ML110120351

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Regulatory Analysis for Rg 4.20
ML110120351
Person / Time
Issue date: 04/30/2012
From:
Office of Nuclear Regulatory Research
To:
Bayssie, Mekonen, RES/DE/RGDB 251-7489
Shared Package
ML110100839 List:
References
DG-4018 RG-4.020, Rev 1
Download: ML110120351 (2)


Text

REGULATORY ANALYSIS PROPOSED REVISION 1 OF REGULATORY GUIDE 4.20 CONSTRAINT ON RELEASES OF AIRBORNE RADIOACTIVE MATERIALS TO THE ENVIRONMENT FOR LICENSEES OTHER THAN POWER REACTORS (Draft was issued as DG-4018, dated June 10, 2010)

Statement of the Problem This regulatory guide is being updated to reflect the applicability of references, to clarify the subject matter, and to be consistent in format with other regulatory guides.

Objective The objective of this regulatory action is to clarify the applicability of the constraint on air emissions of radioactive material to the environment and acceptable methods for demonstrating that the constraint is met.

Alternative Approaches The U.S. Nuclear Regulatory Commission (NRC) staff considered the following alternative approaches:

Do not revise Regulatory Guide 4.20.

Revise Regulatory Guide 4.20.

Alternative 1: Do Not Revise Regulatory Guide 4.20 Under this alternative, the NRC would not revise or issue additional 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, the licensees, or the NRC. However, the no-action alternative would not address identified concerns 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 4.20 Under this alternative, the NRC would revise Regulatory Guide 4.20, taking into consideration the applicability and availability of referenced documents and guidance.

One benefit of this action is that it would further clarify the applicability of the guidance and its references and clarify methods that a licensee can use to demonstrate that it meets the constraint.

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 the NRC staff and its applicants would be the benefits associated with enhanced efficiency and effectiveness in using 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 4.20.

The staff concludes that the proposed action will clarify the methods acceptable for licensees to demonstrate that they have met the constraint on air emissions of radioactive material to the environment.

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