ML20010C560

Request for OMB Review & Supporting Statement Re Request for Schedule Info from Utils on Const of Nuclear Plants Through Automated Info Mgt Sys.Estimated Respodent Burden Is 82-h Annually

ML20010C560
Person / Time
Issue date:	06/26/1981
From:	Besaw W, Scott R NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20010C551	List: ML20010C550 ML20010C560
References
NUDOCS 8108200190
Download: ML20010C560 (11)

Text

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17. Acstract-Nstds and usss l'30 words orless)

NRC rcquests schedule and status information from utilities on the construction of Nuclear Power plants testing and ful load through an automated management information-developed for this specific purpose

18. Related report form (s) (give OMB num0er(s). IRCNfs),

i2o Catalog of Feceral Domestic Assistance Program Number internai agency report form numcer(sj or symbol (s))

l N/A i

l N/A

21 Small business or organization C Yes E No i

19 Type of affected public (Checa as many as apply) 22.Ty e of activity of affected cubfic ind:cate 3-cigit S!andar:

l Industrial Classification (SIC) code's! luo to 10, - if over c

1 C indsvoC:.;als orhouseholds 10, cne:k C Multtcle or C All 2 C state orlocalgovernments 3 C ! arms 1

a iG tusinesses or other onstituticns (exce:t farms)

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23 Br:ef description ot affected puchc (e L"reta'l grocery stores."" State education agencies.* "nousehotos on 50 largest SMS A s")

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NRC licenses with Construction permits 24 Durcose (Checn as many as apoly 11more than cne. uncicate l26 CoIIecticn metnod iCneck as many as a:coys 4

tecor"'inant by an asterisst) 1 C ma.! sci'-acTi"istered i C a;

lication for cerefits l

2 2 ctr.er 53;f-ada tnistered 2 C Or:gra n evah.ation 3C teieon:ne intervien 4 C personal anterview 3 C geners' cur:cse statistics j

j 4 C regulatcry or:0mpha :e l

SC reccrdnee: ng recu:rement l

5 E cr: gram p!anning er management Recu. red retentien cenod:

sears j

S C 'esearen 6'O otner-cescrice:

j 25 F*e:;eaty cf Use

27 C:;tection agent (C,aec" oneJ I

2 Ncnte:urring

' I recuesting Decartment< Agercy 4:f :n; ':. ec.= as maay as accly>

2: Ot'er Federal Ce:ar*mert ge-cy 2 C on :::as,cn 6

semanrually 3 C craate cont'a:!:'

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72 arnua'li 4 2 'e:Or:r'eec.rg rec cement 1

4 C m :nt*:y BC tienriatif f C :t.er-descr:ce:

51 cuarter';

92 Otrer-cescr:be-251 at r;ti er agency f:r informat On 00itect;cn or

'30 Oc ycu arcrmse conocertiahty' f

e a= r; in:.: ate statute. reg iatien.;udicia: decree.

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m s.::: rting statement,

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Aeclct_of 1954 ERA Act of 1974 c e :,.e m -. y,, 3; 7 ::.,, n.

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3 C ancato'/-cite statute. n:,t FR tatta:n copy cf i

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i COMPLETE ITEMS 33 THRu 35 ONLY IF RULEV AdlNG SUBMisslON 2; ::r

.ance ::sts to the Octoc 34 is there a reguiatory m:a:t

35 ts there a statutcry or b,c:0 a' analysis attacned ?

ceactine affect.ng issuance ?

$. Minimal C Yes E No C Yes. Enter date l

E NO I

CZ;;7;FIC ATION SY AUTHCRi2ED OFFICI ALS SUBMITTING REQUEST-We cer:4 mat the nter natica =ccectica or rwerac ; sa:m:te: f:r review s me: essa r ter t'e cr: Der ce fo nance c' tre ageacy's funct:ces t*at the crc::sai re: reseats tne m :- um : Lone ::wr:en a-: recerat c st c:-s s e-t

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0 8108200190 810630 O

PDR ORO EUSOMB 1

PDR a..

