ML20052F399
| ML20052F399 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/1982 |
| From: | Donoghue D, Scott R NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| Shared Package | |
| ML20052F397 | List: |
| References | |
| OMB-3150-0011, OMB-3150-11, NUDOCS 8205120422 | |
| Download: ML20052F399 (81) | |
Text
.n REEUEST FOR OMB REVIEW (Und:r th) Paperwork R: duction Act and Ex:cutiv3 Ord:r 12291) 1 Important - Read instructions (SF-83 A) before completing this Office of Information and Regulatory Affairs form. Submit the requirednumber of copies of SF-83, together Office of Management and Budget with th3 material for which review is requested to:
Washington. D.C. 20503 i
- 1. Department / Agency and Bureau / Office originating request 3.Name(s) and telephone number (s) of person (s) who can best U.S. Nuclear Regulatory Commission
'E.*TNMNi1"Y88ft18817'U2-8585 2.6-digit Agency / Bureau number (firstpart of 11 digit Treasury
- 4. 3-dsgit functional code (last part of 11-digt! Treasury Account Account No.)
No.)
3 1
0 2
0 0 2 7 8
- 5. T6ts2 of information CoIIectson or Rulemaking C. ts this a rutomaking submission under Section 3504 th) of 10 CFR 50, Domestic Licensing of Production P.L.96-511 ? (Check one) and Utilization Facilities M No (Section 3507 submission) 2 C Yes. NPRM. Expected date of publication:
1
- 6. A. Is any ontormstron coIIection (reportong or recorckeepmg) 3 0 Yes. final rule. Expected date of pubtscation:
inv:Ived? (Check or;e)
Effective cate:
b Yes and proposal is attached for review D. At what phase of rulemaking is this submission made?
2 C Yss but Droposalis not attached - skip to question D.
3 C No - skip to ouestion D.
1 C Not applicable
~
B. Ars the tespondents pnmanly educationalagencies of 20 Maior rule. at NPRM stage' instituticM oris the purpose related to Federaleducation 3 0 Maior Fina\\ rule for which no NPRM was published program 3 ?
40 Major Final rule, after publication of NPRM r
O Yss 6 No 5 C Nonmajor rule, at NPRM stage 6 C Nonmaior rule. at Final stage COMPLETE SHADED PORTIONIFINFORMATION COLLECTION PROPOSALIS ATTACHED
- 7. Current (or former) OMB Number
- 8. Requested
- 12. Agency report form number (s) 3150-0011 Expiration Date NRC-366, Reg. Guide 1.70, Reg. Guide 1.16 Expirttion Date
- 13. Are respondents only Federal agencies?
4/30/82 4/30/85 O Vis UJ
- 9. ls proposed information collection listed in
- 14. Type of request (Check one).,
th3 information collection budget 7 byes O No 1 C preliminary plan
.,,.~
- 10. Will thss proposed information collection 2 O new (not previously approved or euporec more tnan 6 montns ccui.o the agency to exceed its information ago) coll:ction budget allowance? (if yes, attach O Yes 8 No 3 b revision cm:ndment request from agency hea,d.)
- - ~
a C exten'sion (ediustment to burden oisly)
- 11. Numb;r of report forms submitted for approval 5 C extension (no change) 3 (three)
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e C reinstatement (ero, red w,rnin a months; 15.
- 16. Classification of Change in Burden (explain in supporting statement)
. too,. imu.,ir.
un.a,o r,r um,i N/A No.of Resconses No.of Reporting Hour:
cost to the Public a sirw.tmoi.
N/A
- a. in inventory
'l5,738,050 s 232,000,000 e c,,m:i.o no.o., or
- b. As proposed 5,723,500 s 255,200,000 n oonone.o,.
e co,et..o...o.,,..,
220
- c. Ditference (b-a) l 14,500 s 23,200,000 e a.oo.cnno.iiye,..en Explanation of diff erence (indicate as many as apply)
- e. ooaa.ni t,,.m m varies Adjustments "s"c n*'r'3E "*"
8,100 o Correction-error i
1 is
- c o"'c" a '"$"* *'e i 1
a 23,2m,0m t....
.....s.
varies
- f. Change in use i
li is Program changes
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g Est6 met.o totet hou,s C'f',b"'8" '"
- g. increase
+
+
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,7 '.8* * '5" 5,723.500
- h. Decrease
-- 14,500
-s l
8205120422 820405 Stancard Form 83 (Rev. 3-81)'
PDR ORG EUSOMB For Use Beginning s/1/81 PDR
2
=-
-a:-. : - +
- 17. Abstract-Needs and Uses (50 words crI:ss) jl0 CFR 50 c:ntains the reporting, recordkeeping and. application itcms associated with dom:stic ilic:;nsing of production and utilization facilities t
' 18. Rollted report form (s) (give OMB number (s). IRCN(s),
- 20. Catalog of Federal Domestic Assistance Program Number
- ,_. internal agency report form number (s) or symbol (s))
N/A
- 21. Small business or organization O Yes UNo
- 19. Type'of atiected public (Check as many as apply)
- 22. Type of activity of affected public-indicate 3-digit Standard
'I U D '* '
~ "*#
1 O Individuals or households 10, check' O Multiple or O All 2 O state orlocalgovernments 3 0 farms a$ businesses or otherinstitutions (except farms) 0 0 3 23.Bri f description of affected public (eg,"retailgrocery stores."" State education agencies,"" households in 50 largest SMSAs")
NRC applicants and licensees
) 24. Purpose (Check as many as apply. It rmre trun one. indicate
- 26. Collection method (Check as many as ap' ply) predominant by an asterisk) 18 mail self-administered
~
1 O tpolication for benefits 2 Mother self-administered 2 O program evaluation 3Mtelephone interview 3
3'O general purpose statistics 4Mpersonalinterview i
4M regulatory or compliance SMrecordkeeping requiremen$
3 S O program planning or management Required retention period:va ri edyears 6 0 research 6 0 other-describe:
- 25. Frequency of Use
- 27. Collection agent (Check one) tM Nonrecurring 1 Mrequesting Department / Agency Recurring (chec,k as many as apply) 2 O other Federal Department / Agency 2 Mon occasion 6 Msemiannually 3 O private contractor 3 0 weekly 7Mannually 4 0 recordkeeping requirement 4 Mmonthly 8Mbiennially 5 O other-describe:
5 0 quarterly 9 Mother-describe: daily
- 28. Authority for agency for information collection or
- 30. Do you promise confidentiality?
rulImaking-indicate statute, regulation judicialdecree.
(if yes, explain basis forpledge vy ste Atomic Energy Act of 1954 in supporting statement.)
O Yes CPNo Energy Reorganization Act of I974 31.will the proposed information collection create a new or become part of an existing Privacy Act system of records?
.29.Rsspondent's obingation to reoly (Check as manyas apply)
(If yes, attach ederalRegister notice or proposed draft of 1 O voluntary notice.)
Yes O No w
2 O recuired to obtain or retain benefit
- 32. Cost to Federal Government of 3 5 mandatory-cite statute.not CFR (attach copy of nformation collection or rulemaking S 14,048,150 statutory authority)
Atomic Energy Act of 1954 COMPLETEITEMS 33 THRU 35 ONLY OF RULEM AKING SUBMISSION 33, Compliance Costs to the pubilC i 34. Is there a regulatory impact
- 35. is there a statutory orJudicrat analysis attached?
deadline affecting issuance?
s O Yes O No O Yes. Enter date:
0 No CERTIFIC ATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify that the information collection or rutemaking submittee for revisw is necessary for the proper performance of the agencis functions.that the proposal represents the minimum pubhC burden and Federal cost etnsistsnt with need,and is consistent with appheable OMB and agency pokcy directives Sigvture and title of; APPRo"flNG PouCV OFFICIAL FCm AGENcv
- DATI SU8 MITT'NG C,FFIC6AL CATE hP81 1
oghue V 'th R.
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PART TITLE / SUBJECT BURDEN FEDER L 0 RNMENT 8
FSAR Update 50.71e 80,000 0
80,000 0
9 Oath of Affirmation 50.54f Q
205,000
. _ ~,..
10 Telephone Notification of Significant Events 50.72(a), (b) 280 140,000 280 5-140,000 11 Significant Design and Construction Deficiencies 50.55e 37,500 300,000 37,500 300,000 12 Deports / Records Changes, Tests, and Experiments 50.596 10,750 464,000 10,750 464,000 13 Fracture Toughness, Tests, Surveillance, and Reports Appendix G, H 7,000 70,400 7,000
/0,400 14 Containment Leak Test Appendix J 31,500 3,150 31,500 3,150 15 Periodic R&D Reports 50.35(b)
Q Q
16 Financial R'eports 50.71(b) 440 17,600 17 Proposed, Financial Qualifications, Damage Insurance, 50.54(w)(5) 0 0
TOTAL 5,723,500
$ 14,547,350
=---
3 PART 1 SUPPORTING STATEMENT FOR Application for Construction Permit or Operating License 10 CFR 50.30, 50.33, 50.33a, 50.34, 50;34a, 50.34c, 50.34d, 50.36, 50.59c, 50.80, 50.82, 50.90, and Appendices A, C, E, and K to 10 CFR 50 JUSTIFICATION The Nuclear Regulatory Commission (NRC) is authorized by Congress to have responsibility and authority for the licensing and regulation of nuclear power plants, research and test facilities, fuel reprocessing plants and other utilization and production facilities licensed pursuant to the Atomic Energy Act of 1954.
To meet its responsibilities, the NRC conducts a detailed review of all applications for licenses to construct and operate such facilities.
The purpose of the detailed review is to assure that the proposed facilities can be built and operated safely at the proposed locations, and that all structures, systems and components important to safety will e designed to withstand the effects of postulated accident conditions, without undue risk to the health and safety of the public.
Applicants are required by the Atomic Energy Act to provide such technical information and data that the NRC may determine necessary to promote the public health and safety.
Only in the case of nuclear power plants are 10 or more applications expected to be submitted in the next three year interval, therefore this Supporting Statement is directed only toward such facilities. provides a summary of 10 CFR 50 application requirements and their associated burden.
Before a company can build a nuclear power plant at a particular site, it must obtain a construction permit from the NRC.
Subsequently, the company must obtain an operating license from the NRC before it can operate the plant. The decision by NRC as to whether to approve a company's application for a construction permit or an operating license is based largely on the staff's detailed review of the information provided by the company as part of its application.
Information provided by the applicant as part of the application is crucial to the licensing process as it provides NRC with the information it needs to make a decision with regard to the proposed plant's impact on the public's health and safety.
Information required by the NRC to be included in each application for a construction permit or an operating license is addressed in the specific 10 CFR Part 50 sections for which this Supporting Statement is written., " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants", Regulatory Guide 1.70, Revision 3, indicates the information to be provided in the Safety Analysis Reports and represents a format for SARs that is acceptable to the NRC staff.
Conformance with the Standard Format, however, is not required.
Safety Analysis Reports with different formats will be acceptable to the staff if they provide an adequate
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I basis for the findings requisite to the issuance of a license or permit.
However, because it may be more difficult to locate needed information, the staff review time for such reports may be longer, and there is a greater likelihood that the staff may regard the report as incomplete.
Upon receipt of an application, the NRC staff will perform a preliminary review to determine if the SAR provides a reasonably complete presentation of the information that is needed to form a basis for the findings required before issuance of a permit or license in accordance with 10 CFR Section 2.101.
The Standard Format will be used.by the staff as a guideline to identify the type of information needed unless there is good reason for not doing so.
If the SAR does not provide a reasonably complete presentation of the necessary information, further review of the application will not be initiated until a reasonably <omplete presentation is provided.
The information provided in the SAR should be up to date with respect to the state of technology for nuclear power plants and should take into account recent changes in the NRC regula-tions and guides and in industry codes and standards, results of recent develop-ments in nuclear reactor safety, and experience in the construction and opera-tion of nuclear power plants.
The Standard Format should be used for both Preliminary Safety Analysis Reports and Final Safety Analysis Reports; however, any specific item that applies only to the FSAR will be indicated in the test by adding (FSAR) at the end of the guidance for that item.
An entire section that is applicable only to the FSAR will be indicated by including (FSAR) following the heading.
Applications must contain information in three major categories to permit a complete evaluation by the NRC. These categories are general information, safety information and environmental information which is submitted in two phases through a Preliminary Safety Analysis Report (PSAR) and a Final Safety Analysis' Report (FSAR).
The section of the regulation that addresses each category of information for construction permit and operating license applications and NRC's detailed need within each category of information is outlined below.
1.
Construction Permit:
Section 50.30a provides for the filing of an application for a construction permit.
a.
General information (Section 50.33, 50.33(f)(1)(i) and (ii), and Appendix C).
Here the applicant is identified and his financial l
qualifications are detailed.
l Section 50.33(f)(1)(i) and (ii) requires applicants to submit financial information that demonstrates reasonable assurances that required funds are available.
Section 50.33(f)(1) excludes electric utility applicants from the need to submit financial qualifications and financial reviews.
Financial information is necessary because the NRC must make a i
decision as to whether the applicant's financial resources are l
adequate to permit construction of the plant in a safe manner and to permit finplementation of safety-related programs described elsewhere
a.
5 in the application.
Appendix C outlines the information to be furnished by the applicant in the construction permit application to establish financial qualifications.
Information required for antitrust review must also be included in the construction permit application.
The need for such information is addressed in the Supporting Statement for Section 50.33a.
b.
Safety information (Sections 50.34a, 50.34a(a), 50.34a(b), Appendix B, Appendix E).
Safety information is provided by the applicant at the construction permit stage in the Preliminary Safety Analysis Report (PSAR).
Section 50.34a outlines the minimum information that is necessary in the PSAR to permit the NRC to perform a safety evaluation.
Included in the PSAR are the design criteria and preliminary design information for the proposed reactor and comprehensive data on the proposed site.
The PSAR also discusses situations and the safety features which will be provided to prevent accidents or, if they should occur, to mitigate their effects on both the public and the facility's employees.
The principal features of the staff's safety review of the information provided in the PSAR by the applicant can be summarized as follows:
(1) A review is made of the population density and use characteristics of the site environs, and the physical characteristics of the site, including seismology, meteorology, geology and hydrology.
This review is necessary to determine whether these characteristics have been evaluated adequately and have been given appropriate consideration in the plant design and whether site characteristics are in accordance with NRC siting criteria.
(2) A review is performed of the facility design, and of programs for f.abrication, construction and testing of plant structures systems, and components important to safety for the purpose of determining whether they are in accord with the NRC regulations and other NRC requirements.
(3) A review is performed of the applicant's preliminary calculations of the response of the facility to a broad spectrum of hypothetical accidents for the purpose of determining'whether site acceptability guidelines are satisfied.
(4) For the purpose of determining whether the applicant is technically qualified to operate the plant and whether he has established effective organizations and plans for continuing safe operation of the facility, a review is made of the applicant's plans for:
(i) plant operations inclading otyarizational structure, (ii) technical qualifications of operating and technical support personnel,
L 6,
1 (iii) planning for emergency actions to be taken in the event of an accident that might affect the general public (Elements of preliminary planning that are required to be specified in the PSAR are set forth in 10 CFR 54 and Appendix E).
(iv) quality assurance (Appendix B requires that the applicant provide in the PSAR, a description of the quality assurance program to be applied to the design, fabrication, construc-tion, and testing of safety-related structures, systems, and components).
(5)' A review is made of the description of the preliminary design in systems to be provided by the applicant for control of radiological effluents from the plant.
This review is necessary to evaluate the general adequacy of the systems proposed to control the release of radioactive wastes from the facility within the limits specified by the NRC regulations.
Minimum information required by the NRC for this review is specified in Sections 50.34a(a) and 50.34a(b).
c.
Environmental information.
An Environmental Report, which provides a basis for the staff's evaluation of the environmental impact of the proposed plant, is specified as a requirement of the application for a construction permit in Section 50.30(f), but is justified as part of 10 CFR Part 51, " Licensing and Regulatory Policy and Procedures for Environmental Protection."
