ML19351A247
| ML19351A247 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1989 |
| From: | Roberts T NRC COMMISSION (OCM) |
| To: | Voth M NATIONAL ORGANIZATION OF TEST, RESEARCH & TRAINING |
| References | |
| NUDOCS 8910170087 | |
| Download: ML19351A247 (6) | |
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NUCLEAR REGULATCRY COMMISSION E00 4741 EBeckjord
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October 6, 1989 ilTaylor OGC HThompson Reatons 1-onamaw JBlaha 5
KPerkins JScinto FMiraglia Dr. harcus H. Voth, Chairman EDO r/f National Organization of Test, JRoe Research, and Training Reactors RBernero Director, Penn State Breezeale Reactor KPerkins University Park. Pennslyvania 16802 TMurley/JSnierek
Dear Dr. Voth:
The Commission har received your letter of September 7, 1989, regarding the consolidation of non-power reactor (NPR) activities within the Nuclear Regulatory Commission (NRC).
As Chairman Carr indicated in his August 2, 1989 response to your letter of July 6, 1989, your proposal is being carefully considered.
4 The hRC staff has recomt.eeded to the Commission that increased headquarters management attention be devoted to.non-power reactors.
The staff has proposed a new Non-Power Reactor, Decommissioning, and Environmental Project Directorate within the Office of Nuclear Reactor Regulation to provide centralized l
management oversight of technical review, inspection, and enforce-ment activities for non-power reactors.
The project director would serve as the NRC contact on matters pertaining to such facilities.
In addition, a training course has been developed for l
non-power reactor inspectors.
An initial sussion involving inspectors from all five NRC Regional Offices has been conducted i
to identify improvements that need to be made before the course is offered to all NPR inspectors.
The Cosamission is currently evaluating these and other recommendations
>roposed by the staff and is expected to act on the proposals wit 11n the next few weeks.
l
.With respect to your specific concerns regarding the administra-l tion of NRC requalification examinations at non-power reactor facilities, the staff is evaluating the level of risk associated I
with the operation of non-power reactors and the current requali-fication requirements, as stated in 10 CFR Part 55.
The Commission will consider the need for changes in regulatory oversight based on the results of staff's evaluation.
I want to assure you that the Commission is aware of your concerns and is andressing the issues you have raised.
Sincerely, yh (f)
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4 N-Thomas M. Roberts I
Acting Chairman
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n dbHarcusH Voth Chairman National Organization cf Tcst, L
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Director, Penn State Brezeale Reactor University Park, PA 16802 l
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Dear Dr. Yoth:
Your letter of September 7,1989 and your earlier correspondence appropriately convey the TRTR organization concerns regarding the consolidation of non-power reactor activities within the Nuclear Regul6 tory Commission (NRC).
I wish to t
reassure you that this issue is being carefully considered.
As I indicated in My letter of August 2, 1989 the staff was preparing its recommendations; the Comission ha $ received these recommencations and is evaluating them.
The NRC has already acttd to increase headquarters management attention to i
p non-power reactors. The Non-Power Reactor Decomissioning, and Environmental Project Directorate was formed within the Office of Nuclear Reactor Regulation to provide centralized management oversight of technical review, inspection, 1
and anforcement activities. The oroject director is the NRC contact on matters pertaining to non-powe,r reactors.
in addition, a training course was developed for non-power reactor inspectors and the first session was implemented at the NRC Technical Training Center, r
\\
With respect to your specific concerns regarding the administration of NRC requalification examinations at non-power reactor f acilities, careful considera-tion is being given to thistissue. The staff acknowledges the non-power reactor community's concern that the power reactor philosophy is generally inconsistent with the level of, risk associated with the operation of at least i
sor,e non-power reactors. The staff is evaluating the risk and the current requalification requirements, asistated in 10 CfR Part 55, in an effort to establish a level of non-power reactor regulatory oversight commensurate with the level of risk to public health and safety.
j
! assure you that the NRC staff is carefully considering the issues you have
- raised, s
4 Sincerely, Kenneth M. Carr j
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DISYRIBUTION
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Central File NRC PDR w/cy of incoming \\
Local PDR w/cy of incoming EDO f 00C4741 EDO Reading T. Murley/J. Sniezek J. Partlow ADR4 Reading (w/cy of inco ing)G. Holahan S. Weiss w/cy of incoming OGC-Rockville GPA/CA V. Stello
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Dh Marcus H. Yoth Chairman National Organization of Test.
t Research, ar.d Training React:rs Director, Penn State Brezeale Reactor University Park, PA 10802
Dear Dr. Voth:
Your letter of September 7,1989 and your earlier correspondence appropriately convejt the TRTR organization concerns regarding the consolidation of non-power reactoh activities within the Nuclear Regulatory Comission (NRC).
