ML20071H076

Comment Supporting Petition for Rulemaking PRM-50-60 Which Requested That NRC Change Frequency That License Conducts Independent Reviews of Emergency Preparedness Program from Annually to Biannually

ML20071H076
Person / Time
Site:	Seabrook
Issue date:	06/29/1994
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR17499, RULE-PRM-50-60 59FR17499-00017, 59FR17499-17, NYN-94072, NUDOCS 9407140001
Download: ML20071H076 (2)

Text

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j k;[ON RULE.. PRM JC Y g j -

% (59 FR 17'I99)-

j NOrfh occKEIED- North Atlantic Energy Service Corporation

-USHRC r.o. nor a m Atlantic

$g Seabrook, NIf 03874 t i r (603)474KG1. Fax (603)474-2987 .

'94 JUL -5 AE Z5 The Northea.: utilities system Ted C. Feigenbaum 0FFICLP -1"t -, e pv NYN- 94072 00CKEiW "

• *g senior vice pre.iaen a Chief Nuclear Officer June 29,1994 X~ W Secretary of the Commission United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch

Subject:

Virginia Power; Filing of Petition for Rulemaking, Docket No. PRM-50-60 Gentlemen:

On April 13,1994 a Petition k ,ulemaking Oled by Virginia Power was noticed in the Federal Register (59 FR 17499). That petition requested that the NRC change the frequency that a licensee conducts independent reviews ofits emergency preparedn:ss program from annually to biennially. North Atlantic Energy Service Corporation (North Atlantic), operator of Seabrook Station Unit 1, endorses the subject _ proposed rule change and agrees with the reasons cited in the petition.

Overall industry performance to date indicates eiTective implementation of emergency preparedness

- programs. Given this demonstrated level of performance and the existence of other regulatory oversight methods, a biennial indepeedent review of the emergency preparedness program would be sufGeient .to verify continued program effectiveness. A hiennial audit schedule would allow licensees to have increased Hexibility in concentrating available audit resources in areas of observed weakness based on performance, rather than conducting a mandatory annual audit of marginal safety significance.

_ North Atlantic also supports the proposal that the independent audit be conducted in alternating

. years with the onsite emergency preparedness exercise, and as such would integrate well with another Virginia Power petition for rulemaking that requests a change in onsite exercise frequency from annual to biennial (58 FR 12339). The alternating schedule for exercises and audits would provide for an annual review of the performance of the emergency preparedness program.

-if' you have any questions concerning these comments, please contact Mr. Anthony M4

. Callendrello, Licensing Manager, at (603) 474-9521, extension 2751.

Very truly yours.

W/#

T. C. Feigenbauni TCF:AMC/sm 9407140001 940629

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United States Nuclear Regulatory Commission June 29,1994 Attention: Docketing and Service Branch Page two ec: Mr. Thomas T. Martin Regional Administrator (Jnited States Nuclear Regulatory Commission Region i 475 Allendale Road King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate 1-4 Divisior of Reactor Projects  !

U.S. Nuclear Regulatory Commission l Washington, DC 20555  ;

Mr. Antone C, Cerne NRC Senior Resident inspector P.O. Box 1149 Seabrook, Nil 03874 Nuclear Energy Institute 1776 i Street Suite 400 Washington, DC 20006-3708