ML110400310
| ML110400310 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/2012 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Karagiannis H, 301-251-7477 | |
| Shared Package | |
| ML110400229 | List: |
| References | |
| DG-8040 RG-8.024, Rev. 2 | |
| Download: ML110400310 (2) | |
Text
REGULATORY ANALYSIS REGULATORY GUIDE 8.24HEALTH PHYSICS SURVEYS DURING ENRICHED URANIUM-235 PROCESSING AND FUEL FABRICATION (Draft was issued as DG-8040, dated March 2010)
Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) published Regulatory Guide 8.24, Health Physics Survey during Enriched Uranium-235 Processing and Fuel Fabrication, in October 1979 to identify the types and frequencies of surveys that the NRC considers acceptable for the protection of workers in plants licensed by the agency to process enriched uranium and fabricate uranium fuel.
With the recent surge in new applications for fuel cycle facilities, the NRC recognizes the need for significant revision of this guide to reflect changes in the applicable NRC regulations and to include the addition of American National Standards Institute guidance and other updated references.
Objective The objective of this regulatory action is to provide a more useful and up-to-date version of the guidance for the conduct of appropriate health physics surveys for fuel cycle facilities. Since the NRC issued the original guide, the NRC has revised calibration frequencies and criteria.
Alternative Approaches The NRC staff considered the following alternative approaches:
Do not revise Regulatory Guide 8.24.
Issue a new regulatory guide.
Revise Regulatory Guide 8.24.
Alternative 1: Do Not Revise Regulatory Guide 8.24 Under this alternative, the NRC would not revise this guidance, and the current version would be retained. If the NRC does not take action, there would not be any changes in costs or benefits to the public, licensees, or the NRC. However, the no-action alternative would not address identified concerns and regulatory changes and would fail to provide licensees with a regulatory standard that could be cited as part of an application and to save time in the completion of the document review.
Alternative 2: Issue a New Regulatory Guide Under this alternative, the NRC would withdraw Regulatory Guide 8.24 and replace it with a new guide. With this action, the NRC would revise the guidance and include regulatory changes that would benefit licensees. The impact to the NRC would be the resource commitment in preparing and issuing an entirely new guide and in properly notifying licensees of the replacement of guidance that has been standing for nearly 30 years.
Page 2 Alternative 3: Revise Regulatory Guide 8.24 Under this alternative, the NRC would revise Regulatory Guide 8.24. This action would address important aspects of regulatory changes to fuel cycle facility surveys and would include updated references such as American National Standards Institute standards and National Council on Radiation Protection and Measurements guidance. Much of the guidance remains unchanged, which justifies the revision of a guide that is familiar to applicants and that offers continuity for the NRC staff without a major change. The cost to the NRC of issuing the revised regulatory guide in a timely manner is estimated to be relatively small.
Conclusion Based on this regulatory analysis, the staff recommends that the NRC revise Regulatory Guide 8.24. The staff concludes that the proposed action will enhance the licensing practices of fuel cycle licensees and provide practical and up-to-date guidance for conducting surveys.