4 UPDATING SUPPLEMENTAL SUPPORTING STATEMENT FOR REVISIONS OMB CLEARANCE FOR THE CONSTRUCTION STATUS REPORT 1.

Justification 4

The justification information submitted with the initial request for GA0 clearance is still valid (Enclosure 1).

Subsequently, a renewal request was forwarded to GAO, with updated information, and was 7

approved January 28, 1980, with an expiration date of December 31, 1982 (Enclosure 2).

The Office of Management and Program Analysis is constantly assessing its information gathering activities to increase the usefulness of the data reported and to reduce the reporting burden on respondents.

The recent passage of the Paperwork Reduction Act (P.L.96-511) adds further impetus to the need to assess information requested.

As a result, we are requesting OMB's approval and clearance to nake modifications in format, content, and reporting frequency for the Construction Status Report, NUREG-0030.

The new format will be 8S" x 11" in lieu of the current 8" x 17" size, and would be completely automated (Enclosures 3 and 4).

It is estimated that approximately seven (7) staff weeks are expended for updating the current format manually, and that approximately one (1) staff week would be expended updating the new automated format or a direct savings to the government of approximately six (6) staff weeks per update.

This translates to a savings of seventeen (17) staff weeks annually or approximately an 80% reduction in staff weeks.

The basic content change deletes the detailed construction log networks, and replaces this detail with a simplified set of key construction milestones and activities (Enclosures 5 and 6).

Each report from the respondent would require approximately fifteen minutes to prepare; 82 respondents each would file four (4) reports annually; the estimated total raspondent burden annually would be approximately eightv-cwo-(82) staff hours.

The current respondent burden is approximately Ei6 staff hours.

This would be a reduction on the respondent of approximately 164 staff hours or approximately sixty-six percent (66%).

In order to coincide with the normal construction schedule review cycles of most respondents, the frequency of reporting is proposed to be changed from three (3) times per year to quarterly.

2.

Description of Survey Plan See Enclosure 1.

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' 3.

Tabulation and.-ablication Plans The information collected is reviewed, analyzed, tabulated, and sumarized into a construction status summary report, which is published on a quarterly basis for the NRC, ERDA, as well as ERDA laboratories, the JACE, ACRS, the House of Representatives, the l

Senate, electric ut.!i: ties, contractors, and architect / engineers.

I I

In addition, copies at e available from the NRC/GP0 Sales Program and from National Technical Information Service. Typical tabulatfors cover:

1 Status of Nuclear Power Reacters 1

St.sges of Reactor Construction - By NRC Region Facility Status Sumary Plants By NRC Region

]

Average Duration for Nuclear Power Plant Constructir.

Applicant Fuel Load Date Projection; 1

Statistical and Narrative Highlights

. Data Page - General Plant Data for Each Plant Data Page - Current Construction Status for Each Plant 4.

Time Schedule for Data Collection and Publication, The planncd tirne table for collection of data publication of the first edition is October,1981.

Responde sould provide data for updating by October 16, 1981, status as 6tember 30, 1981.

By the 23rd of the month, NRC issues cor.

' aed Construction Status Report for printing and distribaSn.

i rinting is accomplished within three days and issued % the end of two days upon return of report from the printer. The cycle would then continue on a quarterly time table.

5.

Consultation Outside the Acency A.

See Enclosure 1.

8.

Discussions were held with several respondents, Architect /

Engineers, and Constructors.

It was concluded that the proposed revisions would reduce the respondents reporting burden considerably, while replacement with the new data would considerably enhance the t tility of the Construction Status Report.

l 6.

Estimation of Compliance Burden Respondents are utilities with nuclear power plants under construction who submit quarterly construction status reports to the NRC.

