ML20035A168
| ML20035A168 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1993 |
| From: | Cranford G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | |
| References | |
| OMB-3150-0011, OMB-3150-11, NUDOCS 9303240211 | |
| Download: ML20035A168 (50) | |
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Request for OMB Revief,NE (Rev. $eptemba 1983)
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R:ad instructions before co form. Do not use the same SF 83 Send three copies of this form, the tria'tsrtaHeM4eviewed, and for to request both an Executive 2291 review and approvai under paperwork-three copies of the supporting statement, to:
tha Paperwork Recuction Act. Wf Answer all questions in Part 1. Wthis request rs for review uncer E.O.
Office of information and Regulatory Affairs 12291. complete Part 11 and sign the regulatory certification ff th:s Othce of Management and Budget reouest is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket LiDrary, Room 3201 1320, skip Part 11. complete Part lil and sign the paperwork certsf. cation.
Washmgton. DC 20503 PART f.-Complete This Part for All Requests.
- 1. Department / agency anc Buream c?f.ce onginating reavest
- 2. Agency coce U.S. Nuclear Regulatory Commission 3 1 5
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- 3. Name of person wno can oest answer guestions regarcing trus request Telephone number Joe Mate
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- 4. T4tle of mtormation coivection or ruiemaking 10 CFR 50, Domestic Licensing of Production and Utilization Facilities
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k OM8 SUPPORTING STATEMENT FOR 10 CFR f 50.65,
' REQUIREMENTS FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS" (3150-0011)
Dfscription of the Information Collection The final maintenance rule, published in July of 1991 and effective July 10, 1996, requires that the licensees monitor the performance of certain structures, systems, and components (SSCs) within the scope of the rule against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Monitoring is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled by appropriate preventive maintenance, such that the SSC remains capable of performing its intended function. Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least annually. The objective of preventing failures through maintenance is to be balanced against the objective of minimizing unavailability of SSCs.
In performing monitoring and preventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall effect on performance of safety functions.
This proposed rulemaking modifies the requirement in section 50.65 (a)(3) by reducing the required frequency for evaluations of performance and condition monitoring activities and associated goals and preventative maintenance actions from annually to once every refueling cycle not to exceed 24 months.
The NRC believes that the quantity and quality of data obtained during refueling outages will generally be substantially greater than that which would be available on an annual schedule because evaluations of data accumulated over a period of a refueling cycle, as opposed to the shorter annual period currently required by the rule, will provide a more meaningful basis for the recognition and interpretation of trends and problem areas.
A.
JUSTIFICATION 1.
Need for the Collection of Information.
Licensees must collect and analyze information concerning the performance of SSCs within the scope of the maintenance rule in order for them to use information from past experience to predict future plant ninerabilities and plan appropriate maintenance activities aimed at eliminating or mitigating them.
2.
Acency Use of Information.
Information on performance criteria, goal setting and monitoring results, failure data, unavailability data, and documentation of periodic assessments required by the rule will be reviewed at the licensee's facilities by the NRC's inspectors in order to evaluate SSC performance and ensure that the SSCs are capable of fulfilling their intended function, and i
thereby maintain safe operation of the plant. Reporting of information to NRC headquarters or regional offices is not required.
3.
Reduction of Burden Throuah Information Technoloav.
The requirements in 150.65 do not require licensees to use any particular information technology. However, the NRC encourages the use of new and effective technology that would reduce the i
burden for the collection and management of information.
4.
Effort to Identify Duplication.
Licensees are currently required
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to collect and document information concerning the condition and behavior of plant equipment in accordance with 10 CFR 50, Appendix l
B (e.g., procedures, quality assurance programs, records),
5 50.36 (surveillance requirements), 5 50.48 (fire protection),
50.49 (environmental qualification), 5 50.55a (in-service i
inspection requirements), 5 50.61 (pressurized thermal shock),
5 50.62 (anticipated transient without scram), 5 50.63 (station blackout), and 10 CFR 54 if applicable (license renewal). At least some of this same information will be used by licensees to partially meet the requirements in 150.65 with respect to safety-related SSCs.
5.
Effort to Use Similar Information.
Currently required or voluntary information and documentation will be used where available, i.e.,10 CFR 50 sections listed under item 4 above.
6.
Effort to Reduce Small Business Burden.
The rule affects only l
nuclear power reactor licensees. None of these licensees fall within the definition of a small business, as defined in the Commission's Size Standards (50 FR 50241; December 9, 1985).
1 7.
Conseauences of less Freauent Collection.
Licensees are required to assess the overall effectiveness of their maintenance efforts at least once every refueling cycle provided the interval between evaluations does not exceed 24 months. Collection of failure and l
unavailability information and attendant cause analyses are driven l
by the frequency and type of failures. NRC inspectors will be expected to judge the adequacy of each licensee's' efforts by the i
results in terms of acceptability of failure rates and unavailability rates for plant equipment. Accordingly, the i
frequency of collection of data is driven by events as well as the i
existing maintenance schedule for each plant.
It is not possible to collect the information less frequently and yet insure the safety of the public and plant operation.
8.
Circumstances Which Justify Variation From OMB Guidelines There are no variations from the DMB Guidelines.
9.
