ML20077R516
| ML20077R516 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 08/14/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-56FR26945, FRN-59FR30724, RULE-PRM-20-20 56FR26945-00106, 56FR26945-106, 91-463, AE41-1-108, AE41-1-109, NUDOCS 9108230117 | |
| Download: ML20077R516 (2) | |
Text
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PETITION RULE PRM N
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'G VIftGINIA POWEft Secretary, U.S. Nuclear Regulatory Commission Serial No 91-463 Attn: Docketing and Service Branch NL&P/ CAT /TAH:R1 Washington, D.C. 20555 Gentlemen:
COMMENTS ON PETITION FOR RULEMAKING 10 CFR PARTS 20 AND 35 NRC has requested public comment on a petition for rulemaking filed by Dr. Carol S.
Marcus (56FR26945). The petition requests the NRC to revise 10CFR Parts 20 and 35 to raise the annual radiation dose limit to the public from patients receiving radiopharmaceuticals, delete the requirement that NRC licensees comply with EPA's applicable environm9ntal standards in addition to those of Part 20, and amend 10CFR35.75 regarding maximum activities for radionuclides other than 1131 which is already provided. Virginia Power has the following comments on the petition.
We believe that NRC should apply consistent standards to all classes of licensees.
With regard to the proposed annual dose limit to the public, the same limit should be applied to all licensees. We concur with Dr. Marcus that the annual dose limit to the public should be set at 500 mrem. There have been no demonstrable health effects observed at chronic exposure levels at or beba tt.e current 10 CFR 20 limit of 500 mrem per year.
We also agree with the petitioner's request to delete the requirement for licensees to comply with the provisions of the EPA's applicable environmental standards in addition to complying with the requirements of Part 20 and Part 50, Appendix 1.
Existing NRC regulations have demonstrated a record of providing adequate protection to the public health and safety. The EPA further supports this record through its own review and analyses.
As stated above, we believe the NRC should apply consistent standards for all classes of licensees. Unnecessary duplication of regulation, where there is no clear benefit to the health and safety of the public, should be avoided.
If you have further questions, please contact us.
Very truly yours,
[-
M 1W W. L. Stewart 9108230117 910814 PDR PRM 20-20 PDR h Sl 0
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Serial Numbar 91463 i
pc: U. S. Nuclear Regulatory Comrtission 101 Marlena Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station Mr. M. W. Branch NRC Senior Resident inspector Surry Power Station I
l
.