ML20206E743

EDO Control of Rulemaking Package Re 10CFR50, Licensing of Production & Utilization Facilities to Add App P, 'Gdc for Fuel Reprocessing Plants.' Rulemaking Should Be Discontinued

ML20206E743
Person / Time
Issue date:	01/22/1985
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
References
NUDOCS 8606240001
Download: ML20206E743 (54)

Text

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JAN 2 21985 /

MEMORANDUM FOR: Robert B. Minogue, Director Office of Nuclear Regulatory Research William J. Dircks FROM:

Executive Director for Operations

SUBJECT:

CONTR0L OF NRC RULEMAKING By memorandum of February 13,1984, "Contiol of NRC Rulemaking by Offices Reporting to the EDO," Offices were directed that effective April 1,1984, (1) all offices under EDO purview must obtain my approval to begin and/or continue a specific rulemaking, (2) resources were not to be expended on rule-makings that have not been approved, and (3) RES would independently review rulemaking proposals forwarded for my approval and make reconnendations to me concerning whether or not and how to proceed with the rulemakings.

In accordance with my directive, the following proposal concerning rulemaking has been forwarded for my approval along with recommendations from RES con-cerning the proposal:

Proposed revision of 10 CFR Part 50, Licensing of Production and Utilization Facilities (Sponsored Plants. to Add an Appendix P, General Design by RES - memorandum, Minogue Criteria to EDOfor Fuel dated Reprocessing January 15, 1985. )

I agree with the decision of the Director of RES to discontinue this rulemaking.

The NRC Regulatory Agenda (NUREG-0936) should be modified to reflect the status of this proposal.

(Siped William J.Dircks William J. Dircks Executive Director for Operations cc: V. Stello Distribution:

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SUBJECT:

CONTROL OF NRC RULEMAKING: RES REVIEW 0F ONGOING RES SPONSORED RULEMAKING Based on our review of the ongoing RES sponsored rulemaking " General Design Criteria for Fuel Reprocessing Plants Appendix P," 10 CFR 50, RES recommends that NRC not continue with this rulemaking. This recommendation in draft form has been coordinated with the Division of Fuel Cycle and Material Safety, Office l of Nuclear Material Safety and Safeguards.

The basis for our recomendation is as follows: There is no necessity or urgency for addressing the issue. There has been little or no activity on this item since August 27, 1975, when action for going effective with the Appendix ,

was put in " hold" by the Commission based, in part, on ongoing GESMO activity.

Although commercial fuel reprocessing is at a standstill, the Office of Research will continue to follow, in concert with NMSS, developments as they may occur concerning processing of spent fuel as it may relate to high level waste management and the licensing of such facilities.

The complete RES review package has been sent to OED0 (Attention: DEDROGR) and to the Director, Office of Nuclear Material Safety and Safeguards.

MN M3g' Robert B. Minogue, D1 rector Office of Nuclear Regulatory Research

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Distribution RES Cintal File Circ /Chron/Subj RAMRB r/f JHenry g%* Jilalaro FGillespie Dross R!linogue GArlotto KSteyer MEMORANDUM FOR: Willian J. Dircks CNilsen Executive Director for Operations FROM: Robert B. Minogue Director Office of Nuclear Regulatory Research

SUBJECT:

CONTP.0L OF NRC RULEliAKING: RES REVIEW 0F O!iGOING RES SPONSORED RULEMAKING Based on our review of the ongoing RES sponsored rulemaking " General Design Criteria for Fuel Reprocessing Plants Appendix P," 10 CFR 50 RES recommerds that NRC not continue with this rulenakina. This recomendation in draft forn has been coordinated with the Division of Fuel Cycle and Material Safety, Office of Nuclear Material Safety and Safeguards.

Tne basis for our recemendation is as follows: There is no necessity or urgency for addressing the issue. There has been littic or no activity on this iten since August 27, 1975, when action for going effective with the Appendix was put in " hold" by the Comission based, in part, on ongoing GESti0 activity.

Althounh commercial fuel reprocessing is at a standstill, the Office of Research will continue to follow, in concert with NMSS, developments as they mv occur concerning processing of spent fuel as it my relate to high level waste nanagement and the licensino of such facilities.

The compinte RES review package has been sent to OEDO (Attention: DEDROGR) and to the Director, Office of Nuc1 car Material Safety and Safeguards, p mspeabv 3DismT B. FI1W Robert B. Minogue, Director Office of Nuclear Regulatory Research

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i RES INDEPENDENT REVIEW BOARD i VOTING SHEET TO: F. P. GILLESPIE, CHAIRMAN, RIRB FROM: K. R. Goller, Director, DRPES/RES T]TLE OF RULEMAKING: " General Design Crieria for Fuel Reprocessing Plants"  !-

/ AGREE WITH DRAFT RES REQUEST RIRB

/ INDEPENDENT RECOMMENDATIONS IN DRAFT INDEPENDENT REVIEW MEETING. l i

PACKAGE.  !

MDDIFY DRAFT RES. NOT PARTICIPATING.

INDEPENDENT RECOMMENDATIONS l AS INDICATED BELOW.

COMMENTS AND SUGGESTIONS:

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RES INDEPENDENT REVIEW BOARD V0 TING SHEET T0: F. P. GILLESPIE, CHAIRMAN, RIRB FROM: 0. E. BASSETT, MEMBER, RIRB TITLE OF RULEMAKING: " General Design Crieria for Fuel Reprocessing Plants" s

REQUEST RIRB AGREE WITH DRAFT RES MEETING.

ISDPE*BtNT RECOMMENDATIONS ~

IN DRAFT INDEPENDENT REVIEW NONE OF THE PACKAGE. ABOVE NOT PARTICIPATING.

MODIFY DRAFT RES INDEPENDENT RECOMMENDATIONS AS INDICATED BELOW.

COMMENTS AND SUGGESTIONS:

1. Per discussion with Jim Henry, there are no draft RES independent recommendations to ballot on.

2. I also understand from Jim Henry that the enclosed memorandum dated August 22, 1984 from Minogue to Dircks recommending that NRC not continue with this rulemaking was never dispatched.

3. If the memorandum from Minogue to Dircks immediately behind the ballot sheet, which has been concurred in by the Chairman, RIRB, is the draft RES recommendation which the RIRB is balloting on, I agree with the recommendations included in this memorandum. In the future, it would make more sense to have the RIRB ballot on the draft recommendation before the Chairman, RIRB, has concurred with it.

4. To accomplish an independent review, the action on this rule should have been assigned to someone other than the task leader of the rule.

