ML20044E160
| ML20044E160 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/30/1993 |
| From: | Carns N NIAGARA MOHAWK POWER CORP. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR12339, RULE-PRM-50-58 58FR12339-00022, 58FR12339-22, NUDOCS 9305240023 | |
| Download: ML20044E160 (1) | |
Text
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DOCKET NUMBER r: MON RULE PRM Sor67 l
gUMOHAWK (Sir F(2 /233 9)
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Y NIAGARA NINE MILE POINT NUCLEAR STATION /P.O. BOX 32. LYCOMING. N.Y.13093/ TELEPHONE (315) 349-244 r[
Nos. suu cams 93 MAY -5 P *22 WG Prescent NaclearGeneraton April 30,1993
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1 i:hAfu Mr. Samuel Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Docketing & Service Branch RE:
Virginia Electric and Power Company; Filing of a Petition for Rulemaking,58 Fed. Reg.
l 12339 (1993)
Dear Mr. Chilk:
These comments are submitted by Niagara Mohawk Power Corporation in response to the above referenced notice and invitation to comment on Virginia Electric and Power Company's petition for rulemaking to amend 10 C.F.R. Part 50, Appendix E, Section IV, F.2. We support the petition and believe that the proposed clarification to Appendix E is warranted.
]
Power reactor licensee effectiveness in emergency planning has improved steadily to the point where annual observed exercises no longer provide a significant benefit, let alone a benefit commensurate with their cost in dollars and diverted resources. For the nuclear power industry, over the past few years, emergency planning exercise deficiencies have largely been absent or narrowly focussed. Observations during periodic exercises have been generally minor, and there is no indication that such observations would interfere with the overall implementation of the emergency plan.
i We agree that adequate safeguards exist to assure that no deterioration of emergency planning l
effectiveness on the pan of any licensee occurs during the proposed two-year interval for exercises. As stated, the preposed change requires licensees to take appropriate action to maintain emergency response l
capabilities during this interval. Periodic drills which maintain emergency plan effectiveness would also l
continue to be conducted.
l We also agree that the estimated cost savings would amount to at least $200,000 and that hundreds of l
man-hours of effort could be redirected from exercise scenario development and implementation to l
substantive improvements of overall plant safety. The redirection of resources could provide a net safety benefit.
Respectfully submitted,
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N. S. Carns l
Vice President - Nuclear Generation l
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9305240023 930430 l
50-58 PDR i
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