ML20217J750

Comment Supporting Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for EP Programs,Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors

ML20217J750
Person / Time
Site:	Calvert Cliffs
Issue date:	09/24/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR40978, RULE-PR-50, RULE-PR-73 62FR40978-00004, 62FR40978-4, NUDOCS 9710210272
Download: ML20217J750 (2)

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On at I h ll. Out he 00CKETED nainn.me oas ana iacunc Conman3 O Vice President USNf:C Cah en ridh Nutice l'a er l'iani Nutlear I:ncrp) M'5n Cah en Cidh Pakw a) t.usby , Maryland Mi57 4'" *^-4455 W SEP 29 PS :10 Or < . '-

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September 24,1997

U. S. Nuclear Regulatory Commission Washington, DC 20555 A'ITENTION

Secretary,itutemakings and Adjudications Staff SUILIECT: Cah ert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & 50 318 Comments on Proposed Amendment to 10 CFR Parts 50 and 73 Rules on Frequency of Reviews and Audits for Emergency Preparedness Programs, Safeguards Contingency Plans, and Security Programs For Nuclear Power Reactors (62 FR 40978) _

llattimore Gas and Electriv Company is pleased to provide comments on the subject proposed amendment to 10 CFR Parts 50 and 73 rules. ~lhe proposed amendment covers rules on the emerger;cy preparedness programs, safeguards :ont gency plans, and security programs. The Nuclear Regulatory Commission staff proposes to revise the regulations to:

" require that licensees conductfocused program reviews and audits as needed, based on an assessment by the licen'ee against perforntance indicators or in response to a sigmjicant change in personnel, procedures, eqs ipment, orfacilities, and that all program elements are reviewed and audited at least every 24 months "

We fully endorse the proposed amendment to the rules for the following reasons:

1. Since the original rules were implemented, Baltimore Gas and Electiic Company's performance demonstrates that annual program reviews and audits are not a necessary or efficient use of our (

resources. Ilattimore Gas and Electric Company's internal assessments and the systematic assessment oflicensee performance (sal P) evaluations support this conclusion.

2. The propoud amendment would provide increased Oexibility to better allocate resources and would allow more concurrent scheduling with activities such as drills, exercises, inspections, or operational activities to permit a better review and evaluation of the Emergency Planning and g Security Programs. .

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• September 24,1997 Page 2

3. Ilaltimore Gas and Electric Company's current performance-based assessment approach provides for ongoing assessment of the Emergency Planning and Security Programs, which provides us assurance that performance problems will continue to be identified and corrected in a timely manner.

We have reviewed the comments by Nt. clear Energy Institute and endorse them for future rulemaking.

We panicuhrly support Nue: car Energy institute's suggestion that mandating a maximum frequency is unnecessary under a performance-based program.

The notice also requests comments on suggested performance indicators. Saltimore Gas and Electric Company feels that each utility should be allowed to develop indicators based on their own corrective action programs and industry benchmarks.

We appreciate the opportunity to comment on the generic letter We feel that this proposed rule change will ensure that programmatic problems will continue to be detected and corrected on a timely basis.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

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for C.11. Cruse Vice President - Nuclear Energy CliC/SJR/bjd cc. Document Control Desk, NRC 11. J. Miller, NRC R. S. Fleishman, Esquire Resident inspector,NRC J. E. Silberg, Esquire R.1. McLean, DNR Director, Project Directorate 1 1, NRC J 11. Walter, PSC A. W. Dromerick, NRC