2.
Operating Licensa:
Sec' tion 50.30d provides for the filing of an application for an operating license.
The information provided in this application is essentially an update of the information categories (i.e., general, safety and environmental) previously subm,itted in the appl! cation for a construction permit.
a.
General information (Section 50.33 and Appendix C).
The applicant's financial qualifications must be detailed as they were for the construc-tion permit application, but now the details must demonstrate that sufficient funds are available to operate the plant in a safe manner and to implement all specified safety-related programs.
b.
Safety information (Sections 50.34(b), 50.34(c), 50.34(d), 50.34a(c),
Appendix B, Appendix E).
Safety information is provided by the applicant at the operating license stage in the Final Safety Analysis Report (FS.?R).
Section 50.34b outlines the minimum information that should be -provided in the FSAR to permit the NRC to perform a safety evaluation.
This is essentially an update of information provided in the PSAR and allows the same editorial format.
Among other things, the applicant must address the following items in the FSAR:
l I
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Pertinent details on the final design of the facility, including final containment design design of the nuclear core and waste handling system; the applicant's latest plans for operation of the facility, as well as substantive procedures for coping with emergencies (Appendix E provides elements of emergency planning to be considered in the FSAR); the quality assurance program (Appendix B requires that information pertaining to managerial and administrative controls necessary to assure safe operation of the plant be provided in the FSAR).
The final equipment design and procedures to be used by the applicant to control radiological effluents from the plant to permit the staff to determine whether such systems can control the release of radio-active wastes from the facility within the limits specified by NRC regulations.
Information required by the NRC in the FSAR in this area of review is specified in Section 50.34(a).
c.
Physical Security Plan (Section 50.34(c))
This plan describes the physical program that will be provided in accordance with the requirements of Section 50.34c to assure that the plant will be sufficiently protected against acts of sabotage that could cause releases of radioactive materials in amounts sufficient to represent a hazard to the public health and safety.
Safeguards Contingency Plan (Section 50.34(d))
The Safeguards Contingency Plan, as provided for in 10 CFR 50 will provide a structured, orderly, and timely response to safeguards contingencies and will be an important segment of NRC's contingency planning programs.
Licensee safeguards contingency plans will result in organizing licensees' safeguard resources in such a way that, in t,he unlikely event of a safeguards contingency, the responding participants will be identified, their several responsibilities specified, and their responses coordinated.
c.
Environmental information.
Justified in the Supporting Statement for 10 CFR Part 51.
The staff reviews, in detail, applications for construction permits and operating licenses to determine if the public health and safety will be fully protected.
These reviews are conducted in some 50 different technical disciplines organized within the Office of t
Nuclear Reactor Regulation.
If any portion of an application is considered to be inadequate, the staff requests the applicant to make appropriate modifications or to i
provide needed additional information.
In many cases, the staff l
review results in modifications to the facility's design or operating l
procedures.
The result of the staff review is provided in ? Safety l
Evaluation Report.
This report represents a summary of the re/few
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and evaluation of the application by the staff relative to the anticipated effect of the proposed facility on the ppublic health and safety.
Safety Evaluation Reports are prepared for both construction permit and operating license applications.
Tne public may obtain copies of Safety Evaluation Reports from the Public Document Room.
These application requirements will affect.10 licensees annually.
3.
Appendix K, Emergency Core Cooling System (ECCS) Evaluation ModelsSection II of Appendix K delineates the documentation requirements for the Emergency Core Cooling System (ECCS) evaluation models of Appendix K.
Section II-l.a. requires that a description of each evaluation model be furnished and that the description be sufficiently complete to permit technical review of the analytical approach including the equations used, their approximations in difference form, the assumptions.made, and the values of all parameters or the procedure for their selection.
Section II-1.b. requires that the documentation be sufficiently detailed and specific such that changes to the model which result in a calculated fuel clad temperature different by more than 20'F from the temperature calculated for a postulated Loss of Coolant Accident (LOCA) using the last previously accepted model shall be specified in amendments of the model description.
Section II-l.c. requires a complete listing of each computer program in the same form as used in the evaluation model.
Sect' ion II-2. requires that,for each computer program, convergence shall be demonstrated by modeling or coding studies and calculational time steps to provide sufficient data for a thorough review.
Section II-3. requires that appropriate sensitivity studies be made for each evaluation model, to evaluate the effect on the calculated results of variations in noding, phenomena assumed in the calculation to predominate, including pump,, operation and locking, and values of parameters over their applicable ranges.
Section II-4. requires that, to the extent practicable, predictions of the evaluation models, or portions thereof, be compared with applicable experimental information.
The reporting requirements delineated in Section II of Appendix K are needed to provide the NRC staff with sufficient information to judge the adequacy of the ECCS analysis and its compliance with the regulations.
The information provided under Section II-l.a. allows the NRC staff to assess the adequacy and validity of the overall technical approach used in a respondent's ECCS evaluation model.
Without this information, it would not be possible for the NRC staff to make such an assessment.
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9 The information provided under Section II-b.b-allows flexibility for small changes in an evaluation model while at t?
ame time providing stability to an ECCS model.
A change in an evaluation model that results in a calculated difference in the peak clad temperature of more than 20%F (approximately a 1% change in peak reactor power density) is considered by the NRC as being significant and, as such, should be documented in approved amendments to the model.
The information provided under Section II.l.c. allows the NRC staff to audit an evaluation model.
This documentation is usually provided as a magnetic computer tape and is controlled by NRC to protect proprietary information.
The information provided under Sections II-2, II-3, and II-4, allows the NRC staff to assess the mathematical stability of an evaluation model as well as its sensitivity to various physical phenomena and parameters expected to occur during a LOCA.
Comparison of model predictions with applicable experimental data permits the NRC staff to assess the technical validity of the calculational techniques and the accuracy of the predicted results.
Without the information required in Section II of Appendix K, the NRC staff would be unable to determine the adequacy of the calculational methods used to evaluate ECCS performance.
4.
50.33a, Information Requested by the Attorney General for Antitrust Review Under the Atomic Energy Act as well as other laws to protect trade and commerce against unlawful restraints and monopolies, the NRC is required to report promptly to the Attorney General any information it may have with respect to atomic energy which appears to violate or to tend toward violation of antitrust laws or to restrict competition in private enterprise.
Further, upon f.equest of the Attorney General, the NRC must furnish or cause to be furnished such information as the Attorney General determines to be appropriate for his advice on antitrust aspects of license applica-tions for a utilization or production facility under section 103 of the Atomic Energy Act, as amended.
The Attorney General's request is the basis for the NRC's antitrust reporting requirements.
5.
50.34(f) TMI Reauirements Requires that applications for operating licenses contain the Three Mile Island related requirements relative to the way the requirements will be implemented or satisfied prior to issuance of an operating license. These j
requirements include operational safety features, siting and design, and emergency preparedness and are intended to provide substantial, additional protection in the operation of nuclear facilities based on experience from the accident at Three Mile Island and the various studies and investigations of the accident.
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10 I
These are the same requirements approved by OMB July 9, 1981 as an amendment to our 10 CFR 50 clearance that expires September 30, 1981.
6.
50.36(a) Technical Specifications Requires each applicant for a license to operate a production or utiliza-tion facility to include in the application proposed technical speci-fications.
(Reference Part 2, " Technical Specifications" of the Supporting Statement for the burden associated with this requirement.) This section further requires that a summary statement of the bases or reasons for such specifications other than those covering administrative controls, be included in the application, but shall not become part of the technical specifications.
(The burden associated with this requirement is negligible.)
7.
50.59(c), Application for amendment of license
. Section 50.59(c) requires the holder of a license authorizing operation of a production or utilization facility who desires a change in technical specifications, or who desires a change in the facility or procedures described in the safety analysis report, or who desires to conduct tests or experiments which involve an unreviewed safety question to submit an application for amendment of the license.
Section 50.90 requires the application for amendment of license or construction permit to be filed with the Commission, fully describing the changes and following as far as applicable the form prescribed for original applications.
The requirement for the amendment of the license application is needed to enable the staff to evaluate any changes made at the facility or any new information concerning the facility that may potentially affect the safety of the facility and consequently the health and safety of the public.
8.
50.80(b), Application for transfer of licenses NRC regulation 3 in 10 CFR Part 50 establish requirements for the licensing of production and utilization facilities.
The regulations were issued pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the Energy Reorganization Act of 1974.
Section 50.80, " Transfer of licenses",
specifies in paragraph'50.80(b) that an application for a transfer of a license shall include as much of the information described in sections 50.33 and 50.34 with respect to the identity, and technical and financial qualifica-tions of the proposed transferee as would be required by those sections if the application were for an initial license.
Section 50.80(b) also specifies that the Commission may require additional information, such as data with respect to proposed safeguards against hazards from radioactive materials, and the transferee's qualifications to protect against such hazards.
The requirements described above are needed to assure the transferee's financial capability to run the facility safely and to assure the transferee's technical capability to properly and safely operate the facility in a way that protects the health and safety of the public.
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9.
50.82, Applications for termination of licenses Section 50.82, Application for termination of licenses, specifies that any licensee may apply to the Commission for authority to surrender a license voluntarily and to dismantle the facility and dispose of its component parts.
The Commission requires infermation, including information as to proposed procedures for the disposal of radioactive material, decontamination of the site, and other procedures, to provide reasonable assurance that the dismantling of the facility and disposal of the component parts will be performed such that common defense and security and public health and safety will not be compromised.
The information provided by the licensee will be used by the NRC staff to evaluate the safety and health aspects of the facility dismantling.
Upon satisfactory evaluation, the Commission may issue an order authorizing such dismantling and disposal, and the termination of the license upon completion of such procedures.
Description of Survey Design These application requirements affect approximately 220 licensees, permit holders, applicants for licenses and/or permits that will be required in accordance with the requirements of the subject sections to apply to the Commission for approval to engage in various activities as defined in the justification.
Consultations outside the agency Appendix L of 10 CFR Part 50 was developed in consultation with the Antitrust Division of the Department of Justice and has been amended twice at the request of the Department of Justice to refine the information needed for antitrust review.
Estimate respondent" burden See attachec chart.
Estimated cost to the Government The annual estimated cost to the Government for the review of an application or amendment is 4 man years.
Thus, FY82 reviews will require 100 man years or $10.0 million.
3 TOTAL BURDEN PER APPLICANT ANNUAL BURDEN NO. OF TOTAL OR LICENSEE PER APPLICANT RESPONDENTS ANNUAL CONSTRUCTION PERMIT APPLICATION (5 year process) 10 CFR 50 SECTION (MAN HOURS)
OR LICENSEE ANNUALLY BUR 0EN Filing of App 1fcation 50.30(a)-(d) 240 240 0
Contcnts - General Information 50.33 70 70 0
~
C,ontcnts - Jechnical Information 50.34(a) 320,000 64,000 0
Design Objectives SD.34a (a) & (b) 3,200 600 0
Quality Assurance Plan Appendix B 1,000 200 0
3 Financial Information Appendix C 70 70 0
Emergency Plans & Procedures Appendix E & 50.54 800 200 0
Evaluation Model Description Appendix K 200 40 0
Fira Protection Plan Appendix R & f,0.48 (See Part 4 of Supporting Statement, fewer than 10 affected)
Tcchnical Specifications 50.36 (See Part 2 of Supporting Statement)
Amendments (to any of above) 50.59(c) and 50.90 10,000 2,000 75 150,000 Subtotal Burden:
150,000 L
e
[
1 ll i
)
TOTAL BURDEN PER APPLICANT ANNUAL BURDEN NO. OF TOTAL' OR LICENSEE PER APPLICANT RESPONDENTS ANNUAL [
OPERATING LICENSE APPLICATION (3 year Process) 10 CFR 50 SECTION (NAN HOURS)
OR LICENSEE ANNUALLY BURDEN Oper; ting License State Filing of Application 50.30(a)-(d) 640 640 10 6,400 Cintcnts - General Information 50.33 70 70 10 700 Ccnt:nts - Technical Information 50.34(b)&(c) 380,000 126,600 10 1,266,000 i
Design Ojbectives 50.34a(c) 3,000 1,000 10 10,000 Quality Assurance Appendix B (See Part 3 of the Supporting Statement)
Financial Information Appendix C 0
0 0
0 Emergency Plans and Procedures Appendix E & 50.54 2,400 800 10 8,000 SSf;gurrds Contingency Plan 50.34(d) 600 600 10 6,000 l
Tcchnical Specifications 50.36 See Part 2 See Part 2 See Part 2 See Part 2 Evaluation Model Description Appendix K 0
0 10 0
Fira Protection 50.48 & Appendix R (See Part 4 of the Supporting Statement) i Amendment to License 50.59(c) & 50.90 5,000 2,500 30 75,000 Tr nsfer of License 50.80 0
0 10 0 -'
Appilcation to Dismantle Facility 50.82 0
0 0
Antitrust Review 50.33a 150 150 10 1,500 i
TMI R21ated Requirements 50.34(f) 62,400 20,800 10 208,000 t
Subtotal Burden:
1,581,600 Total Burden:
150,000 1,581,600 1,731,600 b
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14 i
PART 2 I
SUPPORTING STATEMENT FOR 10 CFR 50.36 and 50.36a
" Reporting and Recordkeeping Requirements Contained in Technical Specifications Contained in Licenses to Operate Nuclear Power Plants" l
Each licensee under 10 CFR Part 50 is required to perform reporting and recordkeeping requirements that NRC has approved as a part of the technical specifications submitted as a part of original applications for licenses.
(Sample attached).
The reporting /recordkeeping requirements are set forth as " administrative controls" in Appendix B of each set of technical specifica-tions issued by NRC for each facility.
They are designed to assure opera-tion of the facility in a safe manner.
The typical reporting and recordkeeping burdens with justifications are explained below.
NRC Regulatory Guide 1.16 (Revision 4) " Reporting of Operating Information--Appendix A Technical Specifications", provides the program being used by the NRC staff in order to standardize the reporting requirements section of Appendix A technical specifications of all operating licenses.
For licensees holding operating licenses without Appendix B environmental technical specifications, it may be necessary to include those reports identified in Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," and Regulatory Guide 4.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants," in the technical specifications under the unique-reporting requirements section of the technical specifications.
1.
Radioactive Effluent Report Section 50.36a of 10 CFR Part 50, specifies that to keep releases of radioactive materials to unrestricted areas as low as is reasonably achievable, each license authorizing operation of a nuclear power reactor must include technical specifications.
The NRC staff has developed
" Radiological Effluent Technical Specifications for PWRs" (NUREG-0472) and " Radiological Effluent Technical Specifications for BWR's" (NUREG-0473).
Routine radioactive effluent release reports covering the operation of the, unit during the previous 6 months of operation are to be submitted within 60 days af ter January 1 and July 1 of each year.
This report includes a summary of the quantities of radioactive liquid and gaseous effluents released to the environment and solid waste shipped from the site.
Special-reports are required when certain conditions exist or parameters are exceeded, e.g., when the radiation dose for any calendar quarter is equal to or greater than one half the actual limit, or the annual dose
15, i
exceeds twice the annual limit; when the liquid, gaseous or solid radwaste treatment systems or the building ventilation systems are inoperable for more than 31 days.
Special reports are required when environmental samples contain concentrations of radionuclides which are greater than a certain value identified in the technical specifications, or when unplanned releases occur which are greater than 1 Ci of liquid effluents, or 150 Ci of noble gases or 0.05 Ci of radiciodines in airborne effluents.
Prompt notification.with a written followup report is required when release rates exceed the instantaneous release rate limits of 10 CFR Part 20.106 for liquids or the dose rate limits for noble gases and radiciodines and particulates.
