ML20058E056
| ML20058E056 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/10/1993 |
| From: | John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR48080, RULE-PR-MISC 58FR48080-00003, 58FR48080-3, NUDOCS 9312060142 | |
| Download: ML20058E056 (2) | |
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Log # TXX-933BD NC F 7-File # 10185 l
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~93 NOV 15 A1C:56 1
i 1UELECTRIC 10, 1993- [ [ N ; N [
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c+ rara a Mr. Samuel J. Chilk Secretary U. 5. Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch
SUBJECT:
COMMENTS ON PROPOSED OPEN HEETING POLICY I
Gentlemen:
TU Electric is pleased to provide comments to the proposed statement of -
policy regarding staff meetings open to the public.
The proposed NRC policy defines a public meeting as a "[P]lanned, formal
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encounter...for the expressed intent of discussing substantive issues that-are directly associated with NRC's regulatory and safety responsibilities",
l The policy attempts to distinguish between meetings with outside persons and
-j meetings with NRC contractors and others. as listed-in the policy, for the-l purpose of delineating which meetings are 'to be open to the public. The r
policy presumes that in the interest of keeping the public informed all
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meetings between the' NRC and licensees should be open to the public.
TU Electric requests that meetings between NRC staff and licensee personnel be excluded from the open meeting requirement if any of the following are.
met.
First, the participants are below a pre-defined level of management.
Second, the meetings are administrative in nature. ard they are held to discuss scheduling and constraints associated with completion of licensee j
items or the review of submitted material.
Third, the meetings are technical discussions between a branch reviewer and a licensee employee and are held to answer specific questions or to provide. clarification on-a submitted document.
TU' Electric suggests that such a broad policy as propos'ed by the NRC'would unnecessarily complicate NRC and licensee discussions in encounters where no
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NRC decisions pursuant to the NRC's regulatory or safety responsibility are j
to be made.
TU Electric further suggests that the open meeting policy be
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applied only to those meetings where the participants are in a decision
'j making capacity and the meeting is held incident to NRC's performance of its regulatory and safety duty.
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5 TXX-93380 Page 2 of 2 Under the proposed policy, a visit or discussion between a licensee employee and a technical branch reviewer, held solely to clarify or answer questions related to submitted documents, could be classified as an open meeting.
t TU Electric believes that a discussion held solely to answer or clarify-specific questions, between licensee personnel and a technical branch reviewer, and in which no decisions affecting the NRC's regulatory and i
safety duty will be made should be possible without invoking a public meeting.
TV Electric would be glad to further discuss these comments.
If you have any questions please contact Mr. Jose' D. Rodriguez at (214) 812-8674.
Sincerely, r
William J. Cahill, Jr.
t By: /
J.' S. Marshall Generic Licensing Manager
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