ML19308C944
| ML19308C944 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/02/1974 |
| From: | Oleary J US ATOMIC ENERGY COMMISSION (AEC) |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8002110683 | |
| Download: ML19308C944 (5) | |
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_m UNITED STATES ATOMIC ENERGY COMMISSION l
WASHINGTON, D.C. 20545 l
. }* i APR 2 1974 Licensing Staff REGULATORY REQUIREMENTS REVIEW COMMITTEE A significant step in our program for controlling ratcheting is the recent establishment of an in-house Regulatory Requirements Review Comittee (RRRC). The RRRC will review significant new proposed Regulatory requirements or proposed changes that provide significant relief from existing requirements, and decide whether, when, and to what reactor plants these changes should be applied. This Committee is headed by E. G. Case, Deputy Director of Licensing, and includes J. M. Hendrie, Deputy Director of Licensing for Technical Revieh A. Giambusso, Deputy Director of Licensing for Reactor Projects,.
R. B. Minogue, Deputy Director of Regulatory Standards and J. G. Davis, Deputy Director of Regulatory Operations. The cho ter of the Comittae is attached.
It is not intended that this Comittee be a suostitute for responsible decision-making or accountability within the Licensing management chain. Neither is it expected that ratcheting will be completely eliminated from the reactor licensing process.
Rather, the purpose of the Comittee is to assure that ratcheting is being controlled and justified. Thus, the Comittee will provide final management review, prior to formalization or implementation, of all those items surviving the organizational review chain which constitute significant changes from or additions to existing. Regulatory requirements and interpretations.
Supplemental instructions, as required, concerning matters and procedures for Committee review will be provided from time to time by the appropriate Deputy Directors.
Important Committee conclusions and recomendations will be provided to the staff for information and guidance.
W
, John F. O' Leary Director of Licensing
Enclosure:
As stated f
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3 REGULATORY REQUIREMENTS REVIEW COMMITTEE I.
Introduction The process of review of applications to construct and operate nuclear power plants has been critically examined over the recent past by the Regulatory staff.
Several improvements to the Regulatory process have been identified and implemented, including an extensive staff I
reorganization, publication of Guides to the format and content of safety analysis and environmental reports, and accelerated publication schedules for issuance of Regulatory and Information Guides. Several other important steps are underway to improve further the review process, including promulgation of Standard Review Plans that will specify the nature of the review and the criteria and bases for judgment in each technical review area; institution of a management systen of checks and balances for reviewing at higher management levels any significant new requirements that develop during the review of a pro-E ject; and creation of a permanent management committee of senior Regulatory staff officers to review such proposed new requirements.
It is the purpose of this document to outline the organization and i
function of this permanent management committee, which is called the l
Regulatory Requirements Review Committee (RRRC).
A.
General Charter The fundamental task of this Committee is to review proge sed changes in Regulatory requirements for nuclear power plants that are i
referred to it (of a nature and in a mg.iner to be described); ahd to l
review implementation. schedules including, as appropriate, rosters of affected facilities, i
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The Conrnist, ion's rules and regulations have established over the year.i a significant body of requirements.
Some of these are clear and explicit, but others are in the form of general criteria that allow rather broad interpretation. The latter
' rules are deliberately made general in nature to provide for improvements in an expanding and developing technology. The Standard Format and the Regulatory Guides, as well as a body of implicit interpretations that have acquired accept-ance (and will be explicitly incorporated in the Standard Review Pl'ans),
are all used to aid in the review process by better defining the require-ments of the more general criteria and acceptable design solutions in
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problem areas. The stabilization of Regulatory requirements in written i
form, and establishment of an orderly process of implementation of l
needed changes and additions to these requirements is the general. charter of the RRRC.
r B.
Statters for Committee Consideration 1.
The Co:mittee should review such changes in the items' listed below as may impose significant new Regulatory requirements or provide significant relief from existing requirements:
a.
Standard Review Plans, b.
Standard Formats for Safety Analysis and Environmental Reports, and l
c.
Regulatory Guides used in the licensing reviews of power i
plants.
2.
The Committee should review proposed new Iutes or changes in exis ting rules that impose significant new Regulatory requirements or provide significant relief from existing requirements.
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The Committee should review proposed backfit actions under 10 CFR 50.109.
4.
Administrative or informational changes will be exempt from Comittee review as will routine revisions, amendments, new issues of pertinent regulatory documents, or alternativa j
proposed solutions acceptable as substitutes for regulatory guides receiving the ' normal regulatory review.
Items lacking l
l adequate justification should be disapproved and eliminated as f
they surface through the management review chain, leaving those items for Comittee review that have prior organizational
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approval and constitute a significant change or expansion of existing requirements and interpretations.
It is not expected that a clear-cut base line from which these changes are measured will exist at the initiation of Committee transac tions.
In addition, some overlap with the routine Regulatory review of pertinent documents will occur initially, and some issues will escalate to the Comittee that properly should not. However, as the codification of Committee trans-i 1
actions and decisions proceed and are reflected back into the Regulatory staff, with appropriate additional guidance as required, this initial transitional period will give way to a l
routine procedure for Comittee decisions.
I C.
Administration 1.
Composition l
The Comittee will consist of at least five members appointed
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by the Director of Regulation.
One of the members will bc
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appointed Chaliman by the Director of Regulation. Alternates l
will be designated by the members as required when absence f rom Comittee meetings is unavoidable.
2.
Nature of Coernittee Action The decisions of the Comittee will be in the form of recom-mandations to the Directors of the appropriate Directorates or to the Director of Regulation for approval, approval with modifications, or rejection of the matters submitted.
3.
Format of Input to Comcrittee i
All matters referred to the Comittee will be transmitted by.
memorandum addressed t-the Chairman. The documentation should include a clean draf t of the proposed review plan, format section, guide, rule, or backfit paper. A proposed implementa-tion plan or schedule should be included.
4.
Meeting Frequency I
The Comittee will meet as of ten as deemed appropriate by the i
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- Chairman, j
5.
Summary of Meetings A summary of the meetings, including decisons made and' actions taken, will be prepared and distributed. Such addit.ional documentation as required to express the intent of the Ccanittee will be prepared and distributed. OGC will be kept informed.
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