The information requested in these reports is needed:
(1) to assess the performance of radiological waste treatment system and effluent control systems; (2) to review the actual effluent releases against the expected releases from the plant's operations; (3) to evaluate the year-to year plant performance characteristics for effluent releases; (4) to respond to Congressional and public inquiries; (5) to provide information to the public, local and State governments and other Federal agencies; (6) to determine whether radioactive material released by nuclear power plants ety,have resulted in excessive radiation exposure to the public; (7) to determine whether licensee-initiated actions (a) will reduce the activity or effluents below the design objective levels, or (b) represent licensee's best effort to control effluents; (8) to identify any generic problems regarding radwaste systems and determine whether changes in construction permit and operating license application review are warranted;
~ _
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-- a 16 (9) to assess the impact of unplanned releases upon the health and safety of the public and the capability of the licensee to keep radioactive releases as low as reasonably achievable; and to determine, on a timely basis, if remedial regulatory actions to limit radioactive releases are necessary.
2.
Startup Report Section 50.36, " Technical Specifications," of 10 CFR 50, " Domestic Licensing of Production and Utilization Facilities," requires that ecch applicant for a license authorizing operation of a nuclear power plant include in its application proposed technical specifications.
These technical specifications as approved by the NRC, are incorporated into the facility license and are conditions of the license.
One of the reports normally required by the technical specifications is a startup report.
This report is submitted within (1) 90 days foll,owing completion i
of the startup test progrm, (2) 90 days following resumption or commencement of commercial power operation, or (3) 9 months follwing initial criticality, whichever is earliest.
The report addresses each test identified in the FSAR and should include a description of the test and the test conditions the measured values of the operating condition or characteristics obtained during the test program, and a comparison of these values with design predictions and specifications.
The startup report provides the staff with evidence that the plant systems are functioning as designed and can be expected to perform as planned, in the saf.e operation of the plant.
The report is necessary to identify design deficiencies, and to obtain data on plant operation to verify (or provide a basis to modify) technical specification limits for operation.
The data is also necessary for guidance in determining core reload requirements based on physics data obtained in testing reveal areas where additional performance verification testing is required or where further guidance is needed through additional regulatory guides or revision of existing guides.
There is no source for the required information other than the licensees.
3.
Sealed. Source Leakage Report Section 50.36, 10 CFR Part 50, requires licensees to adhere to technical specifications for the construction and operation of production and utilization facilities.
One specifically identified submission required of licensees by NRC under this authority is the Sealed Source Leakage Report, which includes technical specifications that establish requirements for testing the integrity of sealed sources transferred and for recording and reporting the test results.
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The reporting requirements on sealed sources licensed under 10 CFR Part 50 are included as a Technical Specification appended to the nuclear facility license.
For some nuclear facility licenses, the reporting requirements for failed sealed sources require that a special report be submitted within 90 days following a test in which the results indicate removable contamination levels greater than 0.005mC1. Other nuclear facility licenses require reporting of such test results only as part of an annual report.
Most reporting will be made annually, since any license that requires more frequent reporting can be amended, at the request of the licensee, to call for annual reports.
The information on any sealed source which exceeds the limitation on removable contamination should be reported annually for the licensed nuclear facility.
If such information was not received, the quality assurance record for sealed sources used in operating a nuclear facility would be incomplete and failures would not be reported..Thus, the manufacturing process for maintaining the inte'grity of sealed sources under various operating conditions could be deficient, unknowingly.
The information obtained from nuclear facility licensees in Sealed Source Leakage Reports reflects a special type of use for sealed sources and provides further assurance that the manufacturing p'ocess can produce sealed sources with high integrity.
4.
Monthly Operating Report Section 50.36, " Technical Specifications," of 10 CF.R Part 50, " Domestic Licensing of Production and Utilization Facilities," requires that each applicant for a license authorizing operation of a commercial nuclear power plant include in its application proposed technical specifications.
These technical specifications, as approved by the NRC, are incorporated into the facility license and are conditions of the license.
One of the reports normally required by technical specifications is a report of operating statistics and shutdown experience.
This report is submitted to the Commission by the licensees on a monthly basis.
Information is submitted in the " Monthly Operating Report" regarding (1) Average Daily Unit Power Level; (2) Operating Data; (3) Unit Shutdowns and Power Reductions; and (4) Spent Fuel Storage Capacity.
Using the data from licensee's monthly reports, plus information received from NRC regional offices, the NRC prepares a monthly report, entitled
" Operating Units Status Report." The report indicates, for each licensed unit, average daily power levels, operating status, unit shutdowns and power reductions, and summaries for all nuclear plant operations, including the. capability to off-load spent fuel.
This monthly report is used by the NRC, the Department of Fn.arcy and other Federal and State agencies.
This report is necessary for Federal
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18 and State agencies to keep abreast of current plant operating data, including plant availability, which is of particular use during periods of reduced power output from other energy sources.
Copies of the report are sent to the utilities to share with them the operating experience of other operators of nuclear power plants.
The report is also available to the public.
The information obtained from the utilities is not otherwise available to the Federal Government on a current basis. Without this information Federal and State agengies could not keep abreast of current plant operations.
There is no source for the required information other than licensees.
5.
Non-Routine Environmental Reports Environmental reviews of nuclear facilities often leave some questions only partially resolved.
Data collection efforts authorized under 10 CFR Section 50.36 are intended to resolve these questions.
Potentially significant environmental impacts (e.g., fish kills, excessive chemical releases, habitat disruption) need to be reported promptly so that appropriate action can be taken.
To accomplish this result, Non-routine Environmental Reports are generally required by the technical specifica-tions whenever an adverse effect may occur.
The non-routine report provides information which specifies and quantifies the data concerning the unusual events and provides the basis for recom-mending appropriate action.
It provides the data in a timely fashion so that changes in operating procedures or design modifications can be implemented as soon as possible.
The NRC staff performs a detailed analysis of each event which warrants such study.
The licensee report and the NRC analysis are placed in the public document room and sometimes a press release is prepared.
The staff analysis'tay recommend mitigative action.
There is no source for the required information other than licensees.
6.
Licensee Event Report The Technical Specifications in all licenses require that those operational events defined as reportable occurrences (also called Licensee Event Reports, LER1) be reported to the NRC.
Certain types of occurrences (see NUREG-0161 and Regulatory Guide 1.16) must be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; others within 30 days.
Prompt notification to NRC is necessary for two purposes.
One is to enable NRC to audit the actions of the licensee regarding resolution and corrective measures.
The second is to enable NRC to conduct immediate inspection or take other actions deemed necessary for the protection of the health and safety of the public in light of the safety significance of the event.
(Licensees use attached form NRC 366 for reporting purposes.)
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Information concerning reportable events occurring at all facilities which are licensed or otherwise regulated by the NRC is routinely dis-seminated by NRC to the nuclear industry, the Congressional oversight committees, the public, and other interested groups.
Section 208 of the Energy Reorganization Act of 1974 directs the NRC to submit to the Congress, each quarter, a report listing for that period any abnormal occurrences at or associa0ed with any facility which is licensed or otherwise regulated.
The Act defines an abnormal occurrence as an unscheduled incident or event which the Commission determines is significant from the standpoint of public health or safety.
Each report on an abnormal occurrence must contain:
date and place, nature and probable consequence, cause(s), and action taken to prevent recurrence.
The needs of the regulatory program are served directly by:
(1) assuring that abnormal occurrences are limited, (2) guaranteeing that a sufficient data bank exists on which to draw for generic resolution.of system or component malfunctions and (3) reporting to Congress as required by Section 208 of the Energy Reorganization Act of 1974.
There is wide distribution of this data among industry groups and the resulting actions on system modifications, operating procedures, and maintenance scheduling benefits the whole industry.
There is no source for the required information other than licensees.
7.
Annu'al Environmental Operating Report Section 50.36 of 10 CFR Part 50 requires inclusion of technical specifications, based on analyses in the Safety Evaluation Report, in each license authorizing operation of a production or utilization facility.
Section 51.52 explicitly authorizes conditioning of a license to protect environmental values (e.g., commercial and sport fisheries, rare and endangered species, recreational land and water use).
Nonradiological license conditions are generally incorporated in the license as Appendix B, Environmental Technical Specifications.
The technical specifications discussed in section 50.36 include requirements for an Annual Environmental Operating Report.
The purpose of nonradiological environmental monitoring is to confirm the environmental assessments presented in the Final Environmental Statement (FES) which described the impact of the proposed facility.
The nonradiological programs are also designed to detect unanticipated adverse impacts (i.e.,
adverse impacts which exceed the predictions of the FES or were not predicted) soon enough to take appropriate action.
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20 The operating procedures of a plant are sometimes conditioned to protect environmental values because of predictions in the FES that a potential for significant adverse impact exists. Monitoring programs are usually incorporated to assess the actual magnitude of predicted adverse impacts.
If the impacts are different from those anticipated, the licensee or staff can take action to change the technical specifications or plant design or operating procedures to more adequately account for the actual effects of facility operation.
If the information in the annual reports were not available there would be no information to assess the effectiveness of license conditions or to process requests for changes in those conditions.
Unanticipated environmental effects of operation would not be detected and appropriate action could not be taken if tne information in the Annual Environmental Operating Report were not available.
There is no source for the required information other tha'n licensees.
8.
Annual Radiological Environmental Operating Report Section 50.36 of 10 CFR Part 50 provides that reactor operating licenses will include technical specifications which NRC finds appropriate.
Each reactor license includes a technical specification requiring submission of annual radiological environmental operating reports.
The annual radiological environmental operating reports include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period, including a comparison with preoperational studies, operational controls (as appropriate),
and previous environmental surveillance reports and an assessment of.the observed impacts of the plant operation on the environment.
The reports also include the results of land use censuses required by the Technical Specifications.
If harmful effects or evidence of irreversible damage are detected by the monitoring, the report provides an analysis of the problem and a planned course of action to alleviate the problem.
The annual radiological environmental operating reports include summarized and tabulated results in the format of Regulatory Guide 4.8, December 1975, of all radiological environmental samples taken during the report period.
In the event that some results are not available for inclusion with the report, the report is submitted noting and explaining the reasons for the missing results.
The missing data are submitted as soon as possible in a supplementary report.
The report also includes the followng:
a summary description of the radiological environmental monitoring program; a map of all sampling locations keyed to a table giving distances and directions from one reactor; and the results of licensee participation in the Interlaboratory Comparison Program, required by the Technical Specifications.
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Reports range from around fifty pages to several hundred pages.
The reports provide a timely record of environmental ' radiation around the plant.
The reports are reviewed by the NRC staff to determine whether radioactive material released routinely by nuclear power plants may have resulted in excessive environmental radiation. Without the reports, the NRC staff could not provide adequate assurance.that the public is being protected from such environmental radiation.
9.
Annual Radiation Exposure Report Section 50.36, " Technical Specifications," of 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," requires that each applicant for a license authorizing operation of a nuclear power plant include in its application proposed technical specifications.
These-technical specifications, as approved by the NRC, are incorporated into the facility license and are conditions of the license.
The report on occupational personnel radiation exposure is submitted annually.
The tabulation of occupational exposure data may be submitted along with any report of facility changes, tests or experiments, required pursuant to 10 CFR 50.59(b), or as a separate submittal at the option of the licensee.
The information on occupational personnel radiation exposure submitted by the ' licensees is necessary to enable the NRC staff to analyze procedures and hardware radiation exposure problems associated with operation, outage, or maintenance.
The information provides a basis for evaluation of new plant designs or for modifications to present plant designs with respect to assuring that plants are designed for as low as reasonably achie'vable occupational radiation exposure.
Using data submitted by the licensees, the NRC also prepares an annual report entitled " Occupational Radiation Exposure at Commercial Nuclear Power Reactors" (NUREG-0713).
Included in the report is a compilation of in plant occupational exposure data by work and job function.
The informa-tion is required to establish trends among plants and within plants.
10.
Recordkeeping Requirements NRC Regulations.in 10 CFR Part 50, Sections 50.36 and 50.36a establish requirements for recording results of reviews of events reported to the Commission and requirements for recordkeeping as part of administra-tive controls.
The regulations were issued pursuant to the Atomic Energy Act.of 1954, as amended, and Title II of the Energy Reorganization Act of 1974.
~
22 Section 50.36(c)(1)(1)(A) requires recording of the results of reviews of events in nuclear reactors in which a safety limit has been exceeded.
Section 50.36(c)(1)(1)(B) requires recording of the results of the reviews of events in fuel reprocessing plants in which a safety limit has been exceeded.
Section 50.36(c)(1)(fi)(A) requires recording of the results of reviews of events in nuclear reactors in which an automatic safety system does not function as required.
Section 50.36(c)(1)(ii)(B) requires recording of the results of reviews of events in fuel reprocessing plants in which an automatic alarm or protective device does not function as required.
Section 50.36(c)(2) requires recording the results of reviews of events in nuclear reactors and fuel reprocessing plants in which a limiting condition for operation is not met.
Each of the above records of review is required to include the cause of the condition and the basis for corrective action taken to preclude reoccurrence.
Section 50.36(c)(5) requires administrative controls, including recordkeeping, in technical soecifications of a production or utilization. facility as necessary to assure operation of the facility in a safe manner.
Details of recordkeeping are delineated in Section 6.10 of Standard Technical Specification, NUREG-0123 for General Electric boiling water reactors, NUREG-0212 for Combustion Engineering pressurized water reactors, NUREG-0103 for Babcock and Wilcox pressurized water reactors and NUREG-0452 for Westinghouse pressurized water reactors.
The records required by Section 50.36(c)(5) involve such matters as:
Records and logs of facility operation covering time interval at a.
each power level, b.
Records and logs of principal maintenance activities, inspections, repair and replacement of prir'cipal items of equipment related to nuclear safety.
c.
All Reportable Occurrences submitted to the Commission.
d.
Records of surveillance activities, inspections and calibrations required by the Technical Specifications, e.
Records of changes made to Operating Procedures.
f.
Records of Radioactive shipments.
g.
Records of sealed source and fission detector leak tests and results.
h.
Records of annual physical inventory of all sealed source material of record.
i.
Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Saft.y Analysis Report.
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Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories, k.
Records of facility radiation and contamination surveys.
1.
Records of radiation exposure for all individuals entering radiation control areas.
m.
Records of gaseous and liquid radioactive material released to the environs.
n.
Records of transient of operational cycles for various facility components, o.
Records of reactor tests and experiments.
p.
Records of training and qualification for current nembers of the plant staff.
q.
Records of in-service inspections performed pursuant to the Technical Specifications.
r.
Records of Quality Assurance activities required by the QA Manual.
s.
Records of reviews performed or changes made to procedures or
' equipment or reviews of tests and experiments pursuant to 10 CFR Part 50, Section 50.59.
t.
Records of meetings of safety review groups.
These records are used by the licensees, the NRC and other Federal, State and local government agencies for the review of a variety of activities in the facility, many of which affect safety.
The records are also historical in nature and rovide data on which future activities can be based.
NRC p
Inspection and Enforcement personnel can spot check the records required by 50.36 to determine, for example, if (1) plant modifications were performed satisfactorily, (2) the plant was operated within the technical specifications, (3) personnel training has been kept current, (4) plant effluents have been kept within allowable values, etc.
Because of the multiple use nature of many of the records, NRC has estimated only the incremental burden.
There is no source for the required information other than licensees.
DESCRIPTION OF SURVEY PLAN There are 70 operating power licensees.
There are 75 operating /research/ test reactors licensed to operate.
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.m 24 ESTIMATE OF RESPONDENT REPORTING BURDENS 1.
Radioactive Effluent Reports:
These include reports on (a) Exceeding Design Objective Doses, (b)
Inoperable Radwaste Equipment, (c) Dose Contribution from Effluents, (d)
Unplanned Radioactive Release, (e) Exceeding 10 CFR Part 20 Release Limits and (f) Exceeding C1 Content in Liquid or Gaseous Tanks or Ci Release Rate for Offgas System (BWR), which individually affect fewer than 10 licensees annually, which result in a negligible burden and, a Semi-Annual Effluent R4 port which requires each of 145 licensees (290) 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> annually per report for a total burden of 40,600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />.
2.
Startup Report This reporting requirement affects less than 10 licensees annually with a resulting negligible burden.
3.
