ML20038B989

Requests Representative from IE to Discuss Need for IE Bulletin Re Elastometers Used in Asco NP-1 Valves at Committee to Review Generic Requirements 811119 Meeting in Bethesda,Md.Draft OMB Review Request Encl

ML20038B989
Person / Time
Issue date:	11/13/1981
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20038B990	List: ML20038B989 ML20038B991
References
NUDOCS 8112090397
Download: ML20038B989 (6)

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Distribution:

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TEMurley Central File DEDROGR cf /

NOV 131981 1

t HEMORANDUM FOR: Richard DeYoung, Director Office of Inspection and Enforcement FROM:

Victor Stello, Jr.

Deputy Executive Director Regional Operations and Generic Requirements l

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SUBJECT:

REQUEST FOR OMB CLEARANCE FOR IE BILLETIN ON ELASTOMERS USED ASCO NP-1 VALVES Mr. Donoghue, Director ADM, is referring all Requests-for Ole Clearance to my Office.for review of the need for the requirement. Since these Requests for O!S Clearance typically impose a new requirement on licensees, l

I I will refer the Requests, on a selected basis, to the Committee to l.

Review Generic Requirements (CRGR) for their review.

Accordingly, I would like to request that ~a representative from IE (not the CRGR member Mr. Jordan) discuss the need for the enclosed IE Bulletin at the next CRGR meeting on Thursday, November 19,1981, at 1 p.m. in Room 6507 MNBB.

The IE representative should be prepared to discuss the following specific questions:

1.

Hos does this requirement relate to NRR's overall Equipment Qualification program?

2.

What assurance do we have that the solution proposed in the Bulletin will meet.all the EQ requirements?

3.

Why can't this proposed action be integrated into the overall EQ program requirements?

/c Victor tellom Jr.

Deputy Executive Director Regional Operational and Generic Requirements i

Enclosure:

IE Bulletin cc:

D. Donoghue (w/o encl.)

- - J 8112090397 811113 PDR REVGP NRCCR

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UNITED STATES;

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E NUCLEAR REGULATORY COMMISSION o

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WASHINGTON, D. C. 20555 e%[Di,/

Mr. Arnold Strasser Office of Management and Budget Reports Management, Room 3201 New Executive Office Building Washington, D.C.

20502

Dear Mr. Strasser:

In accordance with Section 3507 of Public Law 96-511 of December 11, 1980 and regulations of the Office of Management and Budget, I am enclosing for 0MB review copies of Standard Form-83 and the Supporting Statement covering reporting and recordkeeping requirements for an I&E Bulletin on Elastomers Used in ASCO NP-1 Valves.

The est'imated respondent burden is 6,700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br />.

In accordance with NRC's procedures, my staff has made an independent review of the practical utility and necessity for the proposed information collec-tion and we are in concurrence with this proposal. We have also reviewed for duplication and found no similar requirement in the agency. Therefore, we are transmitting this material for appropriate OMB review and approval.

Sincerely, Daniel J. Donoghue, Director Office of Administration

Enclosures:

As stated J'

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17. Abstr:ct-Needs and Uses (50 w;rds orI;ss)

' ' I'&E Butistin requests licensees to rsview and provide analyses of elastomers used in ASCO NP-1 valvas so that NRC may review health and safety impact -

18. R; lit d report form (s) (give OMB number (s). lRCN(s),

20. Catalog of FederalDomestic Assistance Program Number int:rnzi agency repor.t form number (s) or symbol (s)) ; _....;

N/A 21.Small business or organization O Yes R No

19. Type of affected public (Check as many as spply)

22. Type of activity of affected public-indicate 3 digit Standard industrial Classification (SIC) code (s) (up to 10) - if over 1 O individuals orhouseholds 10, check O Multiple or O All 2 O state orlocalgovernments 3 0 farms

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a)C) businesses or otherinstitutions (except farms) 4

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23. Brist description of atfected public leg,"retailgrocery stores."" State education agencies "" households in 50 largest SMSA s")

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NRC lienntopt

24. Purpose (Check as many as apply. IImore than one. indicate

26. Collection method (Check as many as apply)

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predominant by an asterisk) 1%)(mail self-administered -

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' t O application for benefits 2 O other self-administered '

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3 0 general purpose statistics aO personalinterview

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2 O program evaluation 30 telepnoneinterview.

l aH rsgulatory or compliance 5O recordkeeping requirernent:.

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,jj 5 O program planning or management

[ Required retention period:.

years

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6 0 research

's O other-describe:

l 25; Frequency of Use

27. Collection agent (Check'one) -

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1g Nonrecurring 16 requesting Department / Agency l

Recurring (check as many as appfy) 2 0 'other Federal Department / Agency 2 O on occasion 6 O semiannually.

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3 0 private contractor 3 O' weekly 70 annually 4 0 recordkeeping requirement

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5 0 quarterly 90 other-describe:[

5 O other-describe:

- a O_ monthly -

80 biennially, c

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28. Authority for agency for information collection or' 3o. Do you promis'e confidentiality 7 t

rulsmaking-indicate statute. regulation. judicial decree.

(If yes. explairibasis for' pledge t

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in supporting statement.)

