RS-04-059, Comment (8) Submitted by Exelon Generation, LLC and Amergen Energy Co., Kenneth A. Ainger, on Proposed Rules PR-19, 20 and 50, Re Collection, Reporting or Posting of Information; Availability of Draft Rule Language
| ML041330389 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Byron, Braidwood, Limerick, Quad Cities, Zion, LaSalle  (DPR-002, DPR-012, DPR-019, DPR-025, DPR-029, DPR-030, DPR-039, DPR-044, DPR-048, DPR-056, NPF-011, NPF-018, NPF-037, NPF-039, NPF-072, NPF-077, NPF-085) |
| Issue date: | 04/09/2004 |
| From: | Ainger K AmerGen Energy Co, Exelon Generation Co |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, -RFPFR, 69FR08350 00008, PR-19, PR-20, PR-50, RS-04-059 | |
| Download: ML041330389 (2) | |
Text
ArnerGenS Exekrn.
An Exelon Company AmerGen Energy Company, LLC 4300 Winfield Road Warnenville, IL 60555 RS-04-059 www.exeloncorp.com PROPOSED RuLIt1 (6qF9R o 50)
Nuclear Exelon Generation 4300 Winfield Road Warrenville, IL 60555 DOCKETED USNRC April 9, 2004 May 11,2004 (11:27AM)
Secretary U.S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Staff Washington, DC 20555-0001 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF
Subject:
Reference:
Comments on Collection, Reporting, or Posting of Information; Availability of Draft Rule Language Letter from Ralph L. Andersen (Nuclear Energy Institute) to U.S. NRC, "Comments on 'Collection, Reporting, or Posting of Information; Availability of Draft Rule Language,'" dated April 8, 2004 Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) appreciate the opportunity to provide comments on the draft rule language for collection, reporting, or posting of information noticed in the Federal Register on February 24, 2004 (69 FR 8350). We endorse the comments provided by the Nuclear Energy Institute in the referenced letter, which support the intent of the proposed changes. EGC's and AmerGen's comments are provided below.
Notifications and reports to individuals (10 CFR 19.13 and 20.2205)
EGC and AmerGen consider that the draft rule language appropriately balances avoiding burdensome requirements while ensuring workers have access to their occupational exposure information. The estimated cost savings are approximately $5,000 per site per year in administrative, supplies and management time with a total estimated savings of $85,000 to
$125,000 for the EGC and AmerGen fleet and would not require significant costs to implement.
Labeling containers (10 CFR 20.1904 and 10 CFR 20.1905)
The draft rule language under consideration will provide adequate controls for radioactive materials stored in containers within facilities licensed under 10 CFR 50. The proposed change w4ould be a savings of approximately $25,000 per year to a licensee due to a reduction in the utilization of radioactive material labels and the additional staff required to ensure staging areas within the radiological controlled area have appropriate labels.
1rprn(4Jec SECY-667
April 9, 2004 U.S. Nuclear Regulatory Commission Page 2 Determination of prior occupational dose (10 CFR 20.2104)
EGC and AmerGen consider that adequate protection of radiation workers will be provided by annual occupational dose limits that do not require determination of prior occupational dose.
The changes proposed would not inhibit or degrade the ability to obtain individual dose records.
Definitiohs (10 CFR 20.1003)
The proposed definition change is consistent with the technical basis of the current regulations and clarifies the existing guidance provided in Regulatory Issue Summary 2003-04, "Use of the Effective Dose Equivalent in place of the Deep Dose Equivalent in Dose Assessments."
EGC and AmerGen consider that when incorporated into NRC regulations, the proposed changes will reduce unnecessary regulatory burden while maintaining an adequate level of protection of health and safety.
Please contact Alison Mackellar at 630 657-2817 regarding any questions about this letter.
Respectfully, Kenneth A. Ainger Manager - Licensing