Sealed Source Report Since the licensee will be required to report only those sealed source test results which exceed the removable contamination limit, burden will be negligible, less than 10 licensees are affected.
4.
Monthly Operating Report Seventy (70) licensees each submit 12 reports annually, each report imposing a burden for preparation of 50 staff hours.
70 X 12 X SG staff hours total 42,000 staff hours.
5.
Non-routine Environmental Report An average of less than one report is received from each annually; thus the preparation burden (50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per report) upon each respondent is negligible.
6.
Licensee Event Report Seventy (70) licensees each submit an estimated 50. reports annually under these sections.
Each report requires approximately 25 staff-hours to prepare.
72 X 50 X 25 = A total annual burden for all licensees of 87,500 staff-hours.
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7.
Annual Environmental Operating Report and Annual Radiological Environmental Operating Report Licensees will submit reports for 42 sites in response to this requirement.
Each report causes a preparation burden of 1400 man-hours.
Man-hours per report will be reduced as water quality requirements are deleted from existing licenses.
42 (70 licensees) X 1400 staff-hours - A total annual burden for all licensees of 55,600 staff-hours.
8.
Annual Radiation Exposure Report The estimated burden upon each power reactor licensee for the preparation of one report is 40 staff-hours.
70 X 40 staff hours totals 2,800 staff-hours.
9.
Recordkeeping Requirements These recordkeeping requirements are subject as follows:
70 operating reactors 75 research and test reactors.
The' burden annually for an operating power reactor is estimated to be approximately 2,000 staff hours.
Seventy (70) operating plants X 2,000 staff-hours totals 140,000 staff-hours.
The burden annually for a research or test reactor is estimated to be approximately 80 staff hours.
Seventy-five (75) research or test reactors X 80 staff-hours totals 6,000.
Tatal for recordkeeping burden of all licensees:
146,000 staf f-hours TOTAL BURDEN Total burden for all reporting /recordkeeping requirements for technical specifications is 375,500 staff-hours.
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26 ESTIMATE OF COST TO FEDERAL GOVERNMENT 1.
Radioactive Effluent Reports Total Burden Report Reports /yr Staff-hour / report Staff-hour /yr
- 1. Exceeding Design 3
50 150 Objective Doses
- 2. Inoperable Radwaste-5 12 60 Equipment
- 3. Dose Contribution 2
50 100 from Effluents
- 4. Unplanned Radioactive 10 24 240 Release
- 5. Exceeding 10 CFR Part 5
20 100 20 Release Limits
- 6. Exceeding Ci Content in 3
40 120 Liquid or Gaseous Tanks or Ci Release Rate for Offgas System (BWR)
- 7. Semi-Annual Effluent 146 20 2,920 TOTAL 3,690 2.
Startup Report There are 35 reports per year at 40 staff-hours per report.
35 X 40 =
1,400 staff-hours per year.
3.
Sealed Source There are 35 reports per year at 40 staff-hours per report.
35 X 40 totals 1,400 staff-hours.
4.
Monthly Operating Report The cost to the Federal Government is approximately 5,400 staff-hours.
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27 1
5.
Non-routine Enviro mental Report Approximately 1 staff-month (160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />) of staff effort is expended in reviewing' reports and followup action; with the Office of Inspection and Enforcement and the licensees.
6.
Licensee Event Report The cost to the Government is associated with editing, coding, and tabulating LERs; and publishing results.
We estimate that these activities, including overhead costs, require approximately 1 staff year (2,080 staff hours) of NRC employee time plus approximately 5600,000 in Program Support funding for various contractor activities.
This estimate is not a measure of the practical utility of LERs because it does not include time or money used for the analysis of operating experience; and for-the regulation and inspection of operating reactors, which rely, in part, on information contained in LERs.
7.
Annual Environmental Operating Report One to two staffyears (4,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />) of staff time are projected for reviewing the annual reports.
This estimate includes effort reviewing the reports to provide technical support for specific license amendment actions for individual licensees.
8.
Annual Radiological Environmental Operating Report 20 person-hours / report X 42 reports /yr = a total of 840 staff-hours /yr.
9.
Annual Radiation Exposure Report The cost to the Federal Government is approximately 50 staff-hours.
10.
Recordkeeping
There is no additional cost to the Federal Government.
These estimates are based on professional staff experience and incorporate professional staff time to review submitted reports.
TOTAL COST TO FEDERAL GOVERNMENT:
Costs estimates are.520 per hour with 100% added for overhead.
19,180 staff-hours X $40 = $767,200 Staff cost:
$ 767,200 Technical Contract:
600,000
$1,367,200 l
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28 PART 3 SUPPORTING STATEMENT FOR Quality Assurance Records 10 CFR 50.55a, Criterion 1 of Appendix A, and Criterion XVII of Appendix B NRC regulations in Appendices A and B, Section 50.55a and a proposed revision to Section 50.54 to 10 CFR Part 50 establish requirements for the maintenance of records for those activities affecting quality.
Criterion 1 of Appendix A to 10 CFR Part 50 requires that appropriate records of the design, fabrication, erection, and testing of structures, systems, and components important to safety be maintained by or under the control of the nuclear unit license.
Criterion XVII of Appendix B to 10 CFR Part 50 requires that sufficient records be maintained to furnish evidence of activities affecting quality.
Criteria XVII specifies that at least the following records be included:
Operating logs and results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses are maintained for the time specified in technical specification, which may be up to the life of the facility, or as short as 5 years.
Section 50.55a incorporates by reference Section III and Section XI of the i
American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code.
These sections of the B&PV Code set forth the requirements to which nuclear power plant components are designed, constructed, tested arid inspected.
Inherent in these requirements are certain recordkeeping requirements.
A.
The following Ts a list of the records required on components.
- 1. -Code Data Report 2.
Design Specification Division 1 3.
Design Documents, Division 2 4.
Design Report, Division 2 5.
Overpressure Protection Report 6.
Construction Specification, Divisi;r. 2 7.
As Built Drawings 8.
Certified Material Test Reports 9.
Records of Post-Tensioning Sequence, Procedure and Loads 10.
Heat Treatment Records 11.
Qualification Test Reports 12.
Structural Integrity Test Reports 13.
Final Hydrostatic and Pneumatic Test Reports 14.
Final Nondestructive Examination Reports i
15.
Repair Records l-16.
Weld Procedures j
17.
Construction Report l
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B.
The following is a list of the records required from contractors or systems.
1.
Quality Assurance Program Manual 2.
Design Procurement and QA Procedures 3.
Installation and NDE Pro:edures 4.
Personnel Qualification Records 5.
Purchase Orders S.
Audit and Survey Reports 7.
Calibration Records 8.
Process Sheets, Travelers or Checklists 9.
Rebar Splice Test Reports These records are used by the licensees, National Board Inspectors, insurance companies and the NRC in the review of a variety of activities, many of which affect safety.
The records are historical in nature and provide data on which future activities can be based.
NRC Inspection and Enforcement personnel can spot check the records required by the ASME Code to determine, for example, if (1) the plant was constructed properly, (2) fabrication and inspection personnel were properly qualified, (3) the correct material was used in construction.
The incorporatior, of Section III Summer 1981 Addenda adds the following recordkeeping requirement:
N, N,A, and NPT Certificate Holders are responsible for the documentation of the review and approval of materials used by them as permitted by NCA-1140e.
Because individual States and insurance companies require the ASME B&PV Code be used in the design, construction, testing and inspection of nuclear power reactors there is no incremental burden imposed by the NRC on the seventy operating reactors or the seventy-five reactors under construction.
In Regulatory Guide"l.88 (Revision 2) Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records", (copy attached) NRC states the regalatory position that the requirements and guidelines for collection, storige, and maintenance of nuclear powar plant quality assurance records that are 1.'cluded in ANSI N45.2.9-1974 are acceptable to the NRC staff and provide an adeqcate basis for complying with the pertinent quality assurance require-ments of Appendix B to 10 CFR Part 50 with certain stipulated conditions.
The purpose of Regulatory Guide 1.88 (Revision 2) is to provide guidance to applicants and licensees regarding an implementation scnedule for utilizing this regula-tory guide.
It states, "Except in those cases in which the applicant proposes an acceptable alternative method for complying with the specified portions of the Commission's regulations, the methods described herein will be used in the evaluation of construction permit submittals after issuance of this guide."
9
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30 In addition, in Regulatory Guide 1.28 (Revision 2), " Quality Assurance Progran Requirements (Design and Construction)", (copy attached) NRC describes an acceptable method for complying with 10 CFR 50 with regard to an overall quality assurance program.
Except for certain stipulated modifications.
Regulatory Guide 1.28 (Revision 2) endorses as adequate compliance those requirements set forth in the American National Standards Institute's (ANSI)
N45.2-1977 " Nuclear Quality Assurance Standards".
Maintenance of records as specified above is necessary so that evidence can be furnished to show that activities affecting quality have been accomplished in accordance with NRC regulations.
Records required to be maintained for a specific activity are specified in the license application, license condition or permit or NRC-approved documents.
These records, which will be kept for possibly up to the life of the facility, are available for inspection by the NRC and are reviewed and examined to ascertain whether the activities affecting quality have been accomplished in accordance with NRC requirements.
Also, in case of the malfunction or failure of an item affecting safety, availability of plant records is necessary to aid in the determination of the cause of the failure.
In addition, record maintenance is necessary for other important specific functions such as providing baseline data for inservice inspection and providing data for trend analysis.
The type of records identified specifically in Criterion XVII of Appendix B to 10 CFR Part 50 are of particular importance to provide adequate evidence that licensee activities affecting quality have been accomplished in accordance with NRC regulatory requirements.
While most quality assurance records are routinely required in large utility construction projects by local, State and Federal agencies and insurance companies, the NRC has set forth certain exceptions that impose an incremental burden on nuclear power plant licensees.
Since there is no source for the required information other than the licensees, that incremantal burden is described below.
Description of the survey plan These recordkeeping requirements affect all operating nuclear power plants, approximately 70, and plants under construction, about 75 to a much lesser degree.
The recordkeeping requirement of the Section III Summer 1981 Addenda applies to holders of ASME N, NA and NPT Certificates, which supply and install nuclear components to licensees.
The requirement could be met by adding a statement to the Code Data Report required by ASME that the material had been reviewed and approved.
The signed data report is sent to the licensee along with the component.
This would affect 50 respondents annually.
._a._.
31 i
Estimation of respondent reporting burden Each of 75 plants under construction generates a licensee burden of 20,000 sta f f-hours.
75 X 20,000 staff-hours = 1,500,000 staff-hour /yr.
Each of 70 operating plants causes a licensee burden of 10,000 staff-hours /yr.
70 X 10,000 staff-hours = 700,000 staf f-hours /yr.
Each of 75 research/ test reactors causes a licensee burden of 240 staff-hours /yr.
75 X 240 staff-hours = 15,000 staf f-hours /yr.
The Section III Summer 1981 Addenda would have no impact on either operating plants or plants under construction.
It would apply to new constructior.
(5 minutes per Code Data Report, 5,000 reports per plant, averaged over a ten year construction period burden = 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> /yr, per plant) of which there is currently none.
It does apply to the 50 suppliers and installers as noted in the " Survey Plan".
50 K I,300 reports = 100 staff-hours /yr.
Total Burden The total annual burden for all licensees '.s 3,215,100 staff-hours.
Estimate of cost to the Federal Government Since the subject records are generated and maintained by the licensees the additional cost for the NRC audit of records is only a small part of the inspection program.,, NRC's current estimate is 4,000 staff-hours /yr or $160,000.
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32 l-PART 4 l
SUPPORTING STATEMENT FOR 50.71(a), 50.71(c) and 50.71(d) i Records Maintenance JUSTIFICATION 50.71(a) requires each' licensee and each holder of a construction permit 4
to maintain such records and make such reports, in connection with the licensed j
activity, as may be required by the conditions of the license or permit or by the rules, regulations, and orders of the Commission in effectuating the purposes r
of the Act, including section 105 of the Act.
Data to be maintained would be plant specific and maintained in technical specifications of license.
50.71(c) requires records which are required by the regulations-in this part, G
by license condition, or by technical specification, shall be maintained for the period specified by the appropriate regulation, license condition, or 3
technical specification.
If a retention period is not otherwise specified, such records shall be maintained until the Commission authorizes their disposition.
50.71(d) outlines the manner in which records may be maintained.
4 (1) Records which must be maintained pursuant to this part may be the original 3
or a reproduced copy or microform if such reproduced copy or microform is duly authenticated by authorized personnel and the microform is capable i
of producing a clear and legible copy after storage for the period j
specified by Commission regulations.
(2) If there is a Conflict between the Commission's regulations in this part, 1
j license condition, or technical specification, or other written Commission i
approval or authorization pertaining to the retention period for the same type of record, the retention period specified in the regulations in:this part for such records shall apply unless the Commission, pursuant to L
Section. 50.12 of this part, has granted a specific exemptf: a from the i
record retention requirements specified in the regulations in this part.
3
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. Description of Survey Plan There are 70 operating power licensees.
There are 75 operating research/ test reactor licensees.
)
Estimate of respondent reporting burden l
The burden related to this part is reflected under burdens reported for Parts 1, 2, and 3 of this Supporting Statement.
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Estimate of cost to government The burden related to this part is reflected under burden reported for Parts 1, 2, and 3 of this Supporting Statement.
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O 34 PART 5 SUPPORTING STATEMENT 10 CFR 50.48 AND APPENDIX R TO 10 CFR 50 Fire Protection JUSTIFICATION 10 CFR Part 50.48 amends the regulations.to require certain provisions for fire protection in operating nuclear power plants.
This action is being undertaken to upgrade fire protection at nuclear power plants licensed to operate prior to January 1, 1979, by requiring resolution of certain contested generic issues in fire protection safety evaluation reports.
The program on which this part is dependent is Appendix R - Fire Protection Program for.
Nuclear Power Facilities Operating prior to January 1, 1979, which makes requirements of certain items of fire protection guidance that have been used by the staff since the Browns Ferry fire on March 22, 1975, to evaluate the adequacy of fire protection programs at operating nuclear power plants.
Section 50.48(a) requires that each operating nuclear power plant have a fire protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50.
This fire protection plan must describe the overall fire protection program for the facility, identify the various positions within the licensee's organization that are responsible for the program, state the authorities that are delegated to each of these positions to implement those responsibilities, and outline the plans for fire protection, fire detection and suppression capability, and limitation of fire damage.
The plan must also describe specific features necessary to implement the program described above, such as administrative controls and personnel requirements for fire prevention and manual fire suppression activities, automatic and manually operated fire damage to structures, systems, or components important to safety so that the capability to safely shutdown khe plant is ensured.
Present licensed operating plants have already met the requirement for a plan, therefore, there is no immediate burden.
Section 50.48(c)(5) requires licensees to submit plans and schedules for meeting the provisions of paragraphs (c)(2), (c)(3) and (c)(4) within 30 days after the effective date of this section and Appendix R of 10 CFR 50.
Section 50.48(c)(5) requires licensee to submit design descriptions of modifications needed to satisfy Section III.G.3 of Appendix R to this part within 30 days after the effective date of this section and Appendix R of 10 CFR 50 (2/17/81).
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The NRC published comprehensive fire protection guidelines, Branch Technical Position BTP APCSB 9.5-1, and its Appendix A in 1976.
Licensees have compared their fire protection programs against these guidelines and have discussed their deviations from these guidelines with the NRC staff for the past four years during the NRC's fire protection reviews of operating reactors. A Safety Evaluation Report, and, in most cases, supplements to the Safety Evaluation Report, have been issued for each operating reactor.
These reports describe fire protection alternatives that have been proposed by the licensees and found acceptable by the staff as well as unresolved fire protection issues remaining between the staff and the licensee.
Appendix R provides the Commission's requirements for resolving those issues.
To assure that licensees intend to apply acceptable fire protection measures and that any proposed modifications do not degrade the level of safety previously found acceptable by NRC, it is necessary that N?.C obtain notice of the licensee's intentions so that any deficiences that may affect public health and safety are determined in a timely manner.
