ML19263A653
| ML19263A653 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1983 |
| From: | Norry P NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| Shared Package | |
| ML19262J940 | List: |
| References | |
| OMB-3150-0035, OMB-3150-35, NUDOCS 8312140408 | |
| Download: ML19263A653 (9) | |
Text
INTERIn uSE r Rn Sr 83
"' " *5 5'8' REQUEST FOR OMB REVIEW FOP. bSE FECINM NG 4-83 (REV. 3-81)
IMPORTANT - READ INSTRUCTIONS BEFORE COMPLETING FORM. DO NOT USE THE SAME SF EXECUTIVE ORDER 12291 REVIEW AND APPROVAL UNDER THE PAPERWORK REDUCTION ACT.
ANSWER ALL QUESTIONS IN PART !..
IF THIS REQUEST IS FOR REVl[W "NDER E.D.12291, CUMPLETE PART !!
AND SIGN THE CERTIFICATION. IF THIS REQUEST IS FOR APPROVAL UNDtR THE PAPERWDRK REDUCTI 5 CFR 1320 SKIP PART II, COMPLETE PART III AND SIGN THE CERTlfi!CATM'N.
SEND THRIE COPIES OF THIS FORM, THE MATERIAL TO BE REVIEWED. AND FOR JAPERWORK -- THREE COPIES OF THE SUPPORTING STATEMENT T0: OFFICE OF INFORMATION AND RECULATORT AFFAIRS, OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON. D.C. 20533 d TTENTION DOCKET LIBRARY ROOM 3201 FART 1.
- 1. DEPARTMENT / AGENCY and BUREAU /0FFICE
- 2. AGENCY 3.NAME AND TELEPHONE NUMBER OF PERSON rd0 ORIGINATING REQUEST CODE CAN BEST ANSWER QUESTIONS REGARDING THIS REQUEST E. Jordan (301) 492-4848 31 50 US Nuclear Regulatory Comm.
- 4. TITLE OF INFORMATION COLLECTION OR RULEMAKING 10 CFR 21.21 Notification of Failure to Comply or Existence of Defect and 10 CFR 21.51 Maintenance of Record
- 5. LEGAL AUTHORITY FOR INFDP.MATION COLLECTION OR RULE
- 6. (FFECTED PUBLIC (CHECK alt THAT APPLY)
(CITE UNITED STATES CODE, T'JBLIC LAW, OR EXECUTIVE O 1. INDIVIDUALS OR HOUSEHOLDS ORDER)
U 2. STATE OR LOCAL COVERNMENTS
/ / 3. FARMS T/ / 4. BU3INESSES OR OTHER FOR-PROFIT USC OR Atomic Energy Act of 954, D 5. FEDERAL AGENu ES OR EMPLOYEES as amended
/ 6. NON-PR0llT INSTITUTIONS
- 7. SMA'.L BUSINESSES OR ORGANIZATIONS PART 11. COMPLETE THIS PART ONLY IF THE REQUEST 15 FOR OMJ REVIEW UNDER EJECUTIVE ORDER 12291.
7. REGULATORY INFORMATION NUMBER (RIN)
A CFR SECTION AFFECTED CFR 8'.
TYPE OF SUBMIS$10N
- 10. DOES THIS RFGULATION C0".TAIN REPORTING OR RECC.RD-KEEPING REQUIREMENTS THAT REQUIRE OMB APPROVAL.UNDER CLAS$1FICAT10N THE PAPFRWORK P. EDUCTION ACT AND 5 CFR 12207 D 1. HAJOR YEF O NO C C 2. NONMAJOR STAGE OF DEVELOPMENT 11. IF A HU OR RULE. IS THERE A REGULATORY 7 C ANALYSIS ATTACHED?
O 1. PROPOSED OR DRAFT C 2. TINAL OR INTERIM FINAL, WITH PRIOR
- 1. YES O
- 2. NO O - IF NO, t.."
i WAIVE PROPOSAL THE ANALYSIS 7 O 3. FINAL OR INTERIM FINAL, WITHOUT FRIOR PROPOSAL 3, ygg g 4, yo O TYPE OF REVIEW REQUESTED
- 12. DOES THIS REGULATION AFFECT ANY TRADE SENSlilVE D 1. STANDARD ACTIVITY?
