ML20211J128
| ML20211J128 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1999 |
| From: | Jerome Murphy Committee To Review Generic Requirements |
| To: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20211J113 | List: |
| References | |
| NUDOCS 9909030048 | |
| Download: ML20211J128 (2) | |
Text
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ft UNITED STATES ye NUCLEAR REGULATORY COMMISSION 5
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WASHINGTON, D.C. 20555 4001
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May 10, 1999 MEMORANDUM TO:
William J. Travers Executive Director for Operations i
FROM:
Joseph A. Murphy, Chairman Committee To Review Generic qui ments i
SUBJECT:
DRAFT FINAL RULE TO REVISE REQUIREMENTS OF 10 CFR PARTS,50 AND 72 CONCERNING CHANGES, TESTS AND EXPERIMENTS l
The Committee To Review Generic Requirements (CRGR) held a special meeting on Thursday, May 6,1999, from 1:00 p.m. to 3:30 p.m. At this meeting, the staff presented for CRGR review and endorsement the subject draft final amendments. The Committee complimented the staff for the technical approach embodied in the rule a'nd for developing one of the best Statement of Considerations it has seen in the recent years.
Pending issuance of the final meeting minutes, the purpose of this memorandum is to inform you of the issues raised by the Committee. Without reviewing the staff guidance (associated regulatory guide and inspection guidance), the Committee is at a disadvantage with respect to assessing the backfit implications of the rule and is concerned about the implementation aspects of this rule. Therefore, CP,GR requested the opportunity to review the associated I
regulatory guide and inspection guidance when they are available.
The Committee believes that the different components of this rulemaking identify a seamless process, each step of which is necessary. Thus, this rule change must be considered in its
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entirety. The proposed amendments taken integrally are definite improvements both in the regulatory process as well as in the use of staff resources, and net relaxations in requirements.
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The Committee recommends going forward to the Commission with these amendments.
We also note that if individually considered, various elements of this rulemaking may be interpreted as backfits because they will either require the licensees to modify existing procedures or codify voluntary actions not previously required by the NRC's regulations. For example, the new Subsection (c)(3) will now explicitly include within the scope of the rule evaluations performed subsequent to the last update of the FSAR. This is a new requirement.
Further, the new Subsections (2) vii and (2) viii are new requirements. However, without the j
advantage of having the staff guidance to review,it is arguable whether the new Subsections (2) vil and (2) viii impose an increase or a decrease in burden. Therefore, in parallel with G
9909030048 990602 PDR REVQP tetGCRGR MEETING 341 PDR
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W. J. Travers 2-developing the guidance documents, the Committee recommends consideration of the need to make clear if a burden reduction is associated with Subsections (2) vii and (2) viii, and if a
- modification of the Regulatory Analysis is warranted.
As always, I am available to discuss this matter further.
cc:
F. Miraglia M.Knapp J. Johnson, Ril B. Sheron I
. M. Virgilio M. Federline 4
J. Moore W. Kane B. Mallett S. Collins D. Matthews 4