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DISTRIBUTION:

RES RDG/ ALPHA CEBR RDG/SUBJ bec: R. Minogue D. Ross G. Arlotto K. Steyer C. Nilsen MDIORANDUM FOR: William J. Dircks Executive Director for Operations l'

Robert B. Minogue, Director FROM: i Office of Nuclear Regulatory Research l

SUBJECT:

CONTROL 0F NRC RULElgl KING: RES INDEPENDENT REVIEW BOARD REVIEW 0F ONG0ING RULDIAKING SPONSORED BY RES/DET Based on an independent review by the RIRB of the ongoing rulemaking, Appendix P,10 CFR Part 50, " General Design Criteria for Fuel Reprocessing Plants " sponsored by RES/DET, I agree with the reconnendation of the Director Division of Engineering Technology, RES, that NRC not j continue with this rulemaking.

The basis for our recommendation is as follows:

There is no necessity or urgency for addressing the issue. There has been little or no activity on this item since August 27, 1975, when action for going effective was put in " hold" by the Commission. Commercial fuel reprocessing is at a standstill.

I recensend that the NRC withdraw this item from the Regulatory Agenda. My recommendation has the concurrence of the Director, Division of Fuel Cycle and Material Safety. Office of Nuclear Material Safety and Safeguards.

Robert B. Minogue, Director I office of Nuclear Regulatory Research i

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AUG 2 91984 MEMORANDUM FOR: G. A. Arlotto, Director Division of Engineering Technology, RES FROM: Frank P. Gillespie, Chairman RES Independent Review Board

SUBJECT:

CONTROL OF NRC RULEMAKING: RES INDEPENDENT REVIEW 0F ONG0ING RULEMAKING Enclosed RES is a rulemaking independent review. (review package Enclosure 1) received from a sponsoring office for In accordance with procedures approved by the EDO on May 30, 1984, the rulemaking review package is assigned to your Division for action.

(Enclosure 2)

The ED0-approved procedures allow a total of 20 working days for completing the RES independent review. To assist RES in completing its independent review in a timely manner, please submit the draft independent review package for this specific rulemaking to RAMRB by 7 working days from the date of this memorandum.

p k-) 1.u Frank P. Gillespie, Chairman RES Independent Review Board

Enclosure:

1. " General Design Criteria for Fuel Reprocessing Plants"

2. Procedures for Conducting RES Independent Review of Rulemakings

RES OFFICE REVIEW PACKAGE

DISTRIBUTION: RES RDG/ ALPHA CEBR RDG/SUBJ bcc: R. B. Minogue D. F. Ross G. A. Arlotto R. E. Cunningham, NMS!

K. G. Steyer E 2% C, CAG, ORM (w/ encl.)

RES Mail & Records (w/ encl.)

BEh0PANDUM FOR: William J. Dircks Executive Director for Operations FhCM: Robert B. Hinogue, Director Office of Nuclear Regulatory Research

SUBJECT:

REVIEW DY E00 ON OhE01hG RULEMAKIh0S SP0hSLRED LY RES Enclosed is the review packase of the following specific engoing ruleraking for which RES is the sponsoring Office:

eppendix P, 10 CFR Part 50, " General Design Criteria for Fuel Peprocessing Plants."

This sute.ittal responds to the neroranous dated /tpril 9,1984 frcr. J. t!. Felton, Director, Division of Rules and Records, ADf1, requesting offices to upcate hRC Regulatory Agenda entries.

I recorrend that the NRC not continue with this rulemaking.

The basis for this reccmtrendation is as follows:

There is no necessity or urgency for addressing the issue. There has been little or no activity on this item since August 27, 1976, when action for going effective was put in " hold" by the Contoission. Corrercial fuel reprocessing is at a standstill.

I recensend that the NRC withdraw this item fron* the Regulatory Agenda. tiy recorrendation has been ccordinated in draf t forrn with the Director, Division of Fuel Cycle and Haterial Safety, Office of huclear haterial Safety and Safeguards.

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Robert D. Minogue, Director Of fice of Nuclear Regulatory Fescarch

Enclosure:

RES Ruleraking Review Package for Proposed Appendix P,10 CFR Part 50

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ENCLOSURE 1

TITLE:

General Design Criteria for Fuel Reprocessing Plants CFR CITATION:

10 CFR 50 ABSTRACT:

The proposed rule would establish general criteria f or designing fuel reprocessing plants in order to provide reasonable assurance that fuel reprocessing plants can be operated without undue risk to the health and safety of the public. The general criteria contains the minimum requirements that an applicant must use in the selection of principal design criteria for a fuel reprocessing plant. The principal criteria would establish design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to the safety of the facility. This proposed rule has been indefinitely deferred until needed for NRC's regulation of a reprecessing facility.

TIMETABLE:

NPRM 07/18/74 39 FR 26293 Next Action Undetermined LEGAL AUTHORITY:

42 USC 2133; 42 USC 2134; 42 USC 2201; 42 USC 2232; 42 USC 2233 EFFECTS ON SMALL BUSINESS AND OTHER ENTITIES: No AGENCY CONTACT:

Charles W. Nilsen Office of Nuclear Regulatory Research Washington, DC 20555 301 443-7910 i

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REMARK 5 The attached paper is being returned.

At a meeting with the Cow.ission c'n August 27, this paper was discussed. The Com~:ission said to " hold" this.

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Do NOT disapprovals, use this form clearances, as a RECORD andofsimilst approvals concurrences, act *lons. .

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Title 10 - Energy Chapter I - NUCLEAR REGULATORY COMMISSION Part 50 - LICENSING OF PRODUCTION AND UTILIZATION FACILITIES APPENDIX P General Design Criteria for Fuel Reprocessing Plants On July 18, 1974, the Atomic Energy Commission published in the FEDERAL REGISTER (39 FR 26293), and invited public comments on, a proposed regulation, in the form of an amendment to 10 CFR Part 50,

" Licensing of Production and Utilization Facilities," which would add an Appendix P, " General Design Criteria for Fuel Reprocessing Plants."

The purpose of the amendment was to set forth the minimum requirements for the principal design criteria for fuel reprocessing plants. The principal design criteria establish the design, component, fabrication, construction and testing requirements to provide reasonable assurance that a facility can be operated without undue risk to the health and safety of the public.

Interested parties were invited to submit written comments for consideration within 60 days after publication of the proposed rule in the FEDERAL REGISTER. The comment period was later extended to September 30, 1974.

Subsequently, in accordance with the Energy Reorganization Act of 1974, Public Law 93-438, the Nuclear Regulatory Commission (NRC) was established on January 19, 1975. The NRC assumed the licensing and related regulatory functions of the former Atomic Energy Commission.

Enclosure "A"

Among the comments received was a suggestion that issuance of the proposed General Design Criteria for Fuel Reprocessing Plants is premature in light of current Commission consideration of altern-stive policies regarding plutonium recyle and the interim and long-term storage of commercial high level and transuranium-contaminated radioactive waste. On May 8, 1975 the Nuclear Regulatory Commission published a notice in the FEDERAL REGISTER (40 FR 20142) setting forth the provisional view, subject to consideration of comments to be received, that with certain exceptions no additional licenses or permits should be granted for light water power reactor fuel cycle activities (including nuclear fuel reprocessing) which depend for their justification on wide-scale use of mixed-oxide fuel and which would foreclose future safeguard options or result in unnecessary "grandfathering." Subsequently, after careful review of all comments received and consideration of other factors involved, the Commission has reappraised the guidelines it set forth in its provisional views for determining what related activities could be permitted pending its final decision on wide-scale use of mixed oxide fuel.