Each report would require approximately fifteen minutes to prepare; 82 respondents each would file four (4) reports annually; the estimated total respondent but 'en annually would be approximately cighty-two (82) staff hours.

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3-7.

Estimated Burden to Federal Gwernment

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It is estimated that approximately four (4) staff weeks would be expended annually for updating this management report.

8.

Provisions of Confidentiality of Information See Enclosure 1.

9.

Certification See Enclosure 1.

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ENCLOSURE 1

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F O R O.h

'stANOaRO WORM NO. Os

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CLEARANCE REQUE*.I AND HOTICE OF ACTIC 4 (Under federal Reports Act and Office of M.'*agement and Budget Grcular No. A-40. as amended)

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sieronTAMT - Sut mit the required number of copies of sr-s3. toe. ther CLEARANCE OFFICER with ti.e material for which approval is requested t..

OFFICE OF MANAGEMENT AND BUDGET RE AP m% INUL..JNS BEFORE COMPL ETmG FORM NASIIINCION.D.C. 20$03 PART A REQUEST BY FEDERAL AGENCY FoR CLEARANCE

• liems marked with asteresk may be om.tted for preliminary plans or recordkeeping recuarements 7

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1. SEND "f50TICE OF ACTION TO: $ame and mailing address

2. Bureau and division or office origitt request g

gg Mr. J. M. Felton, Director Office of Management in Division of Rules & Records mation and Procram Cont Office of Administration

2. Namem. titiem. and wephone nurr U. S. Nuclear Regulatory Commiss' ion persal5) who c*a b'St ans"*' eues' regarding request.

Was,ington, D. C.

20555 R. C. Rossi, Division o a

Reg'ulatory Information Systems, MIPC (492-7834 a

FORhl OR

4. Title of form or document submitted

• 5. Agency Form Number (s)

DoCouENT Construction Status Report NA IDENTIFF

6. Type of form or docenent

7. Current (or forrner) o.M.S. clearance -

1. Type of req.

f @ New Number i[~) Apptication sO Preliminary plan a c ntract Nnno 2 f j Program evaluation 2 O Revis.

s O Recordkuping Expiration date 3 O other manJEement s'9 u m*"I 2 O Enten-c report mo c' a O Statistical survey 7Ootnu-W,47

8. Requested emperation date or report

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December 31, 1979

• 10. Frequency of use

11. Related forms or doc..ments (G. e O.At a. number. Encfose en a""'"Y'"'***d' f

i [] Single time s O Quarterir 2 O on occasion s O Semi annually.

a O weekly 7 O Annually

12. Catalcg of Federal Domestic Assistance program nutnDer (if 3; a K ] Monthly e [~l other (See instruer ons)

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COLLECTION

• 134. Collection method 14a. Type of respondents involved

• 15. Summary of estimated AND iCMii os n-y as mol )

f CMai pecemer one) responcent burcen y

1. l M'al OUd

' I~IInd"' duals or households

a. Estimated number of 4

RESPONDENT 5

't enp nunts 2 p( ] Personal interview 2 Q Business firms (non-farm) e 3 O other - Descnbe _,

3 O Farms

b. If sample, acoromimate number in universe 4 O Covernment agencies s O ather - Desen6e y

c. Reports filed annually by eacn responcent titem 10) l

• 13b. Collected by -

d. Total annual responses ia X c Q

4 y Agency 14b. Brief description of respondents s O Contrac tor ti.e.. "housenoids in 50 larges!.)

e. Estimated average number of 1

SMSA's; " retail grocery stores man hours required per response j

s O ather - Describe -., NRC Construction permigees

f. E,stimated To, T AL, MAN Ho,V, R$ 4f e,,,nono,n eu,c n,a x AUTHORITY

• 16a.is report form -

, 16b. Does your agency piec C'""""I"'

A N') CON FF i l( l Voluntary

• 3 O uandatory? C,re smeu,, f i

i: : Yes riX i D E 4 TI ALITY

l i Required to obtain benefit?

