DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs

Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs

ML20071H431
Person / Time
Site:	Diablo Canyon
Issue date:	06/27/1994
From:	Rueger G PACIFIC GAS & ELECTRIC CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR23641, RULE-PRM-50-59 59FR23641-00001, 59FR23641-1, DCL-94-135, NUDOCS 9407150108
Download: ML20071H431 (2)

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' Pacific Gas and Electric Company 77 Beate Spect. Raum 1451 G egary M Rueger PO Em 7MO)

San Fmano CA 94177 Genera.

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415/973'4084 hxlear Pc bb, on Far 415/9734313 DOCKET NUMBER '94 JLL -1 P4:15 June 27,1994 PETmCN RULE PRM 50-54 orritt n sumE1ARY m PG&E Letter DCL 94-135 (9%R.2.N V!) 00CKEfiR < 7ME h:&T

. Mr. Samuel J. Chilk Secretary of the Commission

$l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Viroinia Electric and Power Comoanv: Petition for Rulemakino m Safeauards Continaency Plan and Security Proaram Gentlemen:

PG&E is submitting comments in response to the notice in the Federal Register (59 FR 23641), dated May 6,1994, and invitation to comment on Virginia Electric and Power Company's (VEPCO's) petition for rulemaking to amend 10 CFR 50.54(p),10 CFR 73.55(g) and Part 73, Appendix C by changing the frequency with which each licensee conducts independent reviews of its security programs and safeguards contingency plan. PG&E supports the petition and believes that the proposed revisions to the regulations are warranted.

Power reactor licensee proficiency and effectiveness in security and-safeguards contingency planning has improved steadily to the point where annual audits no longer provide a significant benefit, let alone a benefit commensurate with the cost in dollars and diverted resources. PG&E agrees with VEPCO that a biennial audit frequency would more than adequately provide the requisite feedback and assurance regarding the effectiveness of licensee safeguards contingency plans and security programs. Furthermore, adequate safeguards exist to ensure that changing the audit frequency to two years will have no adverse impact on implementation of nuclear security programs and contingency plans.

PG&E also agrees with VEPCO that an annual audit frequency is not necessary to ensure an adequate safeguards plan and security program, nor is it commensurate with present industry performance and enhancements in this area. Biennial audits would allow licensees to concentrate available audit PDR PRM 3 50-59 PDR

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e Mr. Samuel J. Chilk June 27,1994 PG&E Letter DCL-94-135 resources in areas of observed weakness based on performance. Because the costs associated with the annual audit requirements are not commensurate with the safety benefits, amending the existing regulations to permit biennial audits could provide a net safety benefit.

Sincerely,

'No %r Gregory M. Rueger cc: L. J. Callan Mary H. Miller Kenneth E. Perkins Sheri R. Peterson Diablo Distribution 6492S/EMG/1438

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