ML19246C158
| ML19246C158 | |
| Person / Time | |
|---|---|
| Issue date: | 07/27/1977 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Staats E GENERAL ACCOUNTING OFFICE |
| Shared Package | |
| ML19246C153 | List: |
| References | |
| NUDOCS 7907230565 | |
| Download: ML19246C158 (6) | |
Text
'.
JUL 0 7 1377 The llenorable Elmer B. Staats Comptroller General of the United States Cencral Accounting Office 11ashington, D. C.
20510
Dear fir. Staats:
In accordaace with section 409 of Public Lov 93-153 of Novc=ber 17, 1973, and 4 CFR 10.9 of the regulations of the General Accounting Office, 1 a= enclosing for the review of GAO copies of Standard Forn 83 and the supporting statencnt covering 9 5 71. 51, 71.62 (c), and 71. 63 (c) of 10 CTR Pnrt 71.
This request is for cpproval of 5 5 71.51. 71.62 (c) crid 71. 63 (c) which are in final form and have been approved by the liuclear T.egulatory Cc= mission.
Sincerely.
(Signed) J. M. Feltoca J. M. Felton, I.1 rector Division of Rules & Records Of fice of Administration
Enclosures:
!w stated DISTRIBUTION:
CENTRAL FILE DRR SU3J DRR RDO CHutton f
79072305G3 359 007 4
s (Geier tre Fdo.t! Ref erls An and OfGrc cf Alanqcmeni and Dudy! Circu!st No.
A-40, a1 :mcnded)
IMPORTANT-READ INSTRl]CTlONS fiEFORE COMI'LETING TORN CLEARANCE OFFICER Seinii ihr er.psrri n r-ter,fscrors of SFs3,sofriher scnA OFFICE OF MANAGEMENT AND BUDGET sce marri.uller u hich.uit.rou is repened sc:
VIASHlHGTON. D.C.
20503 PART A-REQUEST BY FEDERAL / GENCY FOR CLEARANCE
- Items marked e.sth anterisk may be omitted for pretermnary plans or recordkeeping recluirernents
- 1. SEN D "' NOTICE OF ACTION TO: (Ns=r sad maileng id,ru)
- 2. OUREAU AND DIVISION OR OFFICE ORIGINAT.
ING REQUEST I'.r. J Os eph M. FeltOn, Director Of, ice Of Standards Division Of Rules & Records Deve10prnen t Office Of Administration L,.
S. Nuclear negulatory CO=nission
- 3. N AMEfS;. TTTLEfS). AND TELEPHONE NO S). OF n
eERSON(s) WHO CAN DEST ANSWER QUES.
Washington, D. C.
20555 11 NS REGAR ING REQMST Robert J.
Doda Transportation & Product Standards Branch, OSD (443-6910)
- 4. TITLE OF FORM OR DOCUMENT SUBMITTED S. AGENCY FORM NUMBER (S) 10 CFR 71.51, 71.62(c), 71.63(C)
- 6. TYPE OF FORM OR DOCUMENT H
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- 7. CURRENT ( er l a,ci re ) CMB
- 8. REQUESTED EXPIRATION
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- 10. FREQUENCY OF USE 2o C: -
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- 11. RELATED FORMS CR DOCUMENTS (Girr OAfB Nem),r. Entlese
- 12. CATALOG OF FEDERAL DOMESTt C ASSISTANCE PROGRAM in parestbrses say so be repiscad.)
NUMBER
- 13A. COLLEC*lON METHOD (Charl es many as apply) 13B. COLLECTED BY-1 2
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RESPONDENT (Isra, 70) o c:
2,020 SEE SUPPORTING STATEMEICS SEE SUPPORTING STATE 1ENT U Q Z
15D. TOTAL ANNUAL R ESPON SES (from 15E, ESTIM ATED AVERAGE NUMBER 15F. ESTIMATED TOTAL HOURS OF RESPONDENT 12 A s UC)
OF HOURS REQUIRED PER R E.
