ML20052F396

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Forwards Request for OMB Review & Supporting Statement Re Reporting,Recordkeeping & Application Requirements of 10CFR50,domestic Licensing of Production & Utilization Facilities
ML20052F396
Person / Time
Issue date: 04/05/1982
From: Donoghue D
NRC OFFICE OF ADMINISTRATION (ADM)
To: Strasser A
OFFICE OF MANAGEMENT & BUDGET
Shared Package
ML20052F397 List:
References
NUDOCS 8205120420
Download: ML20052F396 (9)


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Dear Mr. Strasser:

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g In accordance with Section 3507 of Public Law 96-511 and regulations of the Office of Management and Budget, I am enclosing for OMB review copies of Standard Form-83 and Supporting Statements covering reporting, recordkeeping and application requirements of 10 CFR 50 " Domestic Licensir.g of P oduction and Utilization Facilities."

10 CFR 50 regulations are promulgated by the Nuclear Regulatory Comission pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the Energy Reorganization Act of 1974, amended, to provide for the licensing and regulation of production and utilization facilities. They contain the reporting, recordkeeping and application requirements as they are generally applied in the NRC's licensing and regulatory process. Specific requirements 4

for each licensee are contained in documents called " Technical Specifications" that are issued for every facility licensed to operate.

(See 10 CFR 50.36.)

Guidance on acceptable means of compliance with both 10 CFR 50 and Technical Specifications is provided through publications called NRC " Regulatory Guides."

These " Guides" often cite standards and other requirements established by national standards bodies such as the American National Standards Institute (ANSI) and the American Society of Mechanical Engineers (ASME).

j A more specific and complete discussion of NRC's regulatory procedures is contained in NUREG-0642 (Revision 1) "A Review of NRC Regulatory Processes and Functions" (copy enclosed).

10 CFR 50 affects various types of facilities, including nuclear power plants, research reactors and test reactors, at various stages in the licensing process, including application, construction, operation, amendment, suspension, renewal and shutdown. Therefore, the number of respondents actually affected by each requirement varies, depending on the number of licensing requests initiated j

and/or completed and the number of regulatory reports required by operating events and/or conditions.

For estimating purposes, we have assumed the following annual average number of respondents:

Operating Power Licensees - 70 Operating Research/ Test Reactors - 75 DESIGNATED ORIGINAI, Construction Pemits - 75 Certified 37

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New Applications for Construction Pennits - 0 p-s Appl ica t ions-fee-Opera t ing--L icen ses---50

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Mr. Arnold Strasser In those instances when a reporting /recordkeeping requirement applies to both power reactor and research/ test reactor licensees, we have calculated a combined cumulative average burden of compliance.

For requirements that are event dependent, we have estimated frequency. When that frequency is less than one per year per licensee, we have cited burden as " Negligible."

Based on the above methodology, the infomation collection burden represented by this submittal is approximately 5.7 million hours. This figure reflects a modest reduction of 14,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> that will result from a rule change to 50.54(q). The amended rule will reduce the number of copies to be submitted for changes to emergency plans from 13 to 3 copies.

To facilitate your review of the submittal, we have grouped the pertinent sections of 10 CFR 50 into logical parts, each with a separate Supporting Statement. Unless contrary to the statements below, no infomation is provided in the Supporting Str.tements for each separate part for the following:

1.

Tabulation and Publication Plans Application information submitted to NRC is used to prepare NRC's Safety Evaluation Reports. Reportable information provided by licensees is systematically evaluated by NRC and made available in Public Document Rooms unless deemed proprietary.

2.

Time Table for Data Collection and Publication Not applicable unless specified.

3.

Consultations Outside the Agency All requirements of 10 CFR 50 have been (or are currently) the subject of rulemaking proceedings during which the Comission considered (or is considering) public comments.

4.

Sensitive Ouestions Not applicable unless specified.

Justifications for record retention periods and the number of copies required for various submittals are not included in the separate Supporting Stateraents.

Rather, generic justifications are provided below:

More Than Three Copies Required i

10 CFR 50 contains varying requirements for submission of multiple copies.

In some instances, requirements for copies are unstated and left to a later determination to be specified by the NRC (e.g., See 50.30 (c)(2)).

NRC is revising its regulations (10 CFR 50.4) to allow licensees the option to make submittals in microform. After the final rule is published, a copy wi.L1 ha suh-htad tn nMR fnr__ inclusion in_the 10 CFR 50 case _ file _,

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1 Record Retention Periods Specific retention periodd are in general not identified in 10 CFR 50.

