ML20215G047
| ML20215G047 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 05000000 |
| Issue date: | 07/19/1977 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Case E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20215F899 | List: |
| References | |
| 291, NUDOCS 8610160463 | |
| Download: ML20215G047 (2) | |
Text
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VIHUIMIA Ex.ucimC AND POWER COMPANY Rscuseown.Vsuonnsa conGL July 19, 1977 Mr. Edson C. Case, Acting Director Serial No. 291 Office of Nuclear Reactor Regulation P0&M/JTB:das U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Attn: Mr. Peter L. Strauss General Counsel
Dear Sir:
Pursuant to the provisions of Title 10 of the Code of Federal Regulations, Paragraph 20.6, this letter requests a written interpretation of the regulations contained in Part 20. The specific regulations requiring interpretation are those contained in Part 20 pertaining to reporting of radiation exposure to an individual, including Section 20.408.
-Section 20.408 states:
" Reports of personal exposure on termination of employment or work.-
When an individual terminates employment with a licensee subject to Sec. 20.407, or an individual assigned to work in such a licensee's facility, but not employed by the licensee, completes his work as-signment in the licensee's facility, the licensee shall furnish to the Dirc:: tor of Inspection and Inforcement, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, a report of the individual's exposure to radiation and radioactive material, incurred during the period of employment or work assignment in the licensee's facility, containing information recorded by the licensee pursuant to Sees.
20.401(a) and 20.108.
Such report shall be furnished within 30 days af ter the exposure of the individual has been determined by the li-censee or 90 days af ter the date of termination of employment or. work ass,ignment, whichever is earlier."
It is our interpretation of Section 20.408 that the regulation is making a distinction between termination of employment with a company and termination of a work assignment at a particular facility. This interpretation is supported by 10 CFR 19.3 and 10 CFR 20.3 which states that the " licensee" means the holder of a license. A nuclear power station does not " hold" a license, it is the "fa-cility" that is licensed. Vepco, the corporation, is the holder.
For example, when a Vepco employee goes from one Vepco nuclear power station to another Vepco nuclear ' power station, Section 20.408 does not require that he be given a history of his exposure.
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'Please provide the NRC's interpretation of the cited regulation.
If you require additional information on this natter please advisc.
Very truly yours, C. M. Stallings,
A Vice President-Power Supply and Productions Operations cc:
Mr. Norman C. Moseley 0
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