TON 5U LT A.

17. In developing the report form or ciner documents, were

, ; i Yes - If "yes." identify ocesens and cescribe -

i Tl0N5 OUT.

coiisul ations helo with individuais or organizations SUPPORTING STATEMEN T..See.aste 510E AGENCY cut s id. sour agency?

I 'X i,NO CERTIFICATION SY AUTH0HtZED OFFICIAL 5 $UBulTTING REQUEST - we certify that tre form or other document subm.tted for ae, PfCessary for the proper performance of this Jgency's ihnCtions,that the inferr!*ation reGuested is not avJelable from any other source.fG of our knowledge, and that the reqJest is Consistent enh 4Dolicable o M.S. and agency policy directives. Signature and titre of-Approving offsCial for agency Date Agency clearance officer or other agency offic:al D J t(

r G. L. Hutton J. M. Felton

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, SUPPORTING STATEMENT CONSTRUCTION STATUS REPORT

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i CONSTRUCTION / FUEL LOAD STATUS 1.

Justification (i) The Nuclear Regulatory Commission (NRC) requests schedule and status information from utilities on the construction of nuclear power plants, testing, and' fuel loading.

This information is needed by the NRC for scheduling and meeting licensing commitments to the utilities, for forecasting licensing issuance, and to effec-j tively utilize available NRC technical manpower for inspection and evaluation to assure the safe operation of nuclear facilities.

(ii) Logic networks are developed by the NRC with the cooperation of 4

l utilities with nuclear power plants, and each utility provides the NRC any changes in their construction network.

This information is combined with that provided by the NRC Regional Offices. The Regional Office infornation concerns: construction, testing, fuel loading and critical licensing issues; items of non-compliance with j

regulations standards and technical specifications; deficiencies; i

inspection results; preoperational testing results; status of security plans; and status of quality assurance plans or safety considerations. The NRC Office of Management Information and Program Control reviews and analyzes all submissions, and incorpo-rates changes to the networks and data sheets into the " Construction Status Report," issued monthly.

(iii) The information from the utilities is not otherwise available to i

the Federal G^vernment.

2.

Description of Survey Plan (i)

In October of 1972 the Director of Licensing of the former Atomic En'ergy Commission observed 'a trend of constantly changing fuel loading dates. Because fuel loading readiness is an integral part of the licensing process, he directed the Office of Plans and Schedules to analyze the projected fuel loading dates for those operating license applications ur. der review.

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On October 18, 1972, OPS submitted its analysis to the Director of Licensing.

This analysis concluded:

l Of 38 plants analyzed, 31 had changes in fuel load estimates over the previous six-month period. Of the 31 plants with revised estimates, 28 plants slipped past the. fuel loading date by three and one half months. Three of the 31 are plants with estimates having improvements in the fuel loading date.

In some cases in the OPS study, the scheduled prospective decision date had been met but the plant was not ready for fuel loading.

This resulted in a misallocation of personnel, because valuable staff time could have been better utilized on other applications.

Had a better estimate of the fuel loading date been available, the Directorate of Licensing, the ACRS, and/or the ASLB might have been able to reschedule their respective workloads, thus providing those organizations timely perspective for their review of applications.

In essence, the Director of Licensing concluded that it was nossible to perform a more efficient and effective review if more was, *,own about pre-fuel. loading construction status.

(ii) As a result, the Director of Licensing further requested the OPS to undertake a study of the feasibility of providing greater visibility into the status and progress of cnnstruction for nuclear power plants.

To begin this more expanded fuel-loading study, OPS first performed a brief assessment of the licensing and construction

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processes and their interrelationship.

Regulatory Operations (RO) functions were analyzed, with special attention given to the interface with the review of an OL applica-tion. During the period of years required to build a nuclear power

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plant, R0 conducted construction compliance inspections over the duration of the construction process and begins preoperational test-I ing compliance inspections one and one-half years prior to fuel load-l ing. The frequency and intensity of these inspections increases as the plant nears completion. OPS ana?ysts met with key individuals in central R0 Headquarters in 3ethesda and three regional offices.

