ML20148B442
| ML20148B442 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/06/1997 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-62FR7721, RULE-PR-73 62FR7721-00005, 62FR7721-5, NUDOCS 9705130090 | |
| Download: ML20148B442 (2) | |
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CH Ans.ts II. Cu t'st 00CKEIE0 saltimme Gas and Eleuric Company Vice President U$NRC Calven Clitfs Nuclear Peer Plant 1650 Calven Cliffs Parku ay Nuclear Energy Lusby, Maryland 20657
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8 9 C.C F May 6,1997 DOCKET NUMBER Secretary paOPOSED RULE M 73 U. S. Nuclear Regulatory Comm,ssion i
(lo4FR 77p/)
Washington, DC 20555 ATTENTION:
Docketing and Services Branch SUILIECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on Proposed Rule:
Changes to Nuclear Power Plant Security Reauirements IlEFERENCE:
(a)
Federal Register Notice 62FR7721, dated February 20,1997, Proposed Rule, Changes to Nuclear Power Plant Security Requirements; Request for Public Comments The Baltimore Gas and Electric Company is pleased to provide comments on the subject proposed rule changes.
The proposed rule would eliminate the requirement for security personnel to escort licensee-owned vehicles entering the Protected Area for work-related purposes, provided they are driven by licensee employees who have unescorted access.
We propose the following minor changes:
1.
Change the vehicle from " licensee owned" to " licensee owned or leased." To state only licensee-owned vehicles are exempt could be misinterpreted when a great number oflicensees routinely lease theirfleet of vehicles as a normal business practice.
2.
Change the driver requirements from " licensee employees" to " persons granted unescorted facility access." To limit vehicle operators to licensee employees only is too restrictive. Both company and contract employees must satisfy the same access authori:ation requirements as stated under 10 CFR 73.56 for unescorted access. All employees with unescorted access are also covered under the licensees 'fitnessfor dwy/ continual observation programs.
9705130090 970506 PDR PR
\\ 9 73 62FR7721 PDR hsm
a Document Control Desk May 6,1997 Page 2 Title 10 CFR 73.55 currently recognizes unescorted facility access as an indication of trustworthiness and reliability. Title 10 CFR 73.55(d)(8) states,"The licensee shall issue keys, locks, combinations, and other access control devices to protected and vital areas only to persons granted unescorted facility access," If the Code recognizes unescorted access as a condition to obtain keys to vital and protected areas, it should be the standard to operate a vehicle in protected and vital areas.
We appreciate the opportunity to comment on the proposed rule changes and look forward to their issuance.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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C. H. Cruse Vice President - Nuclear Energy CIIC/SJR/dlm cc:
Document Control Desk, NRC H. J. Miller, NRC R. S. Fleishman, Esquire Resident Inspector, NRC J. E. Silberg, Esquire R. I. McLean, DNR Director, Project Directorate I-1, NRC J.11. Walter, PSC A. W. Qromerick, NRC l
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