ML20217K329

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Requests Relief from ASME Boiler & Pressure Vessel Code Requirement Re End Date of Unit 1 Second ten-year ISI Interval,To Allow Interval to Extend to End of Unit 2 1999 Refueling Outage & Not Later than 990630
ML20217K329
Person / Time
Site: Calvert Cliffs 
Issue date: 04/28/1998
From: Cruse C
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9805010163
Download: ML20217K329 (3)


Text

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9 CH4xtxs II. CRUSE Baltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby. Maryland 20657 410 495-4455 April 28,1998 I

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No.1; Docket No. 50-317 Relief From ASME Code Requirements: Unit 1 Second Ten-Year Inservice Inspection Interval

REFERENCES:

(a)

Letter from Mr. R. A. Capra (NRC) to Mr. G. C. Creel (BGE), dated January 11,1990, " Approval of Second Ten-Year Inservice Inspection Program Plan for Calvert Cliffs Units 1 and 2 (Unit i TAC. 67094; Unit 2 TAC. 67095)"

(b) 1.etter from Mr. C. H. Cruse (BGE) to the NRC Document Control Desk, dated March 18,1997," Notification of Extension of the Inservice Test and Inspection Program Second Ten-Year Intervals" (c)

Letter from Mr. A. W. Dromerick (NRC) to Mr. C. H. Cruse (BGE) dated May 2,1997," Notification of Extension of the Inservice Test and Inservice Inspection Program Second Ten-Year Intervals - Calvert Cliffs Nuclear Power Plant, Units 1 and 2, TAC Nos. M98251 and M98252" (d)

Letter from Mr. C. H. Cruse (BGE) to the NRC Document Control Desk,

/

dated July 21,1997, " Clarification of Notification of Extension of the d

Inservice Inspection Program Second Ten-Year Intervals" (TAC Nos.

M98251 and M98252)

I /

Pursuant to 10 CFR 50.55a(a)(3)(i), Baltimore Gas and Electric Company proposes an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirement concerning the end date of the Unit 1 Second Ten-Year Inservice Inspection (ISI) Interval. Calvert Cliffs Technical Specification 4.0.5 states, in part, " Inservice inspection of ASME Code Class 1, 2 and 3 components... shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g)...."

Paragraph 50.55a(a)(3)(i) allows the use of alternatives to the requirements of Paragraph 50.55a(g) that W iM Mh7 0

v. U v v,,

Document Control Desk April 28,1998 Page 2 provide an acceptable level of quality and safety, when authorized by the Director of the Office cf Nuclear Reactor Regulation.

Reference (a) approved a Second Ten-Year ISI Interval from April 1,1987 to April 1,1997.

Reference (b) extended the end date for the Unit 1 Second Ten-Year ISI Interval to the end of the 1998 Refueling Outage. Reference (d) further defined the date as no later than June 30,1998. Extension of the interval is allowed by Section _XI of the ASME Boiler and Pressure Vessel Code,1983 Edition through the Summer 1983 Addenda. Paragraph IWA-2400(c) of the ASME Code states:

Each inspection interval may be decreased or extended (but not cumulatively) by as much as one year. For power units that are out-of service continuously for six months or more, the inspection interval may be extended for a period equivalent to the outage.

This request is for relief from the above requirement in order to extend the Unit 1 Second Ten-Year ISI Interval.

The reason for the request is twofold:

1. The NRC published a proposed rulemaking in the Federal Register on December 3,1997, indicating its intent to incorporate by reference ASME Section XI,1995 Edition through the 1996 Addenda. The public comment period expired on April 4,1998. We would like to be able to adopt this proposed rulemaking in our Third Ten-Year ISI Interval for Unit I when the rule is implemented. Extending the Second Ten-Year ISI interval will allow us to do so.
2. The Second Ten-Year ISI Interval for Unit 2 presently expires not later than June 30, 1999 (Reference d). Assuming ASME Section XI,1995 Edition through the 1996 Addenda is i

incorporated into the Code of Federal Regulations in 1998 or early 1999, Unit 2 will adopt that ASME Code for the Third Ten-Year ISI Interval. If the Unit 1 Third Ten-Year ISI Interval is started July 1,1998 and is using a version of the ASME Code, different from Unit 2, significant hardship would exist in developing, implementing, and maintaining different ASME Code editions for each unit, without a compensating safety or quality benefit. For this reason, we would like to extend the Unit 1 Second Ten-Year ISI Interval to match that of Unit 2.

i i

Inservice exammations for Unit 1 Third Ten-Year ISI Interval are not required until the fall of 1999 (to support the Unit 1, 2000 refueling outage). If this request for relief is approved, all repair and L

replacements will continue to be accomplished under the 1983 Edition through Summer 1983 Addenda

. of the ASME Code requirements and relief granted by the NRC for the Second Ten-Year ISI Interval until June 30,1999.

Therefore, we request relief from the ASME requirements governing the length of the Unit 1 Second l

Ten-Year ISI Interval to allow the interval to extend to the end of the Unit 21999 refueling outage, and l

not later than June'30,1999

Docum:nt Control Desk

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April 28,1998 Page 3 i

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

Very truly yours, '

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cc:

R. S. Fleishman, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector,NRC i

A. W. Dromerick, NRC R. I. McLea.., DNR Director, Project Directorate I-1, NRC J. H. Walter, PSC l-i