ML20101B993

Comment Opposing Proposed Rule 10CFR20 Re Reporting Requirements for Unauthorized Use of Licensed Radioactive Matls

ML20101B993
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 61FR3334-00044, 61FR3334-44, BECO-#96-020, BECO-#96-20, NUDOCS 9603150192
Download: ML20101B993 (2)

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C m;, em Pilgorn Nuclear Power Staton Plymouth, as hu e ts 02360 96 NG 12 K.C :51 1 OfflCi . . M m i< ,

DOCKL .' c E R W. ,

~ m E. T. Boulette, PhD Seruor Voce President - Nuclear March 1, 1996  !

BECo Ltr. #96-020 I

Secretary, U.S. Nuclear Regulatory Commission DOCKETNtW8ERan x Washington, DC 20555-0001 PROPOSED RULE TR ao UolR35Sh 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 byel 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 the health and safety of the workers at a licensee's facility or to the general public.

• Due to the broad scope of events that could fall under the proposed rule, the specific associated violation and penalties (Severity Level lll 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

" prompt assurance that tho licensee is taking the appropriate actions to assess the situation and to take thr, necessary steps to reduce any likelihood that further exposures would occur" is redundant t.nd unnecessary, e The estimated costs to licensees is seriously underestimated. For potentially reportable events, adtlitional document preparation and intemal 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 />.

9603150192 960301 PDR PR 20 61FR3334 POR 1

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= U.S. Nucirr Regul tory Commission Page 2 Should you require further information conceming these comments, please contact Ms. Susan Landahl at (508) 830-8497.

-a 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 - t/11 Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1 White Flint North -

11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station