ML20149M735

Comment Re Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Endorses NUMARC Comments W/Listed Clarifications

ML20149M735
Person / Time
Site:	Calvert Cliffs
Issue date:	02/17/1988
From:	Tiernan J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-52FR45344, RULE-PR-50 52FR45344-00017, 52FR45344-17, GL-85-07, GL-85-7, NUDOCS 8802290027
Download: ML20149M735 (2)

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E30 POSED RULE m anew D ALTIMORE GAS AND ki(W ELECTRIC

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NvcktAA e=theY February 17, 1988 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Docketing and Service Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Proposed Policy Statement on Integrated Schedules for Implementation of Plant hiodifications

REFERENCE:

(a) Letter from Mr. J. F. Colvin (NUh1 ARC) to hir. S. J. Chilk (NRC),

dated January 25, 1988, same subject (b) Letter from hit. A. E. Lundvall, Jr. (BG&E) to Mr. H. L. Thompson (NRC), dated July 8,1985, Generic Letter 85-07, Implementation of Integrated Schedules for Plant Madifications Gentlemen:

Baltimore Gas and Electric is pleased to have the opportunity to comment on the proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications. We have reviewed the proposed policy statement and have participated in the formulation of the NUMARC comments (Reference a). We would like to take this opportunity to endorse the NUMARC comments as representing our position on this issue with the following clarifications.

We have chosen not to submit our scheduling process for review by the NRC for the reasons outlined in our response to Generic Letter 85-07 (Reference b). We feel strongly that the utility management should retain control over the scheduling process.

Additionally, the policy statement should clearly state that penalties, either implicit or explicit, will not be applied to utilities who fall into categories 2 and 3. This will emphasize the voluntary nature of this program and allow utilities to choose a course of action based on the merits of the progr.am, without duress.

We understand that comments were due to the Commission by January 25, 1988. We apologize for this late endorsement and hope that you will consider it prior to any

\% further action concerning this policy statement.

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Page 2 Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, an+as-JAT/ PSF / dim cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A.Capra,NRC S. A.McNeil,NRC W. T. Russell, NRC D. C.Trimble, NRC ,

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