ML20137F969

Requests Permanent Exemption from 10CFR50,App J Requirement to Conduct Third Integrated Leak Rate Test During Shutdown for 10-yr Inservice Insp Outage.Fee Paid

ML20137F969
Person / Time
Site:	Calvert Cliffs
Issue date:	08/15/1985
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Butcher E Office of Nuclear Reactor Regulation
References
NUDOCS 8508270136
Download: ML20137F969 (3)

Text

= y

• , 4 i

y BALTIM ORE

, GAS AND ELECTRIC CHARLES CENTER

• P. O. BOX 1475 BALTIMORE, MARYLAND 21203 AmtHust E. LUNOVALL. JR.

vice Pats 4DEpst SUPPLY y(

August 15,1985 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation '

Washington, DC 20555 ATTENTION: Mr. Edward 3. Butcher, Acting Chief Operating Reactors Branch #3

SUBJECT:

Calvert Cliffs Nuclear Power Plant )

Unit Nos. I'& 2; Docket Nos. 50-317 & 50-318 Primary Reactor Containment Testing Request for Relief from 10 CFR 50 Appendix 3 Requirements i

Gentlemen:

In accordance with 10 CFR 30.12, we are requesting an exemption from certain requirements of 10 CFR 50.54(o) that have been determined to be impractical. As ,

outlined in 10 CFR 50.12, the information concerning the exemption request is presented herein. -

The requirements of 10 CFR 50 Appendix 3 lil.D.1(a) specify ". . . a set of three tests shall be performed, at approximately equal intervals during each 10-year service period.

The third test of each set shall be conducted when the plant is shutdown for the 10-year plant inservice inspections (ISI) . . . ." in addition to the Appendix 3 requirements, the Calvert Cliffs Unit 1 & 2 Technical Specifications specify the Type A tests must be performed every 4010 1 months. In order to meet this time requirement, a one-time exemption was granted for the first 10-year service period. This allowed Calvert Cliffs to perform the third test prior to the 10-year ISI outage.

We are now requesting a permanent exemption from the requirement to conduct the third ILRT during the shutdown for each 10-year 151 outage, in that no 10-year ISI outage ,

activity specifically alters containment integrity. We feel that the intent of the codes are satisfied by the 4010 1 month frequency. Our scheduled refueling outages are indicated in the following table.

1 ho\

l 8508270136 850815 g/goM 7 g4 g}

s ,

4 Mr. Edward 3. Butcher August 15,1985 Page 2 CALVERT CLIFFS REFUELING OUTAGES UNIT ONE UNIT TWO Spring 82 Fall 82*

Fall 83 Spring 84 Spring 85* Fall 85 **

Fall 86*** Spring 87***

Spring 88** Fall 88 Fall 89 Spring 90

• Last completed ILRT

• • Next scheduled ILRT

• • • 10-year ISI outage (Outage dates based on current 18-month refueling cycle)

No other requirement of 10 CFR 50.54 or Appendix 3 will be affected by granting the exemption. Our previous Type A test performance dates and scheduled 10-year ISI outages make it impractical to perform the Type A test during each 10-year ISI outage.

This request deletes the need for submitting future exemption requests when Type A testing and 10-year ISI outages do not coincide.

Granting the requested exemption will not give rise to an adverse impact on the environment. Performance of the Type A test will continue to ensure satisfactory containment performance. It is in the public benefit to grant the requested exemption as it ensures the safest and most economical testing schedule.

Pursuant to 10 CFR 170.21, Baltimore Gas & Electric Check No. A344146 in the amount of $130 is remitted to cover the application fee for this request.

Should you any questions regarding this matter, please do not hesitate to contact us.

4 Very truly ours,

- ,y < =m AEL/OPB/gla Attachment

s .

Mr. Edward 3. Butcher August 15,1985 Page 3 cc: D. A. Brune, Esquire G. F. Trowbridge, Esquire D. H. Jaffe, NRC T. Foley, NRC