ML20154G385
| ML20154G385 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/18/1988 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-52FR8924, RULE-PR-50 52FR8924-00025, 52FR8924-25, AC73-2-29, NUDOCS 8805240349 | |
| Download: ML20154G385 (2) | |
Text
DOCKET NUMBER h,,f()
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-r April 18, 1988
'88 APR 25 A9 '40 Mr. Samuei J. Chilk Secretary of the Commission co u U. S. Nuclear Regulatory Commission 00CKI'y,g, "',-
Washington, O. C.
20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Proposed Rule Licensee Announcements of Inspectors
Dear Mr. Chilk:
South Carolina Electric & Gas Company (SCE&G) has reviewed the proposed change to 10CFR50.70 which was published in the March 16, 1988 Federal Register dealing with the announcement of inspectors visiting a power reactor site.
The following discussion of the proposed rule 4 being provided since SCE&G considers the rule to be undesirable from both c.
RC and utility perspective.
SCE&G considers the announcement to key management personnel that an inspector has arrived on site to be very beneficial to the accomplishment of the goals of the inspectors.
If management is informed as to the area in which the inspector is interested, contact personnel within the utility organization (or the management themselves) can be designated to provide assistance to the inspector to enable him to more effectively perform an inspection.
If the utility is unaware the inspector is onsite, the inspector is forced to deal with unfamiliar surroundings, lack of indepth knowledge about plant specific procedures and policies, potential inability to contact those individuals best suited for (or even familiar with) his specific inspection area, and a general lack of potentially useful and timesaving assistance.
In actuality, an inspector's surveillance can potentially be conducted in much greater detail with more thoroughness, provided the Licensee is aware of his existence and can readily provide any necessary assistance.
The announcement of an inspector's arrival to essential personnel should not alter the overall attention and performance level of the Licensee. Adherance to approved procedures and company policies is stressed to all 9ersonnel for all shif ts, including days, nights, weekends, and holidays regardless of the supervision being provided to the activity. At an inspector's special request to utility management upon arriving on site, further notification of his presense to plant personnel can be postponed to allow for ongoing activities to be observed by the inspector without the observed individual's specific knowledge. However, this specific type request should be handled on an individial basis and not as a formal rule change.
In general, SCELG contends that the utility management on duty is ultimately responsible for the safe operation of the unit and they should, at all times, be aware of visitors (including inspectors) on site.
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Mr. Samuel J. Chilk April 18, 1988 Page 2 SCE&G is aware of the NUMARC industry response to the proposed rule and is in agreement with its initiative.
The opportunity to comment on this proposed rule is appreciated and the NRC staff is encourdged to reconsider the necessity of this rule change, if you should have any questions, please advise.
Very truly yours, L.
La xt"
- 0. A. Nauman AMM/ DAN: led pc:
J. G. Connelly, Jr./0. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
J. J. Hayes, Jr.
General Managers C. A. Price W. R. Higgins R. M. Campbell, Jr.
NPCF File (811.02)