On November 14, 1975, the Commission published a notice in the FEDERAL REGISTER (40 FR 53056) setting forth, amoung other things, the criteria under which certain licensing actions (including nuclear fuel reprocessing) can proceed in the interim prior to its decision on the wide-scale use of mixed oxide fuel.

c Enclosure "A"

Part of this notice stated that:

The Commission has determined that whether specific fuel recycle related activities (as defined below) should be authorized in the interim will be determined within the context of the individual licensing proceedings on the basis of consideration t7d balancing of the following factors:

(1) Whether the activity can be justified, from a NEPA cost-benefit standpoint, without placing primary reliance on an anticipated favorable Commission decision on wide-scale use of mixed oxide fuel; (2) Whether the activity would give rise to an irreversible and irretrievable commitment of resources that would unjustifiably foreclose for the activity substantial safeguards alternatives that may result from

- the decision on wide-scale use; and (3) The effect of delay in the conduct of the activity on overall public interest.

As is the case with all licenses issued by the Commission, any interim license that may be issued for nuclear power reactor fuel cycle activities will be subject (by regulation or order) to possible additional safeguards requirements. All interim activities that may be authorized pursuant to the above eligibility criteria will

' be conducted at the risk of the applicant, and be expressly Enclosure "A"

subject to amendment, suspension, or revocation in light of the '

Commission decision on wide-scale use of mixed oxide fuel. It.

should be clear that the final Commission decision on the matter of wide-scale use. of mixed oxide fuel could result in changes to the criteria set forth herein and that issuance of the subject rule will not prejudice the later adoption of any such changes by the Commission.

Since the " General Design Criteria for Fuel Reprocessing Plants (1) will establish minimum " safety-related" design criteria requirements against which an application can be reviewed within the scope of the enviromental statement dealing with health and safety, (2) are not intended to provide a base for the protection of fuel reprocessing plants or the licensed material therein and (3) will provide a consistent basis for Staff review of nuclear fuel reprocessing plants in licensing activities, the Commission considers that these general design criteria should be adopted.

Further, two public comments asserted that, since the " General Design Criteria for Fuel Reprocessing Plants" will establish minimum

" safety-related" design criteria requirements, adoption of this rule would lead to major environmental consequences and therefore require an environmental impact statement. The present practice for fuel reprocessing plant licensing approval is to review each application on a case-by-case basis. The General Design criteria Enclosure "A"

I for Fuel Reprocessing Plants will formally establish these minimum '

requirements based on (1) established informal criteria, (2) plant operating data, and (3) requirements established in this chapter.

The general design criteria are intentionally written on a broad basis to accommodate existing as well as innovative methods for conformance. At the time that the proposed amendment to 10 CFR Part 50 " Licensing of Production and Utilization Facilities,"

Appendix P, " General Design Criteria for Fuel Reprocessing Plants" was published for public comment, an " Environmental Impact Appraisal of Proposed Amendment to 10 CFR 50, ' General Design Criteria for Fuel Reprocessing Plants'" was made available to the public. The environmental impact appraisal pointed out that (1) the general design criteria will not change the environmental impact per se, (2) the levels of environmental impact for fuel reprocessing plants can be meaningfully addressed only in the detailed environmental impact statements which are prepared in connection with licensing actions for individual plants, and (3) any environmental impact from the operation of a fuel reprocessing plant is evaluated by application of the principal design criteria during the licensing process. The matter of treatment of radiation dose exposures referred to in these comments is specifically discussed below in connection with criterion 21. The Nuclear Regulatory Commission agrees with Enclosure "A" I

l l

the conclusion of the environmental impact appraisal that an environmental impact statement is not required for " Appendix P, General Design Criteria for Fuel Reprocessing Plants."

As a result of comments received, the following clarifying changes have been made to the text of the proposed amendment:

(1) a definition of "important to safety" is added to Section l

l II, Definitions. The first paragraph of Section I, 1

Introduction, has been amended in order to avoid ambiguity as regards the new definition, (2) the definition " Process Safety Features" is eliminated.

Clarifying revisions to certain criteria eliminated l reference to process safety features. Therefore, this i

definition is superfluous.

(3) the requirements of criterion 2c, pertaining to the capability for determining the entire range of intensity of natural phenomena and the responsibilities of the licensee for obtaining these data, was questioned. The l

intensity of certain natural phenomena, such as floods, tornadoes, and lightning is frequently indeterminable.

The intensity of some meteorological phenomena can be measured, but only within the limit of the instruments.

This criterion has been revised to clarify that only the measurement of seismic event intensity is required, which was the original intent. Editorial changes have been made to make clear that the applicant need only demonstrate Enclosure "A"

the capability of acquiring these data for evaluating the force of seismic event against the facility design bases, (4) criterion 9, subsection d, has been revised to avoid ambiguity in the original wording, which might have required unnecessary direct testing of components containing excessive amounts of radioactive materials, (5) comments concerning criterion 11, criterion 12, and the heading of the section including these criteria indicated possible confusion. Revisions have been made to clarify intent and avoid ambiguity.

(6) criterion 14 has been revised to indicate that process systems operability is required only if necessary to protect the health and safety of the public, (7) criterion 21 has been revised to clarify the intent that radiation exposure should be minimized. Comments asserted that (a) it was inadequate as written because it did not limit the total number of man-rems to the community and (b) it should provide restrictions on the design of fuel reprocessing plants in terms of personnel exposure, as well as dose rate per se. The total number of radiation exposures, in terms of man-rems, is determined from the radiation field intensity, time of exposure, the effect of specific type of radiation, and population exposed.

Enclosure "A"

)

Radiation exposures, either to the public or occupational, are therefore dependent on site location and characteristics, facility design, and operating practices and must be determined on an individual plant basis. The intent of this criterion is that the principal design should specifically address the control of radiation exposure by making every effort to maintain the-total exposures "as low as practicable."

Effective control of radiation exposure is accomplished by competent staff personnel, adequate training, carefully conceived and executed procedures, proper supervision, as

.well as application of good design principles (particularly in the application of remote maintenance techniques).

The general design criteria are intended to enhance this concept-in all aspects of the fuel reprocessing plant.

This criterion has been revised to clarify the requirement that process equipment, process layout, and maintenance provisions, as well as shielding, shall be considered to assure that radiation exposures in accessible areas are as low as practicable.

(8) criterion 24 has been revised to clarify the intent that gaseous effluents as well as liquid effluents will be controlled to be maintained as low as practicable.

In addition, several other editorial changes have been made which reflect comments received.

