ML20083C895

Requests Written Determination of Responsibility from NRC Under Referenced Authorities

ML20083C895
Person / Time
Site:	Calvert Cliffs
Issue date:	09/16/1991
From:	Weyenberg T WHITING CORP.
To:	Potapovs U, Potatovs U Office of Nuclear Reactor Regulation
References
REF-QA-99901238 NUDOCS 9109270210
Download: ML20083C895 (19)

Text

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WHITING CORPORATION 15700 L AT" ROP, HARVEY, ll. 60426-5198 *

(312) 468-9-100 e TAX (312) 7840755 e TEL EX: 25-3274 ,

September 16, 1991 Via Fa.Esimile Uldis Potatovs, Chief Vendor Inspection Branch United States Nuclear Regulatory Commission Washington, D. C. 20555

REFERENCE:

10 C.F.R. 21 and 10 C.F.R. 50, Appendix D

SUBJECT:

Recuest for Determination of ResDonsibility

Dear Mr. potatovs:

The purpose of this letter is to request a written determination from the' Nuclear Regulatory Commission under the referenced authorities. The request is directed to your attention based upon the recommendation of Mr. Frank Jablonski in your Midwest office.

A number of years ago, Whiting Corporation (" Whiting") was contracted to design and manufacture its crane (S/N 10087) for Baltimore Gas and Electric ("BG&E"). The crane was installed and has provided satisfactory service over the years. In early 1990, BG&E began a series of actions which will result a complete replacement of its trolley assembly and result in recalculation of structural stresses and possible modifications to the bridge structure and machinery. Work is to begin in October, 1991.

Whiting has not been a party to the analytical studies regarding the feasibility of this project nor is Whiting involved in the design or execution of the plan.

Whiting raised with BG&E the issue of equipment design responsibility under 10 C.F.R. 21 and 10 C.F.R. 50, Appendix B.

The plain language of Requirement III of Appendix B states " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the annlicant desianates another responsible oraanizatioD. (Emphasis supplied).

_ "It is clear to Whiting from this statement that the party (s) involved in the modification work clearly qualify as " ... another responsible organization" which BG&E must designate as responsible because Whiting as " ..the f

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, WHITING CORPORATION Uldis Potatovs United States Nuclear Regulatory Commission September 16, 1991 Page 2 organization that performed the original design..." has not been asked to participate in or approve the BG&E modification plan.

Further, in Requirement VI of Appendix B, you will find " Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization." As above, Whiting has not been asked to review and approve anything so it should have no further responsibility in this area.

Notwithstanding the foregoing, we have been unable to obtain definitive agreement on this matter with BG&E. I have attached a copy of correspondence between Whiting and BG&E to facilitate your review.

We row ask that you issue a definitive NRC statement that Whiting Corporation will no longer be responsible for reporting issues after the modification / repair work begins. We also ask you to determine that Whiting will have no liability of any kind in the event of a failure of the modified equipment or for the consequences of any such failure with regard to physical plant, environment, personal injury, or death. ,

j Whiting considers this matter to be of extreme importance. We will plan on visiting your offices on Wednesday, September 25, 1991 to discuss the issues with you or your designee. Please contact me at (708) 331-4000, extension 3180 if there is any reason why this would n0 he acceptable. We also ask that you formally acknowledge this reqw st by September 27, 1991 if your definitive response will not be inaued before then.

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-Uldis Potatovs

. United States Nuclear Regulatory Commission-

September 16, 1991 Page 3 ,

Thank' you for your' assistance in this matter. Please contact me if you have'any questions.

