ML20236D021
| ML20236D021 | |
| Person / Time | |
|---|---|
| Site: | 05000054 |
| Issue date: | 02/20/1989 |
| From: | Voth M NATIONAL ORGANIZATION OF TEST, RESEARCH & TRAINING |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20236D019 | List: |
| References | |
| NUDOCS 8903220425 | |
| Download: ML20236D021 (2) | |
Text
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l TRTR
- "*i" conunittee i
National Organization of Test, Dana d M ^ier.unior.ity of Mi.e.uri Research, and Training Reactors M*g's,(",'",",,,*f]
. Arthur O. Johnson, Oregon State University l-Mareus H. Voth, Chairman c.orp W. Nelson, University of Artaana, Chairman Elaet Director Penn State Breazeale Ranctor Taun M.Raby. Nauenalinstitute of Standards and Technelegy University Park, PA 16802 w.de J. Richards, McClellan Air Force Base (314) 865 4 351 Marcus H. Velh, Penn State, Chairman i
l l
February 20, 1989 l
i Mr. Victor Stello, Jr.
Executive Director for Operations U.S, Nuclear Regulatory Commission l
Washington, D.C.
20555 i
Dear Mr. Stello:
I s
In behalf of the Test, Research, and Training Reactor organization I am t
requesting a meeting between representatives of your office and the TRTR organization concerning an issue that has a potential impact on all of our members.
The specific issue is outlined in letters from Region 1 to j
l Cintichem, Inc. dated 1 December 1988 and 11 January 1989.
The licensee is l
being subjected to provisions of 10 CFR 50.70 which we understood to apply only to nuclear power reactors.
The policy laid out in the referenced letters is a major policy implementation
{
that comes without opportunity for comment by affected facilities.
It establishes a precedent that could be applied to any other non-power reactor.
TRTR members question the need for unescorted access.
They have particular unaddressed concerns about issuing keys and permitting unescorted access off hours to inspectors withoJt site-s00Cific training required for safe access to our facilities, time requried for training programs for inspectors, liabilities fur NRC personnel who are unescorted, and the potential consequences of damage done to experiments by unescorted inspectors in areas of our fccilities that are unoccupied. We believe that'all of these issues should be analyzed and each licensee given the opportunity to comment on the policy before a precedent-setting action is taken.
A second concern deals with the integrity of the rulemaking comment process.
Attached to the 1 December 1388 Region 1 letter is your 17 November 1988 letter to nuclear utility executives concerning the implementation of newly promogated regulation 50.70(B)4. When that regulation was proposed for comment, the summary stated that it applied to inspections at power reactor sites.
However, the wording in the regulation did r,at restrict it to power reactors.
TRTR members commented that the rule should clearly specify that it be applied only to power reactors. TRTR coments went on to suggest that if the rule was intended to be applied to nonpower reactors, that it be reissued for comment such that individual licensees could assess the impact on their facilities.
The final rule was published with a specific statement in 50.70(B)4 restricting that provision to power reactors.
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c; Mr. Victor Stello, Jr.
Page 2 February 20, 1989
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We believe that the implementation of this policy is a misunderstanding or misinterpretation of the regulations and the intent with which the regulations were promulgated.
If it is the Commission's intent to enforce a policy of unescorted access for inspectors at any nonpower reactor, we request a meeting between a delegation of TRTR and the NRC to discuss this precedent and its i
ramifications.
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Sincerely yours,
'\\
Marcus H. Voth Chairman l
MHV/skr cc:
Director of NRC Region I i
J I
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