ML20198G195

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Submits Mit Comments on Proposed Changes to 10CFR50,52 & 72. Licensee Supports Stated Intent of Proposed Change & Appreciates If Addl Time for Comment Is Available
ML20198G195
Person / Time
Site: MIT Nuclear Research Reactor
Issue date: 12/21/1998
From: Bernard J
MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9812290012
Download: ML20198G195 (2)


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NUCLEAR REACTOR LABORATORY -

, AN INTERDEPARTMENTAL CENTER OF /  !

MASSACHUSETTS INSTITUTE OF TECHNOLOGY JOHN A. BERNARD 13b Albany Street, Cambndge, MA 02139-4296 Actniation Analysis j Director Te:ofax No. (617) 253 7300 Coolant Chemistry Director of Reactor Operahons Tel. No. (617) 253 4220 Nuclear Meecme 7

Principal Research Engineer Reactor Engineering 1

December 21,1998 N-)D 4

i Nuclear Regulatory Commission

, Attn: Document Control Desk Washington, D.C. 20555

Subject:

RIN 3150-AF94, Proposed Change to 10 CFR Parts 50,52, and 72 Gentlemen:

The Massachusetts Institute of Technology (MIT) offers the following comments 4

on the proposed changes to 10 CFR Parts 50,52, and 72.

l (1) MIT supports the stated intent of the proposed change. However, the change itself is extensive, and we have not had time to evaluate it's full potential impact. If additional time for comment is available, it would be most appreciated.

(2) The existing definition of an "unreviewed safety question," has worked well for  !

MIT, and we believe for the other members of the non-power reactor community.

Our staff resources are quite limited and our staffis fully occupied with relicensing activities as well as other licensing activities. Accordingly, at present, we lack the  !

resources to implement the proposed revision. We therefore request that a large l transition period (at least a year) be allowed during which either the current or the new language that determines the existence of an unreviewed safety question be I allowed, (See comment (3) below.)

(3) The proposed rule appears to be written solely from the viewpoint of the power reactor community. Non-power reactors already represent such a low risk that

' proposed revision is not a benefit. But,it will be an administrative burden because of its complexity. Retention of the existing rule (as opposed to the long transition period suggested above) for non-power reactors might be of benefit.

(4) We believe that ternu such as " minimal increase" or "significant increase" or "more than rninimal" will create difficulty in implementing the proposed rule because of the subjective nature of these phrases. A quantitative approach is essential. At the MIT Research Reactor, we do this by designating changes to certain systems as requiring a certain level of review. (This is in addition to the review for an URSQ, which applies to all changes.) A system'r approach would not be practical l

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Nucleaf Regulatory Conunission December 21,1998 Page Two for power reactors . Perhaps PRA could be used. If a proposed change causes less than an x percent change in the probability of the DBA, then its acceptable for licensee to review it internally. Please note that this method of implementation would not work for non-power reactors because PRA analyses are not needed for these facilities and therefore have not been performed.

Sincerely, ik O A chn A. Bernard, P .

Director JAB /koc .

Enclosure ,,

cc: USNRC - Senior Project Manager, NRR/ONDD USNRC - Region I- Project Scientist Effluents Radiation Protection Section (ERPS)

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