DURDEN (Isren 13D s IJE)
SEE SUPPORTING STATEMENT TfgSSUPPORTING STATEMENT 93,003
- 1EA. IS REPORT FORM:
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SUPPORTihG STATEMENT. (3rr sentaruees) 793 I
O L" S DE teens ouwe your own agenW AGENCY 2 ] NQ CEm Tir1C ATiCN CY AUTHDR.CD O FF!CI ALS SU B MITTING REQUEST ~rt erri,f y sh,i ser f rom,, sier, deren,sr as&meine/ far spree.1 n errena+y toe are portr* pretrenswer t' ter arteris lesense, resi she preposed no:s rollernies erfresent: the monumme i. eden en respeedrerrs teennent s ub tir ured r e-re en a.se*, s w se r se cr en arse n rol?rned n no: o s edsh e p e w. soy *Iber sostre, to the irn o' ear knea les te, sker o6e re!.oraen re noue mre: toroares ne esaare un t e rder:. tw the reeerst r e W!res as ti k requeremenn et she Fe rra r e of Iniormoure Act and ser t rorary An of IS.'t. and u seenures arne a*. re a r.o 0.? L E ar/ ser-re t eise s dortuires. 3rreareer and artir et A PP R O.'IN"r' O FF;CJ AL F O P. M EN CY OATE AGENCY C LEARANCE CFTICER OR OTHER AGENCY DATE
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S'JPPORTING STATDENT FOR 10.C?. 71.51, 71.62(c), 71.63(c) 1.
Justification.
(i)
NRC regulations in 10 CFR Part 71 establish requirements f or transportation and preparation for ship =ent of licensed material, and prescribe procedures, standards, quality assurance programs, and requirements for approval by NRC of packaging and shipping procedures for fissile material and for cuantities of licensed material in excess of type A quantities.
Secticn 71.51 requires a licensee to file a description of the general quality assurance program which he applies to packages for the shipment of radioactive material.
This general quality assurance progra includes and satisfies the applicable criteria contained in Appendix E to 10 CFR Part 71.
Section 71.62(c) requires the licensee to maintain, for the life of the packaging to which they pertain, quality assurance records which furnish documentary evidence of the quality of the packaging.
Section 71.63(c) requires that the licensee. notify the Director of Inspection and Enforcement before f abrication of a package to be used for the shipment of radioactive material which has decay heat loads or operating pressur in excess of specified values.
(ii)
Section 71.51.
This information is required to determine the adequacy of the general quality assuran:e program undet which a transportation package is designed, manuf actured, tested,. used,
maintained and modified.
The information is used to provide a basis for a safety evaluation of the packaging and for issuing approvals for each proposed packaging design and method of transport.
Without this information, the Commission would be unable to determine the adequacy of the general quality assurance program for transportation packages.
In addition, if a general quality assurance prograt were not a p p roved, the Commission would be recuired to evaluate the safety-related characteristics of each packaging on a case-by-case basis.
Sectien 71.62(c).
These records are required in order to f urnish documentary evidence of the quality of the packaging and of the components of the packaging which have safety significance.
The records are subject to inspection by Commission personnel, and must be maintained for the life of the packaging to which
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they pertain.
Without this inf ormation, the Commission would be unable to inspect a licensee f or conf ormance to the quality assurance program (which had been approvea by the Commission for the particular package under consideration).
All licensees maintain some recocds concerning the quality of their transporta-tion packages and methods of transport. This section would produce a uniformity of and completeness of quality assurance provisions for transportation packages and activities.
Section 71.63(c).
This informa tion is required to furnish the Commission with advance notification before fabrication of packages having decay heat loads or operating pressures in excess of specified values.
The information would facilitate communication between the licensee and the Commission to resolve any differences in the adequacy of the safety aspects of the packaging before significant expenditures were committed to such packaging.
Without this notice the Commission would be unable to inspect the critical manuf acturing aspects of the transportation packages which are most significant with respect to safety.
(iii)
The information to be recorded or furnished to the Commission is available only to the particular licensees involved and is not otherwise available to the NRC or other agencies.
~
2.
Descrintion of Survev Plan.
Section 71.51.
This is a one-time reporting requirement whereby a licensee is required to have a general quality assurance program based on the criteria contained in Appendix E to 10 CFR Part 71.
