ML043410278

From kanterella
Jump to navigation Jump to search
Comment (17) of Kevin J. Moles on Establishing and Maintaining a Safety Conscious Work Environment
ML043410278
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 11/23/2004
From: Moles K
Wolf Creek
To: Lesar M
NRC/ADM/DAS/RDB
References
69FR61049 00017, RA 04-0143
Download: ML043410278 (2)


Text

12 W~LF CREE

'NUCLEAR OPERATING CORPORATION Kevin J. Moles Manager Regulatory Affairs November 23, 2004 RA 04-0143 /6/4//VO Michael T. Lesar 0/71=

f 6o Z Chief, Rules and Directives Branch Division of Administrative Services Office of Administration, Mail Stop: T-6D59 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Docket No. 50482: Establishing and Maintaining a Safety Conscious Work Environment

Dear Mr. Lesar:

Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges comments made on a proposed generic communication to provide guidance for licensees in regards to maintaining a safety conscious work environment (SCWE). WCNOC has reviewed NEI letter dated November 15, 2004, and endorses these comments.

WCNOC understands and embraces the need to continually re-establish and maintain a safety conscious work environment. However, WCNOC would like to take this opportunity to emphasize some key issues:

1) SCWE remains under the sole responsibility of the licensee.
2) Such guidance only provides a means for improving the way the SCWE is established and maintained.
3) All actions are not going to be applicable and/or practical for all licensees because such actions may be resource intensive and cumbersome under certain situations.

As a result, WCNOC feels more emphasis should be placed in the Regulatory Issue Summary (RIS), "Establishing and Maintaining a Safety Conscious Work Environment" to clearly note that the RIS should not be used as inspection guidance. WCNOC would refer to this RIS, only as a reference to improve and maintain the 1996 NRC Policy Statement, "Freedom of Employees in the Nuclear Industry to Raise Safety Concerns Without Retaliation." The RIS should make it clear that, not employing one or more of the actions in the RIS should not make a SCWE program deficient.

. /9 I-S-= 29 A"- -Ža

_rs/o ;1 RO. Box 411 / Burlington. KS 66839 / Phone
(620) 364-8831 An Equal Opportunity Employer M/F/HCNVET  ;

j_ I-1>< -D,4

-3 .' 9C1JA15.

- DA nAAn-A4A Page 2 of 2 WCNOC appreciates the-opportunity to provide comments on this proposed document. If there are any questions, please y.

contact me at (620) 364-4126 or Diane Hooper at (620) 364-4041.

Very truly yours, KeinJ.Moe KJM/rlg -

cc: J. N. Donohew (NRC)

D. N. Graves (NRC)

-B. S.- Mallett (NRC) -

Senior Resident Inspector (NRC)-

Document Control Desk (NRC)

I