As a result of those meetings, a comprehensive network logic diagram I

covering the construction of a nuclear power plant and the associated I

inspection program was developed. After the analysis was performed, OPS was familiar enough with the two organizations to develop a means by which the Regulatory operations staff could further support the Licensing efforts and possibly contribute to accelerating the process.

A reduced copy of the network diagram is included at Tab A.

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. At this point, the R0 staff was asked to review the OPS analysis.

The R0 conclusion was that the OPS staff had indeed addressed cer-tain key issues, and that a great many benefits to both parties could be derived from a joint venture between Licensing and Regulatory Operations. Anong the benefits to be derived were:

4 (1)~ Licensing management could gain needed visibility on site conditions; (2) The applicant's. construction plans and sta'tus would become more apparent to Licensing management; (3) A coordinated approach to conducting Licensing reviews and Com-pliance inspections could be establ.ished; and (4) Regulatory Operations could use the network analysis to establish inspection programs pinpointing manpower and budget requirements and numerous other fallout benefits.

It was agreed that the critical issue was the slippage of prospective fuel load dates, and that this should be given top priority.

The establishment. of a realistic prospective fuel load date by giving more visibility to the status of construction was the immediate goal. The Regulatory Operations staff requested that cognizant field staff mem-bers be briefed on this plan; that the network analysis of construction be reviewed and coments from the field offices be incorporated. Up to this point, all research and development work had been conducted in Bethesda.

However, it became apparent that the testing of the networks and data collection had to be accomplished in the field.

To this end, the.0PS staff visited three regional offices (Newark, Atlanta, and Chicago) and interviewed key RO staff, using a similar presentation of each occasion.

One region set up a site inspection, where OPS representatives interviewed the applicant's. site represen-tative.

After the field trips, the OPS staff revised the construction network analysis based on input and concurrence from field inspectors.

The end product is a construction network with key milestones indentifying the construction and testing of major systems and components.

Each milestone or indicator is listed in sequential order, and all must be complete prior to the fuel load date.

Accompanying the network analysis is a data sheet which was also developed with direct input and con-currence from the field inspectors (see Tab B).

In April 1973, the Director of Regulatory Operations requested the Director of Region 1 to assist OPS in a pilot program for testing out the networks developed by the OPS staff.

See Tab C.

As a result of the efforts with the Region 1 office, the Director of Licensing wrote to 10 electric utilities in the Atlanta Regional area asking their 4

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cooperation in the pilot program.

The program was subsequently expanded on an, incremental basis thereaft'er at the request of the Director of Regulation in January 1974.

See Tab D.

This activity has continued since that time.

GA0 3pproval was not solicited during this period because solicitation of construction schedule data is covered under 10 CFR Part 50.33,. Contents of Applications General Information.

50.33 (h) states, "If the applicant proposes to construct or alter a production or utilization facility, the application shall state the earliest and latest dates for com-pletion of the construction or alteration." 10 CFR Part 50.51, Duration of License, Renewal states,..."Where construction of a facility is involved, the Commission may specify in the construction permit the period for which the license will be issued if approved pursuant to 50.56.

Licenses may be renewed by the Commission upon the expiration of the period." 10 CFR Part 50.55, Conditions of Construction Permits, states "Each construction permit shall be subject to the following terms and conditions.

(a) The permit shall state the earliest and latest dates for completion of the construction or modification is completed before the earlies't date specified, the holder of the permit shall promptly notify the Com-mission for the purpose of accelerating final inspection.

(b) If the proposed construction or modification of the facility is not completed by the latest completion date, the permit shall expire and all rights thereunder shall be forfeited.

Provided, however, that upon good cause shown the Connission will extend the completion date for a reasonable period of time."

