FR 2021-03865

The U.S. Nuclear Regulatory Commission (NRC) recently issued a new Regulatory Guide (RG) 1.237, intended to guide changes during the construction of nuclear power plants. This guide specifically applies to facilities being built under a combined license referencing a certified design, per regulations under 10 CFR part 52. Essentially, the guide outlines an acceptable method to implement changes to a nuclear facility’s design, involving its structures, systems, and components. Notably, this guide does not force compliance, meaning facilities are not mandated to follow these guidelines strictly. However, the advisory nature of the guide could lead to varying levels of adoption across different projects.

Summary and Purpose

The key aim of this guide is to provide a consistent and structured approach for making construction-based design changes at nuclear facilities, ensuring that modifications maintain safety and regulatory compliance. By formalizing this process, the NRC seeks to avoid potential inconsistencies and variances that might arise without a standardized procedure.

Significant Issues and Concerns

A few components within the guide could generate confusion or require further clarification:

• Technical Jargon: The document contains specialized terms and acronyms such as "backfitting," "forward fitting," and "issue finality," which could be challenging for individuals not steeped in nuclear regulatory language.

• Non-Mandatory Nature: The non-mandatory nature of the guide might result in ambiguity about when or why stakeholders should follow these guidelines. This could lead to inconsistent practices across different projects.

• Reference Materials: The guide contains numerous technical document references and accession numbers (e.g., ML20349A335, ML20010G336), which may be difficult to understand for those not familiar with the NRC's documentation systems.

Public and Stakeholder Impact

Public Impact:

The general public should find reassurance in the overarching intention of the guide, which is to ensure safe and compliant construction of nuclear facilities. By endorsing a structured process, the NRC is advocating for uniformity in safety practices, which ultimately benefits public safety.

Impact on Specific Stakeholders:

• Nuclear Industry Professionals: For those within the nuclear sector, the guide may introduce a standardized procedure but leaves room for discretion. This flexibility can be both a blessing and a challenge as companies weigh the balance between strict adherence to NRC suggestions and the efficiencies of their internal processes.

• Regulatory Bodies: For state or federal bodies overseeing nuclear safety, the guide serves as a critical benchmark against which to assess facility practices. However, the advisory status of the guide means regulators might encounter varying compliance levels, necessitating additional oversight or clarification in some instances.

• Public Advocacy Groups: These entities may view the guide as an opportunity to advocate for tighter enforcement of NRC recommendations, encapsulating a more uniform approach to the construction of nuclear facilities.

Conclusion

Overall, Regulatory Guide 1.237 represents an effort by the NRC to promote consistent and safe practices in the construction of nuclear facilities. However, its non-mandatory nature and technical density could pose challenges for varying stakeholders, necessitating careful consideration of its provisions and potential impacts on both industry practices and public safety assurances.