ML20148D231
| ML20148D231 | |
| Person / Time | |
|---|---|
| Site: | Texas A&M University |
| Issue date: | 10/12/1978 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20148D215 | List: |
| References | |
| NUDOCS 7811020277 | |
| Download: ML20148D231 (4) | |
Text
--_-
O VALUE-IMPACT ASSESSMENT ON GUIDANCE TO APPLICANTS RELATIVE TO EMERGENCY PLA!NING REQUIREMENTS FOR RESFARCH REACTORS 1
l I. The Proposed Action A. Description
- 1. To 15% v e a regulatory guide that gives specife guidelines for the development and use of emergency plans for research reactors, and associated training of personnel.
B.. Need for the Proposed Action
- 1. Applications for research reactor op3 rating licenses ',
received since December 1970 have fugus1L 3 lacked sufficient information for adequate review by the NRC' staff. Staff
- usually needs to request additional information, sometimes j more than once uhich results in, unnecessary delays.
- 2. Most research reactor licensees received their OL prior l to December 1970 and have not established nor submitted an I emergency plan for NRC evaluation. This guide would provide these licensees with a basis for developing their emergency plans as the need arises. ,
l
- 3. Clear guidance, identifing elements that must be l addressed in an acceptable emergency plan, is not available at the present time.
- 4. This guide will help establish a uniformity or standardi-l zation of licensee emergency plans.
C. Value-Impact of Prooosed Action
- 1. NRC 1
- a. Staff may spend more time early in review
- b. Staff will spend less time later in review
- c. Estimate less staff time required in total
- d. Staff will spend considerable time evaluating emergency plans submitted by licensees who did not have an emergency plan prior to the publica-tion of the proposed guide.
- e. This regulatory guide was requested by liRR and ISE.
A copy of the formal NRR request is attached.
(
7822.020 6 7 t _ _ - _ _ - - - _ -
- 2. Other Government Agencies The guide suggests that licensecs make cooperative agreements and arrangements with State and local governments.
- 3. Industry or Universities
- a. Applicants will spend less time in developing their emergency plan because they will know in the beginning ;
what the staff needs for an adequate review.
- b. Licensees who do not have an emergency plan will spend a considerable amount of time developing and main-taining an emergency plan in accordance with the proposed regulatory guide. .
- c. Applications will benefit from accelerated review time.
- d. There will be an overall improvement in the quality of emergency plans with a potential increase in the level of public safety.
- 4. Public
- a. The proposed guide would establish uniform guidelines
- for research reactor's emergency plan thereby facilitating prompt and effective action to minimi:e the consequences of '
an emergency. This would result in a second ary offect of improving public relations.
D. URC Statutory Authority
- 1. The overall statutory authority for the proposed action is vested with NRC by the Atomic Energy Act of 1954 (as amended).
- 2. The specific regulation covering the proposed action i's 10 CFR Part 50. 34(a)(10) and 10 CFR Part 50.34(b)(6)(v) which require that applicants have satisfactory plans for coping with emergencies. Appendix E to 10 CFR Part 50 sets forth items to be included in the emergency plans, which have not to date been implemented uniformly for research reactors.
E. Need for NEPA Assessment
- 1. This assessment, and internal reviews, indicate that the ~
proposed action: ~
- a. _is not a major action that will significantly affect the quality of the human environment, and
- b. is not now, and is not likely to be, controversial.
- 2. On the basis of this conclusion, a NEPA environ = ental impact statement is not required.
F. Decision on Prooosed Action
- 1. It is judged that adverse impacts are more than offset by favorable impacts and values. Therefore, the proposed action should be implemented.
II. Alternative Methods of Accomolishing Action A. Alternatives
- 1. NRC regulation
- 2. ANSI Standard, endorsed by a Regulatory Guide
- 3. NURIG
- 4. Branch Position
- 5. Regulatory Guide B. Value-Impact of Alternatives
- 1. NRC regulation .
- a. The basic elements that should be in an emergency plan are already a part of the regulations, Appendix E to 10 CFR Part 50. These basic elements now need amplification. 2
- b. A new regulation would not cover the licensing requirements in the necessary detail.
- c. Would require more time and effort than a Regulatory Guide.
- d. Would legally require conformance.
- e. Staff has successfully convinced applicants to conform to Regulatory Guides
- f. Great dif ficulty in =nking changes.
- 2. Endorsed ANSI Standard
, s. The ANSI standard that is now being developed to cover this subject (ANS 15.16) is considered by the staff to be inadequate and therefore will not be endorsed.
- 3. NUREG
, a. NURECs ate informational and cannot contain staff positions.
- b. A NUREG document would be inappropriate because the proposed Regulatory Guide would take a position for complying with the Commission's regulations with regard to the content of emergency plans for research reactors. ,
- 4. Branch Positions
- a. Considered to be a temporary measure until action is accomplished by another alternative (Regulatory Guide).
- b. Branch positions have limited distribution'.
- 5. Regulatory Guide
- a. Can be published for public comment and be effective in about one year.
- b. Less time and effort required than for a new AliSI standard to be developed and endorsed.
- c. Less time and effort required than for NRC regulation.
C. Decision on Method A Regulatory Guide is the preferred method of accomplishing the action.
III. Relationship to Other Existing or Proposed Regulations or Policies A. Guide will use Appendix E to 10 CFR Part 50 as a basis.
B. Backfitting should be required.
IV. Summary and conclusions A. A Regulatory Guide on Emergency Planning Requirements for Research Reactors should be issued.