ML18099A046
ML18099A046 | |
Person / Time | |
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Issue date: | 08/16/2018 |
From: | Office of Nuclear Reactor Regulation |
To: | |
Ellenson, Margaret 415-0894 | |
Shared Package | |
ML18099A041 | List: |
References | |
10 CFR 50.55a, RIN 3150-AJ13 | |
Download: ML18099A046 (5) | |
Text
DRAFT SUPPORTING STATEMENT FOR INFORMATION COLLECTIONS CONTAINED IN APPROVAL OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE CASES PROPOSED RULE 10 CFR PART 50 (RIN-3150-AJ93)
Description of the Information Collection The U.S. Nuclear Regulatory Commission (NRC) regulations in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a incorporate by reference American Society of Mechanical Engineers (ASME) Codes for nuclear power plants. The NRC proposes to change the information collection requirements associated with those regulations, as discussed in this supporting statement. The NRC expects a reduction in burden on respondents due to the use of ASME Code Cases, as described below. The use of ASME Code Cases reduces the need for licensees to submit licensing actions for the use of voluntary alternatives to the ASME Code requirements.
The NRCs regulations in 10 CFR 50.55a incorporate by reference Division 1 rules of Section III, "Rules for Construction of Nuclear Power Plant Components," and Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the ASME Boiler and Pressure Vessel Code (BPV Code); and the rules of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code). These rules of the ASME BPV and OM Codes set forth the requirements to which nuclear power plant components are constructed, tested, repaired, and inspected.
The NRC approves and/or mandates the use of the ASME BPV and OM Codes in 10 CFR 50.55a through the process of incorporation by reference. As such, each provision of the ASME Codes incorporated by reference into, and mandated by, 10 CFR 50.55a constitutes a legally-binding NRC requirement imposed by regulation.
In response to BPV and OM Code user requests, the ASME develops ASME Code Cases that provide voluntary alternatives to ASME BPV and OM Code requirements under certain circumstances. The NRC reviews ASME BPV and OM Code Cases, determines the acceptability of each Code Case, and publishes its findings in NRC Regulatory Guides (RG).
The RGs are revised periodically as new Code Cases are published by the ASME. The proposed rule associated with this supporting statement is the latest in a series of rulemakings that incorporate by reference new versions of the RGs into 10 CFR 50.55a, so they may be used by licensees. The RGs the NRC proposes to incorporate by reference into the regulations are RG 1.84, Design, Fabrication, and Materials Code Case Acceptability, ASME Section III, Revision 38; RG 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 19; and RG 1.192, Operation and Maintenance Code Acceptability, ASME OM Code, Revision 3. These revisions supersede the incorporation by reference of RG 1.84, Revision 37; RG 1.147, Revision 18; and RG 1.192, Revision 2.
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The NRC determined that this regulatory action would improve the effectiveness of future licensing actions. This proposed action would allow licensees to apply the ASME Code Cases listed in the RGs as voluntary alternatives to requirements in the ASME BPV Code and ASME OM Code for the design, construction, inservice inspection, and inservice testing of nuclear power plant components without a request for the use of alternatives or an exemption. This would help ensure that NRC actions are effective, efficient, realistic, and timely by eliminating the need for the NRC review of plant-specific requests for alternatives in accordance with 10 CFR 50.55a(z).
The final rule will result in a reduction in information collection burden due to a reduced number of alternative requests from industry to the NRC as described in this supporting statement.
A. JUSTIFICATION
- 1. Need For and Practical Utility of the Collection of Information Section 50.55a(z) allows applicants to use alternatives to the requirements of 10 CFR 50.55a paragraphs (b) through (h) when authorized by the NRC.
Alternatives are voluntarily submitted by licensees under § 50.55a(z) and are estimated to take 380 hours0.0044 days <br />0.106 hours <br />6.283069e-4 weeks <br />1.4459e-4 months <br /> to prepare and submit. Section 50.55a(z) is an existing requirement that was previously located at 10 CFR 50.55a(a)(3) prior to 2014.
The proposed rule would incorporate by reference revised NRC RGs stating the acceptability of certain ASME Code Cases. Code Cases developed by the ASME are voluntary alternatives to requirements of the ASME BPV and OM Code and often reflect improvements in technology, new information or improved procedures.
Licensee development of alternative request applications and obtaining NRC approval prior to using these Code Cases is burdensome to the licensee.
The approval of ASME Code Cases in the latest revisions of three previously incorporated RGs would reduce the number of alternative requests submitted by licensees under 10 CFR 50.55a(z), because use of these Code Cases will be permitted without the need for submission of an alternative request.