Appendix R - Fire Protection Program for Nuclear Power Facilities Operation, requires manual fire fighting capability at each plant.
It states that a fire brigade of at least five persons on each shift shall be maintained at each nuclear power plant unit.
In addition, the rule requires certain minimum le\\els of training for each brigade member, and training and drills for each brigade as a team.
The rule'also requires maintaining certain records of the training and drills provided for the brigades and brigade members.
The record keeping require-ments have already been agreed to by most licensees as part of the license amendments that resulted from the staff's fire protection review of each plant.
These records are required to enable the staff to evaluate the effectiveness of each training program and thus determine the expected effectiveness of each fire brigade to cope with any fire emergency which may The two speR fic reporting requirements are:
i occur.
A.
"Section III.I.3.d."
At three year intervals, drills shall be critiqued by qualified individuals independent of the licensee's staff.
A copy of the written report from such individuals shall be submitted to NRC for evaluation.
8.
"Section III.I.4" Individual records of training provided to each fire brigade member, including drill critiques, shall be maintained for at least three years to ensure that each member receives training in all parts of the training program.
These records of training shall be available for review.
Retaining or broadened training for fire fighting within buildings shall be scheduled for all those brigade members whose performe e records show deficiencies.
_3 36 Description of survey plan These requirements will affect the nuclear power plants that were licensed to operate prior to January 1, 1979 and that already have the Appendix R requirements identified in their safety evaluation reports.
50.48(a) does not apply to presently licensed plants since they have already committed to these reporting requirements in their approved fire protection programs.
50.48(a) will apply to new licensees on a case-by case basis as applications are approved by the NRC.
No special requirement for a format or form is being imposed with this rule.
Each licensee is free to develop the method and forms that best suit its individual operation.
Estimate of Respondent Burden No. of Respondents Staff Hours Annual Part affected per response Burden 50.48 Fewer than 10 applications are anticipated annually.
50.48(a)
The burden will be reported at such time that the number 50.48(c)(5) of respondents reaches 10 or more.
NRC licensees have already met these requirements.
Appendix R Section III.I.3.0 70 24 1,680 Section III.l.4 70 120 8,400 Total Annual Burden 10,080 Estimate of cost to Federal Government We estimate that the average review time of fire protection plant evaluation reports per plant is 5 staff-hours.
Seventy (70) plants are expected to comply with this requirement annually for' a total annual cost of $14,000 to the Government.
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PART 6 SUPPORTING STATEMENT FOR SECTION 50.54(p)
Physical Security and Safeguards Contingency Plans JUSTIFICATION Paragraph 50.34(c) of Title 10 of the Code of Federal Regulations provides for the submission of a physical security plan by each licensee who is authorized to operate a production or utilization facility.
These plans are for the purpose of protection against acts of industrial sabotage and protection of special nuclear material against theft by establishment and maintenance of a physical protection system.
Section 50.34(d) of 10 CFR Part 50 specifies that each application for a license to operate a production or utilization facility shall include a license safeguards contingency plan in accordance with Appendix C to 10 CFR Part 73.
Section 50.54(p) requires that each licensee prepare and maintain safeguards contingency plan Procedures in accordance with Appendix C of 10 CFR Part 73.
A licensee desiring to make a change which would decrease the effectiveness of a security plan prepared pursuant to Section 50.34(c), Part 73, or a licensee safeguards contingency plan (except for Implementing Procedures) prepared pursuant to Section 50.34(d) or Part 73, as applicable, must obtain prior approval from NRC by submitting an application f er an amendment to the license pursuant to Section 50.90.
A licensee desirir.g to make such a change shall submit an application for an amendment to his license pursuant to Section 50.90.
Section 50.54(p) also states that a licensee shall maintain records of changes to the plans, made without prior NRC approval, for a period of two years from the date of the change, and shall furnish to the NRC a report containing a description of each change within two months after the change is made.
Additionally, Section 50.54(p) requires that the licensee review the safeguards contir.gency plan annually and maintain records documenting the conduct and results of the annual review along with any recommendations derived from the review.
These records are to be available at the plant for inspection by NRC personnel for a period of two years.
Physical Security Plans include general performance requirements which recognize explicitly the need to provide protection from potential threats originating either externally or from within a licensed facility.
The NRC staff utilizes these licensee security plans as it conducts a continuous review to identify the changing kinds and degrees of threats and the vulnerabilities of reactors to such threats. This continuing reactor safeguards program provides a high level of assurance to the NRC and the public that malevolent acts against operating nuclear power plants will not result in undue risk to public health and safety.
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38 The Safeguards Contingency Plan will provide a structured, orderly, and timely response to safeguards contingencies and will be an important segment of NRC's contingency planning programs.
Licensee safeguards contingency plans will result in organizing licensees' safeguards resources in such a way that, in the unlikely event of a safeguards contingency, the responding participants will be identified, their several responsibilities specified, and their responses coordinated.
There are no valid alternatives to the licensee's reporting his physical security plans and updating.them by amendments or other documented changes.
Security data are sensitive and are not widely disseminated.
The applicant is the obvious party to supply the required data and no reasonable alternative reporting procedure exists.
Description of the survey plan All licensees are affected by the application, recordkeeping, 'and reporting requirements of Section 50.54(p).
Estimation of respondent reporting burden The application burden is reported in Part 1 of this submittal.
The maintenance burden is reflected in Attachment A.
Sensitive questions Not applicable.
Estimate of cost to the Federal Government The cost to the Federal Government is approximately 18,620 man-hours at a total cost of $744,800.
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Attachment "A" Annual Burden Estimated Number Per Licensee Total Burden Section Licensees Affected in Man-Hours All Licensees 50.54(p) 1.
Physical Security Plan A.
(Nuclear Power Plants) 70 80 5,600 Man-Hours B.
(Research Reactors) 75 40 3,000 Man-Hoursi 2.
Safeguards Contingency Plan 70 40~
2,800 Man-Hours !
Total Licensees Affected 215 Total First Year Burden for All Licensees 11,400 Man-Hours 6%
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40 PART 7 SUPPORTING STATEMENT FOR 10 CFR Part 50.54(g, r, s, t, v)
Emergency Planning JUSTIFICATION The Nuclear Regulatory Commission amended its regulations in order to require that all production and utilization facility licensees shall, as a condition of their license, submit emergency plans for NRC review and approval, and maintain the emergency plans up to date.
The Commission's interest in emergency planning is focused primarily on situations that may threaten.to cause radiological risks affecting the health and safety of workers or the public.
The Commission and the public have recognized the increasing importance of emergency planning.
Emergency plans should be directed toward mitigating the consequences of emergencies and should provide reasonable assurance that appropriate measures can and will be taken to protect the public health and safety in the event of an emergency.
Although it is not possible to develop a completely detailed plan encompassing every conceivable type of emergency situation, advance planning can create a high order of preparedness, including provisions of necessary equipment, supplies, and services, and ensure an orderly and timely decision-making process at times of stress.
Emergency plans are required as a condition of an application and are submitted as part of the FSAR or final license application to address the elements existing in 10 CFR Part 50, Appendix E.
Some of the items addressed in an emergency plan are:
(1) means for determining the magnitude of a release of radioactive material; (2) criteria.for determining the need for notification and participation of local and State agencies; (3) criteria for determining when protective meahbres should be considered within and outside the site boundary; (4) onsite decontamination facilities and supplies; and (5) arrange-ments for services of qualified medical personnel to handle radiation emergencies.
As noted above, the Commission must find that the emergency plan conforms to the requirements of 10 CFR Part 50, Appendix E, and the plan provides reasonable assurance that, in the event of an emergency, appropriate measures can and will, be taken to protect public health and safety.
Once this finding is made, the existing regulations are, for the most part, satisfied.
As the plant gets older, the licensee may make unilateral changes to the emergency plan, such as changing the decontamination facility into a storeroom or changing the criteria for determining the need for modification and participation of local and State agencies, without approval or notification to NRC.
However, Appendix E does provide for the maintenance and inspection of the implementing procedures of the emergency plan.
41 i
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A distinction should be made between an emergency plan and the implementation procedures (10 CFR 50, Appendix E) of the emergency plan.
Emergency plans must be submitted by the applicant and approved by the NRC before an operating license can be granted.
A set of implementing procedures is required in order to transfer the descriptions in the plan'into detailed step-by-step instruc-tions for plant personnel.
10 CFR Part 50, Appendix E, Section IV, Paragraph E requires the following to be maintained up to date:
(1) The organization for coping with emergencies, (2) the procedures for use in emergencies, and (3) the lists of persons with special qualifications in coping with emergency conditions.
The details of this information are usually in the licensees' implementation procedures and not in the emergency plan.
Thus, existing regulations require that the implementation procedures be maintained up to date.
Such procedures are, in fact, inspected by the Office of Inspection and Enforcement periodically.
However, there is no specific requirement in the Commission's regulations for licensees to maintain emergency plans up to date, and this lack of regulation could be detrimental to the public health and safety in the event of an emergency situation.
Therefore, the thrust of this amendment is not directed to the implementing procedures but to the emergency plan (as submitted in the FSAR).
After careful consideration of the above, the Commission has decided to require research reactor facility licensees to submit emergency l
plans for NRC review and approval when applying for a renewal of the operating license.
All other production and utilization facility licensees will be required to submit emergency plans for NRC review and approval within 120 days from the effective date of this amendment, if they have not done so previously.
Section 50.54(q) authorizes licensees to make changes to their emergency plans if such changes do not decrease the effectiveness of the. plans and the plans, as changed, continue to meet Appendix E of 10 CFR 50.
It also requires that 3 copies of these changes be sent to the appropriate NRC regional office and 10 copies be sent to the Director of Nuclear Reactor Regulation within 30 days after the change is made.
Proposed changes that decreased the effectiveness of the emergency plans were to be submitted to and approved by the Commission prior to implementation and required 13 copies of such proposed changes to be submitted.
A rulema king reduced the _ requirement to 3 copies of each change.
It also established the requirement for controlled copies with concomitant receipt that must be signed by the NRC staff designated to maintain emergency plans current.
Section 50.54(r) requires that each licensee who is authorized to possess and/or operate a research reactor facility under a license of the type specified in Section 50.21(c) and who had not obtained Commission approval of an emergency plan, as described in Section 50.34(b)6)(v), prior to obtaining an operating l
l license shall submit such a plan to the Director of Nuclear Reactor Regulation l
for approval as part of the application for a renewal of the operating license.
Each licensee who is authorized to possess and/or operate any other production l
or utilization facility who has not obtained Commission approval of an emergency plan, as described in Section 50.34(b)(6)(v),' prior to obtaining an operating l
license shall submit such a plan to the Director of Nuclear Reactor Regulation l
for approval within 120 days from the effective date of this amendment.
Section 50.54(s) requires each licensee who is authorized to possess and/or operate a nuclear power reactor to submit to NRC within 60 days of the effective
42 date of amendment the radiological emergency response plans of State and local government entities within a prime exposure pathway Emergency Planning Zone (EPZ), as well as the plans of State governments wholly or partially within an ingestion pathway EPZ.
Section 50.54(t) requires each licensee to provide for the development, revision, implementation, and maintenance of its emergency preparedness program, which shall be reviewed at least every 12 months.
Section 50.54(u) requires each licensee to submit to the NRC plans for coping with emergencies that meet standards in Section 50.47(b) and Appendix E.
The NRC staff will review new and updated emergency plans to determine whether or not licensees have devised effective plans for handling emergency situations.
The Office of Inspection and Enforcement will conduct periodic checks at licensees' facilities to assure that the plans are updated to reflect changing conditions.
~
There is no source for the required information other than licensees.
Description of survey plan These recordkeeping and reporting requirements will affect approximately 145 licensees.
Estimation of respondent repcrting burden The burden for preparing' and submitting the initial Emergency Plan is under 50.30.
The total respondent burden for maintenance of the emergency program is estimated to be 3,000 staff-hours for each of 70 power reactor licensees (210,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) and 30 staff-hours for each of 75 research/ test reactor licensees (2,250) or a total of 212,250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> annually.
This represents a reduction of 14,500.
Estimate of cost to the Federal Government NRC estimated one staff month per year for review of original emergency plans.
If an annual. salary of $25,000 is assumed for NRC reviews, a cost of about
$2,000 per y. ear will result.
NRC estimated 14,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for processing all amendments filed annually at a cost of $560,000.
(Approximately 3 per year per applicant.)
NRC staff time involved in signing receipt for controlled copies is negligible and would provide an incremental change in the previous estimate of $560,000.
Total burden to government for emergency preparedness plans is estimated at
$562,000.
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PART 8 SUPPORTING STATEMENT FOR 10 CFR 50, SECTION 50.71(e)
Periodic Update of the Final Safety Analysis Record (FSAR)
JUSTIFICATION The NRC, through adoption of section 50.71(e) amended its regulations to require each nuclear power reactor licensee to submit at least annually to the Commission revised Final Safety Analysis Report (FSAR) pages that reflect changes in information and analyses submitted to the Commission or prepared as a result of a Commission requirement.
The amendment is being.made to provide an updated reference document to be used in recurring safety analyses performed by the licensee, the Commission, and other interested parties.
The FSAR required to be updated by the rule is the original FSAR submitted as part of the application for the operating license.
It would not include the subsequent supplements and amendments to the FSAR or the license that may have been submitted either in response to NRC questions or on tne applicant's or licensee's own initiative following the original submittal.
These various supplements and amendments must be appropriately incorporated into the original FSAR to create a single, complete and integral document.
The initial revision to be filed will contain those pages from the originally submitted FSAR that are still applicable plus new replacement pages that appropriately incorporate the effects of supplements, amendments and other changes that have been made.
This will result in a single, complete documunt, being filed, that can then serve as the baseline for future changes.
This new rule is necessary because the volume of written information in the docket files of opeating power reactors is large and is increasing at a rapid r
rate.
By the time a power reactor has been in operation for a few years, much of the information in the FSAR has been modified, supplemented or superseded.
This comes about by the applicant's submittal of designs and analyses supporting requested license amendments or technical specification changes, replies to regulatory requests, incident reports, and annual reports describing design and procedural changes.
Consequently, it is difficult for anyone, including an NRC staff member, the licensee, or the public to be certain of the current status of a facility's design and supporting analyses.
To properly execute their respective responsibilities, the NRC staff and the licensee.must work with accurate information.
Problems stemming from a lack of accurate reference documents have existed for some time, but are becoming greater with the passage of time and the addition of new operating plants.
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44 In general, the older a facility is, the more difficult it is to identify the
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correct information.
The newly licensed facilities are not presently a problem, but they would become so in a few years without this new update procedure for licensee FSAR sets.
In addition, as new staff members and licensee employees are assigned to plants with extensive licensing history and are involved in analyses and decisions affecting facility operation, the volume of reference material involved, due to lack of a single organized referene, is staggering.
In such an event, the possibility of error, due to reference to outdated or incorect material, is increased and the resultant risk to the public is likewise affected.
An existing regulation, Paragraph 50.30(c)(2) of 10 CFR Part 50, recognized the need by requiring that the applicant for a construction permit update its application, which includes the Preliminary Safety Analysis Report, to eliminate superseded information and provide an index of the updated application when an Atomic Safety and Licensing Board is appointed prior to public hearing by the Atomic Safety and Licening Board.
If an operating license hearing is held, the application must be updated at that time.
After the operating license is issued, various sections of Part 50 (Section 50.59, for example) require that additional safety analyses be performed for individual facility changes that affect facility safety.
The present regulations, however, do not require that such changes be incorporated into the FSAR.
All changes to the technical specificiations are now treated as license amendments and it would be appropriate to have ar updated FSAR available at all times. Additionally, safety evaluations after operation of the facility has been initiated, required by proposed license amendments, technical specifica-tion changes and other reasons, warrant at least the same supporting documenta-tion as does the hearing process.
In addition to the uses of FSARs previously discussed, FSARs are currently being used for a variety of other reasons such as:
To evaluate pr6 hosed changes, tests or experiments made pursuant to a.
