ML20095J688

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Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants
ML20095J688
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 04/23/1992
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-57FR9462, RTR-REGGD-01.101, RTR-REGGD-1.101, TASK-DG-1022, TASK-RE 57FR9462, 92-196, NUDOCS 9205040106
Download: ML20095J688 (1)


Text

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Regulatory Publications Branch Serial No.: 92-196 Division of Freedom of Information & Publications Services NL&P/RBP R1 Office of Administration United States Nuclear Regulatory Commission Washington, D.C. 20555--

Gentlemen:

DRAFT REGULATORY GUIDE DG-1.Q12 EMERGENCY PLANNING AND PREPAREDNESS

Virginia Power has reviewed Draft Regulatory Guide DG-1022, " Emergency Planning and Preparedness for Nuclear Power Plants." -We endorse the proposed Revision 3 to Regulatory Guide 1.101 as it allows an alternate method for developing Emergency

- Action Levels. -In addition to endorsing comments from the Nuclear Management and Resource Council, Virginia Power offers the following comment with regard for the development of a regulatory position in this area.

The proposed revision appears to require utilities to choose either method and not allow use_ of beneficial sections of the two methodologies. We would suggest that consideration-be given to allowing use of portions of both methodologies, especially-

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with regard to Unusual Event Classifications. -The segregation of methodologies in

- states wh_ich contain more than one utility or site could lead to_the same event being reported under 10CFR50.72 at one location and as an Unusual Event at another. We believe that this could cause confusion within certain state / local agencies.

Should you have any questions regarding our concerns, please contact us, i

Very truly yours, h v prW. L. Stewart L cc: Mr. hon Simard Director, Industry Relations and Administration Division Nuclear Management and Resources Council

-1776 Eye Street, N. W.

Suite 300 Washington, D. C. 20006-2496

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