ML20039C909

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Request for OMB Review & Supporting Statement Re Generic Ltr Concerning Odyn Code.Estimated Respondent Burden Is 109,824-h
ML20039C909
Person / Time
Issue date: 12/08/1981
From: Donoghue D, Scott R
NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20039C901 List:
References
NUDOCS 8112310088
Download: ML20039C909 (9)


Text

REEUEST FOR GM7 REVIEW l

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(Und:r ths Pap:rw'ork R: duction Act and Ex:chtive Ord:t 12291) l w

Import:nt - Read instructions (SF 83A) before completing this Office of Information and Regulatory Affairs f:rm. Submit the required number of copies of SF-83,together Office of Management and Budget with th3 material for which review is requested to:

Washington. D.C. 20503 1.D partment/ Agency and Bureau / Office originating request

3. Name(s) and telephone number (s) of person (s) who can best i

answer questions regarding request i

U.S Nuclear Regulatory Comission Pat Woollev 492-8137 2.6-digit Agency / Bureau number (first part of 11-digit Treasury 4.3-digit functional code (last part of 11-digit Treasury Account h

Account No.)

No.)

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_D_.P__

0_ _D 2_.2_ s

5. Tetis of informatnon Collection or Rulsmaking C is this a rulemaking submission under Section 3504th) of P.L. 96 511 ? (Check one)

Generic Letter re: Odyn Code 3g no <n,ction 33o7,uomi,,;on3 20 Yes.NPRM. Expected date of publication:

6. A. Is any sntorma tion coIIection (reporting or recordkeeping) 3 0 Yes. final rule. Expected dato of publication:

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involved? (Check one)

Effective date:

^

D. At what phase of rulemaking is this submission made?

ig Yet and proposa! is attached for review 2 O Y.es but proposal is not attached - skip to Question D.

3 O No - skip to Question D.

1M Not applicable

~B. Ara the respondents primarily educational a gencies or 20 Major rule.at NPRM stage institutions oris the purpose related to Federaleducation 30 Maior Final rule for whicn no NORM was published

- programs ?

4 O Major Final rule, af ter publication of NPRM f

D Yes. H No 5O Nonmajor rule.at NPRM stage j

6 O Nonmajor rule, at Final stage COMPLETE SHADED PORTION IF INFORM ATION COLLECTION PROPOSAL IS ATTACHED

7. Currcnt (or former) OMB Number
8. Requested
12. Agency report form number (s)

Expiration Date

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N/A N/A

' Expirttion Date

13. Are respondents only Federal agencies?

12/31/82 a yes ' n No

9. ls proposed information collection listed in
14. Type of request (Check one) -

tha information collection buriget?

O Yes' H No 1 O preliminary plan

10. Wili this proposed information collection :

2 X new (notprenousty spproved orexpiredmore than 6 months ciuse the agency to exceed its information fago) i collaction budget allowar ce? (if yes, attach O Yes M No 30 revision amendment request from a gency head.)

4 Cl extension (adiustment to burden only)

11. Number of report forms submitted for approval 5 0 extension (no change).

6 O resnstatement (exputed within 6 months) 15.

16. Classification of Change in Burden (explain in supporting statement)
a. Approrimate size of umwse t,ts4 mores 22 No.of Responses No of Reporting Hours Cost to the Public esc orsempie 22

. a. In inventoryi 5

N/A N/A N/A

! c Estimitednumberof

b. As propose'd '
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22 109,824 5

i r'sSDondents of record teepers per rear 1

c. Dif ferenc,e (b-a) 22 109,824 5

Explanation of difference (indicate as many as apply)'.

~O d Reports annually by each

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4 respondent 6 tem 251 i-22 Adjustments.

4 %

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L' d. Correction-err"or4M'24 i

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'c.Totil annuai responses

6 tem tse n isol 22
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f. Change in use '
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4,992

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+109,824

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109,824 h Decrease

_s 8112310088 811211 Standard Form 83 (Rev. 3-81)

PDR ORG EUSOMB For Use Beginning 4/1/81 PDR

1 r 7. Abstract-N:sds cnd Us:s (50 words orI:ss)

NRC plans to request NRC licensees to per. form analysis on use of Odyn Codes and report results of such reviews.

