ML092930152

Comment (1) of D. Hooper, on Behalf of Strategic Teaming and Resource Sharing, Relating to Draft Regulatory Guide DG-5029 Pressure-Sensitive and Tamper-Indicating Seals for Material Control and Accounting Use.

ML092930152
Person / Time
Site:	Palo Verde, Wolf Creek, Diablo Canyon, Callaway, South Texas, San Onofre, Comanche Peak
Issue date:	10/15/2009
From:	Hooper D Strategic Teaming & Resource Sharing (STARS)
To:	Rulemaking, Directives, and Editing Branch
References
74FR40854 00001, DG-5029, STARS-09012
Download: ML092930152 (3)

Text

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Strategic Teaming and Resource Sharing

ýtljjl e D. Hooper, Acting Chairman STARS Integrated Regulatory Affairs Group P.O. Box 411, Burlington, Kansas 66839 STARS-09012 October 15, 2009 Chief, Rulemaking, Directives and Editing Branch Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission /1 Mail Stop TWB 5B01M Washington, DC 20555-0001 c-f-)

STRATEGIC TEAMING AND RESOURCE SHARING (STARS)

COMMENTS RELATING TO DRAFT REGULATORY GUIDE DG-5029 "PRESSURE-SENSITIVE AND TAMPER-INDICATING SEALS FOR MATERIAL CONTROL AND ACCOUNTING USE"

Reference:

1) 74 FR 40854, Draft Regulatory Guide: DG-5029,"Pressure-sensitive and Tamper-Indicating Device Seals for Material Control and Accounting Use," dated August 13, 2009, NRC-2009-0353 The Strategic Teaming and Resource Sharing (STARS) 1 alliance submits the attached comments in response to the referenced Federal Register notice soliciting comments on the proposed revision to Regulatory Guides 5.10 and 5.15, dated July 1973 and March 1997, respectively. As the comments generally reflect, STARS believes that the methods described in Regulatory Guides must be clear since the staff develops inspection criteria from the information found in the Regulatory Guides.

STARS consists of thirteen plants at seven stations operated by Luminant Power, AmerenUE, Wolf Creek Nuclear Operating Corporation, Pacific Gas and Electric Company, STP Nuclear Operating Company, Arizona Public Service Company, and Southern California Edison.

Callaway Comanche Peak Diablo Canyon Palo Verde San Onofre South Texas Project Wolf Creek

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STARS-09012 Page 2 of 2 Thank you for your consideration of these comments. if there are any questions regarding these comments, please contact me at 620-364-4041, or dihooper@wcnoc.com, or Ted Koser at 361-972-8963, or tckoser@stpegs.com.

Sincerely, D. Hooper, Acting Chairman STARS Integrated Regulatory Affairs Group Attachment Comments on Draft Regulatory Guide DG-5029

Comments on Draft Regulatory Guide DG-5029 Attachment to STARS-09012 Page 1 of 1 The following comments are provided regarding the directions and methods found in DG-5029 (Note: the page numbers refer to the document located on the NRC's Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML091670070).

1. Page 6 - In the third paragraph in section 2.2.2.2, a testing progiam "should" be utilized is described. If the staff believes the manufacturer's testing program is not sufficient, then the wording must be specific as to the types of testing necessary. The current wording will create confusion as to what, if anything is required. For example, phrases such as "multiple attempts" and "significant number of attempts" are subjective and open to interpretation.) The Staff should state the requirements for testing and that the licensee has reviewed the manufacturer's testing program for the seals and found it to be adequate or has otherwise sponsored a testing program.

2. Page 7 - The second paragraph in section 2.2.3 provides suggestions that are not within the scope of the RG. The RG should not provide suggestions to the licensee on control of data outside the scope of this RG. The paragraph should be deleted.

3. Page 7- Section 2.2.4 is outside the scope of this RG. The control of the recorded data is not the subject of this RG. The section should be deleted.

4. Page 10 - The second paragraph under 2.4.6 seems to contain an optional requirement. If the desire is to get vendor verification that seal designs are protected and controlled, then the paragraph should state that explicitly. If this is only a suggestion, the paragraph should be deleted to prevent confusion between the licensee and the staff.

5. Page 10 - The last two sentences under 2.4.6.1 are ambiguous. If the decals are not acceptable for the application, then it should be stated as such. If they are acceptable, delete the last two sentences.

6. Page 10-The last sentence of section 2.4.6.2 should be deleted. The requirement of a company logo on a seal is beyond the scope of this RG.

7. Page 12-All but the last sentence of the third paragraph under section 3.2 should be deleted. It is not appropriate for the RG to specify the organization of the licensee. The procedures and process in place are adequate.