LIC-97-0136, Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Preparedness Programs, Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors

Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Preparedness Programs, Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors

ML20216E989
Person / Time
Site:	Fort Calhoun
Issue date:	08/28/1997
From:	Gambhir S OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR40978, RULE-PR-50, RULE-PR-73 62FR40978-00001, 62FR40978-1, LIC-97-0136, LIC-97-136, NUDOCS 9709110127
Download: ML20216E989 (2)

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444 South 16th Street Mall Otnaha NE 68102-2247 OFFICE OF SFP s . qv RULO G P* :n ADJUDUd.C , ilFF August 28, 1997 LIC-97-0136 DOOKET NUMBER PROPOSED RULE PR 5o4 73 Secretary U. S. Nuclear Regulatory Commission (hQR409 /

Attn: Docketing and Service Branch Washington, D.C. 20555-0001

References:

1. Docket No. 50-285

2. Federal Register Volume 62 dated July 31, 1997 (62 FR 40978)

Subject:

Comments on Proposed Rulemaking Regarding Frequency of Reviews and Audits for Emergency Preparedness Programs, Safeguards Contingency Plans, and Security Programs for Nuclear Power Reactors l

The Omaha Public Power District (OPPD) has reviewed the subject proposed rulemaking.

, OPPD generally supports the proposed rule to extend the review frequency from 12 to 24 l months. However, OPPD has two concerns which need to be addressed in the final regulation.

The proposed rule would require that a licensee assess performance indicators to determine if more frequent reviews are necessary, Without accepted industry or NRC defined performance measures, the rule will only create inconsistency in both operational and enforcement applications. To ensure consistent practice throughout the industry, OPPD recomends that performance standards or measurements be well defined and approved in industry guidelines.

The proposed rule also would require that the frequency of review be altered after a "significant change occurs in personnel, procedures, equipment, or facilities." Again, there is insufficient definition of what constitutes a "significant change." This will result in more confusion and inconsistent application. OPPD recommends that this reouirement be eliminated from the rule in its entirety. If a program is objectively evaluated to a set of standard performance indicators, those predictors will certainly signal when a more frequent review is required. If this statement must be retained to satisfy the coments of the two states which commented on the proposed rule earlier, the rule should be reworded to clearly note that the frequency should be altered only after the licensee reaches a decision that a "significant change" has occurred.

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Secretary V. S. Nuclear Regulatory Commission LIC-97-0136 Page 2 Please contact me if you have any questions.

Sincerely, S. K. Gambhir Division Manager Engineering & Operations Support SKG/mah c: Winston & Strawn E. W. Merschoff, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector Document Control Desk

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