Consultations Outside the Aaency.
The NRC staff has had several interactions in public meetings with NUMARC since the publication
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of the maintenance rule.
1992, NUMARC made a suggestion that the NRC consider theAt e
possibility of going to a refueling cycle outage in lieu of an annual requirement for performance evaluations.
NRC agreed to consider the matter.
10.
Confidentiality of Information.
None.
11.
Justification for Sensitive Ouestions.
No sensitive information is requested under this regulation.
12.
Estimated Annualized Burden to the Federal Government.
The NRC already performs maintenance inspections and maintenance evaluations as a routine part of the inspection process.
The proposed change to the maintenance rule is not expected to impact the burden associated with the inspection activity.
13.
Estimate of Burden. The industry burden will actually be reduced because the performance evaluations performed by power plant licensees will change from annually to once every refueling outage but not to exceed 24 months.
It is currently estimated that the time tt complete a periodic assessment (including data collection) is approximately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> per plant. The staff estimates that the reduced frequency of performing the required evaluation will result in a burden decrease of approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> per plant. The reduction in i
burden to the industry is therefore 16,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> (150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> X 110 plants) and a cost reduction of approximately 2 million dollars (16,500 hrs X $123.00/ hour).
14.
Reason for chance in burden.
The proposed rulemaking would reduce the frequency of licensee evaluations from annually to once every refueling outage, not to exceed 24 months.
15.
Publication for statistical use. None.
B.
COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS:
Not Applicable.
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION n
E WASHtNGTON. D C. 20555 o
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Ron Minsk NRC Desk Officer FROM:
Beth St. Mary
SUBJECT:
CLEARANCES UNDER OMB REVIEW WITH THE SAME OMB CONTROL NUMBER: 3150-0011 By this transmittai NRC is submitting an OMB clearance package for review under OMB Control Number 3150-0011, entitled 10 CFR 50.65, Monitoring the Effectiveness of Maintenance for Nuclear Power Plants, Proposed Rule. OMB currently has under review two other submittals which affect OMB control number 3150-0011. These are the following:
Proposed Rule, 10 CFR 30, 40, 50, 70, and 72, Procedures and Criteria for On-Site Storage of low-Level Radioactive Waste Final Rule,10 CFR 50.65, Monitoring the Effectiveness of Maintenance for Nuclear Power Plants Note that the proposed rule being submitted amends the latter rule mentioned above by reducing the burden.
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NUCLEAR REGULATORY COMMISSION Documents Containing Reporting or Recordkeeping Requirements: Office of Management and Budget (OMB) Review AGENCY:
Nuclear Regulatory Comission ACTION:
Notice of the Office of Management and Budget review of infomation collection.
SUMMARY
The Nuclear Regulatory Comission (NRC) has recently submitted to the Office of Management and Budget (OMB) for review the following proposal for the collection of information under the provisions of the Paperwork Reduction Act (44 U.S.C. Chapter 35).
1.
Type of submission, new, revision, or extension: Revision 2.
The title of the information collection:
10 CFR Part 50.55 - Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.
3.
Tne form number if applicable: Not applicable.
4.
How often the collection is required: Collection is required on a continuing basis as the infomation becomes available.
5.
Who will be required or asked to report: No reporting to the NRC is required. Holders of a power plant operating license under 10 CFR I 30.21(b) or i 50.22 must maintain certain records or data relating to maintenance.
6.
An estimate of the total number of responses: No responses to the.NRC are required or expected.
110 nuclear power plants will be required to maintain certain records or data.
A 7.
An estimate of the number of hours needed annually to complete the requirement or request: This proposed change to 50.65 is expected to result in a savings to the licensees of approximately 150 staff hours per plant.
8.
An indication of whether Section 3504(h), Pub. L.96-511 applies:
Applicable.
9.
Abstract: The Commission is proposing to amend its regulations in 10 CFR 50.65 to change the frequency for commercial nuclear power plant licensees to evaluate the effectiveness of maintenance activities for safety significant plant equipment in order to minimize the likelihood of failure and events caused by the lack of effective maintenance. The i
annual evaluation requirement currently in 10 CFR 50.65 is being amended from annually to once per refueling cycle but not to exceed 24 months because the Commission believes that the quantity and quality of data obtained during refueling outages would be substantially greater than that available on an annual schedule and would provide a more meaningful basis for the recognition and interpretation of trends.
Copies of the submittal may be inspected or obtained for a fee from the NRC Public Document Room, 2120 L Street, (Lower Level) NW, Washington, DC 20555.
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Coments and questions can be directed by mail to the OMB reviewer:
Ronald Minsk Office. of Information and Regulatory Affairs (3150-0011) l NE08-3019 Office of. Management and Budget Washington, DC 20503 i
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coments can also be comunicated by telephone at (202) 395-3084.
j The NRC Clearance Officer is Brenda Jo Shelton, (301) 492-8132.
DatedatBethesda, Maryland,this/7dbdayofd 1993.
For the Nuclear Regulatory Comission.
