ML20039D239
| ML20039D239 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/24/1981 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20039D240 | List: |
| References | |
| FRN-45FR55271, FRN-46FR55271, RTR-REGGD-08.015, RTR-REGGD-8.015, RULE-PR-20 45FR55271, NUDOCS 8112310450 | |
| Download: ML20039D239 (2) | |
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Secretary of the Nuclear Regulatory Commission 9
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Docketing and Service Branch Washington, DC 20555 gg
Dear Sir:
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TROJAN NUCLEAR PLANT A
g Comments on Proposed Replacement of Provisions of Regulatory Guide 8.15, Incorporated by Reference in 10 CFR 20.103 NRC Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection",
contains provisions which require an annual review of the medical status of each user by a physician.
A subsequent letter from Robert B. Minogue, Director, Office of Standards Development for the Nuclear Regulatory Commission, dated March 14, 1978 stated that the NRC did not require a physical examination of each respirator user annually; only a review of each user's medical status.
The NRC has proposed that Regulatory Guide 8.15 be incorporated into 10 CFR 20.103. However, the proposed rule does not include the clarifica-tion of the March 14, 1978 letter stating that physical examinations were not necessari3y required in the annual review of medical status.
The proposed rule in its present form would result in significant cost to utilities when annual status reviews by physicians without required physical examinations as outlined in the March 14, 1978 letter would be adequate.
For this reason, Portland General Electric Company believes that the comments of Mr. Min'ogue's letter should be incorporated in the final form of the rule. This could be accomplished by the following addition to the end of Paragraph C.2:
" Physical examinations would not necessarily be Q$0$
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.s Portland General Electric Coirvenly Secretary of the Nuclear Regulatory Commission j
December 24, 1981 Page two i
i required as a part of the annual medical status review".
I hope that these comments will be of use in formulating the final rule.
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I Sincerely, j
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^_,f Bart D. Withers f
Vice President l
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