ML20153F968

Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged

ML20153F968
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	08/17/1988
From:	Preston B Public Service Enterprise Group
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR27174, FRN-54FR7178, RULE-PR-50 53FR27174-00003, 53FR27174-3, AC83-2, AC83-2-05, AC83-2-5, NLR-N88132, NUDOCS 8809070559
Download: ML20153F968 (3)

Text

' 00CSET NUMBER ) 3-pg(( 10 POSED RULE M E OR UtN5 Pubhc Sennce Electne and Gas Company P O. Box 236 Hancocks Bndge, New Jersey 83 Nuclear Department 'E AUG 18 P3 :01 Qf' 3 v0Cm *: .

.. u August 17 1988 k" NLR - N88132 Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission '

Washington, D.C. 20555 Attention: Docketing and-Service Branch

Dear Mr. Chilk:

COMMENTS ON NRC PROPOSED RULEMAKING LICENSEE FLEXIBILITY DURING NATIONAL CRISIS SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311, 50-354 Public Service Electric and Gas Company has reviewed the proposed rule (FR 27174, Dated July 19, 1988) and submits the following comments for consideration.

Although we are in agreement that licensees should be afforded reasonable flexibility in complying with plant Technical Specifications during a national crisis, we do not support issuance of the proposed rule in its present form.due to a lack of discussion relative to implementation requirements. In our opinion, the cornerstone of effective crisis management is proper advance planning and, where practical, personnel training. For example, Emergency Plans in place at nuclear facilities across the country are designed to provide the necessary framework for formulating an appropriate response to postulated operational l events. Plant operators are trained and tested on the procedures l contained in these plans in order to provide a high degree of  !

assurance that the health and safety of the public is ,

safeguarded.

1 We therefore encourage the NRC to defer issuance of a final rule )

until such time as proper implementation guidance can be i formulated. That guidance at a minimum should address the following issues:

Security of communications between NP.C/ Governmental agencies and licensees during national crises:

1 Guidance on developing and integrating reasonable national crisis contingency procedures into existing licensee programs; 1

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.. J l S. J. Chilk 2 August 17, 1988

- The division of responsibility between the NRC and the licensee during a national crisis: .

- A definition of when the threat to the public due to the continued operation of the plant during a crisis is judged to be greater than that posed by the crisis itself;

- The assumption of liability in the event of miscommunications or adverse plant consequences occurring during or as a result of a national crisis.

We-appreciate the opportonity to provide these comments. If there are any questions'please feel free to contact us.

E cerely,

. 41. .s B. A. Prestc673 Manager - Licensing and Regulation l

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S. J. Chilk 3 August 17, 1988 BC: Assistant Vice President - Nuclea.- Operations Support.

General Manager - Salem Operations General Manager - Hope Creek Operations General Manager - Licensing and Reliability General Manager - Nuclear Quality Assurance General Manager - Nuclear Safety Revieu-Manager -Licensing and Regulation Operations Manager - Salem Operations Manager - Hope Creek Associate General Solicitor SEM/EO (Cover Letter Only) '

J. Caldwell (ATS) .

Microfilm Copy-File No. 1.2.1, 4.2 I

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