In most instances record retention periods a're established by reference in i

plant-specific Technical Specifications which indicate that a constructor or licensee will or has established a Quality Assurance Program in accordance with NRC's Regulatory Guides,1.28 (Revision 2) " Quality i

Assurance Program Requirements (Design and Construction)" and Regulatory e

Guide 1.88 (Revision 2) " Collection Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records". These Regulatory Guides in turn reflect the standards adopted by ANSI and other standards-setting organizations.

l In some cases, however, record retention periods have been designated in i

10 CFR 50 as to-be-detemined by NRC case-by-case, as explained in our j

January 26,1982 letter to Mr. DeMuth. NRC is currently developing a NUREG publication that will list all recordkeeping requirements that NRC imposes on its licensees / applicants; and, in conjunction with this

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effort, will amend its regulations to ensure that recordkeeping require-ments contain specific retention periods.

l Additional Requirements 3

This submittal incorpora1Ies$ two proposed.infomation collection requirements i

under 10 CFR 50 that have,been approved by 02 since our original August 5, 1981 submittal.,_.These requirements are itemized below; 50.54(q) was amended to reduce the number of copies required when reporting changes to emergency plans and to establish a procedure for controlled copies of the changes.

(See Part 7 for additional information.)

j 50.54(w)(5) requires licensees to report April 1 of each year to NRC the l

present level of insurance 'or financial protection they maintain and the sources of such insurance,or protection.

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We believe that this submittal.for 10 CFR 50 reflects a realistic assessment of paperwork burden; however, as part of NRC's overall effort to reduce regulatory and papemork burden we can anticipate further improvements. Please reference the enclosed letter from the Executive Director for Operations, William 01rcks, to the Administrator for Informatioa and Regulatory Affairs, j

Christopher DeMuth, dated January 26, 1982, for greater detail regarding NRC's plans for improvement.

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Mr. Arnold Strasser WR 5'@

In submitting this request for clearance of 10 CFR 50, we realize that its importance and complexity are such that our staff must work closely with yours to assure its timely and proper review. Mr. Thomas Dorian of our Executive Legal Director's Office (492-8690) is available to provide any legal clarifica-tion and R. Stephen Scott (492-8585) of our Reports Clearance Staff is available to arrange for the participation of any NRC staff that your staff may feel are needed at any meetings.

Sincerely.

Original signed by

  • Patricia G.Norrg]

Daniel J. Donoghue, Director Office of Administration

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SUP94ARY OF SUPPCRTING STATEMENTS 10 CFR 50 PART TITLE / SUBJECT BURDEN FEDER L GO RNMENT 1

Applications 50.30 6,400 50.33 700 50.33a 1,500 50.34 1,266,000 50.34a 10,000 50.34d 6,000 50.34f 208,000 50.36 See Part 2 50.48, Appendix R See Part 4 50.59c 225,000 50.80 0

50.82 0

50.90 Under 50.59c Appendix A See Part 3 Appendix C 0

Appendix E 8,000 Appendix K 0

1,731,600

$10,000,000 2

Technical Specifications 50.36, 50.36a 375,500 1,866,400 375,500

$ 1,866,400 3

Quality Assurance 50.55a, Appendix A & B 3,315,000 160,000 3,315,000 160,000 4

Maintenance of Records, Making of Reports 50.71 a, c, d Included in Parts 2 and 3 5

Fire Protection 50.48, Appendix R 10,080 14,000 10,080 14,000 6

Physical Security & Safeguards 50.54p 11,400 744,800 11,400 744,800 7

Emergency Preparedness 50.54 q, r, s, t, u 212,250 562,000 212,250 562,000 i

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April 5,1982 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 and regulations of the Office of Management and Budget, I am enclosing for 0MB review copies of-Standard Form-83 and Supporting Statements covering reporting, recordkeeping and application requirements of 10 CFR 50 " Domestic Licensing of Production and Utilization Facilities."

10 CFR 50 regulations are promulgated by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the Energy Reorganization Act of 1974, amended, to provide for the licensing and regulation of production _and utilization facilities.

They contain the reporting, recordkeeping and application requirements as they are generally applied in the NRC's licensing and regulatory process.

Specific requirements for each licensee are contained in documents called " Technical Specifications" that are issued for every facility licensed to operate:

(See 10 CFR 50.36.)

Guidance on acceptable means of compliance with both 10 CFR 50 and Technical Specifications is provided through publications called NRC " Regulatory Guides."

These " Guides" often cite standards and other requirements established by national standards bodies such as the American National Standards Institute (ANSI) and the American Society of Mechanical Engineers (ASME).

A more specific and complete discussion of NRC's regulatory procedures is contained in NUREG-0642 (Revision 1) "A Review of NRC Regulatory Processes and Functions"(copyenclosed).

10 CFR 50 affects various types of facilities, including nuclear power plants, research reactors and test reactors, at various staaes in the licensing process, including application, construction, operation, amendment, suspension, renewal and shutdown. Therefore, the number of respondents actually affected by each requirement varies, depending on the number of licensing requests initiated and/or completed and the number of regulatory reports required by operating events.and/or conditions.