In September 1975, the NRC Director of the Office of Management Information and Program Control directed that the construction schedule data and output Construction Status report be changed to reflect its usage by the Energy Research and Develop' ment Adminis-tration, the Federal Power Comnission and the Federal Energy Administration.

During the period between September 1975 and July 1976, data utilization was tailored to the requirements of the above referenced federal agencies and the Nuclear Regulatory Com-mission.

As a result of this effort, no additional information was requested from electric utilities.

By July 1976, the NRC Director of Management Information and Program Control requested the Director of the Division of Rules and Records of the NRC office of Adminis-tration to solicit GA0 clearance in accordance with Section 409 of Public Law 93-153.

Prior clearance was not solicited as the NRC was undergoing a transition period resulting from the Energy Reorgani-zation Act of 1974, which created the NRC from the former regulatory organization of the Atomic Energy Conmission.

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(iii) No federally sponsored contractorswere or are anticipated for assistance in this program.

3.

Tabulation and Publication Plans The information collected is reviewed, analyzed, tabulated and summa-rized into a construction status summary report, which is published on j

a monthly basis for the NRC, FPC, ERDA and FEA, as well as ERDA labora-tories, the JCAE, the House of Representatives, the Senate and electric utilities.

In addition, copies are available from the National Technical Infomation Service. Typical tabulations cover:

Regional Map, Actual and Projective Design HWe by State Highlights Plants by Region Project Index Statistical and Narrative Highlights Facility Status Summary

.. Nuclear Power Grid itap Applicant Fuel Load Projection Average Duration for Nuclear Power Plant Planning / Construction Data Page Network Logic & Schedule Milestone by individual plant name 4.

Time Schedule for Data Collection and Publication The planned time table for collection.and publication is monthly.

Re-spondents provide the infonnation by updating changes which have occurred since the previous reporting period and mail the data to the NRC by the second week of the month.

By the 23rd of the month, NRC issues a consoli-dated Construction Status Report for printing and distribution.

Printing is accomplished witnin 3 days and issued by the end of two days upon return of reports from the printer.

5.

Consultations Outside the Agency (1)

Principal electric utility officials were contacted during the pilot program described in section 2, paragraph (ii) above.

See Tab E, which is a typical example. letter of introduction.

Key people at the construction site were then interviewed with respect to their individual projects.

(ii)

Individual comments regarding mobilization, phasing and construction planning were incorporated as a result of each interview.

Changes have been made in response to subsequent coments furnished by respondents.

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- (iii) As a result of the interviews, network plans based on sponsor or respondent use of conventional CPM techniques were verified as a source of available data.

(iv) During the pilot and incremental development phase, noother federal officials were involved. After the pilot i.nd incremental phase, officials within FPC discussed applicability of this data for their

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use. These officials are:

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Norton Savage, et al FPC Ruth Gussman, et al ERDA H. Feinroth, et al FEA Generally, other federal agency comments'were geared toward verifi-cation of need for a common data base, data elements, and recommen-dation for tabulations and update cycles.

(v) NRC will maintain a file of written comments and communications from persons or officials contacted.

6.

Ettimation af Compliance Burden 1

Respondents are utilities with nuclear power plants under construction who submit monthly construction reports to the NRC. Each report requires approximacely one hour to prepare; 40 respondents each file 12 reports i

4 annually; the estimated total respondent burden annually is 480 manhours.

l 7.

Estimate of Cost to Federal Government i

The information contained in the NRC's " Construction Status Report" is designed primarily for NRC, ERDA, FPC, FEA and utility management uses.

The estimated monthly cost of printing this NRC report is $2,200.

8.

Provisions of Confidentiality of Information The information is available pursuant to the Commission's regulation 10 CFR Part 9.

9.

Certifications The Office of Management Information and Program Control is responsible for design, oevelopment and implemental of management information-systems.

See Tab F.

Also enclosed at Tab G is the Executive Director of Operations e

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,