Sin erely,

\, \ \;% h L i kd Thomas G. Weyenberg Director of__ Contracts (A)s TGW/js

-cc: A.: Burke R. Gibson R. Norby C.-Skorpinski James-Taylor, Executive. Director of Operations United States Nuclear Regulatory Commission

-Attachments Whiting Letter to BG&E dated March 7, 1991 BG&E Letter to Whiting dated March- 15,_1991 Whiting _ Letter-to BG&E dated' March 26, 1991

-- BG&E Letter.to. Whiting. dated April 2, 1991 BG&E Letter to-Whiting _ dated' April 17,. 1991-Whiting Letter.to BG&E dated May 28, 1991 BG&E. Letter to Whiting.--dated-June 25, 1991 BG&E Letter to Whiting dated July 12, 1991

- Whiting:Telefax to BG&E dated July _12, 1991 BG&E Letter to Whiting dated August 16, 1991 BG&E Letter to Whiting ~ dated August 19,_1991 4

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WHITING CORPORATION

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M Michael Jeffreys, Buyer BALTIMORE: GAS-&: ELECTRIC CO'.

Major Projects & Contract Services 2900 Lord Baltimore Drive Baltimore, Maryland 21207 Dear Mr. Jeffreyst

REFERENCE:

AlteraLions to Whiting Crane Serial Number 10087 l

This letter will provide notice to you of Whiting's serious concerns regarding proposed modifications to Whiting crane S/N 10087 under a contract recently awarded by BG&E to Ederer.

The crane in question was designed and manufactured for nuclear service by Whiting Corporation for DG&E and is subject to compliance with very specific and critical nuclear regulations under 10 CPR 21. Several questions have been raised by Whiting's Product Manager and Senior Quality Assurance Engineer with respect to responsibility and potential liability which may result from future problems attributable to d es ig n or d es ig n changes. In addition, we are concerned about the extent of our duties and obligations-as they are perceived by the NRC.

The provisions of 10 CFR 21 which deal with the control and responsibility systems and mechanisms for multiple manuf acturers of equipment is confusing at best. In this case, it appears there is no regulatory provision to apportion responsibility. To our

, knowledge, this is the first instance in a nuclear application l where the equipment of one supplier is modified by another without l the concurrence and participation of the original manufacturer. It is our opinion that BG&E, at a minimum, has the responsibility to define and establish the relationships and associated procedures for this unique hybrid situation and submit them for approval of all af fected parties. Should BG&E f ail to accomplish the above in a timely f ashion, Whiting will be obligated to report the situation to the NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after the condition is firmly established. (Please refer to Appendix B of 10 CPR 50 which served as a basis for our conclusions.)

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. WHITIN C3 CORPO A ATION Mr. Micrael Jeffreys, Buyer BALTIMNE GAS & ELECThIC CO.

March *i, 1991 Page 2

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' Attached you will find copies of Whiting's internal correspondence which raised this broad issue as well as a chat cterization of the 65 problems, real and potential, as we see them. .re seek your prompt (

review and appropriate corrective action duly coordinated with and accepted by all parties. Absent such an agreement Whiting will be N

compelled to pursue the niost connervative approach and notify the h URC of our concerns. We believe : hat a period of one week f rom the date you receive this l e t'o e r provides adequate time for your response. Accord.' agly, if we have not been f avored with a reply to this letter by Mv..ch 18, 1991, we will contact th' NRC as described

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Please contact ma if you have any question:

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biomanG. Weyettberg j Director of Contracts ./

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I B A LT O AORE OASAND Ct.ECTRic SPEN'l FUEL STOR,'.'JE PROJECT MEMORANDUM 10: Mr. Th amas G. Weyenberg Serial:dFSP/91 138 Director of Contracts Whiting Corporation 15700 Lathrop ilarvey. Illinois 60426-5198 FROM: R. ll. Dufresne SUllJECT: Alterations to Whiting Crane Serial Number H087 ,

DATE: Maren 15,1991 BG&E and the Spent fact Storage Project acknowledge recejp t of your March 7,1991 letter regarding alteratbus to Whiting Crane Serial Number 10087 (Calvert Cliff's Auxiliary Building Gane). We are reviewing tl.e items which you identified and will respond to your inquiry after we have made a decision.

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Project Manager Spent Fuel Storage Project !IN/[/#6 gggp00$[/Cy RiiD:dap MAR 2j s, cc: J. P. Bennett CONTRAcg gL.. .