I wish to reassure ou that this issue is being carefully considered. As I indicated in my letter of August 2,1989 the staff was preparing its recomendations; the Comission has received these recommendations and is evaluating them.
The NRC has 1 ready acted to increau headquarters managenent attention to non-power rea rs. The Non-Power Reactor, Decomissioning, and Environmental Project Direct te was formed within the Office of Nuclear Reactor Regulation to provide centr ired management oversight of technical review, inspection, and enforcement ac ivities. The project director is the NRC contact on matters pertaining to non-p er reactors, in addition, a training course was developed for non-power reactor nspectors and the first session was implemented at the NRC Technical Training Snter.
I believe that these actions provide some degree of alleviation pending t' Comission's review of the staff's recomendations.
With respect to your specif concerns regarding the administration of HRC requalification examinations non-power reactor fatilities, careful considera-tion is being given to this iss'e and a proposed pr3 gram revision is being developed for Comission review d approval. The ; tat f amowledges the non power reactor comunity's con rn that the power reactor philosophy is inconsistent with the level of risk associated with the operation of non-power reactors. The staff is evaluating t > risk and the current requalification requirements, as stated in 10 CFR Par 55, in an effort to establish a level of non-power reactor regulatory oversight mmenswate with the level of risk to public health and safety. The staff has 'ot excluded the possibility of revising the rule to eAplicitly exclude non-power r ctors, if appropriate, or of implementing an interim program that would p vide sone level of relief from the current requalification philosophy.
I asture you that the NRC staff is carefully cons dering the issues you have raised.
"This correspondence addresses policy Sincerely, issues previously resolved by the Comission gagts factual information, or restatEinnbth M. Car DISTRIBUT W Centrai T M NRC PDR w/cy of incoming Local PD w/cy of incoming EDO # 0004741 EDO Reading T. Murley
. Sniezek J. Partlow ADR4 Reading (w/cy of incoming)G. Holahan S. Weiss w/cy of incoming OGC-Rockvill GPA/CA V. Stello J. Tay1)r H. Thompson J. Blaha E. Beckjord, R K. Perkins J. Roe F. Miraglia J. f,cinto, 0GC R. Bernero, NMSS D. Mossburg, PMAS ED064741)
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'e D N Marcus H2 V;th, Chairman Test, Research, and Trai;ing React:rs Director Penn State Breezeale Reactor University Park, PA 16802
Dear Dr. Yoth:
Your letter of September 7,1989 and your earlier correspondence appropriately,
conveys the TRTR organization concerns regarding the consolidation of non-pcwer reactor activities within the Nuclear Regulatory Comission (NRC).
I'wisb'to reassure you that this issue is being carefully considered. As 1.indicatied in my letter of August 2,1989 staff recomendations were forthcoming hav6 now been received by the Commission and are being evaluated.
j The NRC has already taken action to provide increased headquarters management attention to non-pcwer reactors. The Non-Power Reactor. Decopm'issioning, and Environmental Project Directorate was formed within the Of te of Nuclear Reactor Regulation to provide centralized management over;. ht of technical 6
review, inspection, and enforcement activities. The ' project director is the NRC contact on matters pertaining to non-power reectors'.
In addition, a training course for non-power reactor inspectors.was/ developed and the first session implemented at the NRC Technical Training Cfnter.
I believe that these actions provide some alleviation pending Comission's decision, i
With respect to your specific concerns regarding the administration of NRC requalificationexaminationsatnon-powerrpetorfaciities. Careful consideration is being given to this issue and a proposed program revision is being developed for Commission review aryd approval.
The staff acknowledges the non-power reactor operations, it,is evaluating the risk and the current requalification requirements, as stated in 10 CFR 55, in an effort to establish a level of non-power reactor regulatory oversight comensurate with the level of risk to public healtVand safety.
The staff has not excluded the possibility of revising the rulp/ o explicitly exclude non-power reactors, if t
appropriate, or of implementin,g an interim program which would provide some level of relief from the current requalification philosophy, t
I hope I have succeeded in assuring you that the issues you have raised are being given careful consheration.
