U.S. NUCLEAR REGULATORY COMMISSION May 2009

Revision 2

REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 3.52 

(Draft was issued as DG-3031, dated September 2008) 

STANDARD FORMAT AND CONTENT FOR THE HEALTH AND 

SAFETY SECTIONS OF LICENSE RENEWAL APPLICATIONS 

FOR URANIUM PROCESSING AND FUEL FABRICATION 

A. INTRODUCTION 

 This guide directs the reader to the type of information acceptable to the U.S. Nuclear Regulatory 

Commission (NRC) in its evaluation and verification of the safety basis for the licensing of special 

nuclear material (SNM). It references the application of NUREG-1520, “Standard Review Plan for the 

Review of a License Application for a Fuel Cycle Facility” (Ref. 1), issued March 2002, to the format and 

content of license renewal applications for fuel cycle facilities. 

The regulatory framework that the NRC has established for procedures and criteria for the 

licensing of SNM is set forth in Title 10, Part 70, “Domestic Licensing of Special Nuclear Material,” of 

the Code of Federal Regulations (10 CFR Part 70) (Ref. 2). In 10 CFR 70.73, “Renewal of Licenses,” the 

regulations specify that applications for license renewal (including licenses for enriched uranium 

processing, fuel fabrication, uranium enrichment, enriched uranium hexafluoride conversion, plutonium 

processing, fabrication of mixed-oxide fuel, and scrap recovery of SNM) must be filed in accordance with 

10 CFR 2.109, “Effect of Timely Renewal Application” (Ref. 3); 10 CFR 70.21, “Filing;” 10 CFR 70.22, 

“Contents of Applications;” 10 CFR 70.33, “Renewal of Licenses;” 10 CFR 70.38, “Expiration and 

Termination of Licenses and Decommissioning of Sites and Separate Buildings or Outdoor Areas;” and 

10 CFR 70.65, “Additional Content of Applications.” 

 While the regulations provide general information for filing license renewal applications, 

NUREG-1520 provides NRC guidance for reviewing and evaluating the health, safety, and environmental 

protection aspects of applications for licenses to possess and use SNM at fuel cycle facilities. In addition, 

The NRC issues regulatory guides to describe and make available to the public methods that the NRC staff considers acceptable 

for use in implementing specific parts of the agency’s regulations, techniques that the staff uses in evaluating specific problems 

or postulated accidents, and data that the staff needs in reviewing applications for permits and licenses. Regulatory guides are not 

substitutes for regulations, and compliance with them is not required. Methods and solutions that differ from those set forth in 

regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a 

permit or license by the Commission. 

This guide was issued after consideration of comments received from the public. 

Regulatory guides are issued in 10 broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials 

Facilities; 4, Environmental and Siting; 5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 

9, Antitrust and Financial Review; and 10, General. 

Electronic copies of this guide and other recently issued guides are available through the NRC’s public Web site under the 

Regulatory Guides document collection of the NRC’s Electronic Reading Room at 

http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC’s Agencywide Documents Access and Management 

System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML091050098. 
Rev. 2 of RG 3.52, Page 2 

this guidance describes the scope, level of detail, and acceptance criteria for reviews. Thus, this NUREG 

also serves as guidance on the information to be included in licensing applications and establishes a 

format for presenting the information. Use of a standard format will help to ensure uniformity and 

completeness in the preparation of licensing applications. 

 In addition to the contents of the application required in 10 CFR 70.22, applicants must also 

submit an integrated safety analysis (ISA) summary and a description of the safety program established 

under 10 CFR 70.62, “Safety Program and Integrated Safety Analysis,” in accordance with 

10 CFR 70.65. However, the license issued by the NRC does not incorporate the ISA summary. Lists of 

the types of information required to be submitted in an ISA summary appear in 10 CFR 70.65(b); 

Chapter 3 of NUREG-1520 describes the acceptance criteria. NUREG-1513, “Integrated Safety Analysis 

Guidance Document,” issued May 2001 (Ref. 4), provides additional guidance applicable to performing 

an ISA and documenting the results. NUREG/CR-6410, “Nuclear Fuel Cycle Accident Analysis 

Handbook,” issued March 1998 (Ref. 5), provides guidance on acceptable methods for evaluating the 

chemical and radiological consequences of potential accidents. 

Subsequent to the publication of Revision 1 of Regulatory Guide 3.52 in November 1986, the 

NRC revised the requirements for the licensing of SNM. NUREG-1520 superseded and replaced this 

regulatory guide and incorporated the revised requirements. This regulatory guide endorses the methods 

and procedures for evaluation and verification for the licensing of SNM contained in NUREG-1520 as a 

process that the NRC staff has found acceptable for meeting the regulatory requirements. 

This regulatory guide contains information collection requirements covered by 10 CFR Part 70 that 

the Office of Management and Budget (OMB) approved under OMB control number 3150-0009. The NRC 

may neither conduct nor sponsor, and a person is not required to respond to, an information collection 

request or requirement unless the requesting document displays a currently valid OMB control number. 

B. DISCUSSION

Licensees should file a renewal application in proper form not less than 30 days before the 

expiration of the existing license (see 10 CFR 70.38(a) (1)). However, earlier filing is preferable. 

