ML20062D623
| ML20062D623 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/27/1982 |
| From: | Architzel R, Crane C, Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8208060170 | |
| Download: ML20062D623 (2) | |
Text
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BALTI M ORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNOVALL JR.
vicr PRES 40ENT kJPAY July 27, 1982 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attn:
Mr. D. G. Eisenhut, Director Division of Licensing Subj ect: Environmental Qualification Documentation Gentlemen:
During the past several months we have received several written requests for additional information dealing with the environmental quali-fication of safety-related electrical equipment. These requests included lists of reports, calculations, and correspondence identified by your consultant, Franklin Research Institute, as necessary to complete their review. In addition, we have had several conversations with representa-tives of Franklin Research Institute as well as our NRC Project Manager, Mr. D. H. Jaffe, regarding the submission of this information. In response, we have provided updated System Component Evaluation Worksheets (SCEW),
including additional clarification for specific items. However, we did not submit our EQ reference data files or copies of those files. Pursuant to NRC requirements, that information is available in our central EQ file for inspection by the NRC or its consultants.
Because of recent ccnversations with our Project Manager, we find it is necessary to reiterate our position against the outright release of qualification data from our central EQ file. There are several bases for our position.
First, we are required by our License Technical Specifications to maintain this information in a centralized file. Release of this material from our custody would, thus, be a violation of our license.
Second, we are concerned about the nature and extent of Franklin Research Institute's review. The qualification references which they have requested do not constitute complete qualification packages; rather, they only address some of the parameters pertinent to various pieces of equipment.
Misinterpretation could occur since only a portion of the documentation would 8208060170 820727
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Mr. D. G. Eistnhut be reviewed, and erroneous conclusions could be drawn unless all pertinent references were included in the review process. Therefore, it is imperative that this documentation be controlled in our central file so that we can provide the guidance and clarification necessary to ensure complete and correct understanding of the qualification packages. To do otherwise would be a misuse of resources and a violation of good engineering practices.
Third, some of the reports recently requested are proprietary.
Release of that information would violate contractual agreements between BC&E and the affected equipment manufacturers and consultants. Moreover, many of the reports were developed and prepared by commercial concerns similar to Franklin Research Institute.
It would appear that submission of those reports to Franklin Research Institute would provide them with a competitive advantage.
Fourth, we understand that your contract with Franklin Research Institute does noc allow for visits to licensee's facilities to review central files or specific documents referenced in IE Bulletin 79-OlB sub-mittals. If this understanding is correct, then it would seem more appropriate for the Commission to correct what appears to be a contractual deficiency rather than to burden the licensee with an additional drain on limited and valuable EQ resources.
Fifth, the extent of our commitment to resolving the numerous equipment qualification issues is well recognized. We have devoted several man-years of effort and have expended on the order of $1,000,000 on contracts to evaluate and assess the environmental qualification of existing safety-related electrical equipment. We are an active participant in several utility groups and other industry organizations which are addressing various issues pertinent to EQ, and we have been an industry leader in responding to Bulletin 79-OlB and in developing a comprehensive qualification program. In short, we have made (and continue to make) a good faith effort to ensure that the Class IE equipment installed at Calvert Cliffa is adequately qualified.
In summary, we maintain that it is inappropriate for us to releat, documents from our central EQ file; that it is an unnecessary drain on our resources to provide copies of portions of that file; and furthermore, such incomplete documentation could prove misleading. We feel that it is encumbent upon NRC to make reasonable arrangements to review the file. We will welcome NRC and/or its consultants into our offices and provide any assistance necessary for a complete examination of our EQ records.
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Yours very truly,,
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J. A. Biddison, Esquire R.E.Architkl G. F. Trowbridge, Esquire C. Crane D. 11. Ja f f e
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