ML20038B987
| ML20038B987 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1981 |
| From: | Durst J NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA) |
| To: | Murley T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20038B986 | List: |
| References | |
| NUDOCS 8112090394 | |
| Download: ML20038B987 (2) | |
Text
4,'-a o
UNITED STATES Q#g NUCLEAR REGULATORY COMMISSION n
M k
WASHINGTON, D C.20555 N,
%J NOV 5 1981 NOTE FOR:
Thomas E. Murley Director for Regional Operations and Generic Requirements Staff FROM:
Jay B. Durst, Deputy Director Automated Systems Planning Staff Office of Management and Program Analysis
SUBJECT:
PAPERWORK REDUCTION ACT REQUIREMENT ON NRC The Paperwork Reduction Act of 1980 addresses two general areas:
~
(1) reporting and record-keeping requirements imposed by agencies; and (2) general information management activities.
The Act transferred from the General Accounting Office (GAO) to the Office of Management and Budget (OMB) the responsibility for approving the reporting and record-keepirg requirements imposed by independent regulatory agencies.
For a requirement to be enforceable, the document imposing the requirement must carry an OMB clearance number. OMB assumed responsibility for independent agencies on April 3,1981.
On April 24 the NRC, through the EDO, set forth procedures and criteria for preparing clearance packages to submit to OMB for approval. The ED0 in that directive named the Director, Office of Administration, as the NRC Senicr Official for carrying out the responsibilities of the Act.
OMB Circular 81-21 requested the agency to submit the name of its Senior Official by July 1,1981 ard a work plan and schedule for conducting reviews of its information management activities by September 1.
NRC comp'ii ed.
However, no reviews relating to reporting and record-keeping l
requirements were submitted.
In August the NRC submitted an application to OMB for approval of the reporting and record-keeping requirements imposed by Part 50. Almost concurrently, Vice-President Bush's Task Force identified Part 50 as one of the nine most burdensome regulations.
Discussions with the OMB i
l l
~8112090394 811110 PDR REVGP tiRGCRGR PDR 1
NOV 5 581 ihomasE.Murley 2-staff, later confirmed in the DeMuth to Palladino letter of October 30, indicate a strong OMB interest in NRC's systematic review and a work plan due by January 15, 1982.
I sugguest you read the DeMuth letter (attached).
Jay rs Director Aufoma ed Systems Planning Staff Office of Management and Program Analysis
Attachment:
Letter from DeMuth Dated October 30 i
a 5
Y e
l Attachment
, 4"g %
EXECUTIVE OFFICE OF THE PliESIDENT
. [
{J,2) orrict or M ANActv.ttlT AND EUDGE.T w/
w4wmcTm. o.c..w:o s
s., _
e lOfl0
' Eonorable Nun'zio J. Palladino Chairnan Nuclear Regulatory Commission l
Washington, D. C.
20555 s
l l
Dear F.r.,
Palladino:
On Acoust S the Nuclear Regulatory Commission (NRC) submitted 10 i
l
,CFR Par t 5 0, Domestic Licensina of Production and Dtilization rnr,i,-,nn.
f e, r nny recinu "n rin e no Meerwnck Psauction Act.
Shortly thereafter, vice President Bush f aentified nuclear IIcensing as one coecific area in which reporting and pape rwork burcens placed on the oublic could M reduced, Just recently, President Reagan stressed the need to improve the nuclear regulatory and licensin9 Process.
In seeking OMB aoproval of the recordkeeping and reporting requitecents authorised' by Part 50, NRC has made a significant effort to avoid duo 1ication nna reduce burden en re sponcents.
NRC has published a cowrehensive revision to Maulatory Guide 10.1, " Compilation of Reporting Requirements," that will reduce I
the recuired number of cooies for most recorts to three or fever, and a Standard Review Plan, simolifving and consolidating the criteria NRC staff Will use in reviewino noplications to, i
Ngonstruct or operate nuclear power plants.
HRC has just orented the Generic Rhauirements Review Committee to 2ntegrate and control the issuance of new (ts well as back-fitting) regulatory requirements, and requests for information from licensee s.