Section 50.59 and to determine the existence of unreviewed safety questions.
I b.
To supply adverse operating experience to current safety reviews.
c.
For operator training by licensees.
d.
For project manager training, orientation, and reassignment by the Commission.
A reference document by management and by safety review committees.
e:
f.
By IE inspectors to assist in their facility inspections.
g.
By licensing examiners to prepare exams for facility operators.
45 t
h.
In planning emergency responses.
1.
To evaluate operating data by NRC technical reviewers.
The NRC staff will utilize the updated information supplied by licensees in response to the reporting requirement of new section 50.71(e) as a primary reference source to be employed during the numerous safety studies undertaken by licensees, the Commission, and other interested parties.
There is no source for the required information other than licensees.
Description of the survey plan This reporting requirement would affect approximately 80 licensees.
Consultations outside the agency On November 8, 1976, the Nuclear Regulatory Commission published in the FEDERAL REGISTER (41 FR 49123) a notice of proposed rule making inviting written suggestions or comments on the proposed rule by December 23, 1976.
A notice of correction and extension of comment period was published in the FEDERAL REGISTER on December 27, 1976 (41 FR 56204) in which the comment period was extended to January 26, 1977.
The notices concerned proposed amendments to 10 CFR Part 50, " Licensing of Production and Utilization Facilities," to require each applicant for or holder of a power reactor license which would be or was issued after January 1, 1963 to periodically submit to the Commission revised pages for its Final Safety Analysis Report (FSAR) that indicate changes made in the facility or the procedures for its operation and any analyses affected by these changes.
In response to the comments received, the Commission modified the rule to (a) extend its applicability to all power reactors licensed to operate, (b) exclude applicants for operating licenses, (c) clarify the wording of the rule, (d) reduce its impact on power reactor licensees by relaxing some of the time requirements, and (e) require the initial revision to be a complete FSAR.
Estimation of respondent reporting burden Approximately 80 licensees will be affected by this reporting requirement.
The average burden per licensee for the updating is estimated to be 1,000 staff-hours.
Therefore, the annual burden for all licensees is 80,000 s ta f f-hours.
Estimate of cost to the Federal Government There is no additional cost to the Federal Government.
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46 PART 9 SUPPORTING STATEMENT FOR SECTION 50.54(f)
Collection of Information Under Oath or Affirmation JUSTIFICATION NRC regulations, 10 CFR Part 50, Section.50.54(f), adopted January 19, 1956 (21 FR 355), provide that the licensee upon request by the Commission, submit written statements under oath or affirmation to enable the Commission to determine whether a license should be modified, suspended, or revoked.
When the staf f has identified a potential health, safety, or environmental problem at a particular plant or series of plants, the staff may require the licensee or licensees to submit information in order to evaluate the particular situa-tion and to make a determination whether the situation is serious enough to require that the license be modified, suspended, or revoked.
Periodically there are equipment failures, construction problems, and issues discovered or raised by the technical staff during the safety review and brought to the attention of the NRC through licensee reporting procedures, the safety review process itself, and by NRC's inspection staff.
Since many of the flaws and malfunctions which are detected are novel, there is little data available which would enable the NRC to predict, with certainty, what the consequences might be.
In order to develop a reifable data base, accurately appraise the potential long-term significance of the anomaly, and determine what, if any, corrective measures may be necessary, NRC must obtain information from licensees.
Should the information provided by the licensees show that there is only minor safety significance associated with the problem /
situation, the facility license would not be modified, suspended, or revoked.
On the other hand, the Commission may issue an Order that does revoke or suspend the license'to operate a nuclear reactor.
Without the information provided in the licensee's written statements, timely and routine staff action could not be taken and unsafe conditions could continue to exist, thereby potentially endangering the public health and safety.
The Commission requests specific information either from one licensee, on a problem / situation believed to be unique to a particular facility, or from more than one licensee on a problem / situation believed to be generic in nature, i:e., that may affect more than one facility.
Before licensees are requested to provide such information, the staff will have identified the problem /
situation as one having potential safety or environmental significance.
Based on the information otained from licensees / applicants and the staff's evaluation of the problem, new regulatory requirements may be identified.
Depending upon the nature of the problem and its resolution, these new require-ments could be imposed by regulation, or they could be imposed on affected e
47 t
facilities individually by amendment to the technical speci'ications or conditions of their construction permit or operating license.
In addition, the NRC could issue a Regulatory Guide which would describe the nature of the problem and the method or methods found adequate by the regulatory staff for its resolution.
There is no source for the required information other than licensees.
Description of survey plan This reporting requirement can affect any of 220 licensees and construction permit holders.
There are 70 operating power reactor licensees, 15 research/
test reactor licensees, and 75 construction permit holders.
Estimation of respondent reporting burden It is estimated that fewer than 3 individual licensees will be requested to respond annually to the requirements of this section.
Since fewer than 10 annual respondents are involved, there is no reportable burden.
a Estimate of cost to the Federal Government The staf f estimates that prior to each request the staff will require 200 man hours assessing the potential problem.
Once this licensee response is received, the staff is estimated to require an additional 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> before the ultimate decision or license modification is made.
The total federal cost is $205,000.
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.x;w-48 PART 10 SUPPORTING STATEMENT FOR 10 CFR 50.72(a) and (b), 50.54(v)
Notification of Significant Events JUSTIFICATION Following the accident at Three Mile Island on March 28, 1979, the NRC staff acted to ensure the timely and accurate flow of information frem licensees of operating nuclear power plants following significant events.
Dedicated tele-phone lines were installed at all operating power plants to facilitate direct and rapid communications between licensees and the NRC Operations Centet (and Regional Offices).
A line is located in each control room with provisions made for extensions to be located at other specified locations at the facility.
When these phones are picked up to report significant events, they automatic-ally ring at the NRC Operations Center and can be held open as long as needed.
NRC's Office of Inspection and Enforcement (OIE) issued Bulletins and sent letters to each licensee asking that current procedures for notification of NRC following significant events be reviewed carefully.
The letters were intended to ensure that the licensees would notify NRC within one hour of the time that a reactor is determined to be in an uncontrolled or unexpected condition of operation.
After this notification, a continuous communication channel is established a'd maintained between the licensee and NRC.
n The NRC staff has evaluated licensees' responses to OIE's letters and Bulletins and has determined that the current reporting procedures are not providing the prompt notifications expected by the Commission.
The Bulletins issued to licensees by OIE did not impose reporting requirements and as a result, in several instances, iicensees have not notified NRC immediately.
The Commission has, therefore, determined that in order to take necessary action to protect the health and safety of the public, twelve types of significant events should be reported as soon as possible (within one hour) to NRC.
The Commission has promulgated this rule requiring the immediate reporting by telephone of specific significant events. These events, which are described in detail in the rule, include serious events that could result in an impact on the public health and safety such as those leading to initiation of the licensee's emergency plan or any section of the plan, the causing of the nuclear power plant to be in an uncontrolled condition, the exceeding of a safety limit, an act of sabotage, or an uncontrolled release of radioactivity.
With regard to initiation of the licensee's emergency plan, the Commission is presently in the process of promulgating a rule concerning requirements for emergency ple-- for nuclear power plants.
Meanwhile, the Commission has published guh ance on emergency preparedness at operating nuclear power plants in NUREG-0610.
This guidance has been sent to all affected licensees.
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Section 50.54(v) requires that:
In the case of every utilization facility licensed pursuant to Section 103 or
'104b of the Act, the licensee shall immediately notify the NRC Operations Center of any significant event set forth in Section 50.72.
Section 50.72(a) requires that:
Each licensee of a nuclear power reactor licensed under Section 50.21(b) or Section 50.22 shall notify the NRC Operations Center via the Emergency Notification System each. time there is an initiation of any of the following four Emergency Classes:
Notification of Unusual Event, Alert, Site Area Emergency and General Emergency.
(These Emergency Classes are addressed in NUREG-0654/ FEMA-REP-1, entitled " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", Rev. 1, November 1980.) All such notifications to the NRC shall be made immediately af ter notification to the appropriate State or local agencies and shall identify that the notice is being made pursuant to this paragraph.
If the Emerg7ncy Notification System is inoperative, the licensee shall make the required notifications via commercial telephone service, other dedicated telephone system, or any other method which will ensure a report being made promptly to the NRC Operations Center.
Section SC.54(b) requires that:
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Each lice'nsee of a nuclear power reactor licensed under Section 50.21(b) or Section 50.22 shall also notify the NRC Operations Center via the Emergency Notification System as soon as possible and in all cases within one hour of the occurrence of any of the following events if not reported under paragraph (a) above, and shall identify the event as being reported pursuant to this paragraph.
If the Emergency Notification System is inoperative, the licensee shall make the required notification via commercial telephone service, other dedicated telephone,, systems or any other method which will ensure a report being mace promptly to the NRC Operations Center.
The events to be reported are:
1.
Any event that results in the nuclear power plant not being in a controlled condition while operating or shut down.
2.
Any act of nature, event, or personnel act that explicitly threatens the safety of the nuclear power plant or site personnel in the performance of duties necessary for the safe operation of the nuclear plant or the security of special nuclear material, including strikes of cperating personnel, and instances of sabotage or attempted sabotage. When reporting events involving sabotage, attempted sabotage or events which threaten the security of special nuclear material, the licensee shall also comply with the requirements in 10 CFR Section 73.71.
3.
Any event for which plant Technical Specifications require initiation of'immediate shutdown of the nuclear power plant.
4.
Any ' instance of personnel error, equipment failure, or discovery of design or procedural inadequacies that alone could prevent the
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50 fulfillment of the safety function of those structures, systems, or components that are needed to (i) shutdown the reactor and maintain it in a safe shutdown condition, (ii) remove residual heat, or (iii) control the release of radioactive material.
(5) Any event resulting in manual or automatic actuation of Engineered Safety Features (ESF), including the Reactor Protection System (RPS) (Actuation of ESF, including the RPS~, which results from and is part of the planned sequence during surveillance testing or normal reactor shutdown, need not be reported).
6.
Any accidential, unplanned, or uncontrolled radioactive release that exceeds 25% of the applicable limits in the plant Technical Specifications for instantaneous releases offsite or that results in the evacuation of a building.
i 7.
Any onsite fatality or any injury involving radiatio'n occurring onsite that requires transport to an offsite medical facility for treatment.
(As used herein " injury involving radiation" is one in which an injured part of the body is contaminated, the injured person is wearing contaminated clothing at the time of transport, or the injury i. related to radiation exposure).
8.
Any serious personnel radioactive contamination requiring extensive onsite decontamination or outside assistance.
(Personnel contamina-tion that can be readily removed using routine decontamination procedures need not be reported).
With respect to the telephone notifications made pursuant to paragraphs (a) and (b) of this section, each licensee, in addition to making the required notification, shall, during the course of the event:
1.
Promptly report any further degradation in the level of safety of the plant or bther worsening plant conditions including those that require, or may require, initiation of any of the four Emergency Classes if such initiation has not been previously declared, or the change from one Emergency Class to another or a termination of the Emergency Class.
2.
Promptly report the results of ensuing evaluations or assessments of plant conditions, the effectiveness of response or protective measures taken, and information related to plant behavior that is not understood.
3.
Maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC.
The NRC staff will evaluate the information transmitted to the Commission in response to these reporting requirements and make the timely decisions required to provide adequate assurances regarding actual or potential threats to public safety.
There is no source for the required information other than licensees.
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Description of survey plan These reporting requirements will affect approximately 50 licensees currently operating 70 nuclear plants.
Estimation of respondent reporting burden It is estimated that 30 reports annually will be received from each of 70 operating plants in response to the reporting requirement of 50.72(a).
The burden for each phone call is estimated to be 2 minutes.
Therefore, the total annual burden for all licensees covered by this reporting requirement is estimated to be 70 staff-hours.
It is estimated that 5% of the incidents reported under 50.72(a) will require treatment under 50.72(b).
Each of these 50.72(b) reporting situations will result in an additional burden averaging an estimated 2 staff-hours.
Therefore, 105 annual 50.72(b) reporting occurrences will result in a burden of 210 staff-hours.
Thus, the annual burden total for both 50.72(a) and 50.72(b) is 280 staff-hours.
Estimate of cost to the Federal government The cost'to the Federal government will be one (1) man year; $140,000.
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PART 11 SUPPORTING STATEMENT FOR 10 CFR 50.55(e)
Reporting of Significant Design and Construction Deficiencies JUSTIFICATION
" Quality Assurance Criteria f or Nuclear Facilities" as an Appendix B to 10 CFR Part 50, " Licensing of Production and Utilization Facilities," requires an applicant for, or holder of a license to construct or operate, a nuclear power plant to establish a quality assurance program.
This program is to assure, among other things, that all conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance, are promptly identified and reported to appropriate levels of management.
The requirements of 10 CFR Section 50.55(e) were added to the regulations in 1972 to ensure that the more significant of these deficiencies be reported to the Commission. Without the reporting requirement of 10 CFR Section 50.55(e), the Commission would only be notified of deficiencies occurring during the design and construction of nuclear power plants through its Inspection staff or through reports submitted by holders of construction permits, either voluntarily or as requested by the Commission on a case-by-case basis.
Considering the number of deficiencies identified and evaluated by the construction permit holders during the design and construction of nuclear power plants, it is essential that the requirement exist to require reporting on only the more significant deficiencies.
The reports submitted under Section 50.55(e) are necessary to ensure that the staff is promptly informed of deficiencies identified in design and construction so that a timely inspection and evaluation of the deficiency can be made.
Timely evaluation is necessary to adequately protect public health and safety from the potential consequences of the deficiency at the plant reporting and from other similar plants, should the deficiency be generic.
Specific use.s made of the data reported under Section 50.55(e) include evaluation of impact of the deficiency on the quality of construction and of the adequacy of planned corrective action, identification of generic prnblems, inspection and ' enforcement personnel, and identification of problems in management or implementation of the quality assurance program.
There is no source for the required information other than licensees.
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Description of the survey plan This reporting requirement affects approximately 75 plants under construction.
Tabulation and publication plans l
There are no plans to publish the information received from licensees pursuant to this reporting requirement.
t Estimation of respondcnt reporting burden The preparation burden per plant is approximately 500 staff-hours.
75 x 500 staff-hours = A total annual burden for all licensees of 37,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />.
Estimate of cost to the Federal Government The burden will be 7,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> at a cost of $300,000.
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PART 12 SUPPORTING STATEMENT FOR 10 CFR 50.59(b)
Reports and Records for Changes, Tests and Experiments JUSTIFICATION Section 50.59 of NRC regulations allows a holder of a license authorizing operation of a production or utilization facility (i) to make changes in the facility as described in the Safety Analysis Report, (ii) to make changes in procedures as described in the Safety Analysis Report, and (iii) to conduct tests or experiments not described in the Safety Analysis Report, without prior Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety question.
Section 50.59(b) requires the licensee to maintain records of such changes and of tests and experiments which do not require prior Commission approval.
These records must include written safety evaluations which provide the bases for the determination that the change, test or experiment does not involve an unreviewed safety question.
These records are frequently used by NRC regional inspectors.
The records provide background information needed.by.the NRC inspector during his visit to a licensed facility.
He uses these records to confirm the appropriateness of changes, tests or experiments, or during evaluation of abnormal occurrences.
The records are also used by licensees to interrelate subsequent changes and to prepare reports concerning changes, tests or experiments as required by this Section of the ReguYation.
The records and reports assist the NRC staff in evaluating the potential effects of these changes in relation to the health and safety of the public.
The ultimate value is received in the form of assuring the health and safety of the public and is well worth the cost of collecting, storing, and reporting the data.
There is no source for the required information other than the licensees.
Description of the survey This recordkeeping requirement affects all 220 10 CFR 50 licensees.