This is a new requirement where the pertinent criteria of Appendix E should be applied to an extent consistent with their importanca to safety.
Section 71.62(c).
These quality assurance records are to be maintained for the life of the packaging to which they pertain.
The details required in these records are judged to be necessary f or an NRC inspector to verify compliance with the licens'ee's approved quality assurance program. The information is required to be maintained on file fcr inspection. The regulation does not specify how the information is to I a collected by the licensee for inclusion in his files; he is free to choose the most efficient method, wnich may include standardized reporting forms.
Section 71.63(c).
NRC staff considers packages covered under this section (these having a decay heat load in excess of 5 kW or those with an operating pressure in excess of 15 psig) to be of sufficient significance with respect to safety so as to require notification prior to fabricatien.
This will f acilitate resolving problems with the adequacy of package safety pric to f abrication and will provide f er planned inspections during f abrication.
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4
3 3.
Tabulation and Publication Plans.
There are no plans to publish the information received by the NRC or recorded by the licensee pur suant to 10 CFR Part 71.
4.
Time Schedule for Data Collection and Publication.
Not applicable.
5.
Consultations outside the Agency.
Section 71.51.
No persons outside NRC were consulted and cost estimates were made by the NRC staff.
Licensees were advised of the reporting requirement and given the opportunity to comment on it by publication in the Federal Register.
Section 71.62(c).
No persor's outsid t of NRC were consulted.
Since all transportation licensees maintain controls and records to varying degrees on their transportation packaging activities, this requirement is not expected to present implementation difficulties to licensees.
None of the corrents received on the proposed rule which was published in the Federal Register on December 28, 1973 objected to the record-keeping provisions of this proposed section.
Section 71.63(c).
Since the costs, both to the licensees; and to NRC, of implementing this reporting requirement are small, no persons outside of NRC were consulted.
The estimates were made jointly by standards and inspection staf f.
Persons were advised of the reporting requirement, by publication of a nctice in the Tederal Register, and given the opportunity to comment on it..
6.
Estimations of Conoliance Burden.
Section 71.51.
Approximately 2,000 licensees are expected to file a descriptien of their general quality assurance. program under this section.
Each description takes an estimated 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> each for a total of 80.000 man-hours.
Approximately 20 licensees, using large packages, are expected to file a description of their quality assurance programs which take an estimated 100 man-hours each for a total of 2.000 man-hours.
The overall licensee burden is 87 ;00 man-hours.
This is a one-time requirement f or each -licens Further-more, if a quality assurance prograu under 10 CFR Part 50 is in effect, the licensee need only indicate that he will apply that program to transport packaging.
Section 71.62(c).
/.pproximately 1,500 licensces will maintain records under this section covering packaging for an estimated 3,000 large shipmeats and 80.000 small shipments each vear.
The records on large packages require an es timated 3.000 man-hours per year ad the rL0 1;O l
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records on small packages require an estinated 8,000 man-hours per year, for a total of 11.000 man-hours per year.
Section 71.63(c).
An estimated 6 licensees are expected to fi3 e reports under this section; each report is expected to require about 30 minutes to prepare for a total burden of about 3 man-hours per year.
Total.
Based upon the above, the total man-power burden for the reporting and record keeping requirements for 5571.51, 71.62(c),
and 71.63(c) is approximately 93,003 man-hours per year.
7.
Estimate of Cost to the Federal Government.
NRC review of the quality assurance programs under 571.51 requires a total of 41,600 man-hours.
NRC inspection activities of records maintained under 571.62(c) require 1,000 man-hours..NRC staff under 571.63(c) is about 3, man-hours.
S.
Confidentiality of Information.
Release of the inf ormation obtained pursuant to the reporting and record keeping requirements ci 5510 CFR 71.51, 71.62(c), and 71.63(c) is subject to the provisions of the NRC's regulation 1b CFR Part 9.
9.
Aeolication of Federal Information Processing Standards.
The format and contents of inf ormation submitted to NRC or recorded pursuant to 10 CFR Part 71 are not applicable to FIPS.
Enclosures:
1.
Notice of Rule Making, 10 CFR Part 71 2.
Headnote Statement for Federal Register
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