Sincerely, Kenneth M. Carr GT 4741 DISTRIBUTION Central File '.
NRC PDR w/cy of incoming Local PDR w/cy of incoming EDO i 000474)
E00 Reading T. Murley/J. Sniezek J. Partlow /
ADR4 Reading (w/cy of incoming)
G. Holahan S. Weiss wr,cy of incoming OGC-Rockville H. Thomp/
V. Stello J. Taylor GPA/CA son J. Blaha E. Beckjord, RES K. Perkins J. Roe F. Miraglia J.Sejnto,OGC R. Bernero, NMSS D.Mossburg,PMAS(ED0f0004741) i F. Miraglia J. Roe w/cy of incoming K..Perkins PDNP ADSP (A)D:DRSP Tech. Ed.
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DOC DT 09/07/89 FINAL REPLY Marcus H. Voth
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. Chairman Carr FOR SIGNATURE OF:
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NON-POWER REACTOR REGULATOf;Y MATTERS Taylor 1"hompson DATE: 09/12/89 Blaha Beckjord, RES ASSIGNED TO:
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CFFICE CF THE SECRETARY i
CORRESPONDENCE CONTROL TICKET PAPER NUMBER:
CRC-89-1001 ACTION OFFICE:
IDGGING DATE: Sep 11 89 i
EDO AUTHOR:
i AFFILIATION Marcus H. Voth FA (PENNSYLVANIA)
LETTER DATE:
k Sep 7 89 FILE CODE:
SUETECT:
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Ref Coma's Aute 2 1989 ltr t
organization's co,ncerns re noniterates the TRTR k
re charcteristic of the concernsregs--and req for cor power reactor ACTION:
Signature of Chairman
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DISTRIBUTION:
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NOTES:
i DATE DUE8 Sep 25 89 1
SIGNATURE
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Septeder 7, 1989 The Honorable Kenneth H. Carr, Chairman US Nuclear Regulatory Comission Washington, DC 20555 Dear Honorable Chairman Carri In your August 2,1989 letter, you anticipated action regarding reorganization of NRC staff respon ible for non-power reactor regulation at approximately this date. As the omission considers this issue, we wish to reiterate the TRTR organization's concern that there be a single individual designated who has the responsibility, authority, and accountability for all regulatory activity related to non-power reactors.
We believe this can only be effectively accomplished by consolidating all activities involving r.on-power reactors in a single group. Significant improvement in dialogue and responsiveness has developed in recent years, but the process continues to suffer from the lack of a focal point within the NRC Staff. We again assure you that our intent is to meet our charter of conducting the nation's research and educational programs in the most effective and efficient manner with the utmost attention to the safe operation of our facilities and to the protection of the health and safety of the general public.
The second reason for this letter is a request to correct a specific problem characteristic of the above concern.
In 1987, Part 55 was amended to require reactor operator requalification exams to be administered by NRC personnel during each six-year cycle.
Despite assurances by Staff personnel that the amendment was intended for power reactors, the final rule was issued so as to include non-power reactors. There are numerous sound reasons why this is unnecessary and undesirable for non-power reactors.
To date, no one has taken responsibility for what is generally agreed to be an oversight. More importantly, the situation has not been corrected.
In reviewing the matter, Mr. Victor Stello assured us in his April 11, 1988 letter that implementation would be deferred to the end of the six-year cycle such that there would be no impact before early 1991.
In subsequent discussions he comitted to take action to exempt non-power reactors from the rule.
Since his departure, it appears that this comitment will not be honored without high-level intervention.
TRTR does not have access to a study initiated by the Staff which supports our position. We understand that a generic evaluation of facilities 2 megawatts and smaller and a specific evaluation of each non-power reactor above 2 megawatts shows that the consequences of the most severe scenarios do not support the need for the rule in question.
Since we do not have access to this study, and do not care to dwell on the manner the issue has been handled in the past, we believe it best be executed within the Comission. We therefore request that you initiate the necessary action for b 0 l 9 O bh Q p(y
n prompt reconsideration of the regulation in question as it applies to all non-power reactors As always, we stand ready to meet with you and your staff and provide additional information which you may request.
We are most appreciative of your assistance in designating a single focal point for non-power reactor regulatory matters and in revisiting comitments to correct the requalification requirements.
Sine rely lro rs, h
L Marcus H. Voth Chairman, TRTR MHV/jlw l
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