Enclosure "A"

On the basis of the foregoing and af ter careful consideration of all comments received and other factors involved, the Nuclear Regulatory Commission has adopted the amendment in the form set forth below.

Pursuant to the Atomic Energy Act of 1934, as amended, the Energy Reorganization Act of 1974 and sections 552 and 553 of title 5 of the United States Code, notice is hereby given that the following amendrent to Title 10, Chapter 1, Part 50 of the Code of Federal Regulations, is published as a document subject to codification.

1. Paragraph (a)(3)(i) of 5 50.34 is amended to read as follows:

5 50.34 Contents of applications: technical information.

(a) Preliminary safety analysis report. Each application for a construction permit shall include a preliminary safety analysis report. The minimum information

• to be included shall consist of r the following:

(3) The preliminary design of the facility including:

(i) The principal design criteria for the facility.

Appendix A, General Design Criteria for Nuclear Power Plants, establishes minimum requirements for the principal design criteria for water-cooled nuclear power plants similar in design and location Enclosure "A"

to plants for which construction permits have previously been issued by the Commission and provides guidance to applicants for construction permits in establishing principal design criteria for other types of nuclear power units. Appendix P, General Design Criteria for Fuel Reprocessing Plants, establishes minimum require-ments for the principal design criteria for fuel reprocessing plants;

2. Footnote 2 to 5 50.34 is deleted.

3. A new Appendix P is added to read as follows:

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• Eonpared to the proposed rule published in the Federal Register (39 FR 26293), additions are underlined and deletions are lined l

through and bracketed.

Enclosure "A" i

APPENDIX P GENERAL DESIGN CRITERIA FOR FUEL REPROCESSING PLANTS TABLE OF CONTENTS I. INTRODUCTION II. DEFINITIONS Fuel Reprocessing Plant Important to Safety Radiological Protection Confinement System Single Failure

[Precese-Gefety-Features]

Redundant Equipment or System III. CRITERIA Number OVERALL REQUIREMENTS Quality Standards and Records 1 Protection Against Environmental Condi-tions, Natural Phenomena and Missiles 2 Protection Against Fires and Explosions 3 Sharing of Structures, Systems, and Components 4 Proximity of Sites 5 Testing and Maintenance of Systems and Components 6 Emergency Capability 7 PROTECTION BY MULTIPLE CONFINEMENT BARRIERS AND SYSTEMS Confinement Barriers and Systems 8 Ventilation and Offgas Systems 9 Enclosure "A"

PROCESS SAFETY [ FEATURE 6] Number Protection Systems 10 Instrumentation and Control Systems 11 Separation of [ Precess-Safety-Feeeures]

Protection Systems and Control Systems 12 Control Room 13 Process Systems 14 Utility Services 15 NUCLEAR CRITICALITY SAFETY Safety Margins 16 Methods of Control 17 Neutron Absorbers 18 Ancillary Criteria for Nuclear Criticality Safety 19 RADIOLOGICAL PROTECTION Access Control 20 Radiation [ Shielding] Control 21 Radiation Alarm Systems 22 Ef fluent Monitoring 23 Effluent Control 24 FUEL AND RADI0 ACTIVE WASTE [6TORAGE] MANAGEMENT Fuel and Radioactive Waste Systems 25 Waste [Bisposal] Management Systems 26 DECOMMISSIONING Decommissioning 27 Enclosure "A"

I. INTRODUCTION Pursuant to the provisions of 5 50.34, an application for a construction permit for a fuel reprocessing plant must include the principal design criteria for the proposed facility. The principal design criteria establish the design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety, [that-isr-etenetueesy-eyeeeme r-and componente-thee-peevide-eensenable-aseuranee-that-the-fee 414ty-een be-eperated-without-undue-elsk-te-the-heeleh-and-eafety-ef-the publie-) as defined in Section II, Definitions.

These General Design Criteria are intended to aid the applicant for a construction permit for a fuel reprocessing plant in selection of the principal design criteria and to establish minimum requirements for the principal safetyrelated design criteria for fuel reprocessing plants. The development of these General Design Criteria is not yet complete. For example some of the criteria, such as those for waste management systems and decommissioning, are being amplified and developed. Any omissions do not relieve the applicant from the i

requirement of providing the necessary safety features in the l

design of a specific facility. In addition to satisfying the General Design Criteria, the applicant must:

1. Design against the loss of confinement capability or

! other capability which would jeopardize the health and safety of the public where such loss of cabability results from any single failure in systems important to safety; Enclosure "A" l

2. Provide redundancy and/or diversity in systems important to safety;

3. Minimize the possibility of nonrandom, concurrent failures of redundant elements in protection systems;

4. Provide design [erdeerfa] bases for resistance of the facility to upper limit accidents and design bases for maximum probable natural phenomena;

5. Provide adequate protection for employees from hazards which could affect their performance of actions required to protect the public from exposure to radiation.

There may be some fuel reprocessing plants for which the General Design Criteria are not sufficient and for which additional criteria must be satisfied in the interest of public safety. In f

particular, it is expected that additional or different criteria will be needed to take into account variations in sites and environ-mental conditions. Also, some of the General Design Criteria may not be necessary or appropriate for a specific plant. For plants such as these, departures from the General Design Criteria must be identified and justified.

II. DEFINITIONS FUEL REPROCESSING PLANT A fuel reprocessing plant means the structures, systems, and components required for the separation, recovery, storage, and handling of fissile and fertile nuclear material, byproducts, and waste from irradiated nuclear fuels or materials, and includes Enclosure "A"

- _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ = _ _ _ .

those structures and protection systems or components required to provide reasonable assurance that the plant can be operated without I

undue risk to the health and safety of the public.

IMPORTANT TO SAFETY The term important to safety applies to those structures, systems and components the failure of which might cause or substantially contribute to a release of radioactive materials or radioactivity in excess of the design base quantities or the regulations of this chapter.

RADIOLOGICAL PROTECTION Radiological protection means protection against internal and external ionizing. radiation.

?

CONFINEMENT SYSTEM A confinement system means the barrier and its associated systems, including ventilation, between areas containing radioactive substances and the environment or areas in the plant which are normally expected to have levels of radioactivity lower than that which the barrier is designed to confine.

SINGLE FAILURE A single failure means an occurrence which results in the loss of capability of a component to perform its intended safety func-tion (s) . Multiple failures, i.e., loss of capability of several components, resulting from a single occurrence are considered to be a single failure. Systems are considered to be designed against an Enclosure "A"

assumed single failure if neither (1) a single failure of any active component (assuming passive components function properly) nor (2) a single failure of any passive component (assuming active components function properly) results in a loss of the capability of the system to perform its safety functions.

[PR06ESB-6AFETV-FEATURES]

[A-precess-safety-feature-means-a-feature-designed-ee-prevene, limie,-er-miefgate-the-release-ef-radienceive-material.]

