ML080910452
| ML080910452 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/2008 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Orr M/RES/415-6373 | |
| Shared Package | |
| ML080910445 | List: |
| References | |
| DG-3033 RG-3.025, Rev. 1 | |
| Download: ML080910452 (5) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION May 2008 OFFICE OF NUCLEAR REGULATORY RESEARCH Division 3 DRAFT REGULATORY GUIDE
Contact:
M. Orr (301) 415-6373 DRAFT REGULATORY GUIDE DG-3033 (Proposed Revision 1 of Regulatory Guide 3.25, dated December 1974)
STANDARD FORMAT AND CONTENT OF SAFETY ANALYSIS REPORTS FOR URANIUM ENRICHMENT FACILITIES A. INTRODUCTION This regulatory guide directs the reader to the type of information acceptable to the U.S. Nuclear Regulatory Commission (NRC) staff for review of a safety analysis report (SAR) for uranium enrichment facilities.1 This document also refers the reader to guidance on the standard format and content of SARs and other documents submitted as part of an application to construct or modify and operate a nuclear fuel cycle facility. Title 10, Part 70, Domestic Licensing of Special Nuclear Material, Subpart H, Additional Requirements for Certain Licensees Authorized to Possess a Critical Mass of Special Nuclear Material, of the Code of Federal Regulations (10 CFR Part 70, Subpart H) (Ref. 1) identifies risk-informed performance requirements and requires applicants to complete an integrated safety analysis (ISA) and submit an ISA summary and other information to the NRC for approval.
This regulatory guide endorses the standard format and content for SARs and ISA Summaries described in the current revision of NUREG-1520, Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility (Ref. 2), as a process that the NRC staff finds acceptable for meeting the regulatory requirements.
The NRC issues regulatory guides to describe to the public methods that the staff considers acceptable for use in implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations and compliance with them is not required.
1 The SAR may be a separate report submitted as part of the application or may be integrated into the license application.
This regulatory guide is being issued in draft form to involve the public in the early stages of the development of a regulatory position in this area. It has not received final staff review or approval and does not represent an official NRC final staff position.
Public comments are being solicited on this draft guide (including any implementation schedule) and its associated regulatory analysis or value/impact statement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rulemaking, Directives, and Editing Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; emailed to NRCREP@nrc.gov; submitted through the NRCs interactive rulemaking Web page at http://www.nrc.gov; faxed to (301) 415-5144; or hand-delivered to Rulemaking, Directives, and Editing Branch, Office of Administration, US NRC, 11555 Rockville Pike, Rockville, MD 20852, between 7:30 a.m. and 4:15 p.m. on Federal workdays. Copies of comments received may be examined at the NRCs Public Document Room, 11555 Rockville Pike, Rockville, MD. Comments will be most helpful if received by July 25, 2008.
Electronic copies of this draft regulatory guide are available through the NRCs interactive rulemaking Web page (see above);
the NRCs public Web site under Draft Regulatory Guides in the Regulatory Guides document collection of the NRCs Electronic Reading Room at http://www.nrc.gov/reading-rm/doc-collections/; and the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML080910452.
DG-3033, Page 2 This regulatory guide contains information collection requirements covered by 10 CFR Part 70 that the Office of Management and Budget (OMB) approved under OMB control number 3150-0009.
The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.
B. DISCUSSION As part of its redesign of the materials licensing program, the NRC consolidated and updated guidance documents for fuel cycle facilities license applications and revisions in NUREG-1520. Various chapters of NUREG-1520 provide current, program-specific guidance and review procedures for facility and site descriptions, ISA and ISA Summaries, environmental protection, and management measures.
NUREG-1520 is available electronically through the Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1520/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. The mailing address for the PDR is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; and email PDR@nrc.gov.
In addition, copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Information Service (NTIS), at 5285 Port Royal Road, Springfield, VA 22161, online at http://www.ntis.gov, by telephone at (800) 553-NTIS (6847) or (703) 605-6000, or by fax to (703) 605-6900.
C. REGULATORY POSITION This regulatory guide endorses the method(s) of formatting and submitting a SAR or an ISA Summary for a uranium enrichment facility described in the current revision of NUREG-1520 as a process the NRC has found acceptable for meeting the regulatory requirements.
D. IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees regarding the NRCs plans for using this draft regulatory guide. The NRC does not intend or approve any imposition or backfit in connection with its issuance.
The NRC has issued this draft guide to encourage public participation in its development. The NRC will consider all public comments received in development of the final guidance document. In some cases, applicants or licensees may propose an alternative or use a previously established acceptable alternative method for complying with specified portions of the NRCs regulations. Otherwise, the methods described in this guide will be used in evaluating compliance with the applicable regulations for license applications, license amendment applications, and amendment requests.
DG-3033, Page 3 REGULATORY ANALYSIS
- 1.
