ML20101F664

Comment Supporting Proposed Rules 10CFR19 & 20 Re Proposed Rule to Extend Implementation of New 10CFR20

ML20101F664
Person / Time
Site:	Nine Mile Point
Issue date:	06/11/1992
From:	Sylvia B NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-57FR21216, FRN-57FR38588, RULE-PR-19, RULE-PR-20 57FR21216-00006, 57FR21216-6, AE21-2-015, AE21-2-15, NMP87206, NUDOCS 9206250072
Download: ML20101F664 (2)

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NIAQARA MCMWK POWER CORPORATION 'NINE Mit E ro.N" '30 Dox 63. LYCOf6N1 N r 039 UbMR0 HONE (36) 349-2M2 B ROph $yNia Il%7"" "'"*"

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Secretary United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Do.keting and Servicing Branch

SUBJECT:

Comments on Proposed Rule to Extend Implementation of the New 10CFR20

Dear Sir:

This letter provides the Niagara Mohawk Power Corporation comments on the proposed rule to extend the implementation date of the revised 10CFR Part 20, " Standards of Protection Against Radiation," as noted in the Federal Register of May 1992 (57 Fed. Reg. 21216).

Niagara Mohawk supports adoption of the proposed rule by the NRC. We believe that changing the required implementation date to January 1,1994 will result in a more of fective and of ficient implementation of the revised Part 20. The proposed date provides the necessary time for alllicensees to review the new and revised regulatory guides to clarify key points of the revised Part 20. The proposed dato changt ylill also allow for-more consistency between NRC licensed f acilities and those of Agreement Sttos than would have resulted with the existing one year difference in implementation dates. The-proposed extension will allow the Nine Mile Foint Nuclear Station (and other licensees) to better allocate resources to implement the new requirements, while maintaining current functions to protect public and worker safety.

Our support for the January 1,1994 implementation date is based on the current status of supporting regulatory activities, it is our understanding that all regulatory guides will be issued prior to the end of this year. Furth?t, additional guidance regardint,. the preparation and submittal of proposed operating license amendments needed toimplement the revised Part 20 will be issued within the next few months. Any delays in these actions would diminish the advantages outlined above.

We believe that current radiation protection programs at nuclear power plants adequately protect public and worker health and safety. It would be imprudent to rush the schedule af ter all the years it has taken to develop the revised Part 20, especially since significant additional protection will not be achieved by earlier implementation. We support the NRC 9206250072 920611 h-)h PDR PR 19 57FR2t2tb PDR f

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t Page 2 United States Nuclear Regulatory Commission Junell,1992 proposal to adjust the implementation date and encourage continued initiatives by the NRC toward successfulimplementation.

We appreciate the opportunity to provide our cornments on this very important issue.

Sincerely, I

Y B. Ralph Sylvia Exec. Vice President Nuclear BRS/ECG/Imc xc:

S. W. Wilczek, Jr., VP Nuclear Support, NMPC D. K. Greene, Manager Licensing, NMPC W. L. Schmidt. Senior Resident inspector, USNRC R. L. Anderson, NUMARC a

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