ML17304B308
| ML17304B308 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/27/2017 |
| From: | Ashkeboussi N Nuclear Energy Institute |
| To: | Szabo A NRC/OCIO, US Executive Office of the President, Office of Information and Regulatory Affairs, US Executive Office of the President, Office of Mgmt & Budget (OMB) |
| References | |
| NRC-2017-0048 | |
| Download: ML17304B308 (5) | |
Text
NIMA ASHKEBOUSSI Director, Fuel Cycle Programs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8022 nxa@nei.org nei.org October 27, 2017 Mr. Aaron Szabo Desk Officer Office of Information and Regulatory Affairs (3150-0009)
NEOB-10202 Office of Management and Budget Washington, DC 20503
Subject:
Industry Comments on the Information Collection for Domestic Licensing of Special Nuclear Material (Docket ID: NRC-2017-0048)
Dear Mr. Szabo:
On behalf of the Nuclear Energy Institutes1 (NEI) fuel cycle facility (FCF) members, we appreciate the opportunity to comment on the information collection renewal entitled 10 CFR Part 70, Domestic Licensing of Special Nuclear Material (Docket ID NRC-2017-0048). The regulations in 10 CFR Part 70 establish requirements for licensees to own, acquire, receive, possess, use, and transfer special nuclear material. The information in the applications, reports, and records is used by the Nuclear Regulatory Commission (NRC) to make licensing and/or regulatory determinations concerning the use of special nuclear material.
A burden spreadsheet was published on www.regulations.gov (through the above referenced docket ID, under the Supporting Documents folder). Overall, some burden estimates were reasonably captured and this letter and attachment will not address those specific estimates as industry believes no changes are needed. However, we do believe that several of the burden estimates in Table 1 (Annual Reporting Burden) are miscalculated by several orders of magnitude. Specific examples, with industrys suggested burden estimates, are provided in the attachment (see column 4 labelled industry input). We also believe that the estimates in Table 2 (Annual Recordkeeping Burden) are generally too low. Industry offers the revised figures based on decades of historical operational and regulatory compliance experience, as well as input from technical, managerial, and regulatory affairs specialists who complete the referenced reports. It is industrys expectation that the numbers reflected in the attachment will be seriously considered to reflect the new burden estimates for Part 70 reporting and recordkeeping. At a minimum, based on industrys long 1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
Mr. Aaron Szabo October 27, 2017 Page 2 experience with the time burdens for regulatory compliance, there should be much closer alignment and calibration between the NRCs estimates and the estimates suggested in this attachment.
We hope these suggested burden estimate figures better inform the renewal of this information collection, and look forward to seeing how industrys experienced input is incorporated in the final revised burden estimates. Furthermore, we hope this letter highlights the heavy administrative burden that several Part 70 requirements place on licensees. Please contact me or Hilary Lane (202-739-8148; hml@nei.org) if you have any questions.
Sincerely, Nima Ashkeboussi Attachment c:
Mr. David Cullison, OCIO, NRC Mr. Craig Erlanger, NMSS, NRC Mr. Merritt (Nick) Baker, NMSS, NRC
1 ATTACHMENT Industry Burden Hour Estimates on the Information Collection Renewal entitled 10 CFR Part 70, Domestic Licensing of Special Nuclear Material (Docket ID NRC-2017-0048)
Table 1: Annual Reporting Burden Requirement Description Burden Hours per
Response
Industry Input:
Burden Hours per Response Industry Comments 70.20a(d)
Transportation of SNM 40 60 This includes licensee time to prepare, review, and approve the plan. The amount of time required to assure that each shipment complies with the security plan would require an additional 1-2 hours per shipment to verify seals are intact, and to verify that the required notifications and acceptance of shipments are received.
70.20b(f)
Notification of shipments 4
Intentionally blank The responses per respondent is currently 1.
This is a poor estimate for the number of annual shipments (and hence notifications) that a licensee would make. Industry suggests the responses per respondent is changed to 200. Notifications include the time required to make notifications 10-days in advance of each shipment, notifying the operations center 2-days prior to each shipment, and notifications of any schedule changes on a secure telephone. Licensees may make 4+ shipments each week.
70.21(a),
70.22(a),
70.32(c)(1),
70.33, 70.34, Filing an application or renewal 213 3,000 An analysis of NRC billing for the review of new applications or renewals will demonstrate the significant
2 70.39(a), 70.73 burden placed on licensees and applicants. For example, two licensees currently in the review process have been invoiced for approximately 6700 hours0.0775 days <br />1.861 hours <br />0.0111 weeks <br />0.00255 months <br /> (cumulatively),
and spend a considerable amount of time supplementing their renewal application based on NRC requests for additional information (RAI). The responses per respondent estimate of 35 is also low, due to several rounds of RAIs, and several questions in each round.
70.22(a)(9) and 70.25 Funding Plan Decommissioning funding plan 300 550 The first DFP submittal will be the most burdensome to the licensee (industry predicts 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> for the first submittal, which can vary depending on the size of the facility and number of buildings involved). 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> for a subsequent submittal is reasonable.
Industry suggests a burden estimate that reflects an average of the initial and subsequent submissions.
70.25(e) NRC licenses and 70.25(e)
Agreement States Detailed cost estimate, once every 3 years 8
160 Industry must take into consideration the 8 event adjustments and tables 6.1 through 6.8 from NUREG 1757, Vol 2 70.32(a)9 Notification of filing for bankruptcy 1
10 Intentionally blank 70.32(c)(2)
Control and accounting of source material 13.3 Intentionally blank General comment: this estimate is too low 70.32(i)
Emergency plans 16 85 While 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> may be adequate for tracking changes and notifications alone, more hours are needed to make changes to
3 the source documents.
70.38(e)
Financial assurance for decommissioning 40 60 Intentionally blank 70.50(a),(b)
Immediate and 24-hour reporting 4
24 Involves additional investigative and review time to create the report 70.50(c)(1) and (c)(2)
Contents of reports 4
120 Estimate includes hours spent on the 30-day follow-up report after an initial report is made 70.51(a)
Records for license termination 2
1,000 This increase is due to the large burden in identifying and recovering decades worth of historical files, which must be transferred to the respective NRC regional office. For several licensees, records are in hardcopy form only, which would require a dedicated team to transition files to an electronic format.
70.59 Effluent monitoring reports 5
40 Intentionally blank 70.72(d)(3)
ISA annual update 40 600 Intentionally blank 70.74(a),
70.74(b), and 10 CFR Part 70, Appendix A Reports to ops center, written
- reports, reportable safety events 40 60 Increased burden hours due to written follow-up reports