ML20154G748
| ML20154G748 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 04/15/1988 |
| From: | Hintz D WISCONSIN PUBLIC SERVICE CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-NRC-88-54, FRN-53FR8924, RULE-PR-50 53FR8924-00010, 53FR8924-10, AC73-2-17, NUDOCS 8805250068 | |
| Download: ML20154G748 (2) | |
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e NRC-CU-54 WPSC 1414) 4331598 TELECOPIER (414) 433-1297 EASYLINK 62891993 N D.[iEI WISCONSIN PUBUC SERVICE COAPORATION t.W 600 North Adams
- P O. Box 19002 e Green Bay, WI 543o7 9002
'88 APR 19 N2:25 DOCKET NUMBER '4 d PROPOSED RULE L53 H2 M2N]
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. y 4, April 15, 1988 Secretary of the Commission Attention Docketing and Service Branch U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant 53 FR 8924, Announcement of Inspectors We have reviewed the subject proposed rule and the d"aft NUMARC comments to it dated April ll, 1988. WPSC endorses the NUMARC corr."ents as supplemented below.
We are seriously concerned about the health and well-being of any individual admitted to the site with minimal or no familiarity with the site or plant con-Uitions. ' Changing plant conditions require that personnel consult with various plant departments in order to avoid the hazards of an industrial facility. WPSC could be held liable for injury to an NRC inspector without first having an opportunity for prevention by advising the individual of known hazards.
A second item of concern stems directly from the proposed wording of the rule.
The rule states that the licensee shall "ensure" that the arrival and presence of an NRC inspector is not announced or otherwise communicated by its employees to other persons at the facility unless specifically requested to do so.
This wording is overly broad and vague and represents an impossible task for the
- licensee, it is far more reasonable to require a licensee to develop procedures to prohibit intentional notication of the target of the inspection by the site security group for a specified period of time when requested to do so by the inspector in writing.
Thirdly, there is no limit with regard to when NRC could use this audit tech-nique. We view this method as radical and as such should be reserved for situations where the NRC has reasonable'suspicfons that its, regulations that have a direct impact on public health and safety are being intentionally violated.
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O Secretary of the Comission April 15, 1988 Page 2 Lastly, the nuclear industry has made a concerted effort to maintain a ocod working relationship with the NRC by maintainina a free and candid dialoa through individual licensees, NUMARC, INP0 & other groups formed to resolve spe-cific issues.
This rule, if promulgated, will tend to introduce an element of unintended antagonism in NRC/ Licensee relationships.
Thank you for your consideration of these comments.
Sincerely, pp' XWA D. C. Hintz Vice President - Nuclear Power DWS/jms cc - Mr. Robert Nelson, US NRC US NRC, Region 111 US NRC Document Control Desk
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