ML20153C141

Comment on Proposed Rule 10CFR2 & 51 on Subpart M Re Transfer of Operating License

ML20153C141
Person / Time
Site:	Pilgrim
Issue date:	09/20/1998
From:	Leonardi D AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR48644, RULE-PR-2, RULE-PR-51 63FR48644-00001, 63FR48644-1, NUDOCS 9809230355
Download: ML20153C141 (2)

Text

i DOCKET NIAABER / l 1 R0 POSED RULE $ ot d 51 ,

DOCKETED I (G3 FR 4%W)

USNRC  !

September 20,1998 1 i

% SEP 22 A7 :41 j The Secretary of the Commission ,

I U.S. Nuclear Regulatory Commission OFFh O Washington, DC 20055-0001 Rat  ;

i ADJUDD + ' 7FF  ;

Attention: Rulemaking and Adjudication Staff ]

l

Subject:

Comments on Proposed Rule 10 CFR 2 Subpart Part M j i

Federal Register: September 11,1998 (Volume 63, Number 176)

Page 48644-48653 j

~

I have been a Licensed Operator (op 10984) for 6 years and work at the Pilgrim Nuclear Power Station. I have been an employee of Boston Edison, Pilgrims owner, for 10 years. ]

Currently, Boston Edison is planning to sell Pilgrim and transfer the operating license. l My comments are directed more to what is missing in tiie proposed rule rather that to l what it contains.

Comment 1. In ress onse to the statement "In general, license transfers do not involve any changes to plant op tration. :r sigmficant changes in personnel ofconsequence to the continued reasonab e assurance ofpublic health and safety, but rather involve changes in l ownership orpartial ownership offacilities at a corporate level." this is grossly misinformed and a dangerous assumption to base the transfer of an operating license.

The factual matter is that significant losses of critical personnel must be anticipated and factored into the transfer decision. The training time required to replace Licensed Operators and other Critical Personnel of a year or more must be considered in the transfer proceedings. If the retention of critical plant personnel is not assured in advance of the license transfer the pressures on the remaining personnel can greatly reduce the margin of safety to the public. Requiring critical personnel to work extended shifts due to staff shortages, unavailability or lack of qualified staff, has a direct effect on their ability to correctly perform needed tasks during transients and normal operation. The [

proposed rule must require the applicant to submit a critical staff retention plan. This is a o matter clearly with in thejurisdiction of the Commission', Q2.1308 (c) of the proposed rule.

Comment 2. In response to the aspect of the rule where there is no provision "for any separate discovery" and relies on the public document room. The Public Document Room is difficult to use. I would prefer a separate section on the NRC web site for each

- 8 650.47 Emergency plans. (b)(2) on-shift facilP.y licensee responsibilities for emergency response .... adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, time;y augmentation of response capabilities is available. .

Also 50.54(m)(1). 50.54 (m)(2)(i, shrough tv) 9809230355 990920 PDR PR 2 63FR48644 PDR 7 5I0

.~ .. .-. . - - . -- _ . . . . -. . - _ . - . . ~

. v s

'e proposed License Transfer. Where all relevant documents and correspondence maybe accessed. Tnis location must also have an index of all relevant documents and a short description of the information contained therein.  !

I appreciate the opportunity to submit comments on this very important topic. If you have any questions, please contact me at 508-428-3595.

Sincerely,

)

David 1.conardi,(op 10984)

I 1 Pinetree Circle 1 Sandwich, MA 02563 l

(508)428-3595 l

l 4

I I

i I

l 4

t .i.