O Yes ~ p No~~

ER Act of 1974

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-AE Act of 1954 '

31, will the proposed information[c_ollection create a new or &

become part of an existing Phvacy Act system of records?.

29. Rsspondent's obligation to repty (Check as mtny as apply)

(If yes, attach FederalRegist& notice orproposed draftof notice.) -

{]-Yes[U No.

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t O voluntary

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2 O required to obtain or retain benefit

32. Cost to Federal Government of

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3M mandatory-cite statute.nct CFR (attach copy of information collection or rulemaking $ 32.000 3

- statutory authority).

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COMPLETE ITEMS 33 THRU 35 ONLY IF RULEM AKING S_UBMISSION

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33. Compliance costs to the public 34.js there a regulatory impact

35. ls there a statutory orjudicial analysis attached?

deadline affecting issuance?

S O Yes O No O Yes. Enter date:

0 No, 9:

CERTIFICATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the information col!ection or rulemaking submitted for

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ressw is necessary for the proper performance of the agency's functions, that the proposal represents the minimum public burden and Federal cost 4

Consistent with need, and is consistent with applicable CMB and agency policy directives. Signature and title of:

AMWovwvG PoOCY OFFICI AL FoR AGENCY oATE su8usTTING oFFICI AL oATE 4 '-

l Daniel J. Donochue R. S. Scott f

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h Supporting Statement for I&E Bulletin on Elastomers Used in ASCO NP-1 Valves

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Justification

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(i)

NRC has an established program of communications with its' licensees.

' -I&E bulletins notify licensees / applicants and request. them

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to take appropriate action and report to NRC results of inspections, corrective measures taken or analysis performed.

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This specific-request for clearance involves an I&E bulletin j

on.the use c'f Elastomers in ASCO NP-1 Valves.

s The background section of the' bulletin addresses generic problems 7

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assoTiated with using ASCO NP-1 valves with Viton elastomers in harsh environments. Recent tests indicate that the valves are not qualified to perform a dynamic function after being exposed to a total gamma rad.iation level in excess of 20 megarads.

Said-

. valves may be located inside containment, where the postulated gammafradiation. level could exceed 20 megarads, and could be required to perform a safety-related function subsequent to such e

' an exposure.

s The_ primary purpose of the bulletin is to assure that ASCO NP-1

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valves'with Viton elastomers are not used in locations where

s the total postulated gamma radiation exposure level could exceed 20 megarads. The' reporting requirements are to ensure that valves containing Viton parts are rebuilt with suitable elastomers s--

on a timely basis or that the use of such elastomers poses no unfue risk to the health and safety of the public. The information

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obtained will be reviewed by regional and headquarters personnel is f to verify completeness and'to determine t5e Ecceptability of

,f submitted analyses.

' Since the requested reviews and analyses pertaining to the use of ASCO HP-1 valves with Viton parts have not been performed to date, data concerning the use of said valves in locations where the total postulated gamma radiation level could exceed 20 megarads is not presently available from any source.

(ii)

See ab'ove.

r (iii)

There is no other source for the data.

4 (iv)

Not applicable.

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t Supporting Statement 2

2.

Description of Survey Plan-The bulletin will be applicable to all operating nuclear power plants and plants for which a construction pennit has been issued.

In total this represents about 150 total units. However, about 60 of these units are duplicates of other units'at the same site, and probably would not require a separate report.

3.

Tabulation & Publication Plans There are no current plans for publication of the data obtained.

4.

Time Schedule for Data Collection & Publication,

The time schedule is outlined in the bulletin.

5.

Consultations Cutside the Agency With the exception of personnel employed by the ASCO Company, we have not consulted with persons outside of the NRC. As required by NRC regulations, ASCO provided NRC with information regarding the failure of valves containing Viton parts to perform adequately after being exposed to high radiation doses.

Additional discussion were held with ASCO personnel to obtain a better technical understanding of the tests performed and the potential failure modes of the valves.

6.

Estimate of Respondent Reporting Burden As stated in Item 2, the bulletin will require reports from about 150 nuclear power plants that are operating,qr under construction. However, because some units are identical to other units at the same site, about 90 individual reports are expected. Those plants not using ASCO NP-1 valves for safety related applications need only submit a negative declara-tion to that effect.

We estimate that roughly one quarter of all reports would fall into this category.

Since all nuclear power plants are required ta.mainta.tn a list of.all. safety related equipment, making a detennination that the plant is not using the ASCO NP-1 valves in safety related appli-cations is estimated to require about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Thus, for plants in this category, the total respondent reporting burden would be about 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> i

(about 25 respondents times 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per respondent).

The reporting' burden for the plants using ASCO NP-1 valves in safety related applications would be greater. Such plants are required to determine the system function for each valve, determine if replacenent of the Viton parts is necessary, and provide a schedule for replacement.

It is estimated that the reporting burden will be 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per respondent, or a total of 6500 hours0.0752 days <br />1.806 hours <br />0.0107 weeks <br />0.00247 months <br /> (65 respondents times 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per respondent).

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7-Supporting Statement 3

7. Sensitive Questions Not applicable.

8. Estimate of Cost to Federal Government We estimate that the total cost to the government for the preparation of the bulletin and review of the responses is $32,000. This cost is dominated by the technical review that each response will receive to assure that each respondent has adequately addressed the safety issues raised by this bulletin.

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