ML20195H374
| ML20195H374 | |
| Person / Time | |
|---|---|
| Site: | Texas A&M University |
| Issue date: | 11/15/1988 |
| From: | Feltz D TEXAS A&M UNIV., COLLEGE STATION, TX |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR36795, RULE-PR-26 53FR36795-00268, 53FR36795-268, NUDOCS 8811300366 | |
| Download: ML20195H374 (2) | |
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TEX AS ENGIN EE RING EXPERIhfEgGSTATION TEXAS A&M UNIVERSITY r
cou2GE STADen TEXAS 77p7le 21 P 4 d 9 15 November 1 J
NUCLEAR SCIENCE CENTER 409/845 7551 Secretary of'the Commission Attn:
Docketing and Service Branch U.S. Nuclear Regulator y Comeission Washington, D.C.
20555 Reference Proposed Rulemaking on a Fitness-for-Duty Program, 10 CFR Part 26. Federal Register Vol. 53, Nc. 184
Dear Sir:
The Texas Engineering Experiment Station, Nuclear Science Center Reactor is part of the Texas A&M University System and welcomes the cpportunity to comment on the pro-posed Fitness-for-Duty Program" regarding the consideration that the rule be ex-tended to include non-power reactors.
The reference for comments f.cm non-power reactors is made on pc.ge 36797 of the notice in the Federal Register of 22 September 1988, Vol. 53, No. 184.
We desire to go on record as opposing any consideration that this proposed rule for power reactors be applied to non-power reactors for the following reasons:
1.
Non-power reactor facilities have emall staff in number and the maintenance of these facilities are normally handled by the reactor or facility staff re-quiring few if any outside individuals needing access to the facility.
2.
Non-power reactors have very small physical plants and surveillance of individuals' requiring access to the facility is easily maintained.
3 The potential hazards to the general public from the operation of non-power reactors is significantly less than the potential hazards presented by power reactors thereby greatly reducing the concerns and requiremsnts of the per-formance levels of unescorted personnel within the facility.
However, in the interest of safe operatior, of non-power reactors these facilities will continue to implement measures to control unescorted individuals and to protect vital and estir'.ial equipment within the facility.
4.
Requirements that Management review and certify operators to be mentally and physically fit to perform licensard duties at non-power reactors in our opinion provides adequate surveillance of "Fitness-for-Duty" requiremnets.
Due to smal. staff in number, these individuals are observed continuously ar.d any unusual behavior would not go unnoticed.
8811300366 001115 PDR PR 26 53FR36795 PDR HESFARCH AND DDTLOPMENT FOR Mr% KIND D5/ c L
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There is concern that the proposed Fitress-for-Duty Program" would restrict access of the facility to students and researchers, would impose an unnecessary expense upon non-power reactors thvt r.?storically have limited funding, would result in administrative concerr.s regarding additional work-load, and finally would provide administrators with yet an additional argument to stop funding and call for elimination of programs resulting in reactor shut down.
We ask that these concerns be recognized in any consideration that the "Fitness-for-Duty" proposed rule be applied to non-power reactors.
Sincerely.
J [5 Donald E. Feltz i
Director DEF/ym I
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