REDUNDANT EQUIPMENT OR SYSTEM Any equipment or system that duplicates the essential function of any other equipment or system is considered to be redundant to the extent that either may perform the required function regardless of the state of operation or failure of the other.

III CRITERIA OVERALL REQUIREMENTS CRITERION 1 - QUALITY STANDARDS AND RECORDS Structures, systems, and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed and in accordance with quality assurance criteria in Appendix B. Appropriate records of the design, fabrication, erection, and testing of structures, systems, and components important to Enclosure "A"

safety shall be maintained by or under the control of the fuel reprocessing plant licensee throughout the life of the plant.

CRITERION 2 - PROTECTION AGAINST ENVIRONMENTAL CONDITIONS, NATURAL FHENOMENA AND MISSILES

a. Structures, systems, and components important to safety shall be designed to withstand the effects of and to be compatible with the plant environmental conditions associated with operation, maintenance, plant shutdown, testing, and accidents.

b. Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, lightning, hurricanes, floods, tsunami, and seiches without impairing their capability to perform safety functions. The principal design criteria for these structures, systems, and components shall include: (1) resistance to the most severe of the natural phenomena reported for the site and surrounding area, with appropriate modifications to take into account the limited quantity of the historical data and the period of time in which the data have been accumulated; (2) safety features to cope with combinations of the effects of accident conditions and the effects of natural phenomena; and (3) features which provide for safe shutdown under emergency conditions, confinement of radioactivity during the emergency, and safe startup following unscheduled shutdown.

c. Capability shall be provided for determining the intensity of [ natural-phenomena 3 any seismic event which may occur for comparison Enclosure "A"

with design bases of structures, systems, and components important to safety. [shall-be-previded.]

d. Structures, systems, and components important to safety shall be appropriately protected against dynamic effects, including (seismie-meefen-and] the effects of missiles and discharging fluids, that may result from equipment failure and from other similar events and conditions both inside and outside the fuel reprocessing plant.

CRITERION 3 - PROTECTION AGAINST FIRES AND EXPLOSIONS Structures, systems, and components important to safety shall be designed and located so as to continue to perform their safety functions effectively under fire and explosion exposure conditions.

Noncombustible and heatresistant materials shall be used wherever practical throughout the facility, particularly in locations vital to the functioning of confinement barriers and systems, to methods of controlling radioactive materials within the facility, and to the maintenance of safety control functions. Explosion and fire detection, alarm, and suppression systems shall be designed and provided with sufficient capacity and capability to minimize the adverse effects of fires and explosions on structures, systems, and components important to safety. The design of the [ fire-suppression system] facility shall include provisions to protect against adverse

effects [in-the-event-of-system] which might result from operation or failure [v] of the fire suppression system.

Enclosure "A"

CRITERION 4 - SHARING OF STRUCTURES, SYSTEMS, AND COMPONENTS Structures, systems, and components important to safety shall not be shared between a fuel reprocessing plant and plants of any type unless it is shown that such sharing will not impair the capability of the fuel reprocessing plant to perform its safety functions, including the capability for orderly and safe shutdort in the event of an accident or incident.

CRITERION 5 - PROXIMITY OF SITES Fuel reprocessing plants located near other nuclear facilities and other activities licensed under this chapter shall be designed to assure that the cumulative effect of discharges resulting from their operation will not result in undue risk to the health and safety of the public.

CRITERION 6 - TESTING AND MAINTENANCE OF SYSTEMS AND COMPONENTS Systems and components [thee-have-safety -- related-fenetiens) important to safety shall be designed to permit inspection, maintenance, and appropriate testing to assure their continued functioning.

[ fee-the-life-ef-the-feeilityv]

CRITERION 7 - EMERGENCY CAPABILITY Structures, systems, and components important to safety shall be designed to assure capability for safe shutdown of plant operations and for handling of [an] emergene[y]ies. The design shall assure capability Enclosure "A"

for use, as necessary, of onsite facilities and shall facilitate the use of available offsite [feefliefee-and) services such as

[hespleels] fire and police [departmene] protection, medical and ambulance service, and [ue414ey-persennel] other services as may aid in recovery from emergencies.

PROTECTION BY MULTIPLE CONFINEMENT BARRIERS AND SYSTEMS CRITERION 8 - CONFINEMENT BARRIERS AND SYSTEMS The total confinement system shall consist of one or more individual confinement barriers and systems which successively control against the release of radioactivity to the environment.

The confinement system shall be designed to protect against the effects of accidents or external natural phenomena and shall be fabricated, erected, appropriately tested, and maintained to assure prevention of abnormal leakage, rapidly propagating failure, or gross rupture during the design life.

CRITERION 9 - VENTILATION AND OFFGAS SYSTEMS The ventilation and offgas systems shall be designed and appropriately tested to assure the confinement of radioactive materials during normal or abnormal conditions. To accomplish this objective, these systems shall be designed to meet the following requirements:

i Enclosure "A" t

4

a. The proper ventilating air flow direction shall be maintained across the confinement barrier, that is, between areas inside the barrier and areas outside the barrier, under operating and accident conditions.

b. The ventilation system shall accommodate changes in operating conditions such as variations in temperature or pressure and shall be capable of safely controlling all radioactive offgases that could be associated with normal or accident conditions.

c. The continuity of necessary ventilation shall be assured by means of redundant equipment, fail-safe control systems, or other provisions.

d. Provisions shall be made for testing 2 (all-eafety-related eempenente) during normal operation1 [af-the-systeme-ee-demonstrate ehefe-abilfey-ee-peeferm-et-design-efficieney-and-te-funeelen-during emeegency-eenditiene. ] all component functions important to safety to the extent necessary to provide reasonable assurance that they will perform their designed functions.

e. Ventilation systems shall be designed to permit the continued occupancy of any and all areas where such occupancy is required for normal plant operations, for safe shutdown or maintaining the plant in a safe shutdown condition. [The] Their design shall include protection against the intake or accumulation of radioactive and other hazardous materials. The design shall also permit the timely and safe evacuation of personnel from all areas.

Enclosure "A" I

i

. f. Vessel and dissolver offgas systems shall be designed to confine the radioactive materials during normal operation and to assure that the [eeneenereefen] release of radioactive, materials in the effluent gases is as low as practicable. Such systems shall also be designed to retain their confinement and separation capability to reduce releases resulting from an accident condition to levels consistent with the regulations contained in this chapter.

PROCESS SAFETY [FEAMiRE6]

CR)'ERION 10 - PROTECTION SYSTEMS

a. Protection systems shall be designed (1) to initiate action that will assure that specified acceptable operating design limits are not exceeded as a result of operational occurrences and (2) to sense potential hazardous or accident c onditiotis and to activate systems and components required to assure the safety of operating personnel and the public or to give audible and visual alarm so that action can be taken in a timely manner to assure such safety. Protection systems and components shall be activated automatically where this mode is compatible with the safety require-ments to be satisfied.

b. Protection systems shall have reliability and in situ testability. The design of protection systems shall provide for

redundancy and independence at least sufficient to assure that (1)

! no single failure results in loss of the protection functions and Enclosures "A" l

1

(2) removal from service of any component does not result in loss of the required redundancy unless it can be otherwise demonstrated that the protection system will operate with acceptable reliability.