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21 Gerald F. CrAnford, Desiq(Ated Seniorlfficial for Information Resources Management s
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7 MEMORANDUM FOR:
Janes M. Taylor Executive Director for Operations
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FRON:
Eric 5. Beckjord, Director Office of Nuclear Regulatory Research j
SUBJECT:
REVISION OF THE MAINTENANCE RULE (10 CFR 50.65)
A Staff Requirement Manorandum (SRM) dated February 17, 1993, Enclosure 1, i
directed the staff to publish a proposed rule modifying the period for the l
performance of evaluations required of power plant licensees under paragraph (a)(3) of 10 CFR 50.65 (Maintenance Rule), from annually to once per refueling cycle but not to exceed 2 years. The SIDI stated that the proposed rule should l
be published in the Federal Racister on March 15, 1993, for a 45-day period.
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', contains a proposed rulemaking package consisting of a Federal l
Register Notice, a public announcement, and the Congressional letters developed by RES on this subject.
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The Offices of Administration, Enforcement, Analysis and Evaluation of
'i operational Data, Nuclear Reactor Regulation, and Information Resources Management have reviewed and concurred on this proposed rulemaking. The l
Office of the General Counsel has no legal objection. If you have any questions please call Joseph J. Mate at 492-3795.
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Eric S. Beckjord, Digictor Office of Nuclear Regulatory Research
Enclosures:
1.
SRM dated 2/17/93 l
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Proposed Rulemaking Package s
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- EMORANDUM FOR:
James H. Taylor Executive Director for Operations
- 4 FROM:
Eric S. Beckjord, Director
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Office of Nuclear Regulatory Research
SUBJECT:
REVISION OF THE MAINTENANCE RULE (10 CFR 50.65) i A Staff Requirement Memorandum (SRM) dated February 17, 1993 Enclosure 1, directed the staff to publish a proposed rule modifying the period for the performance of evaluations required of power plant licensees under paragraph (a)(3) of 10 CFR 50.65 (Maintenance Rule), from annually to once per refueling cycle but not to exceed 2 years. The SRM stated that the proposed rule should be published in the Federal E1 gill.tr on March 15, 1993, for a 45-day period., contains a proposed rulemaking package consisting of a Federal Register Motica, a public announcement, and the Congressional letters developed by RES on this subject.
The Offices of Administration, Enforcement, Analysis and Evaluation of Operational Data, Nuclear Reactor Regulation, and Information Resources Management have reviewed and concurred on this proposed rulemaking. The Office of the General Counsel has no legal objection.
If you have any questions please call Joseph J. Mate at 492-3795.
Eric S. Beckjord, Director Office of Nuclear Regulatory Research
Enclosures:
1.
SRM dated 2/17/93 2.
Proposed Rulemaking Package See next page for Distribution RECORD HOTE:
A copy of the proyhKCW 3, li%.
sed rule was sent to the OIG for information on g
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Cone ce:
/DRA) RDB/dRF 00/Otg/RES 0FFC:Ise/DRA NAME:JMate:
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SBahadur FCostanzi is DATE:} /il /93" 3/j]/93 b/11/93 5/e/ /93 J /// /93 0FFC:D:0E 0:IRNMD:NRRR6* # D:AE00 D:ADN NAME:JLiebe GCranford TMurley EJordan PNorry DATE:8/$/93
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NAME: WParler CJR(Joets 458ec ord DATE: 3 /il/93 W 93 J M 93 0FFICIAL RECORD COPY
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ENCLOSURE STAFF REQUIREMENTS MEMO 1
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February 17, 1993 REFER TO:
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oerce or vna eGCRETARY i
d MEMORANDUM FOR:
James M. Taylor Executive Director for o rations FROM:
Samuel J. Chilk, Secre 3
SUBJECT:
STAFF REQUIREMENTS - BRI.
ON IMPLEMENTING i
GUIDANCE FOR THE MA RULE AND i
INDUSTRY VERIFICATION AND VALIDATION EFFORT, l
10:00 A.M., FRIDhY, JANUARY 29, 1993, 4
COMMISSIONERS' CONFERENCE ROOM, ONE NEITE FLINT NORW, ROCKVILLE, MARYLAND (OPEN M PUBLIC ATTENDANCE)
The Commission was briefed by-the NUMARC and.the NRC staff on the l
implementing guidance for the maintenance rule and the' industry
-l verification and validation effort.
NUMARC was represented by Corbin McNeill, President and Chief Operating _ Officer Philadelphia Electric Company Tom Tipton, Vice President, NUMARC
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t The Commission requested further infor1sation from NUMARC.
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concerning the participants in their workshop on implementing the maintenance guidance.
l The Commission requ a ted that the maintenance inspection guidance j
for the maintenance rule be published for public comment and be j
the subject of a ic workshop.
(WMP) (
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(SECT Suspense 6/1/94) 9300026 l
Consistant' ith the authority delegated to the EDO by the
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w Cosmission-for rulemaking of a minor nature, the staff should l
publish a proposed rule modifying the periodicity of the j
evaluations ~ of monitoring actiyities and associated goals'and i
preventive maintamanaa sotivitled - required of licensees under paragraph (a)(3) of the Maintenance Rule (10 CFR 50.65) from -
i annually to once per refueling interval (not to escoed 2 years);
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obtain and address public comments on the proposed rule; and, provided significant concerns are not identified through the comment process, ' implement the final rule change.