Estimation of respondent reporting burden The burden per licensee is estimated by the staff to be 100 man-hours annually for power reactor licensees (70 X 100 = 7,000) and 50 man-hours annually for research/ test reactor licensees (75 X 50 = 3,750) for a total annual burden of 10,750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br />. -
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Estimate of cost to the Federal Government There is an additional burden to the Federal Government of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per ifcensee; 11,600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> total; at a cost of $464,000.
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PART 13 SUPPORTING STATEMENT FOR 10 CFR 50, APPENDIX G AND APPENDIX H, SECTION IV Fracture Toughness Testr, Surveillance and Reports JUSTIFICATION Appendix G to 10 CFR Part 50 specifies minimum fracture toughness requirements for the reactor coolant pressure boundary of water-cooled power reactors.
Section V specifies how radiation damage to the reactor beltline is to be accounted for in the fracture control plan for the reactor.
Paragraph V.C.
requires that certain extra steps be taken in the event that the normal fracture analysis requirements specified in Paragraph V.B. cannot ce satisfied.
Paragraph V.D. requires a thermal anneal of the reactor vessel beltline if the procedures of Paragraph V.C. do not indicate the existence of an adequate safety margin.
Paragraph V.E. requires that the proposed programs for satisfying the require-ments of Paragraphs V.C. and V.D. be reported to the Director of Nuclear Reactor Regulation for review and approval at least three years prior to the date when the predicted fracture toughness levels will no longer satisfy the requirements of Paragraph V.B.
The information in the report required by Paragraph V.E. will be used by the Operating Reactors. Division to perform a safety evaluation of the reactor vessel.
This evaluation will be the basis for approval to continue operation for a specified time and for approval of the ad;8tional procedures that will be required to continue operation beyond that time.
The three year lead time is needed to provide time to obtain supplemental fracture toughness data on archive material that has been subjected to accelerated irradiation, and to evaluate the fracture analyses th'at will be submitted which use that data.
Section III.B contains the materials test requirements for the Charpy V-notch tests and drop weight tests.
Paragraph III.B.S specifies that records are to be kept on (1) the test results, with traceability to the material in each component, (2) the qualification of test personnel, and (3) the calibration of test equipment.
The records maintained by licensees for the life of the facility in response to this requirement are available for inspection by the staff to determine compliance with Appendix G.
There is a continuing requirement that certain pieces of the data will be needed to support a licensee's fracture control plan or fracture analysis for some component in an operating plant.
The data will be used by the NRC staff in making its safety evaluation of the licensee's submittal.
Material properties of the actual material in the component are an essential input to such evaluations.
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The records that must be retained per Appendix G are of considerable value to the plant owner in the event of some sort of material deterioration problem or the discovery of a flaw that requires a fracture analysis. The frequency of occurrence of such situations for a given plant is difficult to estimate -
perhaps once every three years on the average.
The value to the plant owner i
lies in the ability to provide a sound basis for estimates of material toughness that are an essential part of the fracture analysis.-
The impact of not obtaining the information from records would be that the fracture analyses would have to be based.on conservative estimates derived from the published data base of typical material properties.
The impact of an overly-conservative analysis could be the removal of some unimportant defect found in inspection with considerabl economic loss due to the power outage and unnecessary exposure of maintenance personnel to radiation.
There is no source for the required information other than the licensees.
Appendix H of 10 CFR Part 50 requires a material surveillance program for each reactor vessel to monitor changes in the fracture toughness of the reactor vessel beltline materials resulting from their exposure to neutron irradiation and the thermal environment.
Paragraph IV requires:
(a) the test results
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obtained from the specimens contained in each surveillance capsule shall be j
reported to the Director of Nuclear Reactor Regulation, NRC, for each capsule withdrawal, and (b) new pressure-temperature operating limits for the reactor, based on the surveillance test results, shall be reported.
Surveillance reports are reviewed by Divisio, of Operating Reactors staff,
.whose. evaluation is the basis for approval of the proposed pressure-temperature operating limits for the reactor.
The impact of not obtaining the reports required by Paragraph IV would be that the pressure-temperature limits for the reactor would have to be checked against conservative estimates of radiation camage such as those given in Regulatory Guide 1.'99, Revision 1.
At the present time there are too many uncertainties in the assessment of radiation damage to a reactor vessel to l
permit a licensee to forego monitoring radiation damage and reporting the surveillance test results to the NRC.
Without the information required by Paragraph IV of Appendix H there would be insafficient basis for approval of continued operation beyond a few years' life.
There is no source for the required information other than the licensees.
Description of the survey plan The reporting and recordkeeping required effect 5 licensees for Appendix G Section V.E., 70 for Section III.B, and 180 for Appendix H.
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58 Estimation of respondent reportina burden Appendix G section V.E.
Negligible Section III.B 100 staff-hours, 70 X 100 = 7,000 Appendix H Negligible, less than.1 report per licensee per year Cost to the Federal Government Appendix G Section V.E. requires 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per report 160 X 5 = 800 staff-hours at a total cost of $36,000.
Section III.B is negligible Appendix H requires $38,400 based on staff experience.
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SUPPORTING STATEMENT FOR 10 CFR 50, APPENDIX J Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors JUSTIFICATION 10 CFR 50, Appendix J, " Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," provides for preoperational and periodic verification, by tests, of the leakage integrity of the primary reactor containment and-systems and components which penetrate containment of water-cooled power reactors.
Tests are conducted upon completion of construction of the primary reactor containment building (containment), periodically during each 10 year service period (approximately every 3-b 3 years), and during shutdown for refueling (approximately every 18 months bur in no case at intervals greater than 2 years).
The Appendix also establishes acceptance criteria for such tests.
One of the conditions of all operating licenses for water-cooled power reactors is that primary reactor containments shall meet containment leakage test requirements set forth in 10 CFR 50, Appendix J.
Section V.B., " Inspection and Reporting of Tests," requires submission to the NRC of a summary technical report, " Reactor Containment Building Integrated Leak Rate Test," approximately 3 months after the conduct of each preoperational and periodic test.
Furthermore, such reports must include a separate accompanying summary report analyzing and interpreting the test data for any tests that failed to meet the acceptance criteria of Appendix J.
Results and analyses of the supplemental verification test employed to demonstrate the validity of the leakage rate test me,asurements are also required to be included.
The primary reactor containment is designed to contain any operational or post-accident releases of radioactivity within specified limits.
Calculations of the impact of a radiological release on public health and safety are dependent upon predictable leakage from containment.
The required tests make sure that the containment is built as designed, and that leakage limits are not exceeded.
Reports of preoperational leakage tests are needed by the NRC (Inspection and Enforcement and the Office of Nuclear Reactor Regulation) since these tests are the only means by which it can be verified that these structures have in fact been built within the leakage levels specified as a condition of licensing by the NRC.
Information included in the report is reviewed to determine the results achieved, as well as to judge the accuracy and validity (reliability) of the data.
9
60 The reports of the periodic leakage tests are needed by the NRC (IE and NRR) in order to verify that containment leakage is maintained below the specified level throughout its operational life.
Periodic information is needed for the same reasons as preoperational test information, but in addition, is compared with that in the preoperational test report and previous periodic test reports.
If the preoperational or a periodic leakage test was not successfully completed, operation of the reactor would not be permitted.
There is no source for the required information other than licensees.
Description of the survey plan NRC anticipates 86 reports annually from a universe of 220 construction permit holders and licensees.
Estimation of respondent reporting burden The burden on licensees for preparation of each report is estimated to be 366 man-hours.
Approximately 86 reports are suomitted annually.
86 x 366 man-hours = A total annual burden for all licensees of 31,500 man-hours.
Estimate of cost to the Federal Government The cost to the Federal Government for the review of each report is estimated to be 536.00.
Approximately 86 reports are submitted annually:
86 x $36.00 = $3,150.00 l
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PART 15 SUPPORTING STATEMENT FOR 10 CFR 50.35(b)
Periodic Research and Development Reports JUSTIFICATION Section 50.35, Issuance of Construction Permits, specifies in paragraph 50.35(b) that "The Commission may, in its discretion, incorporate in any construction permit provisions requiring the applicant to furnish periodic reports of the progress and results of research and development programs designed to resolve safety questions".
This procedure allows the Commission, by special reference in a facility construction permit, to request information concerning ongoing R&D activities that are in support of a construction permit.
However, reports are not currently being filed under Section 50.35(b).
These reports would keep the staff apprised of the progress and findings of licensee R&D programs and increase the likelihood that any safety problems would be resolved in a timely manner.
The NRC Staff would evaluate the results obtained from licensee R&D programs.
The staff would then determine what, if any, corrective measures were appropriate and develop regulatory procedures including revisions to, existing review processes and possible facility modification, if necessary.
There is'no source for the required information other than licensees.
Description of the survey plan This reporting requTrement is not currently being utilized to-obtain information from licensees.
Estimation of respondent reporting burden This reporting requirement is not being employed by NRC to obtain information from licensees at this time and therefore imposes no respondent burden.
NRC requests renewal of the clearance for this section, however, in order to receive timely information from licensees on potential new technological developments for both power reactor and fuel reprocessing systems.
Ongoing R&D programs throughout the industry create the possibility of safety-related issues arising at any time.
The NRC staff must be able to obtain information from licensees concerning current research projects in order to make informed judgements about the effects of current research on future licensing actions.
Estimate of cost to the Federal Government Negligible e
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PART 16 SUPPORTING STATEMENT FOR 10 CFR 50.71(b) and APPENDIX C.III Annual Financial Report.
JUSTIFICATION The requirement for the annual financial report, including the certified financial statements, arises from the Atomic Energy Act of 1954, as amended, section 182 " License Applications." Section 182a provides, among other things, that each application for a license shall state such information as the Commission, by rule or regulation, may determine to be necessary to decide, such of the financial qualifications of the applicant as the Commission may deem appropriate for the license.
Section 10 CFR 50.71(b) provides for the filing of annual financial reports, including certified financial statements, of facility licensees with the Com.ai s sic n.
The fundamental purpose of the financial qualifications provision is the protection of the public health and safety and the common defense and s ec.uri ty'.
An applicant's financial qualifications affect his ability to meet his ' responsibilities on safety matters.
The Commission reserves the right to require additional financial information during the operation of a' facility, particularly in cases in which the nuclear power plant will be commonly owned by two or more existing companie.s, or in which finuncing depends upon long-term arrangements for the sharing of the electric power output-of the facility by two or more electric power generating companies.
The annual financial report is the only financial document routinely filedsby a licensee after an operating permit has been issued for a nucla=.r power plant.
The a'inual financial reports are used by NRC staff for financial monitoring of the respondents.
If it appears that any respondent is experiencing financial difficulties, this information is provided to NRC management for their
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consideration.
The information is also placed in NRC docket files and thereby s
made available for inspection by the public.
NRC Tas submitted to the Commission a final rule which will eliminate requirements
'with respect to financial' qualifications for electric utility applicants for a license to construct or operate a production or. utilization facility as prescribed in Section 50.21(b)-ot Section 50.22.
It will require electric utility licensees to maintain property; damage insurance. 'The NRC rulemaking for 50.54(v)(3) is at the proposed stage.
No burden will be imposed until the rule is finalized and an effective date for compliance is established.
At such time as the rule is' finalized, the necessary action will be initiated to incorporate the burden into.the NRC inventory.
ThereisnosourcefoNtherequiredinformationotherthanlicensees.
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Description of the survey plan This reporting requirement affects approximately 220 licensees annually.
i Estimation of respondent reporting burden i
The annual burden per licensee is estimated by the staff to be 2 staff-hours.
220 x 2 staff-hours = A total annual burden for all licensees of 440 staff-hours.
- This is based on staff's. experience.
Estimate of cost to the Federal Government i
The annual burden is estimated to be 2 staff-hours / report 220 x 2 = 440 -
staff-hours total for a total cost of $17,600.
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64 PART 17 SUPPORTING STATEMENT FOR Financial Qualifications, Damage Insurance, 10 CFR 50.54(w)(5)
Justification A new reporting requirement has been proposed by which licensees of commercial nuclear power plants would be required to submit annually proof that they carry the maximum amount of onsite property damage insurance available from private sources.
This new reporting requirement arises out of a recently-proposed amendment to the Commission's regulations that such insurance be obtained.
The information submitted by licensees will be used by the NRC staff to assure that licensees are complying with the requirement to maintain onsite property damage insurance.
(See amendment to 50.54(w)(5) attached.)
Description of survey plan Reporting requirement would affect 70 licensees.
Tabulation and publication plans i
There are no plans to publish the data.
Time schedule for data collection and publication Information will be collected from licensees as long as they remain licensees and the insurance and reporting requirement remains in effect.
The information will not be published as such.
Consultations outside the agency Regulation received public comment during proposed rule stage.
Estimation of respondent reporting burden The NRC final rule is now before the Commission.
No paperwork burden will be imposed until the Commission approves the rule, OMB approves the paperwork requirements and the rule becomes effective according to its terms.
When the rule is effective, the necessary action will be initiated to incorporate the burden into the NRC inventory.
Average reporting burden to each licensee should be a letter to NRC of no more than one paragraph indicating both the amount of onsite property damage insurance being carried by the licensee and the insurer (s) from whom the insurance was obtained.
Time to complete this is estimated to be no greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per licensee.
No significant variation in burden among licensees is expected.
There are currently 70 licensees.
Thus, the current annual burden would be 280 hours0.00324 days <br />0.0778 hours <br />4.62963e-4 weeks <br />1.0654e-4 months <br />.
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Sensitive questions Not applicable.
Estimate of cost to Federal Government Staff review time of 15 minutes / licensee is expected.
Total staff review time per year is 15 minutes / licensee X 70 licensees = 17+ staff hours. Given the assumption of salary per hour of $40.00 plus 100% overhead, the total dollar cost to the Federal government is $1,360 annually.
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REFERENCE PUBLICATIONS Document Number Document Title Un-numbered Lists Regulatory Guides NUREG-0642 Revision 1 A Review of NRC Regulatory Processes and Functions Regulatory Guide 1.70 Rev, 3 Standard Format and Safety Analysis Report for Nuclear Power Plants (LWR Edition)
NRC Form 366 Licensee Event Report Regulatory Guide 1.28 Quality Assurance Program Requirements Revision 2 (Design and Construction)
Regulatory Guide 1.88 Collection, Storage, and Maintenance Revision 2 of Nuclear Power Plant Quality Assurance Records NUREG-0737 Clarification of TMI Action Plan Requirements NUREG-0546 Technical Specifications Regulatory Guide 1.16 Reporting of Operating Information Revision 4 Appendix A, Technical Specifications Regulatory Guide 1.21 Measuring, Evaluating, and Reporting Revision 1 Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants Regulatory Guide 4.1 Programs for Monitoring Radioactivity in Revision 1 the Environs of Nuclear Powsr Plants NUREG-0472 Draft Radiological Effluent Technical Revision 3 Specifications for PWR's NUREG-0473 Draft Radiological Effluent Technical
' Revision 2 Specifications for BWR's NUREG-0161 Instructions for Preparation of Data Entry Sheets for Licensee Event Report (LER)
File Regulatory Guide 4.8 Environmental Technical Specifications for Nuclear Power Plants NUREG-0713 Volume 1 Occupationa diation Exposure at Commerci? auclear Power Reactors 1979 y
s.
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67 I
l REFERENCE PUBLICATIONS (Continued)
Document Number Document Title NUREG-0654 Revision 1 Criteria for Preparation and Evaluation of i
Radiological Emergency Response Plans and i
Preparedness in Support of Nuclear Power Plants NUREG-0452 Revision 3 Standard Technical Specifications for Westinghouse Pressurized Water Reactors NUREG-0799 For Comment Draft Criteria for Preparation of Emergency Operating Procedures Regulatory Guide 1.99 Effects of Residual 'El.ements on Predicted Revision 1 Radiation Damage to Reactor Vessel Materials l
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Mr. Christopher DaMuth Administrator for Infontation and Regulatory Affairs Office of Management and Budget Washington, D.C. 20503
Dear Mr. DeMuth:
By letter of October 30, 1981, to Nunzio palladino, Chairman of the United States Nuclear Regulatory Comission (NRC), you requested the NRC submit to the Office of Management and Budget (OMB) its plans to identify and implement imorovements in controlling the paperwork burden imposed on NRC licensees.
