ML050840283
| ML050840283 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 03/24/2005 |
| From: | Dewolfe G Wisconsin Public Services Corp |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, 70FR07196 00002, PR-150, PR-2, PR-30, PR-40, PR-50, PR-52, PR-60, PR-63, PR-71, PR-72, PR-73, PR-76, RIN 3150-AH57 | |
| Download: ML050840283 (2) | |
Text
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WPS Resources Carorsto,go 700 North Adams Stregt
>: °:x 19002 Groiun Say. WNI X~307-5002 March '24, 2005 DOCKETED DOCKETED USNRC Rulemaldngs and Adjudications Staff March 24,2005 (5:00pm)
Secretary, U.S. Nuclear Regulatory Commission OFFICE OF SECRETARY Washington, D.C. 20555-0001 AULEMAKINGS AND ADJUDICATIONS STAFF RE:
RIN 3150-AH57, Proposed Rules: Protection of Safeguards Information
Dear Staff Member:
Wisconsin Public Service (WPS) wishes to submit commentary on the proposed rules governing the Protection of Safeguards Information. WPS is a natural gas and electric utility serving northeastern and central Wisconsin and an adjacent portion of Upper Michigan. WPS is the majority owner of the Kewaunee Nuclear Plant located in Kewaunee, Wisconsin. This facility is operated by the Nuclear Management Company (NMC), which has been contracted by WPS to provide these services. The NM4C is the holder of the NRC Operating License for the KNPP.
There are approximately 148 represented employees located at the Kewaunee facility who are employees of WPS. We have found it difficult to address and manage labor issues that arise out of safeguarded information that has been reserved for access by specific members of the licensee who have been determined by NMC to have a need to know. The difficulty arises from the circumstance that while NMC has sole responsibility for access authorization determinations, WPS maintains responsibility for negotiating with the bargaining unit and for disciplinary issues up to and including termination of employment. For example, if the NRC issues an order affecting working conditions that is safeguarded, WPS's ability to effectively determine what if any of the changes will affect represented employees and would require impact bargaining with the labor union prior to implementation is severely hampered without access to the safeguarded information. In addition, when there is a dispute over the application of a safeguarded adjudication table and action is taken upon an employee, because neither the employer nor the union has access to the information, there is not an effective means to respond to the union and resolve the concems.
WPS would fully support changes in the regulations on safeguarded information that would grant appropriate persons at a parent or affiliate company access to pertinent safeguarded information when needed. We would also support changes in the regulations that would allow union leadership access to applicable safeguarded information. This would more fully allow both the union and employer to exercise procedurals rights granted under labor law.
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RIN 3150-AH57 March 24, 2005 Page 2 We fully appreciate the importance of balancing the safety and security of the public with the rights of represented employees. We believe that an appropriate balance between these two can be achieved, and respectfully request that this commentary be given careful consideration. Should you have any questions, you may contact me at (920) 433-1086.
Sincerely,
"/7, ary DeWolfe Director, Labor Relations & Safety f
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Charlie Schrock Greg Veith TOTTSTVl0£T6:01
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