ML19305E640

Comments on Proposed Rule 10CFR20:recommends That NRC Review Need for Data Contained in Reg Guide 1.16,Revison 4 & Reg Guide 10.1 W/Thought of Reducing Amount of Data Required

ML19305E640
Person / Time
Site:	Monticello
Issue date:	04/17/1980
From:	Mayer L NORTHERN STATES POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-45FR18023, RULE-PR-20 NUDOCS 8005200153
Download: ML19305E640 (2)

Text

h...- TC 8005200 g NSP NORTHERN STATES POWER COMPANY M I N N E A PO Li s. M I N N E G OTA 55401 9(E$ET KUldED n m

&n YSEFg/fd20 -(K-/ o" April 17, 1980 Secretary of the Commission US Nuclear. Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch O.)

MONTICELLO NUCLEAR GENERATING PMNT Docket No. 50-263 License No. DPR-22 -

% i PRAIRIE ISLAND NUCLEAR GENERATING PLANT h APR 2 4 > m -

Docket Nos. 50-282 License Nos. DPR-42

' N Ieustuy h 50-306 DPR-60 N

.p, Comments on Prspeaed Rulemaking g ,

10 CFR 20, Standards for Protection Against Radiation Advance notice of proposed rulemaking under 10 Part CFR 20, Standards for Protec-tion Against Radiation, was published in the Federal Register dated March 20, 1980.

Comments on the proposed rulemaking were solicit.d. NSP, as an operating reactor licensee, has been subjected to ever-expanding reporting requirements by the NRC, although in a few instances in recent years the NRC has made revisions which eliminated some unneeded reporting and has consolidated a few other reporting requirements. We of fer for consideration a consolidation and simplification of occupational exposure reporting requirements.

10 CFR 20.407 requires the submittal, within the first quarter of each calendar l year, of a personnel monitoring report to the Director of Management and Program Analysis. Nuclear plant technical specifications usually require the submittal of an annual report on occupational exposure covering the previous calendar year and which is to be submitted prior to March 1 of each year. Guidance for the content of this report is contained in NRC Regulatory Guide 1.16, Revision 4, and it is to I

be submitted to the NRC IE Regional Of fice (2 copies) and the Director, IE, (40

! copies) in accordance with NRC Regulatory Guide 10.1.

h We suggest that the NRC review the needs for the data contained in these two f

reports with the thought of reducing the amount of data required, and combine the I resultant needed data into one annual report with one primary NRC addressee and a L

substantially reduced number of copies. If the regulation as revised contains a requirement for a report which substituter for the-report currently required by s#

'l .

.- -y. ,

NORTHERN CTATED POWER COMPANY Secretary of the Commission April 17, 1980 Page i i

technical specifications, the NRC can issue amendments removing this requirement from the technical specifications. 'Ihis would be similar to the removal of the respiratory protection requirements from technical specifications af ter they had been included in the 10 CFR Part 20 regulations.

a' o .

L 0 Mayer, PE Manager of Nuclear Support Services 1

LOM/jh cc G Charnoff Monticello Nuclear Plant Prairie Island Nuclear Plant 6

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