ML20024G021
| ML20024G021 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/03/1990 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR41095, FRN-56FR40178, RULE-PR-50 55FR41095-00004, 55FR41095-4, AD32-2-51, NUDOCS 9012270246 | |
| Download: ML20024G021 (2) | |
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South Carchne Ettetr.c & ois Compen John L. Skolds P O. Box 06 (fff,4/O f Wce P'e5' dent 4
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B, SCE&G tG wkG December 3, 1990 811.02
'90 DEC -7 PS :05-
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. ; t. h i o Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555
~ Attention: Docketing and Service Branen
+
Gentlemen:
Subject:
VIRGIL C.-SUMMER STATION PROPOSED RULE CHANGE T0
" EMERGENCY RESPONSE DATA SYSTEM" (ERDS)
~
Reference:
55FR41095 South Carolina Electric & Gas Company (SCE&G) has reviewed the subject proposed change to 10CFR50 which would require licensees to participate in the Emergency Response Data System (ERDS) program and to set a definite schedule for its; implementation. The following comments are submitted:
Contrary to the proposed change, which estimates 5 man-days per reactor year'for.a licensee staff to maintain the on-site ERDS configuration control program, it is estimated that it will require 15 man-days _per reactor year; this is based upon the anticipated doc.imentation which must be. generated and submitted to the NRC as c%nges 'are made in plant computer systems supporting the ERDS.
- Since the' information provided by the ERDS'alone cannot convey a total understanding of plant activities, a potential may exist for the NRC.to alter recommended protective actions to the detriment of the communities involved.
Implementation of the ERDS would not allow a utility to redirect
-its resources to other tasks during an emergency since the voice channel to the NRC must be kept open.
In addition, EROS will
-requi_re additional resources to verify and maintain the necessary l:
equipment to ensure that the transmitted' data is accurate.
The NRC intends to make EP"S information available to state i:
_ governments. _If'a state ooses to utilize the ERDS information, it would_most li.kely require.the licensee to pay for the equipment 4necessary-to receive and process the data, i
9012270246 901203 PDR PR 50 55FR41095-PDR t 959
f Secretary of the Commission December 3, 1990 811.02 Page 2 Several states, including South Carolina, have nuclear power plants with reactors provided by different vendors.
The availability of the ERDS information at the state lovel implies that the state and local governments will provide their personnel with the necessary skills to read and interpret the information from varying reactor types. This will add to an already overtaxed system responsible for responding to emergencies at commercial nuclear reactors.
Without adequate initial and continued requalification training, the inforrration supplied by ERDS would only serve to add confusion to an emergency situation.
If there are any questions on this subject, please contact Mr. Hal Donnelly of my staff on 803-345-4722.
Very truly yours,
[J2(A w
John L. Skolds l
EPM:JLS: led l
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- 0. W. Dixon, Jr.
E. C. Roberts R. J. White S. D. Ebneter G. F. Wunder I
General Managers NRC Resident Inspector L
J. B. Knotts, Jr.
O. C. Warner G. J. Taylor G. F. Gibson J. F. Heilman K. E. Beale NSRC-NPCF RTS (PR 900015)
HUCLEAR EXCELLENCE - A SU MER TRADITION!
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