ML20216C193
| ML20216C193 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/28/1997 |
| From: | Gambhir S OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| LIC-97-0136, LIC-97-136, NUDOCS 9709080240 | |
| Download: ML20216C193 (2) | |
Text
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Omaha Public PowerDistrict 444 South 16th Street Mall Omaha NE 68102-2247 August 28, 1997 LIC 97 0136 Secretary V
S. Nuclear Regulatory Comission Attn: Docketing and Service Branch Washington, D.C.
20555-0001
References:
1.
Docket No. 50-285 2.
Federal Register Volume 62 dated July 31, 1997 (62 FR 40978)
Subject:
Comments on Proposed Rulemaking Regarding Frequency of Reviews and Audits for Emergency Preparedness Programs, Safeguards Contingency Plans, and Security Programs for Nuclear Power Reactors The Omaha Public Power District (0 PPD) has reviewed the subject proposed rulemaking.
OPPD generally supports the proposed rule to extend the review frequency from 12 to 24 months. However, OPPD has two concerns which need to be addressed in the final regulation.
The proposed rule would require that a licensee assess performance indicators to determine if more frequent reviews are necessary. Without accepted industry or NRC defined performance measures, the rule will only create inconsistency in both operational and enforcement applications. To ensure consistent practice throughout the industry. OPPD recommends that performance standards or measurements be well defined and approved in industry guidelines.
The proposed rule also would require that the frequency of review be altered after a "significant change occurs in personnel, procedures, equipment, or facilities." Again, there is insufficient definition of what constitutes a "significant change." This will result in more confusion and inconsistent application. OPPD recomends that this requirement be eliminated from the rule in its entirety. If a program 15 objectively evaluated to a set of standard performance indicators, those predictors will certainly
\\Q signal when a more frequent review is required. If this statement must be retained to satisfy the comments of the two states which comented on the proposed rule earlier, the rule should be reworded to clearly note that the frequency should be altered only after the licensee reaches a decision that a "significant change" has occurred.
9709080240 970828 PDR ADOCK 05000285 P
PDR j
45 5124 Enployment with Equal Opportunity
Secretary U,' S. Nuclear Regulatory Comission LIC-97-0136 Page 2 Please contact me if you have any questions.
Sincerely, S. K. Gambhir Division Manager Engineering & Operations Support SKG/mah c:
Winston & Strawn E. W. Merschoff, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector Document Control Desk