ML20195J659

Submits Proposed Alternative to Requirements of 10CFR50.55a(g)(4) (Automatic Compliance with Latest Approved Edition of ASME Code Every 120 Months).Proposal Will Apply Third ten-year ISI Interval,Scheduled to Begin 990701

ML20195J659
Person / Time
Site:	Calvert Cliffs
Issue date:	06/16/1999
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9906210074
Download: ML20195J659 (2)

Text

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CnA LEs H. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby. Maryland 20657 410 495-4455 June 16,1999 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Proposed Alternative ASME Code Edition for the Third Ten-Year Inservice Inspection Interval

REFERENCES:

(a)

Letter from Mr. C. H. Cruse (BGE) to NRC Document Control Desk, dated January 29,1999, " Proposed Alternate American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI Edition for Unit Nos. I and 2 Third Ten-Year Inservice Inspection Intervals" (b)

Letter from Mr. C. II. Cruse (BGE) to NRC Document Control Desk, dated June 1,1999, " Submittal of Third Ten-Year Inservice inspection Program Plan" (c)

Telephone call from Mr. A. W. Dromerick (NRC) to Mr. E. M. Tyler (BGE) on June 3,1999 (d)

Telephone call from Mr. A. W. Dromerick and Mr. P. Patnaik (NRC) to Mr. E. M. Tyler, et. al. (BGE) on June 9,1999 l[i

/

Pursuant to 10 CFR 50.55a(a)(3), Baltimore Gas and Electric Company (BGE) hereby proposes an alternative to the requirements of 10 CFR 50.55a(g)(4)(automatic compliance with the latest approved edition of the American Society of Mechanical Engineers [ASME] Code every 120 months). Without approval of this proposal, the requirements of 10 CFR 50.55a(g)(4) will apply to the Third Ten-Year Inservice Inspection (ISI) Interval, which is scheduled to begin on July 1,1999. Implementing the 1989 Edition of the ASME Code by July 1,3999 would constitute a hardship for BGE.

,1 s -

J In Reference (a), BGE proposed using the 1998 ASME Section XI Code for the Third Ten-Year ISI Interval. Reference (a) also submitted a line-by-line comparison of the 1989 ASME Section XI Code Edition and the 1998 Code Edition. Reference (b) submitted the BGE Third Ten-Year ISI Interval 9906210074 990616 PDR ADOCK 05000317 G

PDR

. Docum:nt Control Desk

- C' June Iti,1999' Page 2 Program Plan. In Reference (c), BGE was advised that the NRC review of Reference (a) would not be completed by June 30,1999.

Therefore, this letter proposes, as an alternative to 10 CFR 50.55a(g)(4), that the third ten-year ISI interval for Units 1 and 2 begin on July 1,1999 using the 1983 Edition of the ASME Section XI Code with the Summer 1983 Addenda for all Class 1,2 and 3 components. Until such time as the NRC has completed its review of Reference (a), BGE proposes to continue to use the 1983 Edition of the Code We understand from Reference'(d) that the 1983 Edition of the Code may be used through the end of the 2000 Unit I refueling outage even if our request to use the 1998 Edition is approved before the end of that outage. We further understand that any inspections performed in the third interval under the 1983

' Edition of the Code will be creditable to the percentage requirements of the 1998 Edition. During the 2000 Unit I refueling outage, we may perform some examinations that are required by the 1998 Edition but not by the 1983 Edition. We understand that these examinations will be creditable to the 1998 i

Edition, once it is approved.

The use of the 1983 Edition of Section XI (with Summer 1983 Addenda) of the ASME Code for the Third Ten-year ISI Interval, pending NRC approval of Reference (a), provides an adequate level of safety and quality.

We request that t+

NRC approve this proposal before the end of the second ISI interval on June 30, 1999.

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

Very truly yours, f

i CHC/EMT/ dim cc:

R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident inspector, NRC S. S. Bajwa, NRC R.1. McLean, DNR

' A. W. Dromerick, NRC J. H. Walter, PSC 1

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