ML19330B903

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Draft Value/Impact Assessment of Draft Reg Guide 3. Recommends That Reg Guide Be Prepared
ML19330B903
Person / Time
Issue date: 07/31/1980
From: David Harmon
NRC OFFICE OF STANDARDS DEVELOPMENT
To:
Shared Package
ML19330B902 List:
References
RTR-REGGD-3.046, TASK-FP-818-4, TASK-OS REGGD-03.XXX, REGGD-3.XXX, NUDOCS 8008070180
Download: ML19330B903 (4)


Text

DRAFT VALUE/ IMPACT STATEMENT 1.

PROPOSED ACTION 1.1 Description An NRC source material license is required in order to process uranium solutions extracted from in situ uranium solution extraction operations.

General guidance for filing an application is provided in g40.31 of 10 CFR Part 40,

" Domestic Licensing of Source Material." Draft Regulatory Guide FP 818-4 pro-vides specific guidance on the format and content of applications, including environmental reports, for licenses to authorize commercial-scale in situ uranium solution extraction operations.

The guide conforms to NRC regulations and reflects exp;rience gained over the past 5 years in actual licensing cases.

1. 2 Need for Procosed Action Basic detailed guidance is essential to applicants for the efficient pr:paration of applications, including environmental reports, for commercial-scale in situ uranium solution extraction facility licenses ar.d for their review by the NRC staff.

Such guidance is presently delineated neither in NRC regulations nor in regulatory guides.

Based on experience gained in the issuance of such licenses, the NRC staff has identified information that should be contained in applications (including environmental reports) to reflect present needs and practices.

Such information in a regulatory guide will be helpful to both applicants and the NRC staff in reducing the cost and time involved in preparing and processing license applications.

1.3 Value/ Impact of Proposed Action 1.3.1 NRC The proposed guide describes the information needed from applicants for commercial-scale in situ uranium solution extraction facility license reviews by the NRC.

It identifies present needs and reflects present practices.

It snould result in a significant reduction in the number of questions and requests 35 po o s 07 0/fo

for clarification submitted by the NRC staff to applicants, improve the con-sistency in application reviews because of more uniform application submittals,

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reduce the amount of staff review effort in license processing, and expedite licensing actions.

1.3.2 Other Government Agencies Not applicable, unless the government agency is an applicant such as TVA.

1.3.3 Industry The value/ impact on applicants and licensees will be essentially the same as indicated above.

1.3.4 Public Since there is no reduction or ralaxation of any safety requirements, no impact on the public is anticipated other than an improved public understanding of information considered by the NRC staff in the licensing process.

1.4 Decision on Proposed Action I

As indicated in Section 1.2, specific guida.. e oc the format and content of applications (including environmental reports) for 11:enses to authorize commercial-scale in situ uranium solution extraction should be clearly delineated.

Thus, Draft Regulatory Guide FP 818-4 should be issued.

2.

TECHNICAL APPROACH 2.1 Technical Alternatives None available.

2.2 Discussion and Comparison of Technical Alternatives Not applicable.

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2.3 Decision on Technical Approach Not applicable.

I 3.

PROCEDURAL APPROACH 3.1 Procedures Alternatives Possible SD procedures that may be used to carry out the proposed action include the following:

Regulation o

Regulatory guide o

ANSI standard, endorsed by a regulatory guide o

NUREG report o

Branch position o

3.2 Value/ Impact of Procedui'l Alternatives A regulation does not appear to be a reasonable alternative because guidance, j

rather than specific regulatory requirements, is needed.

A NUREG report does not appear appropriate since a NUREG report usually contains only results of specific studies and/or basic research findings.

No specific branch position has been prepared, nor is one anticipated.

Preparation of a regulatory guide appears to b3 the most viable course of action.

3.3 Decision on Procedural Approach A regulatory guide should be prepared delineating specific guidance on the format and content of applications (including environmental reports) for licenses to authorize commercial-scale in situ uranium solution extraction operations.

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4.

STATUTORY CONSIDERATIONS 4.1 NRC Authority 1

NRC authority is delineated in the proposed guide.

4.2 Need for NEPA Assessment The proposed action is not a major action, as defined in 10 CFR Part 51, and does not require an environmental impact statement.

5.

RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES j

Not applicable.

The guide is intended to provide instructive guidance j

for commercial-scale in situ uranium solution extraction license applicants.

It is not considered as a substitute for a careful evaluation of the proposed program by an applicant.

No backfitting is expected from its issuance.

6.

SUMMARY

AND CONCLUSIONS A regulatory guide should be prepared.

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