NPL-95-0321, Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)

Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)

ML20086M799
Person / Time
Site:	Point Beach
Issue date:	07/11/1995
From:	Krieser G WISCONSIN ELECTRIC POWER CO.
To:	NRC
References
FRN-60FR31326 60FR31326-00004, 60FR31326-4, NPL-95-0321, NPL-95-321, NUDOCS 9507250004
Download: ML20086M799 (2)

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U d. .n L el July 11, 1995 l NPL 95-0321 Chief, Rules Review and Directives Branch U.S. NUCLEAR REGULATORY COMMISSION Washington, DC 20555 PROPOSED GENERIC COMMUNICATION; 10 CFR 50.54(n)

PROCESS FOR CHANGES TO SECURITY PLANS WITHOUT PRIOR NRC APPROVAL WISCONSIN ELECTRIC POWER COMPANY COMMENTS Wisconsin Electric Power Company is pleased to submit the following comments in response to the Federal Register notice (June 14, 1995, 60 Fed. Reg. 31326) of opportunity for public comment on the proposed generic letter clarifying the process by which licensees can make changes to security plans without prior NRC approval.

Wisconsin Electric endorses the NRC's proposed clarification of the l language in 10 CFR 50.54(p) and commends the NRC for initiating this action. It is clear that resource savings can result from the  !

elimination of security plan commitments that are no longer considered of value relative to their cost and are in excess of current regulatory requirements.

While Wisconsin Electric concurs with the intent of the proposed generic letter, we believe that one element within the screening criteria may be problematic. Question number one addresses the concern of whether the proposed security plan revision will still meet the regulatory requirement. Question number two addresses the question of whether the revised security plan can defend the facility against a design basis threat. Both of these questions are appropriate and clear. Question number three, however, has the potential to burden the industry unnecessarily and should not be included in the generic letter.

The purpose of the proposed generic letter is to reduce the burden on utilities created by overcommitments. Question number three asks, " Does this change any unique site-specific commitments?"

Some of the desired plan changes could alter a site-specific commitment and, therefor, require a " yes" response to question three even though the proposed change may not decrease the licensees' ability to defend the facility or meet regulatory requirements. It is clear in the proposed generic letter that a

" yes" response to any of the three questions means that the 1

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proposed change can not be processed as a 10 CFR 50.54(p) change.

This would cause the licensee to pursue the change under the more burdensome 10 CFR 50.90 rule. Question number three of the screening criteria'would, in many cases, defeat the purpose of the proposed generic letter. Wisconsin Electric recommends that either question number three be deleted from the screening criteria or that the generic letter wording be changed such that answering

" yes" to question number three does not disallow the proposed change under 10 CFR 50.54(p).

Wisconsin Electric appreciates the opportunity to review the proposed generic letter clarifying the process for making security plan changes without prior NRC approval. If you have any questions regarding our comments, please contact Ms. Joan McCullum, Supervisor, Security at (414) 755-6373.

Sincerely,  ;

l Gary M Krieser Manage Industry and Regulatory Services i

DLB/kmc cc: Rich Enkeboll - NEI '

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