ML19322D239
| ML19322D239 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/19/1979 |
| From: | Cox T NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | Parler W NRC - NRC THREE MILE ISLAND TASK FORCE |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8002100082 | |
| Download: ML19322D239 (17) | |
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O CHANGES IN REO.UEREMENTS o Not all Changes are Reviewed by R R RC.
o Clarification and Editorial Changes.
o Change Rated as Significant and Approved for implementation by N RR Division and Office Director on Ongoing Reviews Pending Review by R R RC.
o Cat. 4 Requirements.
o However, Safety Significance is Determined by Some Intermediate Manage ~ ment Levels for Every Change.
o The Problem is the Same - What Criteria are Used for the Determinations.
4
CHANGES (CONTINUED)
O.
o Changes can involve:
o Need for Different Equipment Design o Need for Different Equipment Arrangement o Need for More Detailed Analyses o Need for Additional Testing o Need for Revised Procedures o in Most Cases industry Views the Changes imposed by the Staff Not to be Justified. Changes That are Forwardfit are Objectionable to Applicants but it is the Backfitting of Changes That is Particularly Onerous to Licensees.
CI-1 AN G ES o Some Changes Relax Staff. Requirements.
o Most Changes, However, increase Staff Requirements of What is Needed to Demonstrate That the Level of Safety Provided is in Accord With the Regulations.
Staff Proposals for Changes Come About as a Result of:
O o Construction Experience o Operating Experience o Licensing Experience o Results of R&D o Test Results o Results of More Refined Analyses o Detection of Past Errors o increase in Staff Expertise
REGULATORY REO.UIREMENTS REVIEIN COM M!TTEE (RRRC) o Formed in March 1974 by L.M. Muntzing.
o Reports to EDO.
o General Charter.
o Stabilization of Requirements.
e Establish an Orderly Process of Defining and implementing Needed Changes.
o Formed While SRP was Under Development.
S
4 M ATTERS REV!EWED BY RRRC.
o Regulatory Guides o
Branch Technical Positions o
Rule Changes o
Petitions for Rule Making o
Replies to Letters o
Standard Review Plans o
Stdff Papers
RRRC ME ViBERSI-!!P p
initial (1974)
Current -(1978)
E.G. Case (Chairman)
E.G. Case (Chairman)
R.B. Minogue R.B. Minogue A. Giambusso R.S. Boyd J.M. Hendrie R.C. DeYoung J.G. Davis V. Stello R.J. Mattson N.C. Moseley H.D. Thornburg T.E. Murley
- Non-Voting S. Hanauer*
I
-wN.<
i RRRC
SUMMARY
OF MEETINGS t
AND DECISIONS l
l f
Decisions No. of T.ime Per. d io Mtgs Cat.1 Cat. 2 Cat.3 Total Mar. - Dec.1974 20 22 4
2 28 Jan. - Jun.1975 10 3
0 2
5 Jul. - Dec.1975 12 20 4
3 27 Jan. - Jun.1976 8
11 4
3 18 Jul. - Dec.1976 C
10 5
2 17 Jan. -- Jun.1977 8
14 5
3 22 Jul. - Dec.1977 6
13 5
2 20 Jap. - Jun.1978 6
7 2
3 12
.y,.
Totals 76 100 29 20 149 Avg / Month 1.5 1.9 0.6 0.4 2.9
)
Y THE RRRC PROCESS o A Change is Proposed Thru Normal Channels to Division or Office Director.
o if the Director Concurs He Submits the Proposed Change to the RRRC Chairman With a Request for Committee Review. In NRR Each Division Director Obtains Prior Concurrence, From Other N RR Division Directors, That
~
Matter is Ready for RRRC Review.
o The RR RC Technical Secretary includes the Subject -
Usually With Others - for RRRC Review at a Forthcoming Meeting.
o The Secretary Prepares and the Chairman issues an Agenda for the Meeting With ~ Copies of the information in Support of Each Proposed Change - Usually a Few Weeks Before the Meeting.
4
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THE RRRC PROCESS (CONTINUED) o The RRRC Meeting is Held - Usually About Half a Day.
o Short Presentation by Sponsor Group and Groups or Individuals Opposing Change.
. o Questions and Answers.
o Roundta' ale Discussion.
o Decision Proposed and Voted Upon - Many Decisions are Unanimous but Many are Not.
o Secretary Prepares Decision Memorandum for RRRC Chairman's Signature - This Usually issues Within a Few Weeks of Meeting.
9
PUBLIC/!NDUSTRY IN PUT o No Direct Formal input From Public or Industry is Requested.
o However, by Virtue of the Process of Development of Mest Changes, a Great Deal of input From Industry, Members of the Public, Local, State, and Federal Government Agencies, and From Public Interest Groups is indirectly and Informally Accumulated Both with
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Respect to the Technical Merit of the Position as Well as to its impact.
o
BASIS FOR RRRC DECISIONS o Collection of Members' Individual Judgments o individual Judgments Derived From:
o Quality of Information Provided o Personal Background and Experience o Education o Familiarity With Viewpoints of Others o Within NRC o Outside NRC o ACRS o Familiarity With Wash-1400 and Other Related Approaches and Results o Fa.miliarity With Regulations and Their Bases
QUALITY AND EXTENTOF VALUE/ IMPACT AN ALYSES o Quality o Some Have Been Excellent.
o Generally, However, There has Been and is Need for improvement.
o Extent of Use
.o Required for Each Proposed Change Reviewed by RRRC.
o Matters Considered at 76th Meeting.
o Revision 2 to Rg.1.68 16 Pages o Revision 3 to Rg.1.29 1.5 Pages o Revision 1 to Rg.1.128 0.3 Page o Pr~oposed Rg. on Valves 4
Pages o Need for RRRC Review of Limited Changes to SRP 3.9.2 and 6.2.6 Oral a
ADDITION AL CHECKS & BALANCES o ACRS o OELD o Public Interest Groups o industry o Applicants and Licensees Appeals o Vendors and ' Architect-Engineers Appeals o AlF 7-n- -.-._._ ^--'
M THE APPROVAL CHAIN The RRRC is an important Part - But Only a Part - of the Management System of Checks and Balances for Review and Approval of Significant New Requirements.
The Overall Chain for the Development and imposition of new Require-ments is:
(1)
Reviewers and Project Manager (2)
Section Leaders (3)
Branch Chiefs (4)
Assistant Directors (5)
Division Directors (6)
RRRC (7)
Office Director e
A DOCU M ENTATIO N
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OF DECISIONS o Memorandum to EDO.
'*2/
o Distribution Down to all involved AD's.
s.
o Sponsoring Group is Informed immediately.
o Public Document Room.
o Memorandum From Director, N R R to Staff.
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REC 5NT CMANGE TO RRRC PROCESS TO PROVIDE MORE PU3UC INPUT 1.
RRRC Will Not Review Changes To SRP's Or RG's Until 60 Days After Public Comments Are Solicited.
2.
Public Comments Will Be Solicitud By A Federal Register Notice And By Direct Mailing To:
Government Agencies o
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industry o
Professional Societies o
Public interest Groups Unions a
3.
Comments Will Be Requested On:
Associated Draft Value-!mpact Analyses o
Associated implementation Schedules o
4.
RRRC Recommendations Will Not Be implemented Until After They Are Made Public.
5.
Appeals Of The RRRC Recommendations Can Be Made Up To 30 Days After They Are Made Public To:
H. Denton, Director, NRR (SRP's) o
. ~.
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