ML092380476

Draft Regulatory Guide 7.3, Rev 1, Procedures for Picking Up and Receiving Packages of Radioactive Material

ML092380476
Person / Time
Issue date:	09/30/2009
From:	Bernie White NRC/NMSS/SFST
To:	Michael Case NRC/RES/DE
White B, NMSS/SFST 492-3303
Shared Package
ML092730475	List: ML092380476
References
RG 7.003
Download: ML092380476 (4)

Text

U.S. NUCLEAR REGULATORY COMMISSION September 2009 OFFICE OF NUCLEAR REGULATORY RESEARCH Division 7 DRAFT REGULATORY GUIDE DRAFT REGULATORY GUIDE 70xx (Proposed Revision 1 of Regulatory Guide 7.3, dated May 1975)

PROCEDURES FOR PICKING UP AND RECEIVING PACKAGES OF RADIOACTIVE MATERIAL A. INTRODUCTION This guide describes an approach that the staff of the U.S. Nuclear Regulatory Commission (NRC) considers acceptable for preparing operating procedures for transportation packages used to ship radioactive material. Title 10, Code of Federal Regulations (10 CFR) 20.1906, Procedures for receiving and opening packages (Ref. 1), and 10 CFR 71.89, Opening instructions, require each licensee to have specific written procedures and to follow those procedures for receiving and opening packages containing radioactive material.

This regulatory guide endorses the methods and procedures in NUREG/CR-4775, Guide for Preparing Operating Procedures for Shipping Packages (Ref. 2), as a process that the NRC staff has found acceptable for meeting both regulatory requirements.

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, U.S. 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 XXXXXXXXXX.

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. ML09XXXXXXX.

This regulatory guide contains information collection requirements covered by 10 CFR Parts 20 and 71 that the Office of Management and Budget (OMB) approved under OMB control number 3150-0014 and 3150-0008, respectively. 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 The regulations in Part 20 establish procedures and criteria to control the receipt, possession, use, transfer, and disposal of licensed material by any licensee in such a manner that the total dose to an individual (including doses resulting from licensed and unlicensed radioactive material and from radiation sources other than background radiation) does not exceed the standards for protection against radiation prescribed in the regulations in this part.

NRC has developed NUREG/CR-4775, Guide for Preparing Operating Procedures for Shipping Packages (Ref. 2) to provide guidance on preparing operating procedures that are acceptable for handling packages containing radioactive material, consistent with the requirements in Part 71, which are also applicable for meeting the requirements of 10 CFR for receiving and opening packages.

C. REGULATORY POSITION This regulatory guide endorses the method described in NUREG/CR-4775, Guide for Preparing Operating Procedures for Shipping Packages, as an acceptable method for preparing operating procedures for pick-up, receipt, and monitoring of transportation packages containing radioactive material.

D. IMPLEMENTATION This section provides information to applicants and licensees about NRCs plans for using this regulatory guide. 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.

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.

REGULATORY ANALYSIS

1. Statement of the Problem NRC published the original Regulatory Guide 7.3 in May 1975, to provide licensees with Agency-approved guidance for complying with the then-current version of Part 20. NRCs implementation

of a risk-informed, performance-based approach, combined with multiple updates and revisions to the regulations, makes the current regulatory guide outdated.

2. Objective As part of a review of transportation guidance, NRC recognized a void in guidance for preparing operating procedures for transportation packages. Additionally, there was significant variation in the level of detail in the operating procedures section of applicants safety analysis reports for transportation packages. Consequently, the staff published NUREG/CR-4775, to fill the void and provide clarification to applicants.

The objective of this action is to provide clear and up-to-date information to support consolidated guidance for procedures for package receipt and opening.

3. Alternative Approaches The NRC staff considered the following alternative approaches:

• Do not revise Regulatory Guide 7.3.

• Withdraw Regulatory Guide 7.3.

• Revise Regulatory Guide 7.3 to match or replace NUREG/CR-4775.

• Revise Regulatory Guide 7.3 to endorse NUREG/CR-4775.

3.1 Alternative 1: Do Not Revise Regulatory Guide 7.3.

Under this alternative, NRC would not revise this document, 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, considered the baseline or no-action alternative, involves no value/impact considerations.

3.2 Alternative 2: Withdraw Regulatory Guide 7.3.

Withdrawing this regulatory guide would eliminate the duplicative and potentially contradictory information that currently exists in NUREG/CR-4775 and Regulatory Guide 7.3.

However, this action would leave a void in the regulatory guide system. Although NUREG-1609, Standard Review Plan for Transportation Packages for Radioactive Material (Ref. 3) and NUREG-1617, Standard Review Plan for Transportation Packages for Spent Nuclear Fuel (Ref. 4) both contain guidance on staff expectations for operating procedures for transportation packages, these documents are guidance to the staff, not applicants.

3.3 Alternative 3: Revise Regulatory Guide 7.3 to Match or Replace NUREG/CR-4775.

NUREG/CR-4775, published in July 1998, provides consolidated guidance on preparing operating procedures for transportation packages. Regulatory Guide 7.3 contains specific guidance about only one of the many areas covered in NUREG/CR-4775. Revising the regulatory guide to match the information in NUREG/CR-4775 would create duplicate sources of information and would require continuing staff resources to ensure that the separate documents continued to contain duplicate information. Revising this regulatory guide to replace

NUREG/CR-4775 would require substantial expansion of the current guide and a large expenditure of labor without a noticeable enhancement in performance or efficiency for NRC or its licensees. This alternative is considered to be an unnecessary use of staff resources.

3.4 Alternative 4: Revise Regulatory Guide 7.3 to Endorse NUREG/CR-4775.

The May 1975 version of the regulatory guide contains outdated guidance for satisfying the requirements of Parts 20 and 71. Failure to revise the regulatory guide will result in continuing to have conflicting guidance documents with the possibility of confusing interested parties. Therefore, the staff has chosen to revise the regulatory guide to direct any interested parties to the guidance provided in NUREG/CR-4775.

4. Conclusion Based on this regulatory analysis, the staff recommends that NRC revise Regulatory Guide 7.3 to endorse NUREG/CR-4775, and thereby provide applicants with guidance on preparing operating procedures for receiving and opening packages containing radioactive material. The staff has concluded that the proposed action will reduce unnecessary burden on both 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.

REFERENCES1

1. 10 CFR Part 20, Standards for Protection Against Radiation, U.S. Nuclear Regulatory Commission, Washington, DC.

2. NUREG/CR-4775, Guide for Preparing Operating Procedures for Shipping Packages, U.S. Nuclear Regulatory Commission, Washington DC, July 1998.

3. NUREG-1609, Standard Review Plan for Transportation Packages for Radioactive Material, U.S. Nuclear Regulatory Commission, Washington DC, March 1999.

4. NUREG-1617, Standard Review Plan for Transportation Packages for Spent Nuclear Fuel, U.S. Nuclear Regulatory Commission, Washington DC, March 2000.

1 Publicly available NRC-published documents such as Regulations, Regulatory Guides, NUREGs, and Generic Letters listed herein are available electronically through the Electronic Reading room on 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 e-mail PDR.Resource@nrc.gov.