ML20098E718

Requests Exemption from 10CFR50,App J Primary Reactor Containment Testing Requirements Determined to Be Impractical.Intent Satisfied by 40 Plus 10-month Frequency. Refueling Outage Schedule Encl.Fee Paid

ML20098E718
Person / Time
Site:	Calvert Cliffs
Issue date:	09/14/1984
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	John Miller Office of Nuclear Reactor Regulation
References
NUDOCS 8410010312
Download: ML20098E718 (3)

Text

. - . - -. . .-

i

.y

/ I

.,' BALTIMORE

, l

' , / l GAS AND / I ELECTRIC A

CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNOVALL,JR.

Vict PntstDENT S UPPLY September 14,1984 U.S. Nuclear' Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC 20555-

- ATTENTIONi Mr. James R. Miller, Chief Operating Reactors Branch #3 4-Division of Licensing

'SUBJECTi Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Primary Reactor Containment Testing Request for Relief from.10 CFR 50 Appendix 3 Requirements Determined to be Impractical Gentlemen:

In accordance -~with 10 CFR 50.12, we are requesting an exemption from certain

-requirements of 10 CFR 50.54(o) that have been determined to be impractical. . As outlined in 10 CFR 50.12, the information concerning the exemption request is presented herein.

The requirements of 10 CFR 50 Appendix 3 III.D.l(a) specify ". . . a set of' three tests shall be performed, at approximately equal intervals during each 10-year service period.

The third test of each set shall be conducted when the plant is shutdown for the 10-year plant Inservice Inspections (ISI)." In addition to the Appendix 3 requirements, the Calvert Cliffs Unit l & 2 Technical Specifications specify the Type A tests must be performed every 40110 months. If the third Integrated Leak Rate Test (ILRT) is performed at the scheduled 10-year ISI outage, the 40 1 10 month testing frequency will be exceeded. We request a permanent exemption from the requirement to conduct the third ILRT during the shutdown ' for the 10-year ISI outage, in that no 10-year ISI outage activity specifically alters containment integrity. We feel that the intent of the codes are i satisfied by the 40110 month frequency. Our scheduled refueling outages are indicated ir.

the following table.

,f 3

8410010312 840914 -

, PDR ADOCK 05000317 p .

. PDR-y'e g- ww- gr *w-+=**wte r s t- My+Nw- *-my e yr -9,e---

9,*M*--

- Mr. James R. Miller

- September 14,1984 Page 2 CALVERT CLIFFS REFUELING OUTAGES UNIT ONE . UNIT TWO Spring 82* Fall 82*

Fall 83 Spring 84 Spring 85** Fall 85**

' Fall 86*** Spring 87***

Spring 88 Fall 88 Fall 89 Spring 90

• Last completed ILRT

• • Next scheduled ILRT

• • • 10-year ISI outage No other requirement of 10 CFR 50.54 or Appendix 3 will be affected by granting the exemption. Our previous Type A test performance dates and scheduled 10-year ISI outage make it impractical to perform the Type' A test during the 10-year ISI outage.

The third of the subject tests will be conducted to meet the 40,+10 month frequency requirement. This test will occur during the outage prior to the 10-year ISI. Performing

-the next Type A test for Unit I and 2 during the 1985 Spring and Fall outages, respectively, will provide periodic assessment of Containment Integrity.

Granting the requested exemption will not give rise to a adverse impact on the environment. Performance of the Type A test will continue to ensure satisfactory containment performance. It is in the public benefit to grant the requested exemption as it ensures the safest and most economical testing schedule.

Pursuant to 10 CFR 170.21, Baltimore Gas & Electric Check No. B394034 in the amount of $150 is remitted to cover the application fee for this request.

Should you aiiy questions regarding this matter, please do not hesitate to contact us.

Very truly yours,

/

/

f ,.

L AEL/OPB/gla _

Attachment

.gy .

7. .

o i

- Mr. James R. Miller

' September 14,1934 l Page 3 j 1

1 cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. Foley, NRC l

.