D. V. Graf  ; rh:. IMENT M. D. Jeffrey:

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WHITING CORPORATION 15700 LATHROP, HARVEY IL 604f6 5199 * (312) 468 9403

• rAX (312) 785-0755 + 1ELEX 25 3274 March 26, 1991 Via Paesimile Mr. R. H. Dufresne Project Manager Spent Fuel Storage Project BALTIMORE GAS AND ELECTR7C Calvert Cliffs Nuclear Power Piant Lusby, MARYLAND 20657 Dear Mr. Dufresne

REFERENCE:

Whiting Letter to BG&E dated March 7, 1991 BG&E Letter to Whiting dated March 15, 1991

SUBJECT:

Alterations to Whiting Crane Serial Number 10087 We are in receipt of your letter dated March 15, 1991 responding to our letter dated March 7, 1991 in which you indicated thct a response to our inquiry would be forthcoming pending a decision on your part.

Two weeks have passed since your last communication and we have not been advised as to what action you want to take.

Please be advised that if we are not provided with a satisfactory response by April 5th, we will be forced to nc,tify the NRC of our conversation.

Sincerely,

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Y M Thomas G. Weyenberg Directar of Contracts TGW/js I cci M. Kwasny R. Norby F. Teggelaar I

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B A L.l iMORc OAS AND tiLECT RIC SPENT FUEL STORAGE PI(OJ ECT MEMORANDUM

'l 0: hir. Thomas G. Weyenberg Serial:SFSP/91 140 Director of Contracts Whiting Corporation 1$700 Lathrop iiarvey, Illinois60-126 5198 $//

I'l(OM: R. II. Dufresne 088gg l(l;l'Isl(1:NCE: Whiting Letter to BO At: dated hiarch 7,1991, O 8' BG&E Letter to Whiting dated hiarch 15,1991, Md4 ,

Whiting Letter to DO& E dated hiarch 26,1991. Cgg7N4C[S g SUll.1ECI: Alterations to Whiting Crane Serial Numi er 100s7 IEN7 DNI l': April 2,1991 13G&E plans to replace the trolley on the subject crane with one produced by another vendor. The trolley r eplacement project will no; begin the installation / modification phase until October,1991 at the earliest, consequently there is not an issue at the present time.

The project is still in the design and manufacturing stages, but before the trolley is replaced, BG& E will discuss the matters ra: sed in your letter with all the affected parties for tesolution.

If you have any questions or concerns regardii,' this matter, please give me a call.

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Project hianager Spent Fuel Storage Project RiiD:daP Copies Sent to: M. Kwasny ec: J. P. Dennett D. V. Nat 4 E-9/

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I WHlNU 00RPORA!!0tj A 15 A LT IM ORE f OAS AND .h* h 2 lW EL.E CT RIC SPENT FUE1E10$dEIQ@jdUl[NI MEM.ORANDUM To Mr. Thomas O. Weyenberg SeriahSFSP/91 145 Director of Contracts Whiting Corporation 157K) Lathrop ilarvey, Illinois 60426 5198 l'ROL R. !!. Dufresne

Reference:

Whiting letter to BO&E dated March 7,1991 BO& E letter to Whiting dated March 15,1991 ,

Whiting letter to BO& E dated March 26,1991 BO&Eletter to Whiting dated April 2,1991 SUlijECT: Alterations to Whiting Crane Serial Number 10087 '

DATE: April 17,1991 This letter confirm's our phone call of April 15,1991 in which I stated the following:

o There are only 3 drawings for the trolley replacement project which are classified as

" Proprietary", those drawings are MS-61974, U.62867, rind U-63011, o BO& E is still holding the drawings which were issued to it in 1970, and those which were released to Ederer in 1990 have been retarned to us.

o The 3 proprietary drawings which Edeter held were not used or referenced by them

! for fabrication of the new trolley.