(SECY Suspense:
publication of proposed l
((399) rule change in Federal MRR)
Register for 45-day j
9300027 comment period - 3/15/93) i (SECY Suspence:
Incorporate public l
comments and publish final rule - 6/1/93) cc:
The Chairman l
Commissioner Rogers Commissioner Curtiss r
Counsissioner Remick Commissioner de Planque
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NUCLEAR REGULATORY COMISSION 10 CFR Part 50 RIN 3150 - AE55 Monitoring the Effectiveness of Maintenance at Nuclear Power Plants l
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NUCLEAR REGULATORY COP 9tISSION 10 CFR Part 50 i
I RIN 3150 - AE55 a
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i Monitoring the Effectiveness of' i
Maintenance at Nuclear Power Plants 8
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I AGENCY: Nuclear Regulatory Commission.
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ACTION: Proposed rule.
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i Sulf 4ARY: The Nuclear Regulatory Commission (NRC) is proposing t' amend its '
regulations for monitoring the effectiveness of maintenance programs at' commercial nuclear power plants. The current regulations require.that nuclear power plant licensees evaluate performance and condition monitoring activities and associated goals and preventive maintenance activities at least annually.
The proposed amendment would change the time interval for conducting i
evaluations from once every year to at least once every refueling cycle, but i
not to exceed 24 months. '
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-l DATES: The comment period (expires 45 days from the date of publication in the Federal Register). Comment received after this date will be considered if u
t it is practical to do so, but the Coassission is able, to ensure consideration only for comments submitted and received on or before this date.
ADDRESSES: Mail written comments to the Secretary, U. S. Nuclear Regulatory Coensission, Washington, DC 20555, Attention: Docketing and Service Branch.'
Deliver comments to: One White Flint North,11555 Rockville Pike, Rockville, Maryland, between 7:45 a.m. and 4:15 p.m. on Federal Workdays. Copies of comuments received may be examined at the NRC Public Document Room, 2120 L Street NW. (Lower level), Washington, DC.
t FOR FURTHER INFORMATION CONTACT: Joseph J. Mate, Office of Nuclear Regulatory i
Research, U. S. Nuclear Regulatory Cosumission, Washington, DC 20555, telephone l
(301) 492-3795.
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SUPPLEMENTARY INFORMATION:
I
Background
On July 10,1991, (56 FR 31324) the Nuclear Regulatory Commission l
published the final rule, ' Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," (i 50.65). The final rule, which will
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become effective July 10, 1996, requires commercial nuclear power plant t
licensees to monitor the effectiveness of maintenance activities for safety-l i
p significant plant equipment in order to minimize the likelihood of failures and events caused by the lack of effective maintenance. Section 50.65 (a)(3)
-j requires nuclear power plant licensees to evaluate the overall effectiveness l
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of their maintenance activities on an annual basis. An industry consensus guidance document and a regulatory guide to provide an acceptable methodology
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for implementing the final rule are expected to be published by June 30, 1993.
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Olscussion Since the Maintenance Rule was published in July 1991, two events have occurred that lead the Commission to reconsider the annual evaluation requirements in i 50.65(a)(3).
First, in the Summer of 1991, the Nuclear Management Resources Council (NUMARC) Steering Group was formed to develop an industry guide for implementing the Maintenance Rule. While developing the guide, the Steering i
Group suggested to the NRC in a public meeting held on February 26, 1992, that instead of annual assessment requirements, the NRC should consider assessments i
based on a refueling cycle interval. The NUMARC Steering Group stated that.
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(1) Significantly more data would be available during refueling cycles M
f than is available on an annual basis, i
(2) Key data free some surveillance tests can only be obtained during i
refueling outages and is not available on an annual basis; and (3) Adjustments to maintenance activities that may be made after such an evaluation would be typically performed after a refueling outage.
The IRNK Steering Group further added that the evaluation process is a-time consuming activity and that with limited data available, the annual evaluation would not provide for meanin[N1 results. With onTy limited data, changes to maintenance programs will likely not be ande because there would 3
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not be sufficient information available for spotting trends or doing trend analysis.
Second, the NRC conducted a regulatory review to eliminate or revise unnecessarily burdensome regulations and published a final rule on August 31,1992 (57 FR 39353) that amended several regulations identified by its Committee to Review Generic Requirements (CRGR). One of those amended regulations was 10 CFR 50.71 (e) (Final Safety Analysis Report Updates) where the frequency of licensee reporting to the NRC was changed from annually to once per refueling cycle. The change was made because the use of a refueling cycle interval provided a more coordinated and cohesive update since, a sajority of design changes and sajor modifications were performed during refueling outages.
In addition, it had no adverse impact on the public health and safety and reduced the regulatory burden on the licensees.
The Commission is now proposing to change the required frequency of maintenance activity evaluations from annually to once per refueling outage.
Evaluation of data collected over the period of a refueling cycle will provide a substantially better basis for detecting problems in degraded performance of structures, systems, and components (SSC's) and weakness in saintenance practices. Evaluations conducted on a refueling cycle basis would also consider and integrate data available only during refueling outages with the data available during operations; under the existing requirements this may not occur depending on whether the annual assessment coincides with the refueling outage. Furthermore, evaluations of data accumulated over the period of a 4
refueling cycle, as opposed to the shorNr annual period required by the rule, will provide a more meaningful basis for the recognition and interpretation of trends. The Commission understands that a normal frequency of refueling l
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outage ranges from 15 to 18 months; however, the conditions may vary from klanttoplant.
