ML20077F734
| ML20077F734 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/10/1994 |
| From: | George Thomas DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR47565, FRN-60FR7900, RULE-PR-20 59FR47565-00006, 59FR47565-6, AF08-2-007, AF8-2, AF8-2-7, NUDOCS 9412150037 | |
| Download: ML20077F734 (2) | |
Text
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D0v eiNUMBER a
PROPOSED RULE N 10' b.
DuquBSnB @ Company Bag'vapy Power Smaon C 9 F F //7545) DOCKETED
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.USNRC (412) 643-8069 FAX
GEORGE S. THOM AS U." se'n*, e's" *"
November 10, 1994 0FFICE C' s_tC9,..J,. -
weiear eo.., oivision 00CKEipp.L1 M Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555
. Attention:
Docketing and Service Branch
Subject:
10 CFR Part 20, Frequency of Medical Examinations for Use of Respiratory Protection Equipment
~
Duquesne Light Company (DLC) is responsible for the operation of
. Beaver Valley Power Station Units 1 and 2.
DLC is submitting the following comments for consideration. in response to the Nuclear Regulatory. Commission's (NRC) issuance of a proposed rule which was published in the September 16, 1994 Federal Reaister (59 FR 47565).
The. NRC proposes to amend its regulations concerning the frequency at which medical examinations are required to ensure.the safe use of respiratory protection equipment..
Section 10 CFR 20.1703 (a) (3) (v) currently requires the determination by a physician prior to initial fitting of respirators, and at least every 12 months thereafter, that the individual user is physically able to use the respiratory protection equipment.
The proposed revision would require determination by a physician prior to initial fitting of respirators and either every 12 months thereafter or periodically at a frequency determined by a physician, that the individual user is medically fit to use the respiratory protection equipment.
DLC supports the continued practice of requiring a
medical determination prior to initial fitting of respirators.
This is especially important for incoming workers for which there is no familiarity of past medical history.
On
- occasion, workers are restricted from all respirator use based upon evaluation.of their incoming medical determination.
If regulations were changed to permit. fit testing prior to this medical evaluation, these workers could be put at risk.
Because of the vast differences-in respirator usage (e.g., type of respirator, frequency of use, environmental conditions), DLC feels that the frequency of medical examinations is best determined by.the examining physician, with guidance from American. National Standards i
Institute.
Therefore, DLC is in favor of changing the frequency of reexamination to "either every 12 months thereafter or periodically at a frequency determined by a physician," as proposed.
9412150037 9411IPDR l
QR 47565 59 3blD
'10'CFR Part 20, Frequ ncy of M dic21 EXEnin2tions for Use of Respiratory Protection Equipment Page 2 DLC is aware'of no technical reasons why the. frequency of medical examinations should not be reduced.
A reduction will likely reduce costs and permit greater flexibility, with no significant health risk
-to the worker.
Thank you for the opportunity to comment on this issue.
Sincerely, George S. Thomas b