 NUREG-1520 addresses the health, safety, and environmental protection requirements of 

10 CFR Part 20, “Standards for Protection against Radiation” (Ref. 6), and 10 CFR Part 70, including the 

accident safety requirements reflected in Subpart H, “Additional Requirements for Certain Licensees 

Authorized to Possess a Critical Mass of Special Nuclear Material,” of 10 CFR Part 70. In addition, because 

NUREG-1520 describes the scope, level of detail, and acceptance criteria for reviews, it serves as regulatory 

guidance for licensees to determine what information to present in a license renewal application. 

NUREG-1520 is not a substitute for NRC regulations and compliance with it is not required. Methods and 

solutions different from those described in the NUREG-1520 may be acceptable if they provide a basis for 

the staff to make the determination needed to renew a license. 

 NUREG-1520 discusses the major topics addressed within the safety program description of a 

renewal application, including general information, organization and administration, the ISA and ISA 

summary, radiation protection, nuclear criticality safety, chemical process safety, fire safety, emergency 

management, environmental protection, decommissioning, and management measures. To facilitate the 

staff’s review, a license renewal application should address the contents of NUREG-1520 in the same 

order as that presented in the document. 
Rev. 2 of RG 3.52, Page 3 

 NUREG-1520 focuses on safety and environmental impact reviews and not on safeguards. 

NUREG-1280, “Standard Format and Content Acceptance Criteria for the Material Control and 

Accounting Reform Amendment,” issued April 1995 (Ref. 7), and NUREG-1065, “Acceptable Standard 

Format and Content for the Fundamental Nuclear Material Control Plan Required for Low-Enriched 

Uranium Facilities,” issued December 1995 (Ref. 8), contain review criteria applicable to the safeguards 

sections of a license application. 

Appendix A, “Filing Standards for Submittals,” to NUREG-1520 provides additional guidance 

regarding the acceptable and preferred format for new and renewal applications. Appendix A covers style 

and composition, the handling of proprietary and classified information, and procedures for updating or 

revising pages and incorporating information by reference, such as previous submittals, statements, or 

reports filed with the NRC with respect to an existing license. 

 

 As part of the content of an application, 10 CFR 70.22(a)(3) requires that an applicant specify the 

period of time for which the license renewal is requested. In 2006, the NRC established a new policy 

extending the maximum license term for certain fuel cycle licensees who are required to submit ISA 

summaries for approval (Ref. 9). The new policy extended the maximum license term to a 40-year 

period. The NRC may approve license terms for less than 40 years, on a case-by-case basis. 

C. REGULATORY POSITION 

This regulatory guide endorses the methods and procedures for evaluation and verification of the 

licensing of SNM detailed in NUREG-1520 as a process that the NRC has found acceptable for meeting 

the regulatory requirements. 

D. IMPLEMENTATION 

The purpose of this section is to provide information to applicants and licensees regarding the 

NRC’s plans for using this regulatory guide. The NRC does not intend or approve any imposition or 

backfit in connection with its issuance. 

 In some cases, applicants or licensees may propose or use a previously established acceptable 

alternative method for complying with specified portions of the NRC’s regulations. Otherwise, the 

methods referenced in this guide will be used in evaluating compliance with the applicable regulations for 

license renewal applications. 
Rev. 2 of RG 3.52, Page 4 

REFERENCES1 

1. NUREG-1520, “Standard Review Plan for the Review of a License Application for a Fuel Cycle 

Facility,” U.S. Nuclear Regulatory Commission, Washington, DC, March 2002. 2

2. 10 CFR Part 70, “Domestic Licensing of Special Nuclear Material,” U.S. Nuclear Regulatory 

Commission, Washington, DC.

3. 10 CFR Part 2, “Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders,” 

U.S. Nuclear Regulatory Commission, Washington, DC.

4. NUREG-1513, “Integrated Safety Analysis Guidance Document,” U.S. Nuclear Regulatory 

Commission, Washington, DC, May 2001. 

5. NUREG/CR-6410, “Nuclear Fuel Cycle Accident Analysis Handbook,” U.S. Nuclear Regulatory 

Commission, Washington, DC, March 1998.

6. 10 CFR Part 20, “Standards for Protection against Radiation,” U.S. Nuclear Regulatory 

Commission, Washington, DC.

7. NUREG-1280, “Standard Format and Content Acceptance Criteria for the Material Control and 

Accounting (MC&A) Reform Amendment,” U.S. Nuclear Regulatory Commission, Revision 1, 

Washington, DC, April 1995.

8. NUREG-1065, “Acceptable Standard Format and Content for the Fundamental Nuclear Material 

Control (FNMC) Plan Required for Low-Enriched Uranium Facilities,” Revision 2, U.S. Nuclear 

Regulatory Commission, Washington, DC, December 1995. 

9. 71 FR 70441, “Maximum 40-Year Licensing Terms for Certain Fuel Cycle Facilities,” Federal 

Register, Volume 71, Number 232, p. 70441, Washington, DC, December 4, 2006. 

 

1 Copies of the non-NRC documents included in these references may be obtained directly from the publishing 

organizations. 

2 All NRC regulations listed herein are available electronically through the Public Electronic Reading Room on the 

NRC=s public Web site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/. Copies are also available for inspection 

or copying for a fee from the NRC=s Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR=s 

mailing address is USNRC PDR, Washington, DC 20555; telephone (301) 415-4737 or (800) 397- 4209; fax (301) 

415-3548; e-mail pdr.resource@nrc.gov.