ML20149M964
| ML20149M964 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/23/1988 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Miraglia F NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| References | |
| GL-88-02, GL-88-2, NUDOCS 8802290325 | |
| Download: ML20149M964 (3) | |
Text
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B ALTIMORE OAS AND ELECTRIC CHARLES CENTER
- P. O. DOX 1475 ' BALTIMORE. MARYL AND 21203
,10S EPH A.is ten AN V,CE Pats 10ta,t NwCLEAR Castmov February 23, 1988 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20$$$
ATTENTION:
hir. Frank J. Miraglia Associate Director for Projects
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & $0-318 Generic Letter 88-02. IntearAted Safety Assessment PrqgIgm flSAP) 11
REFERENCE:
(a) Letter from hir. A. E. Lundvall, Jr. (BG&E) to Mr.11. L. Thompson, Jr.
(NRC), dated Jiily 8,1985, Generic Letter 85-07, Implementation of integrated Schedules for Plant Modifications Gentlemen:
Baltimore Gas and Electric has reviewed Generic Letter 88-02 concerning utility participation in the ISAP 11 Program. At this time, we have no interest in participating in this proposed program.
It appears from the information provided in the generic letter that the ISAP 11 program consists of a plant specific, risk based, integrated schedule. We have implemented an Integrated Management System (IMS) which is a planning and scheduling system similar to the integrated schedule for plant modifications outlined in a proposed NRC policy statement. Gur IMS provides a resource leveling, tracking, and reporting capability. The scheduling portion of the system uses a benefit-risk / cost methodology for prioritizing projects. We have also performed a modified Level 1 PRA as part of our participation in the voluntary IPE program. We will upgrade our Level 1 PRA when the requirements are finalized as part of the IPE generic letter.
Within our IMS program we have always provided for discussions with the NRC, however, we continue to feel that our scheduling methods should not be the subject of a license amendment. The response to Generic Letter 85-07 (Reference a) explains why we oppose the use of a license amendment for our plant modification scheduling. Because the ISAP progritm appears to require a license amendment for modifying accepted schedules, it runs counter to our previous, as well as current, opinion.
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February 23, 1988
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In summary, we have closen not to participate in the ISAP 11 program for two reasons; (1) we prefer to upgrade our L.evel i PRA as part of the separate IPE program and (2) the requirement for a scheduling license amendment is contrary to our current position.
Should you have any questions regarding this matter, we will be pleased to diteuss them with you.
Very truly yours,
/ /
Cft444--
JAT/ PSF /dtm Attachment ec:
D. A. Brune Esquire J. E.
Silberg, Esquire R. A.Capra,NRC S. A.McNeil NRC W. T. Russell, NRC D. C. Trimble, NRC NRC Document Controf Desk
4 Integrated Safety Assessment Pregran (ISAF) !!
Response Ferrat to Generic Letter 88-02 Facility Name: calvert cliffs 1&2 Utility: Baltimore Gas & Elect ric Individual Contact Name: P. S. Furi Phone humber:(301) 260-4374 An expression of interest will not be considered a cociniteent te participhte on the part of the utility.
1.
Would you be interested in participating in ISAP II? If so, in what time frarre?
We are not interested in participating in ISAP II.
2.
Do you believe that an industry /NRC seninar consisting of a brief discussien by hRC followed by a question and answer period would be beneficial prior to making a decision?
See Item 5.
3.
Would you be interestec in a one-en-one meeting with the f;PC to discuss your particular facility or facilities?
See Item 5.
4 If you remain :,rdecided regaroing participation, what additieral infermation do you neec in order to take i decisteni N/A S.
Cc you have any potential concerns abeut participating iri lfAP !!?
e We prefer to upgrade our L.evel 1 IRA as part of the separate IPE program, o The r e q u i rc rr.e n t for a scheduling licensing amendment is cont rary to our previously established position.
S.
Do ycu have ar.y :u;gestier.s for progran improverents or charget?
Nene, at this time.
,