ML20151R070
| ML20151R070 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 04/18/1988 |
| From: | Mroczka E, Sears C NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| B12891, NUDOCS 8804270231 | |
| Download: ML20151R070 (3) | |
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'Ta r.::";0%~C av) ses-swo April 18, 1988 Docket Nos. 50-213 50-245 50-336 50-423 B12891 Re:
10CFR50.70 Secretary, U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D.C. 20555 Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2 and 3 Coments on Proposed Rule (FR Volume 53, No. 53)
Licensee Announcement of Insoectors On March 18, 1988,(I) the Nuclear Regulatory Comission (NRC) proposed to amend its regulations to ensure that the presence of NRC inspectors on power reactor sites is not announced or comunicated to licensee personnel without the expressed request to do so by the NRC inspector.
Connecticut Yankee Atomic Power Company (CYAPC0) and Northeast Nuclear Energy Company (NNECO) respectfully submit the following coments.
CYAPC0 and NNECO agree with the intent of the proposed rule which we understand is to ensure that unannounced inspections involve a realistic and representative review of ongoing plant activities as they are being performed.
We welcome and endorse this concept of independent evaluation.
- However, though we believe that the rule makes sense conceptually, we perceive that it is unworkable, inappropriate for the majority of circumstances and will likely present an enforcement problem.
it our nuclear plants, certain practices and procedures have been established
> carry out our responsibilities for safe and reliable plant operation.
In particular, we take steps to ensure that personnel within the plant are properly authorized for access and truly have a need to be on-site, especially during off-normal hours.
For instance, during off-normal hours at the Haddam Neck Plant, all individuals entering the protected area that are not plant employees or security personnel must be authorized by the control room prior to entry.
This practice was briefly discussed with NRC Staff personnel in the ggk (1) See 53FR8924 k#
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3 U.S. Nuclear Regulatory Commission B12891/Page 2 April 18, 1988 context of the proposed rule.
The Staff indicated that the proposed rule was not intended to change or conflict with current station practices.
Staff personnel stated that if security personnel normally call the control room to authorize all visitors on-site during off-normal hours that this practice could continue.
However, the proposed rule as currently written does not appear to allow this practice.
Therefore, this could lead to questions of interpretation and possible allegations of non-compliance if current practices continue.
In addition, unfamiliar personnel in the plant may be challenged during off-normal hours as to the purpose of their presence with subsequent notification of the control room staff.
The intent of these practices is to provide additional safeguards during those times when less than the normal complement of staff are at the plant. The proposed rule clearly appears to be in conflict with these practices and may cause normal prudent actions by licensee personnel in the conduct of routine work to be construed by NRC Staff inspectors as a violation of the proposed regulation.
This could happen if shift personnel observe an NRC inspector in the plant and by practice or procedure inform the shift supervisor of an "unfamiliar individual" being present on-site.
This could also be the case for security personnel who are obligated to inform their supervision or if security management or control j
room staff review printouts showing personnel access to the plant or vital areas.
While we support the intent of the proposed rule, we believe that a regulation is not the appropriate vehicle to effect the desired results.
In fact, this proposed rule is in direct conflict with the type of constructive practices that should be encouraged rather than eliminated.
While we agree that badged NRC Staff inspectors should be provided unhindered access to power reactor sites and be able to observe typical and ongoing licensee activities without "inappropriate warning", it is not clear that this proposed rule will achieve that end.
Notwithstanding the above, if the NRC elects to adopt a rule change, CYAPC0 and NNEC0 propose the following changes:
o The proposed rule should be changed to state that a licensee will ensure that the presence of an NRC inspector on-site is not announced to the plant staff if the inspector specifically requests npt to do so.
This request should be presented in writing to the security access point personnel.
This way security or plant personnel would have written justification for not complying with station practices, o
The proposed rule should also provide clarification for how long the rule applies after the inspector enters the facility.
It is not reasonable to expect that the presence of the inspector can remain "unnoticed" and not be discussed indefinitely.
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U.S. Nuclear Regulatory Commission B12891/Page 3 April 18, 1988 i
i Overall, if issued. the proposed rule should be much more explicit to preclude inadvertent violation of NRC regulations.
Such issues as the type of discussion, if any at all, that is considered acceptable with respect to the presence of NRC inspectors on-site and the length of time the rule applies should be more clearly defined.
CYAPC0 and NNECO appreciate the opportunity to comment on the proposed rule and trust that this input may be useful in the finalization of the rule.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY
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E. J. Hroczka Senior Vice President Lbo#L By:
C. F. Sears Vice President cc:
W. T. Russell, Prcion I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant M. L. Boyle, NRC Project Manager, Millstone Unit No. I D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2 and 3 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
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