ML20044E144

Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Required Emergency Planning from Annual to Biennial

ML20044E144
Person / Time
Site:	Cook
Issue date:	05/03/1993
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR12339, RULE-PRM-50-58 58FR12339-00024, 58FR12339-24, AEP:NRC:0508X, AEP:NRC:508X, NUDOCS 9305240009
Download: ML20044E144 (2)

Text

- . . --

g ,n_

h % '" PETITION RULE PRM fO-67 Pacer Company

, F.D Box 16531 Co!uebus. OH 43216 Gf f k /2Mh luriii.D U5hhC -

sNotANA MCN#GAN-2.Y 93 W2 -5 All :10 powsn

rig ? ~ a .- 1 U.LKi'of: , ~ '

5 i

AEP:NRC:0508X l l

Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 l Lienese Nos. DPR-58 and DPR-74 i NOTICE OF RULE CHANGE ON EXERCISE DRILLS l Secretary  !

U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 Attn: Docketing and Service Branch May 3, 1993 i l

4

Dear Mr. Secretary:

l

}

Volume 58, No. 41 of the Federal Register includes a notice of i receipt of petition for rulemaking from Virginia Electric and Power Company. We are providing comments regarding the proposed j petition for rulemaking to change the frequency of required  ;

emergency planning exercises from annual to biennial. >

Ve enthusiastically support this initiative. We believe our j commitment to emergency planning will not be affected by this  !

change. Our level of attention to emergency planning at Cook  ;

Nuclear Plant has received and continues to receive strong  ;

management support. l Our present practice of holding multiple in-house drills each year will not change if the proposed rule is adopted. This includes l

five full-scale drills each year (one with each operations shift),  ;

two backshift auSmentation drills, medical drills with both  !

servicing local hospitals and ambulance company, and single-  !

facility-only drills as needed to improve performance on specific obj ectives . These drills are closely monitored by our staff who '

have been trained in observation and emergency planning. All critique items generated by these controllers are given prompt attention by the emergency planning staff.

For the most part, these drills take advantage of past scenarios that are " recycled" with alterations to challenge the players, 9305240009 930503 i

PDR 50-58 PRM PDR h

i

- l

(

a i

l

)

AEP:NRC:0508X i l

accommodate simulator upgrades or plant modifications, or address industry events of interest. This type of scenario preparation is 1 far less costly than generating completely new scenarios as l required for evaluated exercises. Labor costs necessary for Cook Nuclear Plant to prepare for and conduct this year's exercise are l expected to exceed the $200,000 estimate given in the petition. l This does not include the valuable simulator time that is '

necessary for the development of new scenario packages.

In conclusion, we believe that the elimination of the biennial  ;

utility-only NRC-evaluated exercise would not decrease the j effectiveness of the Emergency Plan or the Cook Nuclear Plant's '

ability to successfully protect the health and safety of the i public.

Sincerely, )

i E. E. Fitzpatrick Vice President eg )

i cc: A. A. Blind - Bridgman J. R. Padgett G. Charnoff

, A. B. Davis - Region III NRC Resident Inspector - Bridgman NFEM Section Chief d

1 l

. i

. t l

l i

j  !

l AEP:NRC:0508X ,

I i

i i

, be: D. H. Malin/K. J. Toth S. J. Brewer i M. L. Horvath - Bridgman

, L. G. LewisfD. R. Williams /S. L. Colvis i J. E. Rutkowski/R. S. Krieger J. B. Shinnock W. M. Dean, NRC - Washington, D.C.

U. G. Smith, Jr.

AEP:NRC:050BX '

DC-N-6015.1 i

i f

3 a

4 4

d e

l i

t

'f iu

.i

_ . . , .