ML20072K306

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Comment Supporting Proposed Rule 10CFR26 Re Changes to FFD Requirements
ML20072K306
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 08/09/1994
From: Denton R
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-59FR24373, RULE-PR-24 59FR24373-00024, 59FR24373-24, NUDOCS 9408300004
Download: ML20072K306 (2)


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A nonuer u. naro~ DOCMETED sairimore aas uns siccinc company Vice ernident USHRC catari clips sucicar rower riant Nuclear Energ'y 1650 Cahcri Chfs Parkway 1 Lusby, Mar \ land 20657 yl d' 58 6-2 2 " " 4455 '""'

94 AUG 17 P 1 :36 410 260-4455 Balitmore OFFICE Di' 5Er:RE TARY DOCKETHE & . V T i .

WW DOCKET NUMBER Po0 POSED RULE N M August 9,1994 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Clifts Nuclear Power Plant i Unit Nos.1 & 2; Docket Nos. 50-317 & $0-318 Comments on Consideration of Changes to Fitness-for-Duty Requirements (59 FR 24373. May 11.1994)

Baltimore Gas and Electric Company (BGE) supports the comments provided by the Nuclear Energy Institute (NEI). We strongly suppon the reduction in vital area controls discussed in SECY-93-326, and we accord that initiative higher priority than revising the existing Fitness-for-Duty (FFD) program. Our i

experience with the existing FFD program is that while it tests some workers who do not have access and opportunity to significantly afTect nuclear security, the program is workable. This program could be enhanced by permitting adjustment of the frequency of testing on the basis of the results of tests already conducted, as was recommended by NEl in its letter dated June 22,1993.

In the event that revision of vital area security controls as discussed in SECY-93-326 is removed from active consideration, BGE would encourage reconsideration of this FFD initiative.

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

Very truly yours,

%\n for R. E. Denton Vice President - Nuclear Energy RED /TER/dlm 9408300004 940809 PDR PR S/ O 24 59FR24373 PDR

Decument Control Desk August 9,1994 Page 2 l

cc: D. A. Brune, Esquire J. E. Silberg, Esquire P. T. Kuo, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R.1. McLean, DNR J. H. Walter, PSC I

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