ML19308C942
| ML19308C942 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/02/1974 |
| From: | Anthony Giambusso US ATOMIC ENERGY COMMISSION (AEC) |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8002110681 | |
| Download: ML19308C942 (2) | |
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UNITED STATES
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^^td APR 2 1974 Reactor Projects Staff REGULATORY REQUIREMEfiTS REVIEW COMMITTEE (RRRC)
As you are aware, a Cc:rmittee has been formed to minimize and control ratcheting in the Regulatory process. The charter for the Comittee describes the matters which are appropriate for Comittee consideration and the format for input to the Comittee.
All such matters originating in RP that constitute significant changes from or additions to existing requirements and interpretations will receive review at all levels of RP management up to and including the appropriate Assistant Director. This successive review will eliminate those items lacking adequate justification, and the Assistant Director will forward to me those items that survive for consideration, and forwarding, as appropriate to the Committee.
It is not expected that we in RP will have any significant difficulty either in our own proposals or reviewing proposals of others in determining just what constitutes changes in the specific Regulatory documents outlined in the charter (Regulaticns, Safety Guides, Standard Format). These documents contain specific wording and any propased change will require specific rewording which will then focus the matter under consideration.
However, as expressed by the Director of Regulation "...the Comittee will be responsible for more precisely defining the intent of existing regulations which are general in nature and subject to broad interpretations." It is in this area that difficulties may occur in determining what definitions or broad interpretations of existing requirements may be changing to the degree that they should be subject to review by licensing management and the RRRC. We have the unique responsibility in RP of assessing requirements and interpretations from all of Regulatory for all plants. A subtle change in the inter-pretation of an existing requirement may not appear to the originator as a significant ratchet for a particular plant but when viewed from the overall RP standpoint as to its impact on successive and prior plants, may indeed have the potential for a significant ratchet.
It is expected that all levels of RP maragement, including Project Managers, will be alert to these potential ratchets, regardless of their source, and after appropriate review will surface them to the i
Comittee through the RP chain in order to be considered for changes to Regulatory requirement documents.
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n Reactor Projects Staff APR 2 1974 As the Comittee reviews proceed and decisions are reflected back into the staff, additional instructions and guidance will be provided as required.
$ s h a >>r $ c a w A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing 4
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