ML20072B177
| ML20072B177 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/29/1994 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR30308, RULE-PRM-9-2 59FR30308-00003, 59FR30308-3, NUDOCS 9408160024 | |
| Download: ML20072B177 (2) | |
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South Carolina Electric & Gas Compsny John L. Skolds P.o. Box 88 Senior Wce President i
Jenkinsville SC 29065 Nuclear Operations (803) 345-4001 00CKETED 3
SCE&G usnec ASCnnNConpany July 29,1994
'94 NC -5 P4 :20 Refer to: RC-94-0202 Secretary f:I U. S. Nuclear Regulatory Commission D-Washington, DC 20555 Attention: Docketing and Service Branch DOCKET NUMBER PETmCN RULE PRM 9-1 Gentlemen:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 COMMENTS ON OHIO CITIZENS FOR RESPONSIBLE ENERGY INC. PETITION FOR RULEMAKING t
This letter provides comments on Ohio Citizens for Responsible Energy Inc. (OCRE) petition for rulemaking to change the rules regarding public access to information as stated in 10 CFR Part 9, particularly information that is held by licensees but is not submitted to the NRC.
Regarding PRM-9-2, petition to the NRt for rulemaking, South Carolina Electric &
Gas Company (SCE&G) disac rees with the petitioners position. Resulting rules would increase the administrative aurden and costs to licensees while providing no benefit to public health and safety. Furthermore, lack of public access to information on nuclear regulation to the level desired by the petition would not undermine public confidence in the regulatory program of the NRC.
The proposed rule would be a significant burden on licensees. One example given in the petition of information not available to the public is compliance to the Station Blackout Rule. The Station Blackout Manual documents com aliance to the Station Blackout Rule at V. C. Summer Station and contains dozens o" references. Some of those reference documents have references themselves. The Appendix R Design Basis Document, referenced in the Station Blackout Manual, has 219 references.
Screening the references along with the manual for relevance or proprietary information would significantiv increase the burden on licensees. This burden would be multiplied for evoy separate request for information on Blackout Rule
~
compliance received.
This increased burden could impede the normal work processes of a licensees staff.
The licensee could receive numerous individual requests for information from grou ps such as OCRE, as well as arivate citizens. Even if a request were deemed l
frivol ous, the licensee could be "orced to prove this under the appeal process mentioned in the proposed rule. This added work load would increase administrative costs to the licensee while providing no real benefit to the health and safety of the public. Additionally, licensees would in turn result in added costs tothis pro the customer since added costs to their customers.
gB1 24 940729 9-2 PDR
Secretary, U.S Nuclear Regulatory Commission PR 940015 2
Page 2 of 2 Aside from the added burden to licensees, failure to implement the proposed rule would not undermine the public confidence in the NRC regulatory process. Public confidence in the NRC regulatory process, we believe, comes from the continued safe operation of NRC regulated facilities, not the level of access the public has to licensee information.
Considering that the aroposed rule would increase the administrative burden and costs to licensees whil e providing no benefit to public health and safety, and that, contrary to the petition, lack of public access would not undermine public confidence in the regulatory program of the NRC, SCE&G does not agree with this petition. Under the current program,information relevant to a !icensee's compliance to regulations such as the blackout rule is located in NRC inspection reports which are available to the public. It is the opinion of SCE&G that this program,which allows meaningful public participation in the regulatory process with no undue burden on licensees, shoulcl be maintained.
SCE&G appreciates the opportunity to review and provide comments on this petition for rulemaking.
Very truly yours, John L Skolds JDH/JLS/nkk c:
O. W. Dixon R. R. Mahan R. J. White D. A. Lavigne K. W. Nettles M. D. Quinton G. J. Taylor Central File System NSRC 1
RTS (PR 940015)
File (811.02,9.003)
NUCLEAR EXCELLENCE - A SUMMER TRADITION!