ML051040225
| ML051040225 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/30/2005 |
| From: | Archie J South Carolina Electric & Gas Co |
| To: | Annette Vietti-Cook NRC/SECY/RAS |
| Byrdsong A T | |
| References | |
| +adjud/ruledam200505, 70FR07196 00021, PR-02, PR-150, PR-30, PR-40, PR-50, PR-52, PR-60, PR-63, PR-71, PR-72, PR-73, PR-76, RIN 3150-AH57 | |
| Download: ML051040225 (2) | |
Text
,, ',a, Jeffrey B. Archie
- 1 (001 0 Vice President, Nuclear Operations r3 1 5 o 803.345.4342 AcE S&GC A SCANA COMPANY March 30, 2005 Ms. Annette L. Vietti-Cook DOCKETED Secretary of the Commission USNRC U. S. Nuclear Regulatory Commission April 13, 2005 (2:37pm)
Washington, DC 20555 OFFICE OF SECRETARY Attention: Rulemakings and Adjudications Staff RULEMAKINGS AND ADJUDICATIONS STAFF
Dear Ms. Vietti-Cook:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 RIN 3150-AH57, REQUEST FOR COMMONENTS ON THE PROPOSE RULE, PROTECTION OF SAFEGUARDS INFORMATION, 70 Fed.Rec. 7196; February 11, 2005 South Carolina Electric & Gas Company (SCE&G) has reviewed the above subject proposed rulemaking, and the reference letter from the Nuclear Energy Institute (NEI) to the USNRC. SCE&G endorses the comments made by NEI in the reference letter dated March 28, 2005. In addition to the comments made by NEI, please find attached comments by SCE&G that were not addressed by NEI.
If there are any questions, please call Mr. Mark P. Findlay at (803) 345-4186.
SBR/JBA/sr C: N. 0. Lorick S. A. Byme N. S. Carns T. G. Eppink R. J. White K. R. Cotton NSRC RTS (C-05-0647)
File (811.02, 2.028)
DMS (RC-05-0050) aimrn al +tt=Se6%1--- a SCE&G l Virgil C.Summer Nuclear Stolion
- P.0.Box 88
- Jenkinsvile, Souih Coroflna 29065
- T(803) 345.5209
- wwscona.com
Ms. Annette Vietti-Cook C-05-0647 RC-05-0050 Page 2 of 2 Discussion of proposed amendments by Section Definition of Trustworthiness and Reliability.
The reference that this expectation is embodied in Section 73.55 and 26.10 infers that these elements must also be completed to determine trustworthiness and reliability for access to SGI. Ifthis is the expectation then it should be specified in the requirements. However this will be very challenging to administer especially for the contract engineering firms who are never at the site. There is also no guidance on how long an individual can have access to SGI without any update of information.
Section73.22 (a)(1 )(vii)(viii)(ix). These sections reference the safeguards contingency plan and training and qualification plan. These are now part of the composite Security Plan that was submitted as result of the Order.
(a)(1 )(x), ...safeguards or security emergencies. This text is not consistent with the Plan template that used the phrase security contingency events.
(a)(1 )(xii) Recommend revising the wording in the'end of the sentence....by significantly increasing the likelihood of theft, diversion, or sabotage of material or a facility to the wording that is used in the definition of SGI, significantly increasing the likelihood of radiological sabotage or theft or diversion of source, byproduct, or special nuclear material.
(c) Add that SGI may also be store in the Reactor Control Room.
Section 73.23 (a)(1 )(ix) ...safeguards or security emergencies. This text is not consistent with the Plan template that used the phrase security contingency events.
(a)(1)(x) Recommend revising the wording in the end of the sentence....by significantly increasing the likelihood of theft, diversion, or sabotage of material or a facility to the wording that is used in the definition of SGI, significantly increasing the likelihood of radiological sabotage or theft or diversion of source, byproduct, or special nuclear material.