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18. Rslatsd report form (s) (give OMB number (s). IRCN(s),
20. Catalog of Federal Domestic Assistance Program Number intzrnalagency teport form number (s} or symbol (s)) _

21.Small business or organization O Yes X@ No f

19.Typ3 of affected public (Check as manyas apply)

22. Type of activity of affected public-indicate 3-digit Standard

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1 O Individuals orhouseholds 10, check O Multiple or O All 2 O state orlocalgovernments

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3 O fErms

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4 lQ businesses orotherinstitutions (except farms) 4

_B_ _3_.

$3. Brist dsscription of affectec public (e.g.,"retailgrocery stores,"" State education agencies,""househo' Ids in 50 largest SMSAs")

NRC licensees

24. Purpose (Check as many as apply. lf more than one, indicate
26. Collection method (Check as many as apply) ^ T ' ~:

pr2 dominant by an asterisk) 1l% mailself-administered ij Y '.f p 1 O application for benefits 2 O 'other self-administered i MN g

'Wi 2 O program evaluation 30 telephoneinterview 3 0 gtneralpurpose statistics 40 personalinterview 4 (0 regulatory or compliance 50 recordkeeping requirement..,, %

' ears _f,5, m.,,,.

5 O program planning or management

, Required retention period:

y 6 0 research 6 0 other-describe:

25. Frse ;sney of Use
27. Collection agent (Check one) 1 % Nonrecurring 1 [% requesting Department / Agency Recurring (check as ma,9 as apply) 2 O other Federal Department / Agency :

2 O onoccasion 60 semiannually 3 O private contractor i

3 0 weekly 70 annually 4 O recordkeeping requirement.

4 O monthly 80 biennially 5 0 other-describe:

5 0 quarterly 90 other-describe:

88. Authority for agency forinformation collection or
30. Do you promise confidentiolity? ' ' /

rulamsking-indicate statute, regulation, judicial decrce.

(If yes, explain basis forpledge

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stc.

in supporting statement.)

O.Y.eS_ )CX No V ER Act of 1974 L

31. Will the proposed information collection create a new or AE Act of 1954 become part of an existing Privacy Act system of records?
29. R:spondent's obligation to repty (Check as many as apply)

(If yes attach FederalRegister notice orproposeddrait of 1 O voluntary notice.)

O YesXXXNoi 2 O rcouired to obtain or retain benefit

32. Cost to Federal Government of 80,000 3 %) mandatory-cite statute.not CFR (attach copy of information collection or rulemaking S statutory authority)

COMPLETE ITEMS 33 THRU 35 ONLY IF RULEM AKING SUBMISSION

33. Compliance costs to the public

' 34. Is there a' regulatory impact

35. ls there a statutory orjudicial analysis attached?

deadline affecting issuance?

0 Yes O No O Yes. Enter date:

O No CERTIFIC ATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the information collection or rulemaking submitted for r vi:w is n;cessary for the proper performance of the agency's functions, that the proposal represents the minimum public. burden and Federal cost Consist!nt with need, and is consistent with applicable OMB and agency policy directives. Signature and title of:

APPROVING *CUCY oFFICI AL FoA AGENCY DATE suBusTTING OFFICI AL DATE l1-[ d[

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ephe S~c i

D:niel J. Donoghue l

w SUPPORTING STATEMENT

- FOR-GENERIC LETTER 81-37 ODYN CODE REANALYSIS REQUIREMENTS A.l.

Justification.

(c)

Bases for Issuance j.

By letter dated November 4, 1980 (enclosed) the NRC informed a class of licensees of a requirement for use of a specific computer

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code in certain-licensing basis calculations. The code, known as ODYN, _was found by the Staff to provide better best estimate calculation predictions of reactor core response-to pressurization.-

J transients than the code currently in use, called REDY. A schedule -

1 for implementation using ODYN vice REDY in licensing basis calcula-1-

tions for certain future licensing actions (e.g., core reloads) and previously completed transient analyses that employed REDY was provided. The letter also informed licensees that a safety evalua-l tion documenting the basis for the Staff's acceptance of the ODYN code would be forthcoming.

By letter dated January 29,1981 (enclosed) the NRC provided the licensees with safety evaluations. describing its basis for acceptance of the ODYN code, information required for ODYN application, 'and a description of two options (called "A" and "B") for application that were based on known reactor protection system scram response times.-

OMB clearance had not originally been requested by NRC because the action was considered to be only a~ refinement of existing require-ments that simply substituted a better. analytical technique.

