ML24002B086

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Rev 1 Withdrawal
ML24002B086
Person / Time
Issue date: 03/11/2024
From: Stephen Poy
NRC/NMSS/DFM/FFLB
To:
Shared Package
ML24002B082 List:
References
RG-3.025, Rev 1
Download: ML24002B086 (2)


Text

Basis for Withdrawal of Regulatory Guide

Regulatory Guide Number: 3.25, Revision 1

Division Titles: Standard Format and Content of Safety A nalysis Reports for Uranium Enrichment Facilities

Office/Division/Branch: NMSS/DFM/FFLB

Technical Lead: Stephen Poy

Subject:

Basis for Withdrawal

(1) What regulation(s) did the Regulatory Guides support?

Regulatory Guide (RG) 3.25, Revision 1, was published in 2008 t o provide updated guidance on meeting requirements in Title 10 of the Code of Federal Regulations, Part 70, Domestic Licensing of Special Nuclear Material, Subpart H, Additional Requirements for Certain Licensees Authorized to Possess a Critical Mass of Special Nucl ear Material, which identifies risk-informed performance requirements and requires applicants to complete an integrated safety analysis (ISA) and submit an ISA summary and other infor mation to the NRC for approval.

(2) What was the purpose of the Regulatory Guide?

RG 3.25, Revision 1 provided guidance on the standard format an d content of SARs and related documents submitted as part of an application to construct or m odify and operate a nuclear fuel cycle facility. This RG Revision endorsed the standard format a nd content for SARs and ISA summaries described in NUREG-1520, Standard Review Plan for th e Review of a License Application for a Fuel Cycle Facility, as a process that the N RC staff found acceptable for meeting the regulatory requirements.

(3) How was the Regulatory Guide used in regulatory activities, particularly licensing reviews and inspections?

RG 3.25, Revision 1 endorsed the standard format and content fo r an SAR or ISA summary for a uranium enrichment facility described in NUREG-1520 as a proc ess the NRC found acceptable for meeting the regulatory requirements. Applicants use NUREG-1520 while developing fuel cycle facility applications, and NRC staff use NUREG-1520 while reviewing these applications.

(4) Is this Regulatory Guide referenced in other technical or r egulatory documents?

What are the ripple effects on this document if the RG is wit hdrawn?

RG 3.25, Revision 1 is not referenced in other documents. This RG Revision recommends that applicants use NUREG-1520 in preparing a fuel facility license application. No ripple effects are anticipated by withdrawing this RG Revision because NUREG-1520 has been the primary guidance document used by the NRC staff for the review of fuel cycle facility license applications and by applicants for the development of these lic ense applications since 2002. In

1 the case that there is a legacy technical or regulatory guidanc e document referencing this RG Revision, the withdrawal notification will inform the applicant s to use NUREG-1520.

(5) Why is the Regulatory Guide no longer needed (e.g. what is the rationale for withdrawing this Regulatory Guide instead of revising it)?

In RG 3.25, Revision 1, the NRC staff found NUREG-1520 to be ac ceptable for meeting the regulatory requirements for the content and format of SARs and ISA summaries. NUREG-1520 provides current guidance to applicants and NRC staff reviewers on the acceptable content and format of SARs and ISA summaries, so the RG Revision was not ne eded to endorse NUREG-1520.

(6) What guidance is available once the Regulatory Guide is wit hdrawn?

NUREG-1520 includes guidance acc eptable to NRC staff for developing license applications.

Applicants use NUREG-1520 while developing fuel cycle facility applications, and NRC staff use NUREG-1520 while reviewing these applications. RG 3.25, Revisio n 0 is also still available but is not the most recent acceptable guidance for developing and r eviewing these applications.

(7) Is this Regulatory Guide included in any of the licensing b asis documents? If yes, what would be the implications?

RG 3.25, Revision1, is not referenced in any licensing basis do cument.

(8) Do other agencies rely upon the Regulatory Guide, e.g., th e Agreement States, National Aeronautical and Space Administration, and Department of Energy?

The staff is unaware of any other agency that uses or relies on the guidance included in RG 3.25, Revision 1.

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