ML20137X720
| ML20137X720 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/1985 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20137X702 | List: |
| References | |
| RTR-REGGD-3.063, TASK-ES-401-4, TASK-RE REGGD-03.XXX, REGGD-3.XXX, NUDOCS 8510040584 | |
| Download: ML20137X720 (7) | |
Text
DRAFT VALUE/ IMPACT STATEMENT 1.
PROPOSED ACTION 1.1 Description The proposed action is to provide guidance for establishing and operating an onsite meteorological measurement program for uranium recovery facilities.
Recommendations will be provided in the following areas:
(1) meteorological parameters to be measured, (2) siting of meteorological instruments, (3) system accuracy and instrument specifications, (4) instrument maintenance and servicing schedules, (5) data recovery, and (6) data reduction and compilation.
- 1. 2 Need Section 40.31, " Applications for Specific Licenses," of 10 CFR Part 40,
" Domestic Licensing of Source Material," requires applicants for a license to receive, possess, or use source material in conjunction with uranium recovery facilities to provide information needed to assist in demonstrating that opera-tions can be conducted to meet the requirements set forth in Part 40. Section 40.65, " Effluent Monitoring Reporting Requirements," requires that licensees routinely report radionuclide releases to unrestricted areas in liquid and gaseous effluents.
The Uranium Mill Tailings Radiation Control Act (UMTRCA) requires the NRC to conform to 40 CFR Part 192, which sets standards for the control of releases from tailings related to production operations.
- 1. 3 Value/ Impact of Proposed Action 1.3.1 NRC The proposed action will provide applicants and staff with guidance on establishing and operating an accept 6ble onsite meteorological measurement pro-gram for uranium recovery facilities.
Such guidance should reduce inquiries as 8510040584 850930 PDR REGGD 03.XXX R PDR 9
to accepted procedures, reduce ambiguities in documentation, and simplify licens-ing activities by resolving uncertainties associated with the application of various methods.
The impact on the NRC staff will be the expenditure of staff effort on the development of acceptable procedures based on sound technical principles.
Completion of the proposed action is estimated to require 1.0 staff year of effort.
Associated costs include printing and copying costs and costs of normal office supplies.
No additional research technical assistance contract costs in support of this effort are anticipated.
1.3.2 Other Government Agencies The value to other government agencies, including State and local govern-ments, will be reflected in their comments on the draft regulatory guide as it relates to their programs.
The greatest value will be to the various Agreement States in providing useful guidance for their use in developing their own par-ticular criteria.
The principal impact will be on applicant agencies (e.g.,
DOE) and will be similar to the impact on industry as discussed in Section 1.3.3.
Additional work load would accrue at other agencies (e.g., NOAA and EPA) that may participate in terms of review and comment services.
l 1.3.3 Industry Industry will benefit by having available a current source of information concerning NRC recommendations for establishing and operating an onsite meteor-ological measurement program for uranium recovery facilities.
The meteorological measurements obtained from this program can also be used to provide justifica-tion and strategy for implementation of radiological monitoring stations.
Costs to industry will result from having to become familiar with the product document and in review and comment efforts.
The total estimated cost of purchasing and installing the necessary equipment for meteorological monitoring is $20,000.
Annual manpower and other related operating expenses are estimated to be approximately $10,000.
1.3.4 Workers No direct impact on workers is foreseen.
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1.3.5 Public D
The public will benefit by an increased assurance that information repre-sentative of the site is available for use in the design and operation of mill tailings impoundments and estimation of the atmospheric dispersion of routine releases of gaseous and particulate radionuclides.
The public will bear the monetary costs of completing and implementing the proposed action.
In addition, the costs incurred by the uranium recovery facility operators would be expected to be passed on to the consumers of electrical energy in the form of higher electrical rates.
1.4 Decision on Proposed Action The proposed action should be undertaken.
2.
TECHNICAL APPROACH The technical methods of accomplishing the proposed action are to perform the work inhouse or initiate a technical assistance contract with an independ-
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ent contractor.
2.1 Discussion and Comparison of Technical Alternatives The information and expertise needed to write a regulatory guide are cur-rently available within the NRC.
The amount of work necessary to accomplish the proposed action can be performed inhouse within a reasonable time without adverse impacts on other task requirements. Considerable time would be expended on the initiation and completion of a technical assistance contract with an independent contractor.
Although staff time expended on direct work on the proposed action would be eliminated by contracting the task, additional staff time would be required to prepare and issue a contract and monitor centractor performance.
2.2 Decision on Technical Approach Since the information and expertise to accomplish the proposed action exist within the NRC, the completion of the task inhouse is the most beneficial tech-nical alternative.
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3.
PROCEDURAL APPROACH I
3.1 Procedural Alternatives The alternative procedural methods of accomplishing the proposed action are:
National standard endorsed by a regulatory guide NUREG-series report Branch technical position Regulatory guide 3.2 Discussion of Procedural Alternatives 3.2.1 Endorsed National Standard The development of a national standard to be followed by an endorsing regulatory guide would allow a working partnership between industry and the NRC.
However, it would require a one-to two year delay.
Further, the stan-dard would have to be separately reviewed and adopted by the NRC.
{
3.2.2 NUREG-Series Report By definition, a NUREG-series report could provide only technical informa-tion, which would be useful, but is not a viable alternative since the guide-lines will include position statements.
3.2.3 Branch Technical Position Branch technical positions are considered to be temporary measures until a needed action can be accomplished by another, mere suitable alternative.
Because of the limited distribution and circulation of branch technical posi-tionst a branch technical position alone uoes not provide enough opportunity for public comment.
3.2.4 Regulatory Guide A regulatory guide would provide wide distribution of the needed guidance.
It would also provide an established review that wuuld include a public comment review period.
The regulatory guide would use licensing review experience and l
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i outline a formalized acceptance criterion that would eliminate uncertainty with D
respect to establishing and operating a meteorological measurement program for uranium recovery facilities.
3.3 Decision on Procedural Alternatives The development and issuance of a regulatory guide for public comment would best satisfy the need for the proposed action.
4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority Authority for this regulatory guide is derived directly from the Uranium Mill Tailings Radiation Control Act (UMTRCA) of 1978, the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, as amended, and is implemented through the Commission's regulations, in particular, 10 CFR Part 40, " Domestic Licensing of Source Material."
4.2 Need for NEPA Assessment The proposed action does not require an environmental impact statement since it is categorically excluded from the NEPA process in accordance with paragraph 51.22(c)(16) of 10 CFR Part 51.
l 5.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OP POLICIES No conflicts with any existing regulation or go/ernment policy are known to exist.
The following regulatory guides are related:
Regulatory Guide 3.5 Standard Format and Content of License Applica-tions for Uranium Mills Regulatory Guide 3.8 Preparation of Environmental Peports for Uranium Mills 13
Regulatory Guide 3.46 Standard Format and Content of License Appli-I cations, Including Environmental Reports, for In Situ Uranium Solution Mining Regulatory Guide 4.14 Radiological Effluent and Environmental Monitor-ing at Uranium Mills The proposed action will supplement these regulatory guides in providing more detailed guidance.
Subsequent changes to these existing guides may be needed to implement UMTRCA but not in pursuance of this proposed action other than to reference this guide.
6.
SUMMARY
AND CONCLUSIONS The NRC has both the need and the authority ta implement the proposed action.
The technical and procedural alterns' ves most favored are to have the proposed action developed inhouse as a regulatory guide.
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