o Bechtel also has a set of the proprietary drawings. They were issued to them by Whiting in 1970 during construction of the Calvert Cliffs Nuclear Power Plant, it is not BO&E'r. responsibility to obtain the drawings from Bechtel for Whiting, o Drawing #U 62867 (O!rder Details) was used by Bechtel for a Seismic Analysis of the crane. That analysis revealed that the girders need additional stiffeners which will l be added as a part of the trolley modification, i

As a result of the aforementioned you stated you would

o Check with Whiting Engineering to verify if those were the only proprietary drawings of concern.

o Determine the proper course of action for the proprietary drawings presently held by 83&E.

o Reby to Whiting Management the issue of the proprietary drawings held by Bechtcl.

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II)Ptf1OnTiiD stionsp,rJ'oncerns regarding this issue please give me a call at 301260-4971.

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R. H. Dufresn97 Project Manager Spent Fuel Storage Project R!iD:dap cc: J. P. Bennett J.11.Cowhill (Bechtel) f G. J. Falibota (Dechtel)

D. V. Graf M. D. Jeffreys O. Tesfaye 9

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WHITING CORPORATION J .-

15700 LATH 40P. HAftVE V IL 60426 598 * (3 V) 468 4 WJJ e FAX (312) 785 0765 + TELEX 25-3274 May 28, 1991 R. H. Dufresne Project Manager Spent Fuel Storage Project BALTIMORE GAS AND ELECTRIC 2900 Lord Baltimore Drive Baltimore, Maryland 21207

REFERENCE:

Whiting Letter to BG&E dated March 7, 1991 BGLE Letter to Whiting dated March 15, 1991 Whiting Letter to BG&E dated March 26, 1991 BG&E Letter to Whiting dated April 2, 1991 -

BG&E Letter to Whiting dated April 17, 1991

SUBJECT:

Resolution of Drawings Issue - Crane S/N 10087

Dear Mr. Dufresne:

Thank you for your letter of April 17, 1991 in which you summarized your progress regarding the disclosure of Whiting Ccrporation's propr ietary d rawings. This letter will provide you with Whiting's

, direction for final disposition of this issue.

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! Please return the Whiting drawings (MS-61974, U-62067, and U-63011) recently returned to you from Ederer along with a letter from Ederer which certifies no copies of the listed drawings were made, retained or furnished to others.

With regard to the drawings currently in Bechtel's possession, we

, are in disagreement. Bechtel had no need for cranes when Whiting l S/N 10087 was fabricated. But for the needs of Baltimore Gas and l Electric, Bechtel would not have contracted with Whiting for crane

S/N 10087. Bechtel therefore was acting solely as an agent of l BG&E. The contract did not contain a provision which would have granted Bechtel permissien to retain copies of Whiting's l proprietary drawings. Anything Bechtel acquired as agent for BG&E i

should have been turned over to BGAE. Consequently, Whiting holds l BG&E responsibile for its agent's actions and maintains that BG&E has an obligation to Whiting to obtain any original drawings or copies thereof whien Bechtel may have inappropriately acquired while f unctioning as BG&E's egent. A Bechtel certification similar

. WHITING CO A PO A ATION R. H. Dufresne BALTIMORE GAS AND ELECTRIC May 28, 1991 Page 2 to the one to be obtained frem Ederer should also be required by BG&E and furnished to Whiting. In addition, you previously referred to comments of one Joe Cowhill of Bechtel who said he wcul? not relinquish the Whiting drawings in his possession.

Please provide Mr. Cowhill's full name, position title, and address.

Please submit to Whiting the above drawings (and any copies thereof) as well as the letters f rom Ederer and Bechtel by June 28, 1991.

• As stated in ea-lier letters, Whiting Corporation can no longer be regarded as design agent for any portion of the referenced crane after modification work begins. Whiting is not a party to the planned alterations and is therefore not in a position to render any judgment or opinion regarding the integrity or capacity of the equipment or any of its ccmponents. Accordingly, Whiting requests that by June 28, 1991 a BG&E letter stating Whiting is no longer the design agent for the affected crane be prepared and submitted to the NRC with a copy furnished to Whiting.

