ML19309C822
| ML19309C822 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1979 |
| From: | Jim Hickey NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19309C819 | List: |
| References | |
| SECY-80-054, SECY-80-54, NUDOCS 8004090301 | |
| Download: ML19309C822 (5) | |
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VALUE-IMPACT ASSESSMENT AND REPORT JUSTIFICATION ANALYSIS FOR NRC REGULATORY AMEN 0MENTS IMPLEMEN7ING EPA 40 CFR 190 1
l Prepared by:
John W. Hickey Office of Standards Development U.S. Nuc1kar Regulatory Commission Washington, D.C.
20555 Telephone:
301-443-5966 November 1979 8004090 %
1 Enclosure "0"
A.
Summary B.
Reportir.g Requirements 1.
Regulatory Background 2.
Description of Reporting Requirements 3.
Need for the Reports C.
Cost to Licensees and NRC
.1.
Method of Determining Costs 2.
Costs to Licensees 3.
Costs to NRC 0.
Alternatives 1.
Alternative Data Sources 2.
Duplication E.
Valu6/ Impact Assessment i
2 Enclosure "D"
A.
Summary Under the proposed NRC regulations, power reactors, uranium mills, UF 6 production plants, and commercial uranium fuel fabrication plants would have to comply with EPA's regulation 40 CFR 190.
This would involve certain reporting requirements, necessary for NRC to determine compliance.
The cost to NRC and licensees would be minimal.
No alternative data source exists.
B.
Reporting Requirements 1.
Regulatory Background The Environmental Protection Agency (EPA) regulation 40 CFR Part 190,
" Environmental Radiation Protection Standards for Nuclear Power Operations,"
requires certain uranium fuel cycle facilities to operate such that radioactive releases to the environment and resulting radiation doses are below certain limits (42 FR 2858, January 13, 1977).
The Nuclear Regulatory Commission (NRC) is responsible for implementa-tion of these standards as outlined in an Atomic Energy Commission / EPA Memorandum of Understanding (38 FR 24936, September 11, 1973).
2.
Description of Reporting Requirements The new regulations would explicitly require operating licensees to submit reports to NRC whenever release limits associated with compliance with 40 CFR 190 are exceeded.
Specifically,10 CFR S 20.405 would be amended to require these reports.
i Applications for licenses covered by 40 CFR 190 would have to include j
information on control programs for radioactive releases and expected doses to the public, in order to allow NRC to determine compliance with 40 CFR 190.
However, most of this information is already required by existing regulations (approved by GAO), so the additional reporting burden is negligible.
3 Enclosure "D" l'
3.
Need for the Reports NRC must have reports in cases where 40 CFR 190 may be violated, so that it can take appropriate action to protect the public health and the environment.
C.
Cost to Licensees and NRC 1.
Method of Determinino Costs The new reporting requirement is similar to other reporting require-ments (already approved by GAO) for cases where other NRC regulations are violated.
Cost estimates are based on staff estimates similar to those done in the past.
2.
Cost to Licensees
'All operating reactors, uranium mills, UF6 plants, and commercial uranium fuel fabrication plants will be subject to the reporting requirement, currently a total of 79 licensees.
About 8 professional man-hours will be required to prepare a report, which would be a few pages in length.
About 20-50 copies of the report will have to be typed, copied, and distributed, at a cost of about $100.
The NRC staff expects very few reports, so the burden on licensees will be minimal.
3.
Costs to NRC The NRC staff will review any report received.
Depending on the case, the review could take from one hour to one week.
Since very few reports are expected, the cost to NRC will be minimal.
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4 Enclosure "D"
D.
Alternatives 1.
Alternative Data Sources Only the licensee can provide the requested information.
2.
The reporting requirement does not duplicate any other requirement.
E.
Value-Impact Assessment It is the NRC staff's judgment that this requirement is a necessary part of NRC's enforcement responsibilities.
The burden on licensees will be minimal.
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Enclosure "D"
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ENCLOSURE E l
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