ML101720311

Regulatory Analysis to Regulatory Guide 4.16, Revision 2

ML101720311
Person / Time
Issue date:	12/15/2010
From:	Office of Nuclear Regulatory Research
To:
Bayssie Mekonen/RES 251-7489
Shared Package
Ml101720225	List: ML101720311 Regulatory Guide 4.16
References
DG-4017
Download: ML101720311 (2)

Text

REGULATORY ANALYSIS Proposed Revision 2 of Regulatory Guide (RG) 4.16, Monitoring And Reporting Radioactive Materials In Liquid And Gaseous Effluents From Nuclear Fuel Cycle Facilities.

Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) staff issued Revision 1 to Regulatory Guide 4.16, Monitoring and Reporting Radioactivity in Releases of Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication Plants and Uranium Hexaflouride Production Plants, in December 1985. Revision of this regulatory guide is necessary to update references and practices and to communicate its applicability to the enrichment plants which have come under the regulatory authority of the NRC since the issuance of Revision 1 of the guide.

Objective The objective of this regulatory guidance is to communicate an acceptable method and practice for collecting and documenting information on the identity, concentration, and quantity of radionuclides in liquid and gaseous effluents from uranium enrichment plants, nuclear fuel processing and fabrication plants, and uranium hexafluoride production plants.

A degree of uniformity in the programs for monitoring and reporting data on radioactive material in effluents is essential. This guide provides a basis for uniform reporting, for comparing data from different sources, and for permitting the preparation of consistent summaries for use by the NRC staff as the basis for assessing a licensees effluent controls and the potential environmental impact of radioactive material in effluents.

Alternative Approaches The NRC staff considered the following alternative approaches:

Do not revise Regulatory Guide 4.16.

Revise Regulatory Guide 4.16.

Alternative 1: Do Not Revise Regulatory Guide 4.16 Under this alternative, the NRC would not revise the guidance, and the current guidance would be retained. If the NRC does not take action, there would not be any changes in costs or benefit to the public, licensees, or the NRC. However, the no-action alternative would not address the concerns identified with the current version of the regulatory guide. The NRC would continue to review each application on a case-by-case basis. This alternative provides a baseline condition from which any other alternatives will be assessed.

Alternative 2: Revise Regulatory Guide 4.16 Under this alternative, the NRC would revise Regulatory Guide 4.16, taking into consideration that this guidance is now meant to encompass uranium enrichment facilities and that industry standards and other regulatory guidance with applicability to this subject have been developed since the last revision of the guide was issued.

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One benefit of this action is that it would enhance uniformity among licensees and make NRC guidance consistent with current industry standards and guidance applicable to this subject area.

The impact to the NRC would be the costs associated with preparing and issuing the revised regulatory guide. The impact to the public would be the voluntary costs associated with reviewing and providing comments to the NRC during the public comment period. The value to NRC staff and its applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license applications and other interactions between the NRC and its regulated entities.

Conclusion Based on this regulatory analysis, the NRC staff recommends revision of Regulatory Guide 4.16.

The staff concludes that the proposed action will enhance the collection and documentation of information on the identity, concentration, and quantity of radionuclides in liquid and gaseous effluents from uranium enrichment plants, nuclear fuel processing and fabrication plants, and uranium hexafluoride production plants. It could also lead to cost savings for the industry, especially with regard to the efficiency of the NRC staffs review of effluent impact, which includes: (1) reviewing the licensees estimates of the potential annual radiation doses to the public; (2) determining whether the licensee met the requirements of applicable regulations and kept concentrations of radioactive material in liquid and gaseous effluents as low as is reasonably achievable (ALARA); and (3) assessing the adequacy and performance of the licensees effluent controls.

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