The protection systems shall be designed to permit the periodic testing of [4es] their functions [and-effiefenefes) while the plant is in operation, to determine whether failures or losses of redundancy may have occurred.

c. Protection systems shall be designed to fail into a safe state or into a state demonstrated to be acceptable on some other defined basis if conditions such as disconnection of the system, loss of energy or motive power, or adverse environments are experienced. '

CRITERION 11 - INSTRUMENTATION AND CONTROL SYSTEMS Instrumentation and control systems shall be provided to monitor [safetyrelated] variables important to safety and operating systems over anticipated ranges for normal operation, for abnormal operation, for accident conditions and for safe shutdown. These systems shall be provided [with engineered safety features) in the redundancy required to assure adequate safety of process and utility operations. The variables and systems that require con-stant surveillance and control include parts of the process, the over-all confinement system, [each] confinement barriers and [4ts] their associated systems, and other systems that affect the overall safety of the plant. Controls shall be provided to maintain these 9

Enclosure "A" h

i I

variables and systems within the prescribed operating ranges under all normal conditions. Instrumentation and control systems shall be designed to be fail into a safe state or to assume a state demon-strated to be acceptable on some other basis if conditions such as disconnection, loss of energy or motive power, or adverse environments are experienced.

CRITERION 12 - SEPARATION OF [PROGESS-SAFETV-FEATURES] PROTECTION SYSTEMS AND CONTROL SYSTEMS

[The-process-safety-features] Protection systems shall be separated from control systems to the extent that a change or failure in [either] a control system leaves intact a protection system [which saefsfies-all] with acceptable reliability and independence require-ments. [ef-the-precess-safety-systems]

CRITERION 13 - CONTROL ROOM A control room or control areas shall be designed to permit occupancy and actions to be taken to operate the plant safely under normal conditions and to maintain the plant in a safe condition under accident or other abnormal conditions. [Instrumentatien-and I

eenerels-in-the-eenerel-reem-er-eenerel-areas-shall-be-designed-with l

l suffiefent-redundeney-ee-allew-the-plane-ee-be-pue-inte-a-safe eendiefen-if-any-ene-eentrel-reem-or-eentrel-aree-is-removed-frem service.] There shall be sufficient redundancy in systems to allow l

l the plant to be put into a safe condition if any one control room or control area is removed from service.

- Enclosure "A" l

i i

(

CRITERION 14 - PROCESS SYSTEMS Process components and systems are the first confinement barrier. The design of each process system shall provide capability for the system to maintain its integrityi and operability if necessary, to protect the public health and safety under all normal

[ precess-eendittene) and abnormal conditions, including the maximum l

expected inventories of fissile materials and other radionuclides.

Provisions shall be included for the safe handling of anticipated nonroutine process [ requirements) conditions.

CRITERION 15 - UTILITY SERVICES

a. The design of each utility service system required for emergency conditions shall provide for the meeting of safety demands under normal and abnormal conditions. The design of [eafety-related]

utility services and distribution systems important to safety shall include redundant systems to the extent necessary to maintain, with adequate capacity, the ability to perform safety functions assuming a single failure.

b. Emergency utility services shall be designed to permit testing of their functional operability and capacity, including the full operational sequence, of each system for transfer between I

normal and emergency supply sources, and the operation of associated safety systems.

i i

t Enclosure "A" i

i

1

c. Provisions shall be made so that, in the event of a loss of the primary electric power source or circuit, reliable and timely emergency power will be provided to instruments, confinement sy. stems, utility service systems, and process systems in amounts sufficient to allow operations to be shut down safely and to be maintained in a safe shutdown condition with all safety devices essential to safe shutdown functioning. The onsite emergency power sources and the electrical distribution circuits shall have inde-pendence, redundancy, and testability to assure performance of their safety functions in the event of a single failure or an accident.

NUCLEAR CRITICALITY SAFETY CRITERION 16 - SAFETY MARGINS The design of process and storage systems shall include margins of safety for the nuclear criticality parameters that are commensu-rate with the uncertainties in the process and storage conditions, in the data and methods used in calculations, and in the nature of the immediate environment under accident conditions. All process and storage systems shall be designed to be maintained suberitical and to assure that no nuclear criticality accident can occur unless at least two unlikely, independent, and concurrent or sequential changes have occurred in the conditions essential to nuclear criticality safety.

Enclosure "A"

CRITER10N 17 - METHODS OF CONTROL l

a.- Favorable geometry, in which equipment or systems are  !

subcritical by virtue of neutron leakage under worst credible conditions, is the preferred method of nuclear criticality control.

b. Where the favorable geometry method of nuclear criticality control is not practical, the use of permanently fixed neutron-absorbing materials (poisons) is the next preferred method of control.

c. Where both the favorable geometry and the permanently fixed neutron-absorbing materials (poisons) methods of nuclear criticality control are not practical, administrative controls of moderation, fissile material concentration, total fissile material, 4

or the use of soluble neutron-absorbing materials (poisons) shall be employed when combined with margins of safety measurements or appropriate analysis and engineered safety features.

i CRITERION 18 - NEUTRON ABSORBERS Where solid neutron-absorbing materials (poisons) are used for f the prevention of nuclear criticality, the design shall provide for positive means to verify their continued efficacy. Soluble neutron-absorbing materials may be used as a primary nuclear criticality

, control provided: (1) two indepe.ndent methods are provided to assure the presence of the required concentration of neutron absorber and (2) the equipment containing the fissile material is located i

behind sufficient barriers and shielding to reduce the probability i'

and extent of accidental contamination of the environment and Enclosure "A"

accidental radiation exposure to personnel in the event of a criticality accident.

CRITERION 19 - ANCILLARY CRITERIA FOR NUCLEAR CRITICALITY SAFETY

.a. Process and storage systems shall be designed to assura that no mechanisms that could cause segregation of fissile materials can be present in components whose nuclear criticality safety is dependent on the homogeneous distribution of fissile material.

b. Components whose nuclear criticality safety is dependent on a limiting concentration of fissile material shall be designed so that either (1) mechanisms that could cause critical concentra-tions of fissile materials are not present or (2) concentration is controlled by positive instrumental means.

c. Process and storage systems shall be designed to assure that the transfer of fissile material from safe systems to unsafe systems is not possible as a consequence of any single failure or operating error.

i d. Confinement system components shall be designed to assure i that leakage from equipment or from one confinement zone to another

, i l

l l confinement zone cannot result in a condition that would result in

! nuclear criticality.

A t

e. The spacing between discrete accumulations of fissile

! materials shall be controlled so as to maintain a suberitical l- >

! state.