Statement of the Problem The NRC published Regulatory Guide 3.25, Standard Format and Content of Safety Analysis Reports for Uranium Enrichment Facilities, in December 1974 to provide licensees and applicants with agency-approved guidance for complying with the then-current regulations for uranium enrichment facilities contained in 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities (Ref. 3). Since the initial publication of the regulatory guide, the requirements for uranium fuel cycle facilities, including uranium enrichment facilities, have been expanded and relocated to 10 CFR Part 70.
The current 10 CFR Part 70 identifies a risk-informed, performance-based approach which makes the existing regulatory guide outdated.
- 2.
Objective As part of its redesign of the materials licensing program, the NRC consolidated and updated guidance documents for fuel cycle facilities license applications and revisions in NUREG-1520. Various chapters of NUREG-1520 provide current, program-specific guidance and example procedures for facility and site descriptions, ISA and ISA Summaries, environmental protection, and management measures.
The objective of this action is to provide clear and up-to-date information to support consolidated guidance for the preparation of a SAR or an ISA Summary by uranium enrichment facilities.
- 3.
Alternative Approaches The NRC staff considered the following alternative approaches:
Do not revise Regulatory Guide 3.25.
Withdraw Regulatory Guide 3.25.
Revise Regulatory Guide 3.25 to match or replace NUREG-1520.
Revise Regulatory Guide 3.25 to endorse NUREG-1520.
3.1 Alternative 1: Do Not Revise Regulatory Guide 3.25 Under this alternative, the NRC would not revise this guidance, and applicants would continue to use the original version of this regulatory guide. However, this alternative would leave conflicting guidance in place and could cause unnecessary confusion. This alternative is considered the baseline or no action alternative and, as such, involves no value/impact considerations.
3.2 Alternative 2: Withdraw Regulatory Guide 3.25 Withdrawing this regulatory guide would eliminate the problem of duplicate and occasionally contradictory information appearing in NUREG-1520 and this guide. However, this action would leave a void in the regulatory guide system and provide no quick means for interested parties to identify the standard format and content of a SAR for a uranium enrichment facility that the NRC finds acceptable.
Although this alternative would cost relatively little, it could impede the publics access to the most current information.
DG-3033, Page 4 3.3 Alternative 3: Revise Regulatory Guide 3.25 to Match or Replace NUREG-1520 The NRC first published NUREG 1520 in March 2002 to provide guidance on the format and content of the license application for a fuel cycle facility. Regulatory Guide 3.25 contains specific guidance about one of the many areas covered in NUREG 1520. Revising the regulatory guide to match the information in NUREG 1520 would create duplicate sources of information and would require ongoing staff resources to ensure that the separate documents continued to contain duplicate information.
Revising this regulatory guide to replace NUREG 1520 at this time would require an expansion in scope of the current guide and an expenditure of staff resources without a noticeable enhancement in performance or efficiency for the NRC or its licensees. This alternative is considered to be an unnecessary use of staff resources at this time.
3.4 Alternative 4: Revise Regulatory Guide 3.25 to Endorse NUREG-1520 The December 1974 version of the regulatory guide is based on the regulatory requirements contained in 10 CFR Part 50, while 10 CFR Part 70 contains the most current regulatory requirements for uranium enrichment facilities. Failure to revise the regulatory guide will result in conflicting guidance documents and the possible confusion of interested parties. Therefore, the staff has chosen to revise the regulatory guide to direct any interested parties to the most current guidance provided in NUREG-1520.
- 4.
Conclusion Based on this regulatory analysis, the staff recommends that the NRC revise Regulatory Guide 3.25 to endorse the SAR guidance in the current revision of NUREG-1520. The staff concludes that the proposed action will reduce unnecessary burden on both the NRC and its licensees and will result in an improved and more uniform process. Moreover, the staff sees no adverse effects associated with issuing this regulatory guide.
DG-3033, Page 5 REFERENCES
- 1.
10 CFR Part 70, Domestic Licensing of Special Nuclear Material, Subpart H, Additional Requirements for Certain Licensees Authorized to Possess a Critical Mass of Special Nuclear Material, of the Code of Federal Regulations (10 CFR Part 70, Subpart H), U.S. Nuclear Regulatory Commission, Washington, DC.2
- 2.
NUREG-1520, Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility, U.S. Nuclear Regulatory Commission, Washington, DC.3
- 3.
10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, U.S. Nuclear Regulatory Commission, Washington, DC.
2 All NRC regulations listed herein are available electronically through the Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD; the mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; and email PDR@nrc.gov.
3 NUREG-1520 was published by the U.S. Nuclear Regulatory Commission. The report is available electronically through the Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1520/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. The mailing address for the PDR is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; and email PDR@nrc.gov.
In addition, copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Information Service (NTIS),
at 5285 Port Royal Road, Springfield, VA 22161, online at http://www.ntis.gov, by telephone at (800) 553-NTIS (6847) or (703) 605-6000, or by fax to (703) 605-6900.