Concurrent with the above, Whiting believes it is appropriate that the BG&E contractor who will be making the modifications to the bridge of the ref erenced crane and supplying the new trolley should notify the NRC of that contrector's assumption of design agent respone'bility for the crane. This letter should be received by the NRC prior to the commencement of any work. It would be appropriate that a copy of that letter be furnished for Whiting's files.

You stated you would require a Whiting " release" for BG&E's use of Whiting's drawings, in conjunction with planned "stif fening" of the bridge on this crane. Whiting has carefully considered the lost opportunity cost of this earlier unauthorized conversion of Whiting's proprietary data and has concluded that a f ee of $15,000 (payable prior to the start of any modifications) would be a fair and equitable consideration. We will provide you with such a release upon execution of a BG&E purchase agreement which is acceptable to Whiting.

WHITING CORPORATION i l

R. H. Dufresna BALTIMORE GAS AND CLECTRIC May 28, 1991 Page 3 Thank you for your assistance in rectifying this unfortunate series of events. If you have any questions, please contact me.

Sincerely, M

ihomas G. Weyenbeh

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Director of Contrahts .

TGW/js cci A. Burke ,

M. Kwasny J. Luszyk R. Noroy C. Skorpinski l

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' n .t-+t n' a s a ns w un srtur rutt epos n uutiuose OADAND lit.E CT RIC SPENT FUEL STORAGE PROJECT WHITING CORPORATION un Mr Thomas a Weycobe,y BON 291991 seriahsrsent.iss l'uoM n. H. Duke >ne CONTRACTS DEPARTMENT Rt furnt e: Whiting leitet to DG AU d. ted May 28,1WI SLlit.lLCli Alteration > to Winting G.me Senal Number 1000 .

DNiin June 25.1W1 These ar e several pointn that you laned in youi May 28, tWI letter that deses ve a ic)l ohne.

'I he leie premise of Whiting's contention that drawinp of crane S/N 1(087 are proprietary,is cajoncou> This conciunion is token from the original continct which did not in fact pre >elve ils proprietory status. That puitha>e oider siipuhited not only supply of the eranc>, but also supply ul drawings and data as weit The puscha>c order include > all wntsact tea ms und makes no mention o any lese'vanon of rights legardmg pro!nietat) intorniatiun, llecause those dlawing> we e pa I of 110& E's putchase,it is under no obligation to return them of pay foi them a accond time. Those drawing have been eclamed foi our u>e for uppruxinunely 20 years.

Bethiel Power Corp., a .uchneet.cnginees f or the design bases plant, and as BO&E's contiact agent l

hu the pur*hase ol the croom,,ipinopriatch iceciwd nipies of the drawinn, and will continue to retain l'iem an uur agent.

Whiting'6 Status as desi};ner of the erancs in question i> a continuing one While it obviously is not responuble for modification > perlotmed t:y a ditfeient contracter, hs responsibility as to the NRC Part 21 noliheation requirements williem;;in mdefinitely and can not be unilaterally disavowed, 11 aveynf 4 > tion., oi conceina segerdmg thi> inue, plea >e sentact me.

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Cf Project Managet bjAllt fuel biorage Poyect RilD;dnp cc J. P. Dennett D, V. Graf I

J. H. Cow hill M. D. Jef ficp G. J. Falihoia G. Tolaye

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• P O HOX 1476

• HALTIMOHL. MARYt.AND 21203 1475 OUTAGE AND PROJECT MAN AGEMENT DEPARTMENT

[2";fffd3"*"# Serial:SFSPN1 164 f July 12.1991 TO: Mr. Thomas O. Weyenberg

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FROM: R.11. Dufresne ,

Reference:

Whitingletter to DG&Lideited July 3.1991 SU13]ECTi Nierations to Whiting Crane Scrial Number 10W7 This letter confirms oor phone call of July 11,1991. in which it was agreed that Whiting Corporation wc.uld not pursue a course of action related to the subject drawings until at least August 19,1991. At that time BG&F.will give Whiting Corporation a definitive response on the drawing issue.

