ML103370659
| ML103370659 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/2011 |
| From: | Kevin Ramsey Office of Nuclear Regulatory Research |
| To: | |
| O'Donnell, Edward, RES/DE/RGB 251-7455 | |
| Shared Package | |
| ML103360486 | List: |
| References | |
| DG-3039 RG 3.67, REV 1 | |
| Download: ML103370659 (2) | |
Text
REGULATORY ANALYSIS REGULATORY GUIDE 3.67 STANDARD FORMAT AND CONTENT FOR EMERGENCY PLANS FOR FUEL CYCLE AND MATERIALS FACILITIES Draft was issued as DG-3039, dated May 2010 Statement of the Problem Regulatory Guide 3.67 was published in January 1992. Since that time, new regulations have been published and experience has been gained with the implementation of material and fuel cycle emergency plans. Revision of this regulatory guidance is necessary to update and improve the information provided.
Objective The objective of this regulatory action is to update the guidance.
Alternative Approaches The U.S. Nuclear Regulatory Commission (NRC) staff considered the following alternative approaches:
Do not revise Regulatory Guide 3.67.
Revise Regulatory Guide 3.67.
Alternative 1: Do Not Revise Regulatory Guide 3.67.
Under this alternative, NRC would not revise the guidance, and the current guidance would be retained. If NRC does not take action, there would not be any changes in costs or benefit to the public, licensees or NRC. However, the no-action alternative would not address identified concerns with the current version of the regulatory guide. 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 3.67.
Under this alternative, NRC would revise Regulatory Guide 3.67, taking into consideration the new regulations and experience gained since 1992.
One benefit of this action is that it would clarify how the guidance applies to new regulations in 10 CFR Parts 63, 70, 72, and 76. Another benefit is the addition of information regarding the marking and control of sensitive information under policies that were revised after the terrorist attacks on September 11, 2001.
The impact on NRC would be the costs associated with preparing and issuing the regulatory guide revision. There may be some voluntary costs to licensees and applicants associated with implementing this guidance, however that cost should be low. The impact on the public would be the voluntary costs associated with reviewing and providing comments to NRC during the public comment
Rev. 1 of RG 3.67, Page 2 period. The value to NRC 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 NRC and its regulated entities.
Conclusion Based on this regulatory analysis, the NRC staff recommends revision of Regulatory Guide 3.67. The staff concludes that the proposed action will enhance the quality of emergency plans submitted by material and fuel cycle licensees. It could also lead to cost savings for the industry, especially with regard to the need to provide additional information and revisions when emergency plans are submitted for approval.