For estimating purposes, we have assumed the following annual average number of respondents:

Operating Power Licensees - 70 Operating Research/ Test Reactors - 75 Construction permits - 75 New Applications for Construction Permits - 0 Applications for Operating Licenses - 50

- Applications for Amendments - 100

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Mr. Arnold Strasser April 5, 1982 i

h In those instances when a reporting /recordkeeping requirement applies to both power reactor and research/ test reactor licensees, we have calculated a combined cumulative average burden of compliance.

For requirements that are i

event dependent, we have estimated frequency. When,that frequency is less than one per year per licensee, we have cited burden as " Negligible."

Based on the above methodology, the information collection burden represented by this submittal is approximately 5.7 million hours. This figure reflects a modest reduction of 14,500 hcurs that will result from a rule change to 50.54(q).

The amended rule will reduce the number of copies to be submitted for changes to emergency plans from 13 to 3 copies.

To facilitate your review of *he submittal, we have grouped the pertinent l

sections of 10 CFR 50 into logical parts, each with a separate Supporting Statement.

Unless contrary to the statements below, no information is provided in the Supporting Statements for each separate part for the following:

1 Tabulation and Publication Plans Application information submitted to NRC is used to prepare NRC's Safety Evaluation Reports.

Reportable information provided by licensees is systematically evaluated by NRC and made available in Public Document Rooms unless deemed proprietary.

2.

Time Table for Data Collection and Publication Not applicable unless specified.

3.

Consultations Outside the Aaency All requirements of 10 CFR 50 have been (or are currently) the subject of rulemaking proceedings during which the Commission considered (or is considering) public comments.

4.

Sensitive Questions Not applicable unless specified.

. Justifications for record retention periods and the number of copies required for various submittals are not included in the separate Supporting Statements.

Rather, generic justifications are provided below:

More Than Three Copies Required 10 CFR 50 contains varying requirements for submission of multiple copies.

In some instances, requirements for copies are unstated and left to a later determination to be specified by the NRC (e.g., See 50.30 (c)(2)).

NPC is revising its regulations (10 CFR 50.4) to allow licensees the option to make submittals in microform. After the final rule is published, a copy will be submitted to OMB for inclusion in the 10 CFR 50 case file.

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I Mr. Arnold Strasser April 5, 1982 Record Retention Periods Specific retention periods are in general not identified in 10 CFR 50.

In most instances record retention periods are established by reference in plant-specific Technical Specifications which indicate that a constructor or licensee will or has established a Quality Assurance Program in accordance with NRC's Regulatory Guides 1.28 (Revision 2) " Quality Assurance Program Requirements (Design and Construction)" and Regulatory Guide 1.88 (Revision 2) " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records". These Regulatory Guides in turn reflect the standards adopted by ANSI and other standards-setting organizations.

In some cases, however, record retention periods have been designated in 10 CFR 50 as to-be-determined by NRC case-by-case, as explained in our

~

January 26, 1982 letter to Mr. DeMuth. NRC is currently developing a NUREG publication that will list all recordkeeping requirements that NRC imposes on its licensees / applicants; and, in conjunction with this effort, will amend its regulations to ensure that recordkeeping require-ments contain specific retention periods.

Additional Requirements This submittal incorporates two proposed information collection requirements under 10 CFR 50 that have been approved by OMB since our original August 5, 1981 submittal. These requirements are itemized below; 50.54(q) was amended to reduce the number of copies required when reporting changes to emergency plans and to establish a procedure for controlled copies of the changes. - (See Part 7 for additional information.)

50.54(w)(5) requires licensees to report April 1 of each year to NRC the present level of insurance or financial protection they naintain and the sources of such insurance or protection.

We believe that this submittal for 10 CFR 50 reflects a realistic assessment of paperwork burden; h.owever, as part of NRC's overall effort to reduce regulatory and paperwork burden we can anticipate further improvements.

Please reference the enclosed letter from the Executive Director for Operations, William Dircks, to the Administrator for Information and Regulatory Affairs, Christopher Defiuth, dated January 26, 1982, for greater detail regarding NRC's plans for improvement.

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Mr. Arnold Strasser April 5, 1982 In submitting this request for clearance of 10 CFR 50, we realize that its importance and complexity are such that our staff must work closely with yours to assure its timely and proper review. Mr. Thomas Dorian of our Executive Legal Director's Office (492-8690) is available to provide any legal clarifica-tion and R. Stephen Scott (492-8585) of our Reports Clearance Staff is available to arrange for the participation of any NRC staff that your staff may feel are needed at any meetings.

Sincerely, J+

.D

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i M aniel J. Donogh e, Director

/

Office of Administration a

Enclosures:

As stated 1

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