ML20214A225
| ML20214A225 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/11/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8705190335 | |
| Download: ML20214A225 (2) | |
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B A LTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERN AN Vict PRESIDENT NUCLEAR ENERGY May 11,1987 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 Request for Exemption from Inservice Inspection Requirements in 10 CFR 50.55a(g)
REFERENCE:
(a)
Letter from Mr. J. A. Tiernan (BG&E), to NRC Document Control Desk, Request for Relief from Replacement Requirements in Section XI of the ASME Boile; and Pressure Vessel Code, Articles IWA-7210, IWC and D-7600, dated May 11, 1987 Gentlemen:
We have determined that the relief from ASME Section XI rcquirements we requested in Reference (a) may also be granted by the Commission in the form of an exemption to the inservice inspection requirements in 10 CFR 50.55a(g). Pursuant to 10 CFR 50.12, we hereby request such an exemption.
We seek either relief from ASME Section XI requirements or an exemption from 10 CFR 50.55a(g). Both are not required.
Section 50.55a(g) states we must meet the requirements set forth in Section XI for all ASME Class 1, 2, and 3 components. This exemption request is limited to fasteners for those components listed in Attachment A of Reference (a) and the requirements in Articles IWA-7210, IWC-7600, IWD-7600, and IWF-7600 of Section XI as they pertain to Certified Material Test Reports or Certificates of Compliance and marking requirements only.
Granting this exemption will not violate any other applicable laws, including the Atomic tergy Act and the National Environmental Policy Act. This exemption will not present an undue risk to the public health and safety, and is consistent with the common def ense and security.
We believe that special circumstances exist that would lead the Commission to consider this request.
Within the narrow scope previously defined, application of 10 CFR 50.55a(g) is not necessary to achieve the underlying purpose of the rule. The underlying purpose of 10 CFR 50.55a(g) is to ensure that structures, systems, and 8705190335 e70321 g$
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Document Control Desk May 11,1987 Page 2 components important to safety are maintained to quality standards commensurate with the importance of the safety function to be performed.
The safety function of the fasteners is to maintain their structural integrity under all expected operating and accident conditions. The quality standards are, as a minimum, those required by regulation at the issuance of the construction permit.
When construction is complete, those standards are maintained by following the requirements of ASME Section XI.
We have established a new quality standard for fasteners of those components listed in Attachment A of Reference (a). That standard is the testing program described in Attachment B of Reference (a) and the sampling program described in Attachment C of Reference (a). The examinations specified in the testing program are sufficient to determine that the structural integrity of the fasteners has been maintained. In the future, we will meet the requirements of ASME Section XI when we replace these fasteners.
By completing all tests, satisfying the sampling criteria, and following the requirements of ASME Section XI for future replacements, we will achieve the underlying purpose of 10 CFR 50.55a(g).
Application Fee Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1910548 in the amount of
$150.00 to cover the application fee for this request.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
<LW i
3AT/ WPM / dim cc:
D. A. Brune, Esquire
- 3. E. Silberg, Esquire R. A. Capra, NRC S. A. McNeil, NRC W. T. Russell, NRC T. Foley/D. A. Trimble, NRC l
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