In order to ensure that an indefinite period of time does not occur between maintenance evaluations, the Commission is proposing the establishment of an upper limit of 24 months between the maintenance evaluations. This would address those licensees that have extended their refueling cycle beyond 24 months for any reason including numerous short outages or extended shutdown periods. Although the Commission believes that it is generally the case that maintenance evaluations will be more effective if conducted in conjunction with refueling outages, licensees would still have the option of conducting them more frequently.
In light of the above discussion, the NRC is proposing to change the requirement for evaluation of the overall effectiveness of maintenance i
activities to be performed once per refueling cycle provided the interval between evaluations does not exceed 24 months.
Finding of No Significant Environmental Impact:
The Commission has determined that, under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule, if adopted, would not be a major Federal action that significantly affects the quality of the human environment and therefore an environmental impact statement is not required.
The proposed amendment does not require any change to nuclear power plant design'or require any modificattedk to a plant. Nor does the rule change the scope of the maintenance mle or affect the nature of the activities to be perfomed, e.g., monitoring, corrective action, and 5
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assessments of compliance. The proposed rule change would only extend the i
i time period for perfornit,g evaluations of the effectiveness of licensees' i
maintenance program from at least once a year to at least once every refueling j
cycle, not to exceed 24 months. The proposed extension should not result in any significant or discernible reduction in the effectiveness of a licensee's j
maintenance program; rather the change would increase the meaningfulness and l
quality of the maintenance evaluations. For these reasons, the Commission finds that the proposed amendment will not result in any significant increase in either the probability of occurrence of an accident or the consequences of i
an accident and therefore concludes that there will be no significant effect on the environment as a result of the proposed amendment.
The environmental assessment is available for inspection at the NRC l
t Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.
i Single copies of the environmental assessment are available from j
Joseph J. Mate, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone: (301)492-3795.
Paperwork Reduction Act Statement l
This proposed rule amends the information collection requirements that l
5 are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
This rule has been submitted to the Office of Management and Budget for review,
j and approval of the paperwork requirements.
Because the rule will relax existI;n;g requirements related t,o the hc-ctHerf assessment of maintenance activities, burden for this at..i.gf ef 4
information is expected to be reduced by 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> per licensee. This l
6
A */93 s
93 3/Q93 a
Offe:
Name:!ERathbun Date: / /93 0FFICIAL RECORD COPY s
i l
NUCLEAR REGULATORY COMMISSION i
i Documents Containing Reporting or Recordkeeping Requiremer.ts: Office of Management and Budget (OMB) Review AGENCY:
Nuclear Regulatory Commission ACTION:
Notice of the Office of Management and Budget review of information collection.
l
SUMMARY
The Nuclear Regulatory Commission (NRC) has recently submitted to the Office of Management and Budget (OMB) for review the following proposal i
for the collection of information under the provisions of the Paperwork-Reduction Act (44 U.S.C. Chapter 35).
1.
Type of submission, new, revision, or extension: Revision 2.
The title of the information collection:
4 10 CFR Part 50.65 - Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.
3.
The form number if applicable: Not applicable.
4.
How often the collection is required: Collection is required on a continuing basis as the information becomes available.
i 5.
Who will be required or asked to report: No reporting to the NRC is required. Holders of a power plant operating license under l
10 CFR I 50.21(b) or s 50.22 must maintain certain records or data l
relating to maintenance.
f 6.
An estimate of the total number of responses: No responses to the NRC are required or expected.
110 nuclear power plants will be required to maintain certain records or data.
i
n i
7.
An estimate of the number of hours needed annually to complete the requirement or request: This proposed change to 50.65 is expected to l
result in a savings to the licensees of approximately 150 staff hours per plant.
f 8.
An indication of whether Section 3504(h), Pub. L.96-511 applies:
Applicable.
9.
Abstract: The Commission is proposing to amend its regulations in 10 CFR 50.65 to change the frequency for commercial nuclear power plant licensees to evaluate the effectiveness of maintenance activities for_
safety significant plant equipment in order to minimize the likelihood of failure and events caused by the lack of effective maintenance. The annual evaluation requirement currently in 10 CFR 50.65 is being amended from annually to once per refueling cycle but not to exceed 24 months
{
because the Commission believes that the quantity and quality of data obtained during refueling outages would be substantially greater than that available on an annual schedule and would provide a more meaningful-basis for the recognition and interpretation of trends.
l Copies of the submittal may be inspected or obtained for a fee from the l
NRC Public Document Room, 2120 L Street, (Lower level) NW, Washington, DC 20555.
I i
l
- y..
Coments and questions can be directed by mail to the OMB reviewer:
Ronald Minsk Office of Information and Regulatory Affairs (3150-0011)
NE0B-3019 Office of Management and Budget Washington, DC 20503 Coments can also be comunicated by telephone at (202) 395-3084.
The NRC Clearance Officer is Brenda Jo Shelton, (301) 492-8132.
