ML20100M525
| ML20100M525 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/01/1996 |
| From: | Boulette E BOSTON EDISON CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-61FR3334, RULE-PR-20 61FR3334-00032, 61FR3334-32, 96-020, 96-20, NUDOCS 9603050390 | |
| Download: ML20100M525 (2) | |
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l Boston Edison Pilgorn Nuclear Power Station Rocky Hill Road 3 R-d k}j j 8 Plymouth, Massachusetts 02360 L
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E. T. Boulette, PhD DOCKET NUMBER Senior Vice President - Nuclear
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March 1, 1996
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Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Docketing and Service Branch Docket No. 50-293 License No. DPR-35 COMMENTS ON PROPOSED RULE 61FR3334 Pilgrim Nuclear Power Station (PNPS) has reviewed the NRC's proposed rule " Reporting Requirements for Unauthorized Use of Licensed Radioactive Materials" noticed for comment in 61FR3334 of January 31,1996. The following are Pilgrim's comments on the proposed rule:
The proposed rule change wording conceming what conditions must be met to require reporting is inexact. The level of situations of intentional or allegedly intentional diversion of radioactive material from its intended or authorized use is broad and could potentially result in unnecessary reporting of events that have little or no risk to t:a E ualth and safety of the workers at a licensee's facility or to the general public.
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. Due to the broad scope of events that could fall under the proposed rule, the specific e
associated violation and penalties (Severity Level lli and assessment of civil penalties) are not appropriate.
The proposed " appropriate corrective actions" listed are those normally taken by licensees in an event under investigation; therefore, the stated basis for notifying the NRC to ensure i
" prompt assurance that the licensee is taking the appropriate actions to assess the situation and to take the necessary steps to reduce any likelihood that further exposures would occur" is redundant and unnecessary.
The estimated costs to licensees is seriously underestimated. For potentially reportable events, additional document preparation and internal reviews are expected to add up to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.
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i n U.S. Nucle:r Regul: tory Commission Page 2 Should you require further information conceming these comments, please contact Ms. Susan Landahl at (508) 830-8497.
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n E. T. Boulette, PhD ETB/PMK/dmc/ Rap 96/radmat cc:
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Mr. R. Eaton, Project Manager Division of Reactor Projects - 1/11 Mail Stop: 1401 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region i 475 Allendale Road King of Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station i
.