Atomic Energy Act of 1954, as amended. The Board has been following with considerable interest the structure of DOE's nuclear health and safety requirements as the transition is being made from the use of Orders to rulemaking. Thus the Board understands the reasons for development and promulgation of nuclear safety requirements through rulemaking. In fact, your response reflected more completely the process that has been developed in discussions with the Board and its staff. Rules are the documents by which the DOE establishes binding requirements of general applicability and are adopted pursuant to the Administrative Procedures Act.
Rules actually require an implementation plan and then allow a period for achieving compliance.
This summary clearly shows that DOE intends that the definition of what constitutes adequacy in the way of protection of workers and the public extends beyond the requirements of rules. In that, the Board definitely concurs. It is the compilation of requirements as envisaged for RIDs that represents the more comprehensive base upon which sites and facilities are to be managed from the environment, health and safety viewpoint. This has also been the thrust of many of the Board recommendations dealing with Order compliance. Requirements in Orders have been and are still the prevailing DOE means for defining safety requirements for contractors.