request Number A-3, concerning a Relief Valve Test Supervisor.
We have received indiention, through our NRR Project Manager, that Relief Request A-3 will be denied. The partial relief requested by this letter addresses part of the i
requirement that Relief Request A-3 addressed, I.
Components for Which Relief is Reauested Relief valve testing per ASME Section XI. IWV-3512.
'.11.
ASME Recuirement from Which Relief is Reauested
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l ASME Section XI, IWV-3512 requires compliance with ASME performance Test f)g Code (PTC). 25.3-1976. Paragraph 3,02 of PTC 25.3 requires a person to i
supervise these tests who has obtained a degree in a branch of Engineering from a recognized school of Engineering and in addition, has at least two years practical experience in fluid flow measurement.
L 8911270012 891113
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- Docume t Contr:1 Desk November 13,1989 Page 2 i
We request relief from the two yects practical experience in fluid flow measurement requirement, i
111.
Basis for Relief We have determined that the requirement to have two years practical experience in fluid flow measurement - is impractical. No fluid flow measurement is required by ASME Section XI, and none is performed by us in satisfying the requirement. The requirement has no effect on the performance of this relief valve testing. Supervision of relief valve testing is being performed by a degreed Engineer satisfying all of the requirements of PTC 25.3 with the exception of fluid flow measurement experience. We have placed an additional person in this position who meets all the requirements, in order to comply.
This person's regular duties have nothing to do with relief valve testing.
IV.
Alternative Testina No alternative testing is proposed. Supervision of relief valve testing will
,l' be performed by degreed Engineers satisfying all of the requirements of PTC 25.3 with the exception of fluid flow measurement experience, l
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
l Very truly yours, 1
l l
l GCC/DLS/ dim cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC S. A.McNeil, NRC W. T. Russell, NRC J. - E. Beall, NRC T. Magette, DNR
.