ML20072C948

Expresses Concern Over Possible Detriments of Regionalizing Nonpower Reactor Licensing Functions.Regionalization May Cause Inconsistent Application of Regulatory Requirements. NRC Should Seek Nonpower Reactor Licensee Input

ML20072C948
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	12/13/1982
From:	Lisa Clark MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20072C947	List: ML20072C948
References
NUDOCS 8303100490
Download: ML20072C948 (2)

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M MASSACHUSETTS LNSTITUTE OF TECHNOLOGY  !

O.K. HARLING 138 Albany Street Cambridge, Mass. 02139 L CLARK. JR.

Director of Reactor Operations Director (617)253- 4 2 0 2 December 13, 1982 The Honorable Nunzio J. Palladino, Chairman United States Nuclear Regulatory Commission Washington, D.C. 20555

Dear Chairman Palladino:

At their annual meeting in College Stati,on, Texas, On October 18-20, 1982, the managers of Test, Research and Training Reactors (TRTR) were' informed that the Nuclear Regulatory Commission is considering the transfer of licensing ' activities associated with non-power reactors (NPR) to its

• regional offices. I am writing on behalf of the TRTR community, because it is. probable that this action will have a significant impact on the NPR regulatory process and the TRTR reactors.

It is recognized that regionalization has many benefits, and some TRTR members are not opposed to it, particularly for activities such as operator licensing, inspections, byproduct licensing, etc. There is, however, significant concern regarding the. areas of reactor licensing and

. lice'nse amendments, including emergency planning, safeguards and similar subjects, esp uially on:the part of those who have been involved in standards development a:.d guidance formulation. ,

We b211 eve that the consolidation in the last three years, of NPR licensing ' activities in one branch, i.e. Standardization and Special Projects, under a limited number of project managers, *has resulted in better communi-cations, more' uniform application of regulatory requirements, improved develop-ment and availability of guidelines and standards, and more knowledgeable staffers with a much clearer under. standing of NPR safety considerations and of the large dif ferences between power reactors and hTR's -- all to the be'nefit of the general public, TRTR and NRC.

The concern with regard to regionalization of' reactor licensing is that -

it may mean a return to the splintered type of arrangement that existed in earlier yeJirs where project managers for NPR's were not in close touch with each other, with the result that regulatory requirements were not consistently applied, the distribution of pertinent information was limited, few NRC staff members had research reactor experience, and NPR licensing actions were l

generally given a low priority.

Prior to October, the TRTR managers were generally not aware o'f the intent to regionalize NPR licensing activities and, hence, unable to evalua'te the impact and to. offer constructive input to the degree appropriate. We now respectfully request that NRC seek input -- from those functioning on both 8303100490 830302 l PDR ADOCK 05000020 l P PDR

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Th2 Hsnsrcblo Nunzio J. Palladino, Chairman December 13, 1982 page 2 sides of the regulatory process -- and carefully review its plans for NPR's, including their effect on the benefits we believe have accrued in recent years, as outlined above.

t I wish to assure you that the TRTR community shares your objective of finding the most efficient and effective'metho'ds of. applying regulatory requirements and will cooperate in every way. We shall be very pleased to meet with you and with the NRC staff to further present our views.

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- - Thank you for.your consideration of this request.

Sincerely, ,

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Lincoln Clark, Jr. d Chairman, TRTR Ld/sbs cc: Mr. Victor Stello, Deputy Executive Director for Operations, USNRC . . .

Mr. Harold R. Denton, Director, Office of Nuclear Reactor Regulation, USNRC TRTR members e

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