ML20071N486

Comment Supporting Petition for Rulemaking PRM-50-59 Re Changing 10CFR50 & 73 for Frequency W/Which Licensee Conduct Independent Reviews & Audits of Safeguards Contingency Plan & Security Program from Every 12 Months to Every 24 Months

ML20071N486
Person / Time
Site:	Clinton
Issue date:	07/21/1994
From:	Phares R ILLINOIS POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR23641, RULE-PRM-50-59 59FR23641-00006, 59FR23641-6, 8G.120, L10-94(07-21)LP, L10-94(7-21)LP, U602315, NUDOCS 9408080012
Download: ML20071N486 (2)

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Ilknois Pow Company 00CXE1EL. canton eom sianon 6

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Chnton. IL 61727 Tel 217 935-8881 ILLIN915

'94 a 25 P243,pms P(u M R uo.94(o7 - 21 >te 8G.120 July 21, 1994 Off 6 '

' M is Tf Docket No. 50-461 00CKE? a r lf'

'E itu id.:,4 Secretary U.S. Nuclear Regulatory Commission Attention: Docketing and Service Branch Washington, D C. 20555

Subject:

Illinois Power's Concurrence with Virginia Powrr's Filing of Petitino for Rulejnakin.g I

Dear Sir:

j As discussed in the Federal Register, Vo me 59, No. 87, Pages 23641 and 23642, Virginia Power (VP) submitted a filing of petition for rulemaking. This petition requested that the Commission amend its regulations to change 10 CFR Parts 50 and 73 for the frequency with which each licensee conducts independent reviews and audits ofits safeguards contingency plan and security programs from at least every 12 months (annually) to nominally every 24 months (biennially). Illinois Power (IP) agrees with VP's conclusion that an annual review is not necessary to ensure an adequate safeguards contingency plan and security program, and that it is not appropriate considering the high standard ofindustry performance in this area During the last three years, the IP Nuclear Assessment Department has issued only one audit finding in the area of security. The change from annual to biennialindependent reviews would allow more time for more urgent tasks that may not be required by regulations. The frequency of audits and reviews can always be increased if warranted by indications of declining performance, management requests, or significant program changes.

The filing of petition for rulemaking should be considered. IP supports their petition and believes that this is a valid cost beneficial licensing action (CBLA). This CBLA does not decrease the safe operation of a facility, but would increase a plant's safe operation as more resources could be applied to are..s.vhich could need additional attention.

Sincerely yours, l

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Richard Phares Director, Licensing JSP/csm jb 9408000012 940721 l

PDR PRM 50-59 PDR

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NRC Clinton Licensing Project Manager NRC Resident Omce, V-690 i

Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety Donald M. Olson, Virginia Power Company b

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