ML20199C272
| ML20199C272 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 10/27/1997 |
| From: | Richard Anderson NORTHERN STATES POWER CO. |
| To: | Frattali S, Hoyle J NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES), NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-62FR40978, RULE-PR-50, RULE-PR-73 62FR40978-00010, 62FR40978-10, NUDOCS 9711190284 | |
| Download: ML20199C272 (2) | |
Text
1 Af/
000KETE0 worthem states Power Company USNRC W EV -7 P2 00 gCRgRY October 27,1997 OFF C R
ADJUD!CMlONS STAFF DOCKET NUMBER Mr. John C. Hoy's PROPOSED RULE PR so ns Secretary U.S. Nuclear Regulatory Commission (V2F#40f7g)
Washington, D.C. 20555-0001 Docket No. 50-263,50-282, and 50-306 Attention:
Ms. Sandra D. Frattali Office of Nuclear Regulatory Research of the NRC Ref: 62 FR 40978 i
Subject:
The NRC's invitation for comments on proposed amendments to NRC Requirements for Emergency Preparedness and Security,10 CFR 50.54, 10 CFR Part 73, (62 Fed. Reg 40978, July 31,1997).
Dear Ms. Frattali:
As requested ir. the Federal Register notice of July 31,1997 (62 Fed.
Reg. 40978), enclosed are NSP's comments on 10 CFR 50.54, 10 CFR Part 73.
Northem States Power (NSP) submitted comments electronically to you on Tuesday, October 14,1997, and this letter serves as a followup copy of those comments, per your suggestion.
NSP has carefully reviewed the above referenced proposed amendments. We have also examined a draft copy of industry comments fonnarded to us by the Nuclear Energy Institute (NEI).
Cons'dering our review of the information provided to us, we have the U
following comments and concerns.
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9 Mr. John C. Hoyl]
Page 2 October 27,' 1997 1.
We believe the NRC's basis for making this rule change is sound.
We agree that current review and audit frequencies are inconsistent with recent regulatory trends. Performance-based testing focusing attention on action to correct demonstrated weaknesses is of significantly greater impodance than schedule driven needs.
2.
We concur with the NEl's content;vl that mandating maximum audit periodicity is unnecessary. Nonetheless, if it is determined that maximum audit periodicity is required, it would be more appropriate for such periodicity to be defined in an industry consensus standard, or an industry guidance document.
3.
We are in agreement with the NRC's proposed amendment language that will require reports be kept at the plants, maintained in auditable form, and available for inspection for a period of 3 years.
4.
We encourage the NRC to publish a regulatory guide to better clarify the meaning of some of the terminology used (e.g.,"as soon as reasonably practicable" and what constitutes "significant change").
Please contact Doug Blakesley (612-330-2896)if you have any questions related to these comments.
Sincerely, h
W tytt Roger O. Anderson Director, Nuclear Energy Engineering Capartment Northern States Power Company
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