- 2. Agency Use of Information The NRC ascertains use of only approved and conditionally approved ASME Code Cases by using the alternative request process or by incorporating the new Code Cases in RGs.
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- 3. Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them.
The NRC has issued Guidance for Electronic Submissions to the NRC, which provides direction for the electronic transmission and submittal of documents to the NRC. Electronic transmission and submittal of documents can be accomplished via the following avenues: the Electronic Information Exchange (EIE) process, which is available from the NRC's Electronic Submittals Web page, by Optical Storage Media (OSM) (e.g. CD-ROM, DVD), by facsimile or by e-mail. It is estimated that approximately 15% of the responses are filed electronically.
- 4. Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.
- 5. Effort to Reduce Small Business Burden No small businesses are affected by this proposed rule.
- 6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently If the NRC did not periodically update and incorporate by reference the RGs listing acceptable, conditionally acceptable, or unacceptable new Code Cases, licensees would be obligated to use the alternative request process if they wanted to use new ASME-approved Code Cases. This process would be more burdensome on both the licensees and the NRC.
- 7. Circumstances Which Justify Variation from OMB Guidelines There are no variations from OMB guidelines.
- 8. Consultations Outside the NRC Opportunity for public comment on the information collection requirements has been published in the Federal Register August 16, 2018 (83 FR 40685).
- 9. Payment or Gift to Respondents Not applicable.
- 10. Confidentiality of Information Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b). However, no information normally considered confidential or proprietary is requested.
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- 11. Justification for Sensitive Questions Not applicable.
- 12. Estimated Burden and Burden Hour Cost This proposed rule would allow licensees to apply the Code Cases listed in the RGs as voluntary alternatives to requirements in the ASME BPV Code and ASME OM Code without a request for the use of an alternative or an exemption. The NRC estimates that this action will result in a reduction in the number of plant-specific requests for alternatives in accordance with 10 CFR 50.55a(z), because licensees can use alternatives such as ASME-approved new Code Cases incorporated by reference in 10 CFR 50.55a without seeking NRCs prior approval.
A review of past Code Case alternative request submittals has determined that plant owners submit a Code Case alternative request that covers multiple units and multiple plant sites. Based on annual code case relief request submissions before and after ASME final rules are published, the staff estimated that if Alternative 2 is not adopted, operating sites would submit 24 relief requests annually for the Code Cases in this proposed rule.
The incorporation by reference of recent Code Cases will allow these Code Cases to be implemented without incurring any burden for preparation of an alternative request under 10 CFR 50.55a(z). Each request for alternatives is estimated to take 380 hours0.0044 days <br />0.106 hours <br />6.283069e-4 weeks <br />1.4459e-4 months <br />; therefore, the resulting reduction in licensee burden is 9,120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> (24 requests x 380 hours0.0044 days <br />0.106 hours <br />6.283069e-4 weeks <br />1.4459e-4 months <br /> per request) and 24 responses annually, a savings of
$2,398,560 (9,120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> x $263/hr).
- 13. Estimate of Other Additional Costs There are no additional costs.
- 14. Estimated Annualized Cost to the Federal Government As a result of the proposed action, the NRC would review 24 fewer requests for alternatives annually. The NRC estimates that reviewing these requests takes an average of 143 hours0.00166 days <br />0.0397 hours <br />2.364418e-4 weeks <br />5.44115e-5 months <br /> per request. As a result the NRC estimates that the incorporation by reference of new Code Cases will result in a savings of $902,616 (143 hrs/relief request x 24 requests x $263/hr).
- 15. Reasons for Change in Burden or Cost The proposed rule would decrease the burden for 10 CFR Part 50 from 4,382,153 hours0.00177 days <br />0.0425 hours <br />2.529762e-4 weeks <br />5.82165e-5 months <br /> and 45,202 responses to 4,367,713 hours0.00825 days <br />0.198 hours <br />0.00118 weeks <br />2.712965e-4 months <br /> and 45,164 responses, a reduction of 9,120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> and 24 responses.
The proposed rule reduces burden by incorporating by reference recent ASME Code Cases. As a result of this incorporation by reference, burden on licensees to submit requests for alternatives under 10 CFR 50.55a(z) will be reduced. Licensees would 4
no longer need to submit alternative requests in order to use these Code Cases, once they are included in NRCs Regulatory Guides.
- 16. Publication for Statistical Use Not applicable.
- 17. Reason for Not Displaying the Expiration Date The recordkeeping and reporting requirements for this information collection are associated with regulations and are not submitted on instruments such as forms or surveys. For this reason, there are no data instruments on which to display an OMB expiration date. Further, amending the regulatory text of the CFR to display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.
- 18. Exceptions to the Certification Statement Not applicable.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.
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