I understand NRC has ef forts planned to reduce the number of amendmente required for changes te technical specification s, to limit certain kinds of reporting to important safety items, and to permit facilities to submit information in a y caster microform, instead of multiple hard copies.
k Because we believe NRC has been taking significant steps to I1 g
accroving the NRC resolve information collection problems, va nre D
request to continue to use the in forn,at ion collections authorszea
{
h
!y Part 5 0. _ % _ c gpr e m p<rme 37741 2n.
lor 7, ano chould t>3 i
2identified by use of DiB No. 3150-0011.
However, this annroval i;3 conditional on certain ef forts to reduce thece burdens.
further approval of the recordkeeping end X)
For OMB to g r ant reporting requirements authorized by Part 50, NRC's needs and the Practical utility of the data must be balanced more ef fectively against the burdens and costs involved.
Uc fully appreciate that
l l
h'RC resolution of the numerous safety and other regulato'ry issues t
l involyed in Part 50 requires access to considerable amounts of inforr.ation from licensees, contractors, operators, and others i
who would be engaged in nuclear activities.
At the same tire, l
NRC needs' to improve its information collection activities 'to l
neet these needs.
Assuring the practical utility of the information for NRC will help minimize burden on 31censees and applicants.
This means NRC should be collecting only such anta as it can use:
seeking only l
I that level of detail needed; having it submitted no sooner than the likely time of actual use; and precisely defining record-keeping recuirements and retention periods, based on likely periodo of actual inspection and use.
Once the data is obtained, IGC should be actually using it, following up promptly and conclusively with the respondent, as necessary.
As the Cr m icsinn vocontiv ominted out to NEC staf f, however, l
f ormal NRC staf f comunicationn with licenseen ( bu) 3e t ins, l
oeneric lette rs. circulars, noticec, rule chances, NUREGs, anc],
l Raoulato_rv Guides) have not Men subiect to central NFC review j
and coordination-Licensees and representatives of industry have complained that this lack of central coordination and control hat resulted in aunlicative and bur 6ensome recordkeeping and I
reportino recuire ants--the submission of the same cata both
~
nonthly and annually, the submission of aggregate data and the raw data itself, the submission of highly detailed data that is never reviewed.
Most of this in cubiect en nom review authority l
and soproval under the Pana rwork Reduction Act_.
l s
To work with you further in this effort to control paperwork, gg) recuest submi ssion en nn.
bv ibnns tv 15, 19 0.
e, f a detailed work plan to implement needed improvements.
The wnrk plan should incluce pro 1ects, staf f, oroanization, planned tarcet dates,- and a schedule f or rendr t ino oroc re ss and _ a_ccornl i shnants to us.
that As a catter of OMB reports clearance, NRC ehould assure notices, bulletins, and other documants calling for recordkeeping and reportina ha e-maa available and submitted for OMB revlew.
forth OP.B approval of the. use of the information collect:ons cet in 10 CFR Part 50 does not include approval cf the recordkeeping and reporting requirements called for by any other NRC l
communications implementing Part 50 unless OMB has so agreed, l
j the public and OMB to review the total Jr. pact involved To parait in related information collections, NRC should attempt to review such collections simultaneously rath'er than one af ter another.
To try to solve spaci fic public corolaints concerning informaticn g
Collection. N RC ntaff chnnl a Po cnrnorncod to contanDL to, v i r.
_ ith tha Nuci o n e acnra Mana, o-ont As ecci a t inn, and equivalent w
9roups, to the extent they can be of assistance.
to have the A3 a nat ter of HRC cont ral rnntrol, we m co vou G: neric Rooui rement s hviaw cn mittee (GRRC) ansure that sny n
u aments
i
. s.
r 3
i 3
o 9*
have oractical utility in olace.
for the NRC, and do not duplicate others adont a nore systematic nethodoloov for evalur,tinoTo help
_t_i sin g and nothods of inplemente inn of an the burden, informtion conection--includina a review of whether recordkeeping renortino is tha M e naans of or i niv ~ ntatinn--3nd
.. a.p p.r n n r i, F e rlmne the no nf fnfmlity sea Enknil tn M 4emocod, 17e look forward to continuing to work with you and your staff on this deportant effort.
~_
Sincerel'i l
[
Chrip oo.er DeMuth
'~
Adminishrator for Infor; nation and Regulatory Affairs
- s s_..
l l
l
- 4 h
e O
w O
ee -
e e
4 9
i e
t