The delay in response to your July 3rd letter is due to the fact that key BO&E personnel have had ,

previous commitments and will not be available until that time.

If you have any questions or concerns icgarding this matter, please call me.

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L Project Manager

• L Spent Fuel Storage Project RllD:dap cc: J. P. Bennett M. D. JetTrcys J.11. Cowhill 1,.G.Noll G. J. Falibotu G. Tesfuye

-D.V.Oruf WillTING CORPORATION SUL191991

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WHITING CORPORATION 15700t m aco -tawE,:t w 6 w e . . ia m n e9400 . FAA U12) 785 0755

• TELEX 25 3214 Date: 7-12-91 Fax Number: (301) 260-6698 Department Number: 698 Whiting Customer Name: --

Whiting Requisition No.:

10: R. H. Dufresre COMPANY NAME: _ BALTlHORE GAS & ELECTRIC FRON: Tom Weyenberg NLM8ER OF PAGES: 1 4XE646fX_

Any problems receiving this transmittal, please call (708) 331-4000, ext. 3630.

I

SUBJECT:

Alterations to Whiting Crane Serial Nuinber 10087 We are in receipt of your facsimile dated today and have no problem with the delay providing we receive a response no later than August 19th, i

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I b'AOftE E3 A LT l GAS AND i

ELECTRIC CHARLES CENTER

• P O box 1475

• BALTIMORE, MARYLAND 21203 1475 DONALD V. GRAF August 16,1991 uiwo NJC 44 AR OV1 AM AND PRO /t ?1 un%AufutNTt(tanturut Mr.1homas O. Weyenberg Director of Contracts Whiting Corporatinn 15700 Lathrop ,

liarvey, IL 60426 519S

Dear Mr. Weyenberg:

ConGrming our telephone conversation of August 14,1991, after much discussion relative to the planned alterations to the Calver t Cliffs Nuclear Power Plant Spent Fuel unne, the following tasks were assigned:

1. BO&E will provide the name and telephone number of a contact at the N1(C for Whiting's use for purposes of obtaining NitC interpretation of Whiting's responsibilities as the original crane designer / manufacturer, pursuant to 10CFIl21 and 10Cril50 Appendix B, because of modifications performed by a different contractor.

2. Whi ting's legal counsel will telephone BG& E's legal counsel, Mr. Jim Bennett (301-234 5607), to discuss the matter of proprietary information.

It was a pleasure talking with you, Tom and we are optimistic that this issue can be quickly resolve in a mutually agreeable manner.

Very truly yours,

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• BALTIMORE. MARYLAND 21203-1475 OUTAGE AND PROJECT MANAGEMENT DEPARTMENT can o.,c,,,r vue...o... n.~i 4V59f MAhvi&Nt*T)att

' August 19,1991 Serial:SFSPf)l.180 Whiting Corporation 157001 athrop liarvey, IL 60426-5198 Attention: Thomas G. Weyenberg Director of Contracts .

Subject:

Calvert Cliffs Nuclear Power Plant Spent Fuel Crane

Dear f.!r Weyenberg:

Pursuant to our telephone conference cal! of August 14,1991, the responsible individual at the NRC that,in our opinion, can provide you with the NRC's interpretation of Whiting's responsibilities as the original crane designer / manufacturer relative to 10 CFR 50, Appendix 11 und 10 CFR 21 is: Dan hicDona:d NP.C Proje':t hianager for Calvert Cliffs Nuclear Power Plant Rorkville, h1D (301)492 1408 Please callif we can be of .ther assistance.

Very truly yours, (D hl L.O.Noll' Project hianager Spent Fuel Storage Project Wllli[!'] 00EP0R'dl0N LON:dap AUG 2 19M cc; J. P. Dennett D. v. Caraf CCN1RACIS DEPARTMENT'

! hi. D. Jeffreys B. S. hiontgomery l

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