Based on subsequent communications between a number of affected licensees and the Staff, it became apparent:that'the less limiting option'(Option B) was applicable for a number of _ facilities.. As a result, it appears reasonable for NRC to take action to provide l

administrative relief from the' schedule provided in the November 4, 1980_ letter. This would result in a substantial reduction in the burden imposed on licensees to perform the required calculationsi j

in accordance with the published schedule.

Accordingly, the Staff proposes to issue the enclosed Generic Letter in order to provide relief to licensees and requests OMB 4

clearance to fulfill the requirements of the Paperwork Reduction Act. The Generic Letter would suspend the required analysis using I

ODYN in certain cases as discussed in the enclosure.

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. After submittal by licensees, NRC reviews the plant-specific an.tlyses in accordance with established procedures to assure that the facilities are operated in a manner that protects the public l

health and safety.

l (ii)

Alternative Data Sources Since a plant-specific detailed analysis is required in each case, there is no source for the required infomation other than licensees.

1 (iii)

Use of Similar Data Existing data is being used where possible to reduce the burden on licensees. That is, it has been detennined that existing calculations which used the REDY code are, under certain circum-stances, acceptable. The enclosed Generic Letter would relieve several licensees from performing redundant calculations.

2.

Description of Potential Respondent Universe The Generic Letter will be distributed to 14 licensees (22 units).

In some cases, a utility may hold more than one NRC license.

3.

Tabulation and Publication Plans There are no plans to publish the infomation received from licensees pursuant to these reporting and application requirements.

4.

Time Schedule for Data Collection and Publication This information is provided in the enclosure.

5.

Consultations Outside the Agency a.

The actions in NRC letters dated November 4,1980 and January 29, 1981 and the enclosed proposed Generic Letter have been discussed on an informal basis with the following licensees:

Tennessee Valley Authority

-- Carolina Power and Light Nebraska Public Power District Comonwealth Edison

-- Iowa Electric Power and Light Power Authority of the State of New York Georgia Power Company Northeast Nuclear Energy Company

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t Northern States Power Company Niagra Mohawk Power Corporation Jersey Central Power a'nd Light Philadelphia Electric Company Boston Edison Company

-Vermont Yankee Nuclear Power Corporation

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i b.

Item a. above lists all affected licensees.

c.

As a result of these discussions, at least two licensees have been identified that would be relieved from performing the required i

analyses as a result of issuance of the enclosed Generic Letter.

t d.

Information obtained from the above consultations was used in the development of the enclosed Generic Letter.

e.

Notice to licensees of the proposed action was given to licensees in the November 4,1980 letter.

i f.

No public comment has been received.

6.

Estimate of Compliance Burden t

Each plant-specific analysis using ODYN costs about 1.2 staff-years. Assuming each licensee were to provide 1 plant-specific analysis in accordance with the published schedule, total cost is about 26.4 staff-years.

Issuance of the enclosed Generic i

Letter would result in a known reduction in burden to licensees to at least~ 2.4 staff-years based on information available at this -

time. Using a base of 2,080 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per staff year. this totals 4,992' staff hours. Total burden for 22 affected licensees is l

109,824 staff hours.

7.

Estimate of' Cost to Federal Government It is estimated that the cost to the Federal Government would be approximately $80,000. This is salary for two GS-14 staff reviewers working full-time for six month-period of time inclusive of overhead l

charges necessary.

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Enclosure:

1.

ODYN Code Reanalysis Requirements (Generic Letter 81-37) 2.

NRC Letter dated November 4, 1980.

3.

NRC Letter dated January 29, 1980.

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ALL. BOILING WATER REACTOR LICENSEES (EXCEPT HUMBOLDT BAY AND DRESDEN.1)-

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SUBJECT:

k ODYN. CODE REANALYSIS REQUIREMENTS.($ENERIC

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By letter dated November 4,1980 we informed"you of our requirements' for use of the ODYN code to calculate pres.surization transients. We stated.that after..

January 1982 all operating BWP.s with General Electric analyses must have the' limiting transients recalculated with.the ODYN code, even if no reload submittal has been receive'd. 49:.r u,3. f. G.

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By letter dated. January 29,1981 'wa provided you a safety evaluation and ai..