Dated at Bethesda, Maryland, this /7M day of %YkJ 1993.
For the Nuclear Regulatory Comission.
Original signed by Gera!d F. Cranford Gerald F. Cranford, Designated Senior Official for Information Resources Management DISTRIBUTION:
RES Circ /Chron DSIR c/f EIB r/f G. Cranford IRM M. Au RES
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NAME: JMkte:
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- 03 /r2493
- 03/0193
- 03'/ t1/93 DATE: 03/ 6193
- 03/,fk/93 "0FFICIAL RECORD COPYr 3
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[Tv J/O-FEo 9*.
RETURN ORIGINAL.TO PDR,HQ.
3 THE STATE Ih of WYOMING
\\
j
.w.i MIKE SULLIVAN l
GOVERNOR Department of Environmental Quality
[
2161 Coffeen Avenue e
Sheridan, Wyoming 82801
[
AIR OUAlfTY LAND QUALITV WATER QUALITY (307)672 6457 (307) 672-64B8 (307) 672-6457 Fax 13071674--6050 Fax (307)672 2213 Fax (3071674-6050
/**
February 4,1993 W
pocA gg DY Mr. William Chapman
@ h Total Minerals Corporation 4
g W
913 Foster Road go Casper, WY 82604 f,;
a RE: Christensen Ranch Wellfield Unit 2, Permit No. 478, TFN 2 6/293
Dear Mr. Chapman:
Enclosed are staff review comments on the Chdstensen Ranch Unit 2 Wellfield Data Package that was submitted November 27,1992. My comments and those of Bob Lucht of the Water Quality Division (WQD) were faxed to you in mid4anuary. Responses to some of the comments contained in those preliminary review memos were made in your response package dated January 22, 1993.
These responses do not take into account the January 22,1993, response package. If you believe that a comment has already been adequately answered, please list the date and location of that particular response.
i i
Authors of the following comments are noted by theirinitials after the heading of each comment (SI - Steve Ingle, BL - Bob Lucht, WQD, GM - Glenn Mooney)
I.
Permit Commitments (GM)
Total Minerals has a permit commitment in the Christensen Ranch Permit No. 478 Amendment No. 2 on Pages 5-43 and 5-44 of Volume I to supply wellfield data packages for approval before beginning operations in a new wellfield unit.
Section 5.7.10.3 describes the requirements for a wellfield unit data package. These I
requirements are listed in bold followed by an assessment of Total's compliance w' h that requirement.
9303240250 930204 i;
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Mr. William Chapman February 4,1993 Page 2 A.
Results of a pumping test that will demonstrate that the perimeter ore zone monitor wells are in communication with the production unit mineralized zone wells.
1.
Water Quality Division Processing of Data (BL)
Well 27_34-1 pump test data was run through AQUlX. Using a Theis curve Rtting routine, the transmissivity calculated to 11.28 and the storage coefficient calculated at.0036. The factor for the curve fit was 10.5Fc. Calculations using Hantush an pan methods were not nearly as good on the curve fit, with sligha Jtr T's and lower S's. The highest T calculated was 15.6 and the lowedj$ was 3.5E-5. The way that Total ran these tests, pumping up to 5 wellstat a time, will not lend itself to easy calculation using this program.
No response necessary.
2.
Land Quality Review of Pump Test (SI)
The pump test data was submitted separately under cover ofletters dated December 6 and 17,1992. The consultant's analysis of the pump test data was submittui on January 22,1993. Additional information on the pump test was submitted on February 3,1993.
The permit does not specifically require approval of the pump test proposal, but several items will require additional clarification. These will be discussed in a separate memo to be submitted later.
No response necessary.
II.
Potentiometric surface maps for the mineralized portion of the K sandstone, the overlying aquifer, and the underlying aquifer as developed from premining water levels.
No potentiometric surface maps using premining or pre-pump test data were included. (GM)
Potentiometric surface maps as developed from premining water levels are required for the mineralized portion of the K sandstone, the shallow zone aquifer, and the deep aquifer.
1 I
A I
Mr. William Chapman February 4,1993 Page 3 Two potentiometric surface maps were included in the Pump Test Data Packages i
submitted on December 6,1992, and December 17, 1992.
1.
The first map submitted in the December 6,1992, package is entitled
" General Location Map,.Mine Units 2 & 3" followed by "With Pump Test Piezometric Contours" in very small type.
i There are several problems with this map. (GM)
(a)
The legend is misleading.
f (b)
The piezometric contours do not extend out as far as the outer momtor nng.
(c)
There is no date when the groundwater elevation data was collected (What stage of the pump test?).
i Total should submit a corrected map.
j 2.
The December 16, 1992, map is also entitled " General Location Map, Mine. Units 2 & 3, Map 1" and below that in much smaller type "Piezametric Contours at,tatic conditions prior to Pump Test 11/22/92."
j This map has much the same problems as the first map above, i.e., (GM)
I (a)
The legend is misleading.
l (b)
The piezometric contours do not extend out as far as the outer monitor ring.
4 i
(c)
There are no dates when the groundwater elevation data was collected. Was it all collected the same day? What day? Ts it an i
4 average of several days?
Total should submit a corrected map.
i C.
