ML091050072
| ML091050072 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/2009 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Karagiannis H, 301-415-6377 | |
| Shared Package | |
| ML091050067 | List: |
| References | |
| DG-3031 | |
| Download: ML091050072 (5) | |
Text
May 2009 1
Response to Public Comments on Draft Regulatory Guide DG-3031, Standard Format and Content for License Renewal Applications for Uranium Processing and Fuel Fabrication, Proposed Revision 2 of Regulatory Guide 3.52 A notice regarding the availability of Draft Regulatory Guide (DG)-3031 (proposed Revision 2 of Regulatory Guide (RG) 3.52) for public comment was published in the Federal Register (FR) on September 11, 2008 (73 FR 52890). The U.S. Nuclear Regulatory Commission (NRC) received comments from the following:
Felix M. Killar, Jr., Senior Director Fuel Supply/Material Licensees Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street NW, Suite 400 Washington, DC 20006 Agencywide Documents Access and Management System (ADAMS)
Accession No. ML083190389 Gerard Couture, Manager Licensing and Regulatory Programs Columbia Fuel Fabrication Facility Westinghouse Electric Company, LLC Columbia, SC 29250 ADAMS Accession No. ML083020054 The NRC staff has combined the comments and their disposition in the following table.
Originator Section of DG-3031 Specific Comments NRC Resolution NEI Section B, Standard Form and
- Content, last paragraph The last paragraph describes situations where the NRC may approve license terms for less than the maximum 40-year time period authorized by the 2006 policy. The examples given may imply to some persons that NRC may only approve license terms at less than the maximum in unique or new situations which may be of concern in longer term operations. In fact, there are several other reasons why a licensee may chose to request a shorter term license renewal, or NRC may choose not to authorize the maximum time period.
The staff has revised Section B to incorporate the comment.
May 2009 2
Originator Section of DG-3031 Specific Comments NRC Resolution SuggestionEdit the last sentence to merely state that The NRC may approve license terms for less than 40 years on a case-by-case basis.
NEI Sections A and B Sections A and B use the term specific information and specific guidance in several places when referencing NUREG-1520, which implies a prescriptive approach to achieving regulatory compliance.
SuggestionDelete the term specific since NUREG-1520 is only one suggested method for compliance with the performance-based regulations.
The staff changed Section A, 3rd paragraph to read:
While the regulations provide general information for filing license renewal applications, NUREG-1520 provides NRC guidance for reviewing and evaluating the health, safety, and environmental protection aspects of applications for licenses to possess and use SNM [special nuclear material] at fuel cycle facilities.
In addition, this guidance describes the scope, level of detail, and acceptance criteria for reviews. Thus, this NUREG also serves as guidance on the information to be included in licensing applications and establishes a format for presenting the information.
The staff changed Section B, 2nd paragraph to read:
In addition, because NUREG-1520 describes the scope, level of detail, and acceptance criteria for reviews, it serves as regulatory guidance for licensees who need to determine what information to present in a license renewal application.
The staff changed Section B, 5th paragraph to read:
Appendix A, Filing Standards for Submittals, to NUREG-1520 provides additional guidance regarding the acceptable and preferred format for new and renewal applications.
May 2009 3
Originator Section of DG-3031 Specific Comments NRC Resolution NEI General Since NUREG-1520 already states in the Executive Summary that it serves as regulatory guidance for license applications and related documents, it appears that this additional Regulatory Guide is redundant and unnecessary.
SuggestionConsideration should be given to adding the 40-year license term issue to NUREG-1520 and eliminating this Regulatory Guide.
Eliminating or withdrawing this regulatory guide would leave a void in the regulatory guide system and would not provide interested parties with a quick means to identify the standard format and content of a license application for uranium processing and fuel fabrication that the NRC finds acceptable.
The staff passed this comment along to the NUREG-1520 Workgroup.
Westinghouse Section B, last paragraph Section B, last paragraph describes situations where the NRC may approve license terms for less than the maximum 40-year time period authorized by the 2006 policy. The examples given may imply to the general public that NRC may only approve terms at less than the maximum in unique or new situations that are of some concern for a longer term operation. There are several other reasons that a licensee may chose to request a shorter term license renewal, or NRC may choose not to authorize the maximum time period.
Suggest this last sentence merely state The NRC may approve license terms for less than 40 years on a case by case basis.
The staff has revised Section B to incorporate the comment.
May 2009 4
Originator Section of DG-3031 Specific Comments NRC Resolution Westinghouse Sections A and B Sections A and B use the term specific information and specific guidance in several places when referencing NUREG-1520.
Suggest deleting the term specific because NUREG-1520 is only one suggested method for compliance with the Regulations.
The staff changed Section A, 3rd paragraph to read:
While the regulations provide general information for filing license renewal applications, NUREG-1520 provides NRC guidance for reviewing and evaluating the health, safety, and environmental protection aspects of applications for licenses to possess and use SNM at fuel cycle facilities. In addition, this guidance describes the scope, level of detail, and acceptance criteria for reviews. Thus, this NUREG also serves as guidance on the information to be included in licensing applications and establishes a format for presenting the information.
The staff changed Section B, 2nd paragraph to read:
In addition, because NUREG-1520 describes the scope, level of detail, and acceptance criteria for reviews, it serves as regulatory guidance for licensees who need to determine what information to present in a license renewal application.
The staff changed Section B, 5th paragraph to read:
Appendix A, Filing Standards for Submittals, to NUREG-1520 provides additional guidance regarding the acceptable and preferred format for new and renewal applications.
May 2009 5
Originator Section of DG-3031 Specific Comments NRC Resolution Westinghouse General Since NUREG-1520 already states in the Executive Summary that it serves as regulatory guidance for license applications and related documents, it appears that this additional Regulatory Guide is redundant and unnecessary.
Eliminating or withdrawing this regulatory guide would leave a void in the regulatory guide system and would not provide interested parties with a quick means to identify the standard format and content of a license application for uranium processing and fuel fabrication that the NRC finds acceptable.
The staff passed this comment along to the NUREG-1520 Workgroup.