ML20154G460

Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility

ML20154G460
Person / Time
Site:	Salem, Hope Creek
Issue date:	04/18/1988
From:	Preston B Public Service Enterprise Group
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR8924, RULE-PR-50 53FR8924-00026, 53FR8924-26, AC73-2-30, NLR-N88062, NUDOCS 8805240383
Download: ML20154G460 (2)

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BRANCH April 18, 1988 NLR-N88062 Mr. Samuel J. Chilk, Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch

Dear Mr. Chilk:

PROPOSED NRC RULEMAKING ON NOTIFICATION OF INSPECTOR VISITS SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272/50-311 AND 50-354 Public Service Electric and Gas Company (PSE&G) submits the following comments on NRC proposed rulemaking relative to licensee announcement of Inspectors (F.R. 8924 dated March 18, 1988).

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1) The existing requirements delineated in 10 CFR 50.70(b)(3) provide the NRC with the required level of access identified in the proposed rulemaking.

The incorporation of the proposed paragraph would simply add a redundant requirement.

2) Justifying the rulemaking on the basis that, "...there have been incidences in the past at several facilities.." gives the appearance that all licensees are being penalized for problems which exist at a few problem facilities. If access problems exist, the NRC should address them on an individual facility basis until such time as it is demonstrated that a generic problem exists.

3) As written, the proposed rule implies that the NRC would expect each licensee to monitor individual l communications to assure that unauthorized notifications are not taking place. Due to the large number of personnel employed by plant operators and the degree of communication that occurs in the normal routine course of events, implementation of such a requirement would be virtually impossible.

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Mr. Samuel J. Chilk 2 April 18, 1988

4) It is not clear as to how the NRC would expect to implement enforcement action under the proposed rule.

It would be inappropriate to cite a facility for unauthorized notifications which originate outside of the work place. Similarly, enforcement action against a facility without identification of the source of the unauthorized notification would also be inappropriate.

If there are any questions regarding these comments, please feel free to contact us.

Sincerely, B. A. Preston Manager - Licensing and Regulation