Re:Security and Control - A Regulation Change is Needed -Reply

[Charles Willis <CAW@nrc.gov>]

Sandy,

I certainly agree that the NRC is improving its efforts to get input from licensees
and the public.  However, the effort isn't as new as might be supposed.  Certainly
the first version of Part 20 was issued for comment back in 1955 and the comments
were reflected in the final rule.  There were extensive comments on Al Brodsky's
"new" Part 20 in about 1961.  I did not get involved in trying  to sway the
regulators until later in the '60s (because earlier I had been working for AEC
contractors) but by the late '60s a dialog on dose calculations and the like had been
established.  I may have it wrong but I believe that the provision for petition for
rulemaking (Part 2.802 ) has been with us since about 1970.  The only point to this
is that the regulators' recognition of the need for input from licensees and others is
not new.  What I fear may be new is that, as a result of "reinvention," downsizing,"
"deregulation," etc., health physicists may have even less time and energy to
provide the essential input to the regulators.  I only hope that Joe Ring, or a
colleague who is cognizant of the details of the security issue,  has the time and
energy to initiate a rulemaking action.

Charlie Willis
caw@nrc.gov