L-95-199, Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial

Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial

ML20086L062
Person / Time
Site:	Saint Lucie
Issue date:	07/10/1995
From:	Bohlke W FLORIDA POWER & LIGHT CO.
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR19002, RTR-NUREG-0654, RTR-NUREG-654, RULE-PR-50 60FR19002-00011, 60FR19002-11, L-95-199, NUDOCS 9507210031
Download: ML20086L062 (1)

Text

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USNRC ppt #(d

% JLt #f P3 :16 JUL 101995 L-95-199 0FFICE OF SE RETARY DOCKEIlh'G 6 SERVICE Mr. J. C. licyle, Acting Secretary BRMCH U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 LM.U NUMBEA P M 0'A D RULE E0 8 O Attn: Docketing and Service Branch g g g )9o

Subject:

Production and Utilization Facilities; Emergency Planning and Preparedness Exercise Requirements (60 FR 19002, April 14,1995)

Reauest for Comments On April 14, 1995, the Nuclear Regulatory Commission published for public comment a proposed rule, " Production and Utilization Facilities; Emergency Planning and Preparedness Exercise Requirements." These comments are submitted on behalf of Florida Power & Light (FPL), a licensed operator of two nuclear power plant units in Dade County, Florida and two units in St. Lucie County, Florida.

FPL supports the proposed rule change to 10 CFR Part 50, Appendix E. FPL points out, however, that the NRC should consider a revision to their emergency preparedness inspection procedures. These procedures are used by regional inspectors as a mechanism for evaluating a licensee's ability to demonstrate implementation of all the major portions of their emergency preparedness program over a 6 year period (NUREG 0654/ FEMA REP 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans in Support of Nuclear Power Programs, Exercises and Drills, N.1.b.). Historically, this demonstration involved the i observation of the licensee's annual emergency preparedness exercise by NRC inspectors. This will no longer be practical since a number of these demonstrations will most likely occur during l the off year drills and exercises. The NRC should consider modifications to their inspection l procedures allowing a licensee to perform its own self evaluation and critique against the criteria l for preparation and evaluation of emergency response plans.  ;

We appreciate the opportunity to comment on this proposed mle.

Very truly yours, l

$.Q p W.11. Bohlke a ~ -

Vice President l

Nuclear Engineering and Licensing l

l WilB/st 9507210031 950710 PDR PR 50 60FR19002 PDR g an FPL Group company