ML20070H679

Comment Supporting Proposed Rulemaking 50-59 Re Virginia Power;Filing of Petition for Rulemaking

ML20070H679
Person / Time
Site:	Beaver Valley
Issue date:	07/13/1994
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR23641, RULE-PRM-50-59 59FR23641-00004, 59FR23641-4, NUDOCS 9407220033
Download: ML20070H679 (1)

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JOHN D SIEE$ER Senior Vice President and Fax (412) 643-8069 Chief Nuclear Officer Nuclear Power Dmsson Qf flQ i f 00CKE!9. 'f

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Secretary, U. S. Nuclear Regulatory Commission Attention: Docketing and Service Branch Washington, DC 20555

Subject:

Virginia Power; Petition for Rulemaking Duquesne Light Company (DLC) is submitting the following comments for consideration in response to the Nuclear Regulatory Commission's (NRC) request. A notice of receipt of petition for rulemaking dated December 30, 1993, which was filed viith the NRC by Virginia Power was published in the May 6, 1994 Federal Recister (59 FR 23641). The petitioner has requested that the NRC amend its regulations to change the frequency with which each licensee conducts independent reviews and audits of its safeguards contingency plan and security program from annually to biennially.

DLC concurs with the Virginia Power submittal. The proposed audit frequency provides a greater degree of flexibility in applying resources, thereby permitting a licensee to implement a more performance-based audit program. The resources presently used for audits of the safeguards contingency plan and security program could be reallocated, if justified by performance, to address more safety-significant concerns that might be identified.

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), prescribes a two-year audit frequency for most operational phase activities commensurate with the activity's operational safety significance. The proposed rule would be consistent with this previously defined regulatory position. The  ;

industry Systematic Assessment of Licensee Performance average rating i for the security category was 1.27 as of October 15, 1993. Clearly, this represents a commendable overall performance in this area and i supports the move to biennial audits which can be supplemented if  ;

performance warrants.  !

l Thank you for the opportunity to comment on this issue. l l

Sincerely, l l

C -

[I. D. Sieber l DEllVERING l

QUALITY ENERGY 9407220033 PDR PRM 940713 50-59 PDR l l

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