NRC-88-0114, Comment Opposing Proposed Rule 10CFR50 Re Unannounced NRC Inspectors

Comment Opposing Proposed Rule 10CFR50 Re Unannounced NRC Inspectors

ML20154G746
Person / Time
Site:	Fermi
Issue date:	04/22/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-88-0114, CON-NRC-88-114, FRN-53FR8924, RULE-PR-50 53FR8924-00030, 53FR8924-30, AC73-2-35, NUDOCS 8805250067
Download: ML20154G746 (2)

Text

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\7 April 22.1988 NRC-88-0114 U. S, cielear Regulatorf Commission Atti < iment Control Desk Wa s) ,, . D. C. 20555 Refetance: Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Proposed NPC Rule c: :lygneunced NRC Inspectors Detroit Edison appreciates the s,. .etunity to comment on the subject proposed rule published in the Federal Register on March 18. 1988.

Detroit Edison believes that the proposed rule is unnecessary and will not serve the purpose envisioned by the NRC. It is important that Panagement at an operating nuclear power plant know at all times who is on site. The safety concerns associated with havitig an unannounced 1 inspector inside the plant f ar outweigh the concerns regarding secrecy on which the proposed rule was based.

Detroit Edison also believes that the rule, as proposed, would be difficult if not impossible to adminicter. A literal interpretation of the rule would suggest that any person onsite would be prohibited from disclosing the knowledge that they have regarding an onsite inspector to anyone. As such, the person would be required to lie to anyone requesting this information based on the proposed rule. It is

> doubtful that such behavior was contesplated when the proposed rule was drafted.

) Furthermore, the proposed rule cuts against the NRC's expressed i guidance regarding accountability under its emergency planning rules. t The NRC requires accountability within 30 minutes following a call for -

an assembly and accountability. Under the proposed secrecy rule.

which might even sequire modifications to the security system and cceputers, the goal of the 30 minute accountability would be in jeopardy. Worse, personnel safety may be in jeopardy, l

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. 1 USNRC April 22, 1988 NRC-88-0114 Page 2 In summary, Detroit Edison believes that the risks and uncertainties regarding this rule far outweigh any benefits which could be derived if it is implemented.

Sincerely, ,

cc: A. B. Davis R. C. Knop ,

T. R. Quay W. G. Rogers .

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