L-94-150, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Licensees Conduct Independent Reviews of Emergency Preparedness Program from Annually to Biennially
| ML20071H128 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Turkey Point  |
| Issue date: | 06/17/1994 |
| From: | Bohlke W FLORIDA POWER & LIGHT CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR17499, RULE-PRM-50-60 59FR17499-00006, 59FR17499-6, L-94-150, NUDOCS 9407140027 | |
| Download: ML20071H128 (2) | |
Text
{{#Wiki_filter:_. - _ _ _ _ _ _ _ _ _. _ - _ _ _ - t, floada Power & light Compny, P G Don 140tR Junu Ucach, il 31908 0470 g g DOChEff0 W USHC FPL '94 JIN 2/ P3 :37 L-94-150 Mr. samuel a. Chilk JUN I 71994 Secretary of t.he Comminaion OfI iL L " Nuclear Regulatory CommMOffdilf" .c ZDJ f NUMBER
- -{
U.S. Wanhington, DC 20555 .,EnnoN RutE PRM h9 -(>O (f4 (( /777'/) ATTENTION: Docketing and Servicen Branch
SUBJECT:
Virginia Power; Filing of Petition for Rulemaking 59 Fed. Reg. 17499 - April 13, 1994 Ruuunat Ior Comnmnia3 On April 13, 1994, (59 FR 3 74 99), the Nuclear Regulatory Commionion (NRC) published for public comment a notice of pe t i t. ion for rulemaking titled " Virginia Power; Filing of Petition for Rulemaking." Florida Power and Light Company (FPL), ao the 1icensed operator of two nuclear power plant unito in Dade County, Florida and two nuclear power plant unito in St. Lucie County, Florida, cubmitu the following commento. FPL concurn with the Virginia Power petition regarding a change in the irequency that Ideenoeen conduct independent reviewn of their emergency preparedness program from annually to biennially. Virginia Power citen eight renoons for the requent to change this requirement. FPL focusen on two of these reasonn: 1) t.he present good performance of industry emergency plano and programa, and 2) the conciatency with the guidance in Regulatory Guide 1.33, " Quality Annurance Program Requiremento (operation)." With respect to the first
- reason, FPL'n Emergency Plan (EP) programa have maintained a long standing SALP one rating, and are managed with the emphania on making the necessary improvement / modifications to maintain this excellent pertormance.
PPL' a performance nupporto Virginia Power's statement that Industry . performance to date indicaten excellent implementation and effective emergency preparedness programa. With respect to the second reason, FPL concurs with Virginia Power that the existing requirement to conduct an annual audit la not of itself necessary to adhere to the underlying purpose of 10 CFR
- 50. 54 (t).
FPL's Quality Anourance performance monitoring program is structured t.oward a performance based auditing philosophy and includes audita of the varioun drillo and exercisen in addition to routine audits of the Emergency Planning Program. FPL believen the performance-based overview with a two-year minimum interval la nufficient to satisfy 10 CFR 50.54 (t). 9407140027 940617 PDR PRM 00-60 PDR
n 'e L-94-150 Page 2 The Virginia Power petition is consistent with ths recommendation of the NRC Regulatory Review Group Summary and Overview Report, and is consistent with FPL's current Quality Assurance initiatives regarding audit frequencies. By employing a 24 month minimum audit frequency for emergency _ preparedness, the Nuclear Industry is provided with additional flexibility to use their resources more f effectively in focusing on other performance improvement opportunities. FPL appreciates the opportunity to comment on this petition. Very truly yours, f b 'b f L W 7, -H. Bohlke Vice President Nuclear Engineering and Licensing WHB/spt J -........}}