Baseline water quality data and proposed monitor well upper control limits.
i Baseline water quality data was submitted for 19 perimeter zone monitor wells, 6 shallow zone monitor wells, 6 deep zone monitor wells, and 17 interior. ore i
zone production wells. Four samples were taken from each well, although a full a
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Mr. William Chapman February 4,1993 l
.l Page 4
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suite of analyses was not conducted for each sample. Generally, there are two full.
l sample suites for each well. Along with those analyses, a total of 8 analyses was done for excursion parameters plus pH,4 samples by an outside lab and 4 by Total's lab.
{
Review of the analyses prompted the following comments:
+
5 1.
Well Coordinates (GM)
^
In future submittals it would be very helpful to have the well coordinates of each well listed on the analysis sheet for that well. This would speed plotting of iso-concentration maps.
l 2.
Potentiometric Surface Elevations (GM)
The potentiometric surface elevation of each well before the time of each j
sampling should be given.
l 3.
Proposed Upper Control Limits (a)
Upper Control Limits (UCLs) were proposed on Table No. 6 of the November 27,1992, submittal. Upper Control Limits for the '
l Perimeter Ore Zone Monitor Zone and the Interior Deep Monitor j
i Zone were proposed.
(i)
Ore Zone (SI, BL) 1 The ore zone UCL's appear adequate.
i-No response necessary.
1 I
(ii)
Deep Zone (SI, BL)
The deep zone UCL's appear adequate.
i i
No response necessary.
(iii) Shallow Zone
s Mr. William Chapman February 4,1993 Page 5 (1)
Division Into Two Groups (SI)
The shallow zone will need documentation tojustify l
dividing the UCL's into two groups. We also require that the Department receive and approve j
this documentation before Total initiating any pre-l conditioning activities.
Total must supply further documentation to justify the division of the Shallow Zone UCLs into two l
groups. Approval for wellfield preconditioning will be withheld until receipt and approval of this j
justification.
(2)
New UCL Parameters and Separate UCLs (GM)
New UCL parameters and separate UCLs for each Shallow Mo, nitor Zone monitor well were proposed.
The new parameters would be chloride, pH, and i
Current excursion parameters listed on Page 5-35 of Volume I of the Christensen Ranch Mine Plan are conductivity, chloride, and total alkalinity. These cover all three monitor zones.
Separate UCL's for each monitor well are allowable if all four baseline sample results from an individual well are eliminated by the tolerance limit process as stated on Page 5-35 of the Christensen Ranch i
Project Mine Plan. Total must state their reasoning in the submittal.
l t
The reason for calculating the pH UCL by the proposed method of the sample mean rninus five standard deviations is not clear. What is clear that this method for calculating a ~ UCL would automatically create a UCL that is lower than the sample average. This would mean that nearly all wells would be defined as being in excursion status i
before commencement of operations.
I i
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Mr. William Chapman February 4,1993 i
Page 6 t
(3)
Changing UCLs (GM) l 1
On page 16 of the November 27,1992, Water Quality Data Package, there is a request for a Non-a Significant Revision (NSR) to change UCLs and method of calculating ~ them for Shallow Zone l
Monitor Wells.
+
4 While it not clearly described, it seems that Total wants to change the UCL parameters for the Shallow Zone to chloride, pH, and uranium and -
establish a separate set of UCL's for each of these new parameters for each Shallow Zone monitor l
well.
It is also not at all clear that a request for a change in the excursion parameters for the Shallow Zone wells is being made.
It is unacceptable because a request for an NSR
]
must be made as a separate package'and include i
replacement pages and an Index Sheet showing the l
locations of the proposed changes.
j
-t It is also unacceptable because no explanation was 1
given for the need for the proposed change and the scope of the change was not specified. Was this proposed change for only the Shallow Zone in Unit 2 or were past and future wellfield Units to be included? The scope of the proposed change must i
be clearly specified.
Total must explain the reasoning behind this request. Any request for a permit change or NSR must be submitted as a separate complete package containing revised pages, Index sheet, and explanation of why the permit change is being requested.
j
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Mr. William Chapman
[
February 4,1993 Page 7 i
D.
Location and completion details for monitor wells and ore zone baseline water quality wells.
1.
Table I contains location and completion details for the monitor wells.
Based on comparisons with adjacent wells, it appears there are several errors in this table: (GM) f l
(a)
The potentiometric surface elevation for MW-78T is exactly the I
same as the ground surface elevation.
1 l
(b)
The potentiometric surface elevation for MW-87T is exactly the same as the ground surface elevation.
i I
Total must explain these anomalies.
l l
2.
Figure 1 is a cross-section entitled " Cross Section of Shallow Zone Monitoring Zones." Several problems were noted with this figure: (GM) i (a)
The title is somewhat misleading as this figure also shows the i
l lithology to the bottom of-the Deep Monitor Sand.
(b)
'"he cross section shows completion intervals for a number of mcaitor wells. The lengths of these completion intervals do not af,ree completely with those completion zones in Table 1. See following table for comparisons:
l COMPARISON OF WELL COMPLETION INTERVALS BETWEEN TABLE 1 AND FIGURE 1 CROSS SECTION WELL NO.
- TABLE 1 -.