I

?

Enclosure "A" t

f I

RADIOLOGICAL PROTECTION CRITERION 20 - ACCESS CONTROL The design of the facility shall provide for control of access to the facility and to areas of potential contamination or high radiation within the facility. The facility shall be designed so that the spread of contamination can be monitored and controlled.

CRITERION 21 - RADIATION [6HIEbBING) CONTROL

[ Shielding-shell-be-designed-te-assure-thee-dese-rates-in accessible-areas-are-eensistene-with-the-regulettens-eentained-in this-chapteer) Process equipment, process arrangement and mainte-nance provisions, in combination with appropriate shielding, shall be designed to assure that radiation exposures in accessible areas are as low as practicable.

CRITERION 22 - RADIATION ALARM SYSTEMS Radiation alarm systems shall be provided to warn plant personnel of significant increases in radiation levels in normally accessible spaces and of excessive radioactivity released in plant effluents. Such systems shall be designed with redundancy and with capability to permit testing their efficiency of operation.

CRITERION 23 - EFFLUENT MONITORING All plant effluent systems shall be designed to include means for measuring and recording the amount of radionuclides in any effluent. In order that- the data thus measured and recorded can be Enclosure "A"

used, the flow of environmental diluting media, either air or water, shall be determined.

CRITERION 24 - EFFLUENI CONTROL The design of the plant shall include means to control the release of radioactive effluents, whether gas, liquid, or solid, during normal operations and under accident conditions. Systems provided to guard against the release of radioactive materials shall be designed to be monitored and tested, and shall be provided with alarms. Capability shall be provided for control of contaminated gaseous effluents and for prompt cessation of the flow of contaminated liquid effluents1 or for retention of [such] liquid effluents as is necessary1 to assure that the concentrations of radioactive materials in [ liquid] these effluents are maintained as low as practicable.

FUEL AND RADIOACTIVE WASTE [6TORAGE] MANAGEMENT CRITERION 25 - FUEL AND RADIOACTIVE WASTE SYSTEMS Fuel storage, radioactive waste storage, and other systems that might contain or handle radioactive materials shall be designed to assure adequate safety under normal and accident conditions.

These systems shall be designed (1) with a capability to test components important to safety to assure their continued design functioning, (2) with suitable shielding for radiation protection under normal and accident conditions, (3) with appropriate confine-ment systems, and (4) with a heat removal capability having test-

, ability and reliability that reflects its importance to safety.

Enclosure "A"

. CRITERION 26 - WASTE [BISP06Ab] MANAGEMENT SYSTEMS The waste [dispesel] management systems shall be designed so their performance will comply with the regulations in this chapter.

DECOMMISSIONING CRITERION 27 - DECOMMISSIONING In accordance with Appendix F, a design objective for fuel reprocessing plants shall be to facilitate decontamination and removal of all significant radioactive wastes at the time the facility is permanently decommissioned.

Effective Date: The foregoing amendments become effective 19 [

(Sec. 161, Pub. Law 83-703, 68 Stat. 948 (42 U.S.C. 2201)); Sec. 201, Pub. Law 93-438, 88 Stat. 1242 (42 U.S.C. 5841)).

Dated at this day of , 1975.

For the Nuclear Regulatory Commission.

Secretary of the Commission Insert a date 30 days af ter date of publication n the

FEDERAL REGISTER.

Enclosure "A"

List of organizations submitting comments on notice of proposed amendment to 10 CFR Part 50: Appendix P, " General Design Criteria for Fuel Reprocessing Plants" Published in the Federal Register (39 FR 26293), July 18, 1974*

1. Dr. Marvin Resnikoff, Sierra Club, Niagara Group 8/2/74 & 9/19/75

2. James P. Hogan, General Atomic Co. 9/16/74

3. C. W. Smith, General Electric, Nuclear Energy Division 9/19/75

4. J. R. Clark, Nuclear Fuel Services Inc. 9/19/74

5. Romano Salvatori, Westinghouse Electric Corp.,

Power Systems 9/19/74

6. R. Nilson, Exxon Nuclear Co. 9/20/74

7. Stanley K. Hellman, Ralph M. Parsons Co. 9/20/74

8. W. J. Price, Allied-General Nuclear Services 9/24/74

9. Neal L. Moylan, New York Atomic Energy Council 9/25/74

10. Dr. Terry R. Lash and John E. Bryson, Esq.

Natural Resources Defense Council Inc. 10/3/73 1

i i

• Copies of comments received are avilable in the Office of the Secretary of Commission.

! Enclosure "B" t

SUMMARY

OF SIGNIFICANT COMMENTS RECEIVED AND THEIR RESOLUTION

a. Comment - Two comments received disagreed with the conclusions in the

" Environmental Impact Appraisal of Proposed Amendment to 10 CFR Part 50,

' General Design Criteria for Fuel Reprocessing Plants,'" that an environ-mental statement is not required. One comment expressed the opinion that an environmental impact statement should be prepared because the proposed Appendix P "would establish the minimum requirements for the principal design criteria for fuel reprocessing plants." Another comment agreed with the above conclusion and in addition asserted that proposed criterion 21 (Radiation Shielding), with no controls on the total man-rems to the community, would lead to major environmental consequences which requires an environmental impact statement, Ab comment included a letter from the National Intervenors to former AEC Chairman Ray, which referenced radiation exposures to short-term employees at the Nuclear Fuel Service fuel reprocessing plant in New York. It also included two newspaper articles pertaining to this subject to substantiate the assertion.

Resolution - The environmental impact appraisal points out that the general design criteria by themselves, do not have any direct effect on the general public or the environment. The general design criteria formalize the considerations used by the Commission in making findings

' needed for issuance of a construction permit for fuel reprocessing plants.

The levels of environmental impact for fuel reprocessing plants can be meaningfully addressed only in the detailed environmental impact statements which are prepared in connection with licensing action for individual plants. Any impact from the operation of a fuel reprocessing M [

' Enclosure "C"

plant is evaluated by review of the principal design criteria during the licensing process. The staff believes that these comments misinterpreted the sense of the general design criteria, and agrees with the conclusion of the environmental impact appraisal that an environmental impact state-ment is not required. (Discussion which addresses criterion 21 specifically is presented in paragraph h.)

b. Comment - A definition of "important to safety" should be included in Section II, Definitions.

Resolution - The purpose of the general design criteria is to establish the minimum design requirements for structures, systems and components that are "important to safety." Therefore, a definition of this phrase is added to Section II.

c. Comment "The general design criteria for fuel reprocessing plants, which includes guidance for design with respect to normal operation and keeping releases 'as low as practicable,' seems inconsistent with the stated purpose in the introduction that the criteria are for structures, systems and components "important to safety."

Resolution - To meet the requirements of this chapter,.the design of structures, systems and components must consider abnormal operation and credible accident releases as well as routine operating releases. The design bases thus developed will reflect the result of these requirements, when the guidelines of the entire chapter are followed. The references to "as low as practicable" in these criteria reflect normal operation effluents and are retained.