J' supplemental safety evaluation describing our basis for acceptance of this-code, and information. required-foi ODYN app.l.ication, including a description of" c

two options for application..

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u For those plants which can be demonstrated 'to have scram times b' unded.,by.the:...... -

o option 'B scram time distribution, the option B calculations would be expected 'to '.'<-.l be less limiting than REDY.

Therefore, delay of ODYN analyses until the next refueling is a reasonable approach.

For such plants, the licensees are requested' h

to submit tp the NRC before January 1982 their conclusion that option B i.s '

.. ' ' applicable to their plant.

Those plants which cannot demonstrate scram times G

bounded by the option B scram time distribution sho'uld, by Jantaary 1982, submit L.

ODYN analyses in accorciance wi.th' option. A or should, propose and support othe.r appropriately conservative operating limitations.

This request for info.rmation.was ap roved.by OMB u..'.- :: cl earance. number-34-50.. :

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C 'ents'on rden and licat l'

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Sincerely,'

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funns dn' B.. isenWt, IftNetor Division of. Licensing.

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0,ffice of Nuclear Reactor Regulation cc:

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January 29, 1981 ALL HOLDERS OF CONSTRUCTION PERMITS AND OPERATING LICENSES FOR

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BOILING WATER REACTORS

SUBJECT:

ODYN CODE (GENERIC LETTER 81-08)

By letter dated November 4,1980, we informed you of our requirements for use of the ODYN code to calculate pressurization transients, and stated that a safety evaluation describing the basis for our acceptance of this code would be mailed to you in the near future.

Enclosed you will find a safety evaluation and a supplemental safety evalu-ation which jointly evaluate the ODYN code and provide information required for application of ODYN.

As you were informed in our letter of November 4,1980, transient analyses performed by General Electric supporting reload submittals received after February 1,1981, must contain appropriate ODYN analyses in place of those previously performed with REDY for the limiting transients. After January 1982, all operating BWRs with General Electric analyses must have the limiting transients recalculated with the ODYN code, even if no reload submittal has been received.

Also, this requirement for the calculation of the limiting transients with the ODYN code.is applicable to applicants for an operating license and is a prerequisite to obtaining an operating license.

incerely, iigisnr&u w/

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rector Darre'l Division o Licensing

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Enclosures:

1) Safety Evaluation
2) Supplemental ~ Safety :: valuation cc: w/o enclosure Service List

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TO ALL HOLDERS OF CONSTPUCTION PERMITS AND OPERATING LICENSES FOR B0ILING WATER REACTORS The use of the ODYN code to e 11culate pressurization transients has been reviewed extensively b1 the staff and discussed with the General Electric Company.

We have found that ODYN.provides acceptable best estimate calculation predictions of the core responses to pressurization transients.

A safety evaluation describing the basis for this conclusion will be mailed to you in the very near future.

This letter is for the purpose of advising you as early as possible of our require-ments for implementation of ODYN for licensing basis calculations performed by the General Electric Company. These requirements are ap'plicable to license applications and all proposed license amendments, including core reloads for which analyses are provided by General Electric.

Transient analyses performed by General Electric supporting reload submittals received prior to February 1,1981, will be reviewed taking into account the results of recent generic transient, analyses with ODYN., Appropriate CPR penalties will be applied on a case by case basis.

Transient analyses performed by General Electric supporting reload submittals received after February 1,1981, must contain l

appropriate ODYN analyses in place of those previously performed with REDY for the limiting transients.

Generally, these will include generator load rejection /ourbine trip without bypass (whichever is limiting), feedwater controller failure - maximum demand, and main steamline isolation valve closure (to satisfy ASME code pressure requi rements).

After January 1982, all operating BWRs with General Electric analyses mus-have the limiting transients recalculated with the ODYN code, even if no reload submittal has been received. The transients analyzed with ODYN most be justified to be the limiting transients.

General Electric has provided an ODYN analysis for the two most limiting events for BWR 3 and BNR 4 plant types and has conmitted to provide analyses for a BWR 2 plant type by November 1,1980. Any 6

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2-November 4, 1980

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penalties resulting from our review of the analyses for any plant type will be applied to all plants of that type until plant-specific calculations have been perfomed with ODYN for the two most limiting transients.

Sincerely,

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arre G.(Ei'senhut, D rector Division of Licensing cc: -Service List O

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