FIGURE I DIFFERENCE INTERVAL (FT)
INTERVAL (FT) f (FT)
MW-67D 62 78 16 MW-71D 73 70 3
MW-91D 57 67 10 MW-93D 64 70 6
MW-68S 43 40 3
MW-70S 23 26 3
' MW-72S 65 30 25 i
MW-94S 42 40 2
MW-96S 38 32 6
l
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l Mr. William Chapman February 4,1993 Page 8
(
t
)
(c)
No scale was given in the legend of this cross section. The only scale visible was the tiny and very dim scales on the E-logs. Both l
'i vertical and horizontal scales must be shown on cross sections.
(d)
The datum elevation used to align the E-logs was apparently the I
i lignite zone. As surveyed well elevations are available for all well locations, these should have been used. Elevation lines across the i
cross section at the 4100, 4200, 4300, 4400, and 4500 levels would aid in location of the various zones and the well completion intervals.
The use of absolute elevations to align the E-logs would also i
reveal any local structure that might influence groundwater movement.
Total must provide a revised cross section that corrects the above-noted i
problems.
E.
Average production unit baseline water quality and proposed restoration l
target values. Production unit baseline data packages will be submitted as supplementalinformation to permit in form of a separate volume.
l No proposed restoration target values were proposed. (GM)
Total must provide proposed restoration target values.
i II.
Groundwater Classifications (BL)
A.
General Comments on Groundwater Classification Of necessity, the following groundwater classifications were made using manual j
i methods because Total has never supplied the files which this department needs to accomplish this classification by computer. Using manual methods means that there could be individual parameters which may have been missed in our classification of these groundwaters. If Total wishes to submit the files necessary
?
on disk, then this depanment will be happy to reconsider these classifications. If Total wishes to point out individual wells which may have been incorrectly classified, the depanment will also be happy to reconsider these classifications.
l' Since the groundwater classification affects the entire restoration program, the i
f f
t
I r
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Mr. William Chapman February 4,1993 j
Page 9 i
time to do any reconsideration is now, not after mining has finished. The files l
that we need are simple ASCII format files showing the actual analytical data, not files showing averages for each well, j
r Total should supply the necessary files on disk.
B.
Ore Zone Classification
[;
The entire Interior Ore Zone at baseline is Class I under Chapter VIII of the
.j Wyoming Water Quality Division Rules and Regulations. This classification is primarily based on TDS and sulfate, neither of which show any single well that l
exceeds either of these standards. Radium is above the Class I standard in mosi l
4 of the wells, but it does not exceed the treatability limit of 100 pCillin any well.
Uranium and other trace metals appear to meet Class I standards.
l i
No response necessary.
l i
C.
Perimeter Zone Classification l
All of the Perimeter Monitor wells at baseline are Class I groundwater under l
Chapter VIII of the Wyoming Water Quality Rules and Regulations. TDS, sulfate, j
f uranium and radium all meet Class I standards in every case. All other trace metals appear to meet Class I standards.
r No response necessary, j
i
)
D.
The entire Interior Shallow Monitoring Zone at baseline is Class III under i
Chapter VIII of the Wyoming Water Quality Division Rules and Regulations, with the exception of the area around wells MW-94S and MW-96S. Those areas are -
Class IV(a) because the radium values exceed 5 pCill and the treatability standard does not apply. This classification is primarily based on TDS and sulfate, neither of which show any single well that exceeds either of these standards. Trace metals appear to meet class III standards.
l l
No respor.se necessary.
j E.
The entire Interior Deep Zone at baseline is Class I under Chapter VIII of the Wyoming Water Quality Division Rules and Regulations. This classification is
'l primarily based on TDS and Sulfate, neither of which show any single well that exceeds either of these standards. Radium is above the Class I standard in a few j
Mr. William Chapman j
J.
February 4,1993 Page 10 l
c of the wells, but it does not exceed the treatability limit of 100 pCill in any well.
Uranium and other trace metals appear to meet Class I standards.
i No response necessary.
3 i
Ill.
Wellfield Preconditioning (SI)
The Department of Environmental Quality will give approval for pre-conditioning only
]
after completion of the Unit 2 North Pump Test. Upon initiation of the pre-conditioning, should an excursion or excursions occur, Total will be required to take extreme measures j
to control the excursion or excursions.
IV.
Miscellaneous Comments (GM) i A.
The Isopac Maps contained in the November 27,1992, are unacceptable. The l
scale is so small that the captions and much of the legend are illegible.
I The Isopac Maps contain little information that allows alignment or orientation i
j of these maps with other inaps. One way to assist in location of the various
[
features would be to place crosses where the state plane coordinates intersect.
~
Total must provide larger scale maps that contain legible legends and captions.
i 1
Total is requested to respond to these comments in the same order as presented here. As.
j discussed above, if response to any of the comments above was made earlier, Total's answer j
should point to the date and location of the response.
j
[
i j
If you have any questions regarding any of the above questions, please feel free to contact me j
or the author of the comment in question.
Sincerely, 0n
&W Glenn Mooney Senior Geologist j
\\gm I
cc:
R. Chancellor i
G. Cash 4
S. Ingle B. Lucht, WQD f
R. Hall, NRC n
j 4%2hl.gm
,