ML101470350
| ML101470350 | |
| Person / Time | |
|---|---|
| Issue date: | 05/27/2010 |
| From: | Ty Naquin Office of Nuclear Material Safety and Safeguards |
| To: | |
| Orr, Mark 301-251-7495 | |
| Shared Package | |
| ML101470137 | List: |
| References | |
| DG-3040 RG-3.013, Rev 1 | |
| Download: ML101470350 (2) | |
Text
5/27/2010 Page 1 REGULATORY ANALYSIS Proposed Revision 1 to Regulatory Guide 3.13, Design, Construction, and Inspection of Embankment Retention Systems at Fuel Cycle Facilities.
Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) published Regulatory Guide 3.13, Guide for Acceptable Waste Storage Methods at UF6 Production Plants, in October 1973 to provide general guidance for UF6 production facility licensees in design guidelines acceptable to the regulatory staff for the safe storage of radioactive wastes using embankment retention systems.
With the expectation of new applications for fuel cycle facilities, the NRC recognizes the need for significant revision of this guide to address newer technology and environmental considerations. The NRC is revising this guidance to provide regulatory recommendations and positions that focus on more modern designs with perimeter embankments.
Objective The objective of this regulatory action is to provide a more useful and up-to-date version of the guidance for UF6 production and other fuel cycle facility operation retention structures. The original regulatory guide also briefly addressed solid radioactive waste storage. Management of solid radioactive waste is a more comprehensive subject, with extensive requirements and will not be addressed in this guide1. This regulatory guide does not apply to uranium recovery or milling operations.
Alternative Approaches The NRC staff considered the following alternative approaches:
Do not revise Regulatory Guide 3.13.
Revise Regulatory Guide 3.13 Alternative 1: Do Not Revise Regulatory Guide 3.13 Under this alternative, the NRC would not revise this guidance, and the original version of this regulatory guide would continue to be available. This alternative is considered the baseline or no action alternative and, as such, involves no value/impact considerations.
Alternative 2: Revise Regulatory Guide 3.13 Under this alternative, the NRC would revise Regulatory Guide 3.13 with consideration of the need to address current regulations and prepare for multiple new license applications. This action would address an important aspect of new fuel cycle facility license applications and would replace old, outdated, and inapplicable guidance with updated guidance that focuses on a regulatory framework that has changed since Regulatory Guide 3.13 was first written. A benefit of this action is that it would enhance fuel cycle facility safety by providing guidance to applicants that will help ensure that the design 1
NUREG/BR-0216, Radioactive Waste: Production, Storage, and Disposal, Rev. 2, U.S. Nuclear Regulatory Commission, Washington, DC, May 2002.
5/27/2010 Page 2 of fuel cycle facility waste retention systems meets todays regulations, resulting in impoundments that are safe and protective of the environment.
The costs to the NRC would be the one-time cost of issuing the revised regulatory guide (which is expected to be relatively small), and applicants would incur little or no cost.
Conclusion Based on this regulatory analysis, the staff recommends that the NRC revise Regulatory Guide 3.13. The staff concludes that the proposed action will enhance uranium fuel cycle facility safety by providing up-to-date guidance on design and construction of embankment retention systems.
Applicants and licensees can use this guidance to ensure that new facilities are constructed to be safe and protective of the environment and to help ensure the NRCs timely and efficient review of submitted designs.