O 2. PENDING O 3. DiERGENCY TES O NO C O 4. STATUTORT OR JUDICIAL DECREE CEPTIFICATION FOR REGULATORY SUBMISSIONS: IN SUBMITTING THl$ REQUEST FOR OMB REVIEW THE AUTHORIZED REGULATORY CONI.:CT AND THE PROGRAM 0FFICIAL CERTIFY THAT TPE REQUIREMENTS OF E.O.12291 AND ANY APPLICABLE POLICY DIRECTIVES HAVE BEEN COMPLIED WITH.
SIGNATURE OF PROGRAM OFFICIAL DAIE SIGNATURE OF AUTHORIZED REGULATDRY CONTACT
- LATE B312140408 831212 PC9 ORG EUSOMB PDR
SUPPORTING STATEMENT FOR 10 CFR 21.21 NOTIFICATION OF FAILURE TO COMPLY OR EXISTENCE OF A DEFECT 10 CFR 21.51 MAINTENANCE OF' RECC9DS 1.
Justification a.
Need for the Information Collection Part 21 was designed to implenent Section 206 of the Energy Reorganization Act of 1974 (42 U.S.C. 5846).
Section 21.21 requires directors and responsible officers of firms and organizations building, operating, or owning NRC -
licensed facilities, or conducting NRC - licensed activities, tu report defects in ccmponents and failures to comply with regulatory requirements which could create a substantial safety hazard.
Alco covered under the regulation are directors and responsible officers of firms and organizations supplying safety-related components, including safety-related design, testing, inspection and consulting services.
NRC licensees and other organizations covered by Part 21 must adopt internal procedures to assure that safety related defects and noncom-pliance are brought to the attention of responsible officers and directors.
Those individuals, in turn, will be requir2d to notify the Commission within two days, and file a written report within five days, of learning of the defect or noncompliance.
Pursuant to Section 21.51 each licensee of a facility or activity subject to.10 CFR Part 21 shall maintain such records in connection with the licensed activity as may be required to assure compliance with Part 21.
Each individual, corporation, partner ship or ther entity subject to Part 21 is recuired to prepare. records in conrection with the design, manufacture, fabrication, placement, erection, installation, modification, inspection or testing or any
i s facility or to be used in any licensed activity sufficient to assure compliance with Part 21.
b.
Practical Utility of the Information Collection The purpose of Section 206 of the Energy Reorganization Act was to assure that the NRC has prompt information on defects that threaten safety.
In addi-tion to imposing obligations on any individual director or responsible officer ur licensees, Section 206 also imposes obligations on the directon or responsi-ble officers of nonlicensees that supply components to licensed facilities or activities.
Section 206 subjects any individual director or responsible officer who knowingly fails to comply with the notification requirements to civil penalties.
Part 21, the Commission's regulation implementi~ng~Section 206, results in reports describing defects in. basic components at licensed nuclear facilities.
These reports are reviewed by the NRC staff to determine whether the reported defects or failure to comply could creste a substantial safety haza)m.
These reports of potential safety problems have resulted in many NRC bulletins, circulars, and information notices, and have contributed to the improved afety of the nuclear industry.
The reporting requirement of Seccion 21.21 is intaa:.ed to assure that the Commission gets prompt notification concerning defects or failure to comply in facil' ties or activities licensed by the Commission.
The records maintained pursuant to Section 21.51 are subject to review by the Commission staff to determine compliance with Part 21.
r<ecords maintained pursuant te C0.o1 f all
. into four categories.
One category consists of records relating to evaluations defined by 621.3(g).
Another category consists of records of previously sub-mitted repo.ts pursuant to S21.21.
The third category consists of records of procedures required to assure compliance with Part 21.
The last category consists of procurement documents necessary to ensure that background specifications are available in order to evaluate potential defects.
Duplicatio[withotherCollectionofInformation c.
There is no duplication of effort or of information sought.
d.
Consultation Outside the NRC None e.
