ML20024D115
| ML20024D115 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/22/1983 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8308030176 | |
| Download: ML20024D115 (3) | |
Text
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v BALTI MO RE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTlMORE, MARYLAND 21203 ARTHUR E LUNDVALL, JR I
Vice Peersiote t
- sum, Director of Nuclear Reactor Regulation Attention: Mr. R. A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Calvert Cliffs Nuclear Power Plant Units Nos.1 & 2; Dockets Nos. 50-317 and 50-318 Supplement I to NUREG-0737
Reference:
BG&E Letter from Mr. A. E. Lundvall, Jr. to Mr. R. A. Clark, dated April 15,1983 Gentlemen:
NRC Generic Letter 82-33 ' equired all licensees to develop and submit r
schedules for the implementation of NUREG-0737, Supplement I requirements. Our response to Generic Letter 82-33, which included BG&E's plans for implementing the subject requirements, was provided in Reference 1. We stated that inasmuch as BG&E's initiative in several areas (i.e.; control room design review, R.G.1.97 review, and emergency response facilities) had placed the Company in a reasonably good position for responding to the overall scope of requirements, we would not be able to provide an integrated implementation schedule until we had developed plans for procuring and installing a safety parameter display system (SPDS) cad for upgrading our emergency operating procedures (EOPs). In addition, we stated that our integrated schedule could not be finalized until it had been adjusted to account for resource (manpower) constraints and the need to complete other work activities of greater safety significance.
Consequently, we indicated that we would submit an integrated schedule for the implementation of Supplement I requirements by December 1,1983 which would provide the basis for final negotiatiens with our NRC Project Manager. Updates to this schedule would be submitted periodically to indicate our progress in completing the required activities and to keep you aware of any changes in work priorities or other problems affecting the schedule (material delivery, installation / testing difficulties, etc.). We did, however, provide you with a preliminary schedule for submitting certain licensing documents required by Supplement 1 (see Section 7 of Reference 1).
On July 11, 1983 you verbally informed us that the NRC was preparing a set of confirmatory orders, to be applied to each operating license, that won!d establish deadlines for the completion of various activities under Supplement 1 to NUREG-0737.
Accordingly, you requested that we provide a schedule for completing each of those activities by July 15,1983.
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Mr. R. A. Clark July 22,1983 i
As we have not yet completed the development of our integrated schedule, we expressed reservations with providing the requested schedular information unless we could be reasonably assured that future extension requests would be considered in a favorable light if sufficient justification could be presented on our behalf. In response to our concern, you stated that the draft confirmatory order contained a provision that would accommodate reasonable extension requests, to be granted by the Director of the l
Division of Licensing, where good cause was shown.
1 In reviewing the specific nature of the activites that you propose to include under the confirmatory orders, and after considering the provision stated above, we i
found that the requested schedules could be provided in advance of our completing the integrated implementation schedule. We provided the desired Information via telephone on July 15, 1983.
This letter officially transmits the schedules discu:: sed in that telephone conversation (see attachment). These schedules are based, where applicable, on the preliminary information provided in Reference I with some additional time allowed for completion of internal reviews and performance of operator training and equipment testing, as appropriate.
With regard to the schedule for completing the Technical Support Center and i
Emergency Operations Facility, please be aware that by the dates listed, each of these facilities will be provided with the instrumentation necessary for the performance of
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their required functions. As we stated in Reference 1, it is possible that additional Instrumentation would be made available to the TSC or EOF as the result of the final l
R. G.1.97 review; however, any such additions should be treated as facility improvements. TSC and EOF operability will not be constrained by completion of the final R. G.1.97 review.
We would be pleased to discuss any aspect of this advance schedule j
information. We will continue to develop an integrated implementation schedule for use as necessary in any future schedule negotiations.
If there are any questions, please do not hesitate to contact us.
Sincerely, NW%
AEL/BSM/vf Enclosure cc: 3. A. Biddison, 3r., Esquire G. F. Trowbridge, Esq.
i Mr. D. H. Jaffe, NRC l
Mr. R. E. Architzel, NRC i
Mr. 3. C. Ventura, Bechtel l
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r-NRC Confirmatory Orders for Supplement 1 Requirements Requirement Date 1.
SPDS a.
Submit list of parameters displayed June 1,1984 and justification for adequacy b.
SPDS operational and training complete October 1,1986 (U2)
October 1,1987 (Ul) 2.
CRDR a.
Submit CRDR Program Plan September 1,1983 b.
Submit CRDR Summary Report with schedule January 1,1984 for implementation of required changes 3.
R. G.1.97 a.
Submit report describing how requirements December 1,1984 have been/will be met b.
Date for implementation of required changes (date to be provided December 1,1984) 4.
Upgraded Emergency Operating Procedures (EOP)
Submit procedures generation package (PGP)
January 15,1984 a.
l b.
Implement upgraded EOPs (date to be provided l
January 15, 1984) 5.
Emergency Response Facilities (ERF) a.
TSC fully functional March 1,1984 b.
OSC fully functional N/A (currently operational) c.
EOF fully functional January 1,1984 l
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