Technical Support for Improving the Licensing Regulatory Base for Selected Facilities Associated with the Front End of the Fuel Cycle

Pacific Northwest Laboratory (PNL) was asked by the NRC Office of Nuclear Material Safety and Safeguards (NMSS) to determine the adequacy of its health, safety and environmental regulatory base as a guide to applicants for licenses to operate UF{sub 6} conversion facilities and fuel fabrication plants. The regulatory base was defined as the body of documented requirements and guidance to licensees, including laws passed by Congress, Federal Regulations developed by the NRC to implement the laws, license conditions added to each license to deal with special requirements for that specific license, and Regulatory Guides. The study concentrated on the renewal licensing accomplished in the last few years at five typical facilities, and included analyses of licensing documents and interviews with individuals involved with different aspects of the licensing process. Those interviewed included NMSS staff, Inspection and Enforcement (IE) officials, and selected licensees. From the results of the analyses and interviews, the PNL study team concludes that the regulatory base is adequate but should be codified for greater visibility. PNL recommends that NMSS clarify distinctions among legal requirements of the licensee, acceptance criteria employed by NMSS, and guidance used by all. In particular, a prelicensing conference among NMSS, IE and each licensee would be a practical means of setting license conditions acceptable to all parties