ML20147E694
| ML20147E694 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/15/1988 |
| From: | Passwater A UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FRN-52FR41442 AB43-2-122, AB43-2-124, ULNRC-1708, NUDOCS 8801210201 | |
| Download: ML20147E694 (3) | |
Text
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.se Etscrmc n
January 15, 1988 DonMd F. Schnell Vce Pr>sident U.S.
Nuclear Reg;,6atory Commission ATTN:
Document Contrcl Desk Washington, D.C.
20555 Gentlemen:
ULNRC-1708 DOCKET NO. 50-483 CALLAWAY PLANT PROPOSED CHANGE TO RETENTION PERIODS FOR RECORDS Referencei Federal Register, Vol. 52, No. 208, Pages 41442-41462, dated October 28, 1987 The referenced Federal Register proposed a change in retention periods for records maintained at Nuclear Power Plantn.
Union Electric has reviewed the proposed changes and offers the following comments.
10CFR50 Sec+ ion 31.12 and Part 73.70 require the storage of either an origin il record or an authenticated copy.
These sections should be reviced to include discussion on how to acceptably authenticate a record.
Par t 73.70 (d') requires that the reason for any entry into a normally unoccupied vital area be listed and maintained for three years.
This requirement was previously deleted in August 1987 and should not be reintroduced into this section.
Part 73.70 (f) states that "A record at each on-site alarm annunciation location of each alarm, false alarm, alarm check, and tamper indication that identifies the type of alarm, location, alarm circuit, date and time.
In addition, details of response by facility guards and watchmen to each alarm, intrusion, or other security incident chall be recorded.
The l
Licensee shall retain each record for three years after the record is made.
This section requires that these records be l
retained at two locations, the CAS and SAS, for three years.
This section should be revised to leave the storage location of these records to the discretion of the Licensee.
Part 73, Appendix B (c) requires that a physical test be l
performed within thirty days of a physical 3xamination.
This requirement was previously deleted in August 1987 and iso basis i
exists to reintroduce this requirement at this time.
l l
The proposed change as written would require the storage of j
most Security Department records, procedures, plans, etc. for a g
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This would incur additional costs associated s ith obtaining storage f acilities for these records.
The current storage requirements allow adequate time for inspections to take place without the encumbrance of maintaining historical records.
In conclusion, Union Electric opposes the changes to the retention period for Security Department records.
Incorporation of the proposed rule would add burden to Licensees without any benefit.
Very truly yours, I
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M A. C. Passwater WEK/ mat
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Gerald Charnoff,-Esq.
Shaw, Pittman, Potts & Trowbridge
- 2300 N. Stree t, N.W.
Washington, D.C.
20037 Dr. J. O. Cermak'
- CF1, Inc.
4 Professional Drive (3uite 110)
- Gaithersburg, MD 20879 W. L. Forney Chief, Reactor Project Branch 1 U.S.' Nuclear Regulatory Commission Region'III 799 Roosevelt Road '
- Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory. Commission RR$1 Steedman, Missouri 65077 Tom Alexion (2)
Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission l
Mail Stop 316 7920 Norfolk Avenue
- Bethesda, MD 20014 Manager, Electric Depar tment Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 t
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