Enclosure "C"

...~-.-z..-..-

- ~ . . . . _.

a

d. Comment - That criterion 2 subsection b implies an unrealistic

- , requirement in that plant stet up capability is required following an i

unscheduled shutdown.

T Resolution - This criterion requires only that the design shall include features which provide capability for safe start-up following unscheduled shutdown. It does not require the licensee to restart the plant, should he deem it advisable to decommission it. It seems reason-able to design a facility so that it may be restarted safely following unscheduled shutdown, therefore this criterion is retained.

1 i

e. Comment - Criterion 2 subsection c should be revised to indicate that the intensity of natural phenomena be restricted to events that can i

be reasonably measured and to indicate that the licensee is not required to install the required instruments where these data are available elsewhere.

i Resolution - The intensity of some natural phenomena stch as floods, tornadoes or lightning is frequently indeterminable. The intensity of meteorological events can be measured, but only within the limits of the instruments. Therefore, this criterion is revised to clarify the original intent, which was to require measurement of seismic event intensity only j

and to reflect that the licensee must demonstrate capability for acquiring f the measurement of this intensity for comparison with design bases.

i

f. Conament - Criterion 16 should be revised to change the requirements J

that tuo unlikely, independent and concurrent or sequential changes occur in conditions that are essential to nuclear criticality safety, to Enclosure "C" r i

i 4

[

t

maintain suberiticality. One' comment requested a change to three and a few requested a change to one, where sufficient shielding is available to mitigate the radiation dose.

Resolution - Mitigation of a criticality accident will be one of the considerations necessary to establish the margin of safety. However, to reduce the requirement to one change could result in a significant increase in the number of criticality accidents. This is considered an undesirable circumstance even if the results of the accident can be mitigated by shielding. The staff believes that there are conditions where the requirement for three unlikely changes could not be accomplished, or is impractical, therefore, the existing criterion is preferred.

g. Comment - Criterion 20 should be completely revised to indicate prevention of accumulation of radioactive materials or make provisions for decreasing the content of radioactive material and to minimize the time required to perform work in high radioactivity areas.

Resolution - Criterion 9, subsection e, establishes the criterion for prevention of radioactive material accumulation. Criterion 21 is revised to require the design to facilitate work in high radioactivity areas. It is felt that otherwise the wording of this criterion is adequate to meet the requirements intended.

h. Comment - (1) although criterion 21 ensures that no individual receives greater than the permissible dose it should further specify a limit to the number of individuals exposed and (2) it should provide Enclosure "C"

restrictions on the design of fuel reprocessing plants in terms of personnel exposure, as well as dose rate per se.

Resolution - The intent of this criterion is that the principal design should specifically address the control of radiation exposures by making every reasonable effort to maintain the total exposures as low as practicably achievable. The objectives of efforts to insure that radiation exposures in accessible areas are as low as practicable is to reduce avoidable exposures. It is not sufficient to control the maximan dose to individuals, the total dose to the group should be as low as practicable. Operating experience with fuel reprocessing plants indicate that this concept is of the utmost importance in all aspects of fuel reprocessing plant operations. Consistent with current NRC regulations, the criterion does not limit the number of individuals exposed to occupational dose limits. However, the criterion has been revised to clarify the requirement that process equipment, process layout and maintenance provisions, as well as shielding will be designed to assure that radiation exposures in accessible areas are as low as practicable.

l Enclosure "C"

DRAFT PUBLIC ANNOUNCEMENT NRC ADOPTS DESIGN CRITERIA FOR NUCLEAR FUEL REPROCESSING PLANTS The Nuclear Regulatory Commission is amending its regulations to establish general design criteria for construction of nuclear fuel reprocessing plants.

The general design criteria contained in a new Appendix P to 10 CFR Part 50 establish minimum requirements for the principal design criteria which must be included in applications to build individual reprocessing plants. The principal design criteria establish the design, fabrication, construction, testing and performance requirements for structures, l

systems and components necessary to provide reasonable assurance that the proposed facility can be operated without undue risk to public health and safety.

The criteria cover overall requirements, protection by multiple confinement barriers and systems, processing safety features, nuclear criticality safety, radiological protection, fuel and radioactive waste management and decommissioning.

Except for certain clarifying changes, the amendments to Part 50 being published in the Federal Register on are substantially the same as those published for public comment in July 1974, and will be effective .

Enclosure "D"

F Drafting Recommendation It is recommended that the notice of proposed rulemaking published for comment on July 18, 1974 be withdrawn.

The proposed rule has been carried tnese many years as it did serve industry as a planning document when the commercial fuel reprocessing industry was active. The current status of, or potential for, commercial fuel reprocessing forms the basis for this recommendation.

Screening Process A. Issue Proposed rule, Appendix P, " General Design Criteria for Fuel Reprocessing Plants," published in the Federal Register on July 18, 1974 as amendment to 10 CFR Part 50.

B. Need for addressing issue There is no necessity or urgency for addressing the issue.

There has been little or no activity on this item since August 27, 1975, when action for going effective was put in " hold" by the Commission. Commercial fuel reprocessing is at a standstill.

Quality Control Evaluation The existing document which was routed for Commission action in August 1975 requires complete rewrite for compliance with current procedures.

{s-ga

DISlRIBU110N:

RES RDG/ ALPHA CEBR RDG/SUBJ bec: G. A. Arlotto K. G. Steyer C. W. Nil sen <. JUL 191984 l

MEM0EAP:DUF. FOR: R. E. Cunninghar, Director Division of Fuel Cycle A heterial Safety Office of huclear Katerial Safety & Safeguards FR&:: Guy A. Arlotto Director Division of Engineering Technology C1fice of huclear Regulatory Research SUFJECT: DRAFT RECOMEF:DATI0t;S TO E00 CONCERf:ItiG WHE1hEk AhD HLk 10 C0hTINUE WITH OhC0!h6 RULENAKING SPUhS0REL bY RES Enclosed for your consideration are draft recorxencations supported by a draf t office review concerning dether ana how to continue with an ongoing ruleraking sponsored by RES for which your of fice is identified as a itser of fice.

This riercranduc constitutes sy concurrence in the enclosed craft recer.tencations.

I plan to dispatch this rettorandur with tt,e enclosed craf t recors.,encations to the Director, RES, two weeks from the above date.

Please acknowledge receipt by returning this r+corancur with or withuut corrents on the draf t recotTendations as indicatec below.

Guy A.

'"db otto, Director

(

Division of Engineering Technology Office of tiuclear Regulator.y hesearch

Enclosures:

A - ERC Regulatory Agenda B - Effective ruler.aking routed for i Comission action Aug.197b l (with note Gossick to hinogue)

C - Task leader's review V8S,/90MSC (A / a f 7d' C e/ V t # ,

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