Other Supporting Information None 2.
Description of the Information Collection a.
Number and Type of Respondents Approximately 12,000 organizations, licensees and nonlicensees, are under the scope of Part 21 reporting requirements.
A previous estimate of 25,000 organizations has been revised downward to 12,000 organizations based on more precise analysis of report data submitted to the NRC.
Huwever, of these 12,000 organizations, only 300 will actually have to file a report with the NRC each year.
Licensees are granted licenses under the following parts:
production and utilization fscility licenses issusd under 10 CFR, Part 50, including nuclear power plants and research and test reactors at various stages in the licensing
. process; by product material licenses issued under Part 40; high-level radioac-tive waste disposal licenses issued under Part 60; special nuclear materials licenses issued under Part 70; the packaging of radioactive materials for transport under Part 71; and spent fuel storage under Part 72.
The nonlicensee suppliers covered under Part 21 are firms of many different sizes, supplying many different types of basic comporants to NRC licensees.
For example, construction and operation of a nuclear power plant involves a multi-tier procurement chain.
At the top of the chain is the electrical utility and the utility's major contractors such as the nuclear steam system supplier.
The next level includes manufacturers who produce components specifically designed.
for nuclear instrumentation and controls and major pvling, pumps, and valves.
These manufacturers in turn procure necessary parts such as resistort, wiring, solid-state devices, and hardware from a multitude of sources. -Ultimately, the procurement chain for such items goes back to the supplier of the facilities or activities and can be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description (e.g., a catalog).
Approximately 300 reports are submitted to the NRC annually under Part 21.
b.
Reasonableness of the Schedule for Collecting Information The.information.is required only when a defect is discovered.
c.
Method of Collecting the Information The method of collection is the submission of written reports to the NRC.
This is the least burdensome method because the use of microfilming equipment,
i
~
. or other advanced information handling techniques or equipment cost too much to be justified for reports that are typically sent once per organization.
There are potentially 12,000 organizations that may be required to submit a report, but based on past experience only about 300 per year need actually respond by making a report.
d.
Adequacy of the Description of the Information The regulations requiring reports are clear and succinct, i.e., 10 CFR 21.21 (b)(3) states exactly what is to be included in the report.
e.
Record Retention Period A proposed rule is being developed which will establish a definitive re-tention period of 5 calendar years.
f.
Reporting Period Reports are required only when a reportable defect is found.
g.
Copies required to be submitted Three copies of the report is required.
The report may be submitted to either the Director, Office of Inspection and Enforcement, U.S.N.R.C., Wash.,
D.C.
20555 or the Director of a Regional Office at the address specified in Appendix 0 of Part 20.
Three copies are.eeded su that each of the following may have a copy:
NRC Headquarters Regional Office, and resident inspector or vendor programs branch, as appropriate.
' 3.
Estimate of Burden a.
Estimated Hours Required to Respond to the Collection 12,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> x 500 reports).
b.
Estimated Cost Required to Respond to the Collection The annual industry time expended on S21.21 is approximately 12,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> x 300 reports) at $760,000 (based on $60.00 per hour of professional staff time).
The burden for 921.51 record keeping is 72,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (12,000 record keepers x 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per record keeper).
The total annual burden is 84,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> annually, previous estimates of burden (101,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) were higher due to less precise analysis of report datc.
c.
Source of Burden Data and Method for Estimating Burden The estimate of burden is based on a su;vey of past re.7 orts submitted to the NRC and an NRC estimate of time and cost per hour of professional time, including overhead, for completing the report.
d.
Reasonableness of Burden Estimates The burden estimates are consistent with pay scales paid to professional engineers and the number of reports sur.~itted to the NRC.
4.
Estimate of.the Cost to the Federal Government The annual NRC staff time expended on Part 21 evaluations is epproximately 7500 hours0.0868 days <br />2.083 hours <br />0.0124 weeks <br />0.00285 months <br /> (300 reports x 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />) or $450,000 (at $60.00 per hour).
.. 5.
Impact on NRC's Information Collection Budget The impact on NRC's Information Collection Budget should be minimal since the number of reports is not expected to change significantly.
e