We are pleased to provide you the enclosed descriptions of our plans.
The NRC has already established several mechanisms to improve the control of the paperwork burden imposed on NRC licensees. On October 8,1981, the Comission established the new position of Deputy Executive Director for Regional Operations and Generic Requirements. The principaT purpose fo F establishing the position is to provide a single agency focal point for controlling generic requirements imposed on, and generic comunications with NRC licensees.
Specifically the Deputy Director for Regional Operations and
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s Generic Requirements coordinates licensing, inspection and enforcement inter-actions with licensees by NRC's major offices responsible for.those activities and provides management control of these activities involving Headquarters He also controls the
' programmatic offices and Regional. operations offices.
imposition of all generic requirements on licensees including paperwork re-In addition, he serves as Chairman of the Comittee to Review quirements.
Generic Requirements which is assigned to review generic requirements imposed on licensees operating one or more classes of nuclear reactors. A detailed description of the functions of that Comittee is set forth in Enclosure 1.
We also have two other efforts in progress which will improve control of reporting and recordkeeping requirements imposed on 1Jcensees. These include a review of NRC guidelines for performing a regulatory analysis and the agency's
, review of existing regulations. These efforts are described in Enclosure 2.
In addition, our plans include two other projects which will lead to improve-ments in the paperwork burden imposed on NRC licensees.
First, a review will be conducted to establish retention periods for those recordkeeping requirements Second, the NRC staff will prepare an NRC whicn current,1y are open-ended.
manual which will govern the imposition of reporting and recordkeeping require-ments on members of the public. A work plan for carrying out these projects.is described in Enclosure 3.
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l Mr. Christopher DeMuth.
We feel the appointment of the Deputy Executive Director for Regional Operations and Generic Requirements, the establishment of the Committee to Review Generic Requirements, and the other projects I have described, represent significant l
efforts to control the paperwork burden imposed on licensees. We recognize the need to continue to monitor our efforts and take additional steps when necessary. To keep the OMB informed of our efforts to control and monitor paperwork burdens imposed on licensees the NRC will provide the reports listed in Enclosure 4 Sincerely, M
k William J. Dircks
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Executive Director, for dperations
Enclosures:
As stated w
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I ENCLOSURE 1 The Comittee to Review Generic Recuirements-
' The United States Nuclear Regulatory Comission established, effective -
November 2,1981, the Comittee to Review Generic Requirements. The objectives of the Comittee are to improve the NRC control over r'equirements imposed on l,
NRC licensees and to focus priorities of the agency and the nuclear industry on those requirements having the greatest safety s.ignificance. The Comittee has the responsibility to recomend to the Executive Director for Operations the.
approval or disapproval of requirements to be imposed on one or more classes of nuclear reactors, thus serving as a single, agency-wide point of control.
t The Comittee will determine whether or not proposed new requirements will contribute effectively to health and safety or will place an unnecessary burden on licensee or agency resources. The Comittee consists of representatives of
-i seven NRC offices, including NRC's four major program offices.
It's Chairman i.s the new Deputy Executive Director for Regional Operations and Generic Require-ments. The Charter of the Comittee prescribing the scope of the Comittee's responsibility and its procedures are now pending Comission review. A copy of the Charter will be sent to you in a few weeks.
As acknowledged in OMS's letter of October 30, 198'1, the NRC has taken a major step in controlling reporting and recordkeeping requirements i'mposed on lifensees in.tne establishment of the Comittee to Review Generic Requirements. The Com-mittee will review the nee.d and practical utility of all reporting and record-s' keeping requirements imposed on one or more classes of nuclear reactors.
Interim
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procedures and review criteria have been established for the _Comitt.ee's review of reporting and recordkeeping requirements (Attached).
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I PROPOSED PROCEDURE FOR THE ASSESSMENT OF REPORTING AND RECORDKEEPING REQUIREMENTS IMPOSED ON LICENSEES
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This p'rocedu're applies to all Requests for OMB Clea'rnance under 'the Paperwork
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5 Reduct' ion Act which are submitted to CRGR as part of the package requesting approval to impose a requirement on one 'or more classes of reactors'.
1.
When a requirement imposes a repor. ting 'o'r recordkeeping requirement on licensees, the office submitting the package will submit a draft of the l:
OMS Clearance Application required in the memorandum of April 24, 1981 from William J. Dircks, Executive Director for Operations to all Directors regarding the implementation of.the Paperwork Reduction.Act.
A copy of, i
the draft OM3 Clearance Application shall be i:encurrently furnished to the Division of Technical Information Document Control.
c 2.
The following factors will by considered by the DEDROGR and the CRGP, evaluating a proposed reporting or recordkeeping requirements:
Is the reporting or recordkeeping requirement needed (i.e., Is is (a) the best maans to achieve a necessary regulatory objectivef).*
(b)
Does the information reported or required to be kept, hava practical utility, i.e.', does the NRC have the capability to use.
the infomation in a timely and useful fashion?
(c) is the schedule for imposing the reporting or recordkeeping reouirement reasonable?
(d)
Is the rehorting or recordkeeping requirement selected the-least burdensome method for achieving a necessary regulatory objective (i.e., Does it impose the appropriate degree of formality and detail?).
(e)
Does the requir'ement duplicate or overlap requirements imposed by the NRC?
(f)
Does the requirement duplicace or overlap requirements imposed by other government agencies?
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(g) Was the method used to-estimate the burden adequate?
(h)
Are'the b'urden estimates reasonable when compared yith similar requirements previously cleared?
(i)
Is the method proposed for collecting or keeping t'he information consistent with sound record management practices?
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2 (j)
I.s the record retention period sufficiently oefinitive.and, reasonable?
i (k) Does the requirement adequately identify the records to be naintained and the information to be reported?
(1) Are NRC administrative. support requirements sufficient to -
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manage the information collected?
1 (m)~ What is the impact on.the agency'~. information collection b'udget?
s 3.
The Office of Administration within five days of the submission of the reporting or recordkeeping requirement will provide to DEDRDGR a written-assessment of the factors set forth above in Item 2.-
4.
DEDROGR will decide which Requests for DMS Clearance should be submitted for CRGR review.
All others will be returned.to ADM for, appropriate action.
5.
For each OM3 Clearance Package submitted for the review, the CRGR will determine if the proposed reporting'or recordkeeping is needed and has potential utility.
6.
The Chairman cf the CRGR, once a reperting or recordkeeping requirement is approved, will provide the Office of Administration,a writter statement of the CRGR decision.
I.
After concurrence by DEDROGR or approval by CRGR, the Office of s'
Administration will ' submit the NRC application to OM3 for clearance.
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ENCt.05URE '. 2 Agency Projects in Progress Which Affect Control of Reporting and Recordkeeping Requirements I
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Review of Acency Value Impact Guidelines In a March 25, 1981, letter to the Comission, Vice President Bush asked that. the Comission comply with the spirit of Executive Order 12291 (the
" Order") and adhere voluntarily to Sections 2 and 3 of the Order. The response to the Vice President stated the Comissio'n's support for the purposes and objectives of the Order and infonned the Vice President that the staff would conduct a study to identify particular changes, consistent with NRC responsibilities under the Atomic Energy Act, 'a bring Comission procedures and practices more in line with the spirit of Sections 2 and 3 of the Order.
To carry out this study, the NRC's Executive Director for Operations on December 7,1981, appointed an agency-wide Task Force to review the agency's Value Impact Guidelines which were adopted in 1978. The objective of the review is to improve the quality and use of analyses within the NRC and to promote consistency with Executive Order 12291.
One of the several principal purposes of the review will be to integrate the analysis of reporting and recordkeeping requirements into the over-all shalyses of substantive regulatory requirements to which these paper-work requirements relate. The integration is expected to result in a
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more effective analysis of NRC regulatory actions and provide a more effective mechanism for identifying the costs and benefits of imposing requirements.
- It is another purpose of the Task Force to consider whether more effective institutional mechanisms are needed to assure procedural compliance with the Value Impact / Regulatory Analysis Guidelines and to assure the analyses of both substantive regulatory requirements and reporting and recordkeeping requirements are adequate.
The revised Guidelines which will be developed by the Task Force is expected to become a principal decision document for the Comittee to Review Generic Requirements and other senior NRC managers including the Agency's Senior Official. '
The revised Guidelines bei,ng developed by the Task Force are expected to become effective in April, 1982. A copy of the revised Guidelines, when appro'ved, will be provided to OMB.
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2.
The periodic and Systematic Review cf Existino Reculations The Commissioners of the United States Nuclear Regulatory Cor.Tnission, in its Three Mile Island Action plan, directed the NRC staff to review all existing HRC regulations over a five-year period.
An interoffice Regulations Coordinating Cpmittee was appointed on September 16, 1980, to coordinate the review. This " periodic and Systematic Review" establishes a mechanism to'icentify potential substantive changes to NRC regulations, through
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l EktLOSURE 2 - page 2 i
analysis of a specific regulation, or through an analysis of several i
regulations affecting the same topic. The review is designed to i'
evaluate all existing regulations for need, benefit cost, content, quality, clarity and structure.
This " Periodic and Systematic Review of Regulations" is also responsive' i
to Section 3(i) of Executive Order 12291 which requires Executive Branch agencies to initiate a review of all existing regulations to determine if they satisfy the criteria of the Executive Order, and to Section 610 of the Regulatory Flexibility Act (Public Law 96-354) which requires agencies to review the continued need for all regulations.which have a significant impact upon a substantial number of small entities. The revised Value Impact / Regulatory Analysis Guidelines discussed above are expected also to apply to these reviews of existing regulations.
Such will further the responsiveness of the NRC review to Executive Order 122gl.
Among the several specific criteria against which the regulations will be reviewed are several which address reporting and recordkeeping requirements.
These include (1) whether' the regulatory requirement is needed, (2) whether alternative approaches have been considered and the least burdensome of acceptable alternatives has been chosen and (3) an estimate has been made of reporting burdens and recordkeeping requirements necessary to comply with the regulations.
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' Where the review of existing regulations finds reporting o' recordkeeping r
requirements which sho'ld be changed, the NRC will apply to OMB for u
approval through normal clearance procedures. OKB.will also be notified of any previously approved reporting or recordkeeping requirements which are deleted.
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I Projects to be Undertaken Which Relate Directly to Information I
Collection Requirements 1.
Review of record retention recuirements for records recuired to be maintained by NRC licensees.
a.
Focus The NRC published a notice in the Federal Recister on May 3,1976 l
(41 FR 18300) which prescribed definite time periods for many of the records required to be maintained by licensees. The NRC regulations still contain a number of recordkeeping requirements for which no definite retention period has been established.
The purpose of this review is (1) to determine.if those retention l'
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periods which have definite time ' periods established are still valid and (2) to establish, where possible, definite retention periods which are currently open ended.
In reaching these decisions, the following will be considered:
1)
Is the retention period justified by Regulatory needs?
- 2) What burden is imposed on licensees as a result of requTring the records to be maintained?
b.
Review Product f
Federal Register Notice of a proposed rule identifying and describing the proposed changes to the NRC recordkeeping requirements.
c.
Tentative Schedule of Milestones and OM5 Deliverables Initiation Date:
February,1982.
Draft Federal Register Notice to the Commission:
June,1982.
Publication of Federal Register N,otice: August, 1982.
Federal Hotice sent to OMS: August,1982.
Final Rule sent to' OMB:
October,1982.
d.
Estimated Resources 12 man months 2.
Preparation of NRC Manual Chapter for processing applications for OM3 approval of reporting and recordkeeping requirements.
a.
Focus
-There are several on-going activities which will affect the preparation of an NRC manual for processing OMB clearance applications.
First, the NRC currently uses interim procedures for processing applications for OM5 aoproval of reporting and recordkeeping requirements imposed on members of the public.
These interim procedures were established in a memorandum dated April 24, 1981, from William J. Dircks, Executive Director for Operations, to all HRC Office Directors (Enclosure 3).
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I Since that time the NRC has developed operating experience applying '
l new guidelines resulting from requirements in the Paperwork Reduction Act.
Second, the NRC has pending with OMB an application for approval l
of an exemption from the requirement to obtain an OMB approval of j
class exemption for an infonnation collectionswhere it is needed due to urgency to protect the public health and sa.fety. Third, a Task '
Force reviewing the Value Impact / Regulatory Analyses Guidelines of i
. the. Agency are addressing the integration of the analyses of reporting and recordkeeping requirements with the technical and administrative regulatory requirements to which they relate.
The results of the OMB consideration of the class exemption, the Task Force review of regulatory analysis guidelines, and knowledge gained from several months of operating experience will provide an adequate i
basis for developing a fonnal manual addressing policies, procedures, and responsibilities for conducting information collections. The Manual Chapter will do the following.
1)
Define the information collections required to be approved i
by OMS.
- 2) Assign responsibility for preparing, evaluating and approving the OMB application.
3)
Establish procedures for obtaining routine OMB approval of v
NRC imposed reporting or recordkeeping requirements and for obtaining an OMB emergency clearance when necessary.
4)
Define the contents of the supporting statement which is to
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g be included in the OMB application.
i 5)
Establish the procedures and define the criteria for exempting I
the imposition of a reporting or recordkeeping requirement due 1
to the urgency of the need to protect the public health and
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t safety under the class exemption.
6)
Establish procedures for giving notice in an information collection requirement when the requirement applies to nine or fewer people and thus is not subject to OMB clearance.
b.
Product NRC Manual Chapter 0230.
c.
Tentative Schedule of Milestones and OME Deliverables Initiation Date:
March, 1982.
Draft Manual Chapter to NRC Offices for Review:
May, 1982.
anual Chapter to the Executive Director for Operations v
fo.r Acproval:
July,1982.
Approved Manual Chapter to OMS:
July, 1982.
d.
Estimated Resources Four(4). man-months.
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ENCLOSURE 4 i
Periodic NRC Reports to be Provided to the OMB I
1.
The NRC Semi-Annual Regulatory Agenda (publish'ed quarterly).
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- 2.,The Monthly Report to the Comission of Actions Taken by the Committee to Review Generic Requirements.
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30503 October 30, 1981 Honorable Nunzio J. Palladino Chairman Nuclear Regulatopy-Commission Washington, D.C.
20555
Dear Mr. Palladino:
On August 5, the Nuclear Regulatory Commission (NRC) submitted 10 j
CFR Part 50, Domestic Licensing of Production and Utilization Facilities, for our review under the Paperwork Reduction Act.
Shortly thereaf ter, Vice President Bush identified nuclear licensing as one specific area in which reporting and paperwork burdens placed on the public could be reduced.
Just recently, President Reagan stressed the need to improve the nuclear regulatory and licensing process.
In seeking OMB approval of the recordkeeping and reporting requirements authorized by Part 50, NRC has made a significant effort to avoid duplication and reduce burden on respondents.
NRC has published a comprehensive U vision to Regulatory Guide 10.1, " Compilation of Reporting Requirements,". that will reduce the required number of copies for most reports to three or fewer, and a Standard Review Plan, simplifying and concolidating the criteria NRC staf f will use' in reviewing applications to construct or operate nuclear power plants.
NRC has just created the Generic Requirements Review Committee to integrate and control the issuance of new (as well as back-fitting) regulatory requirements, and requests for information from licensees.
I understand NRC has efforts planned to reduce the number of amendments required for changes to technical specifications, to limit certain kinds of reporting to important safety items, and to permit f acilities to submit information in a master microform, instead of multiple hard copies.
Because we believe NRC has been taking significant steps to resolve information collection problems, we are approving the NRC recuest to continue to use the information collections authorized by Part 50.
This approval expires April 30, 1982, and should be
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identified by use of OMB No. 3150-0011.
However, this approval is conditional on certain efforts to reduce these burdens.
For OMB to grant further approval of the recordkeeping and reporting requirements authorized by Part 50, NRC's needs and the practical utility of the data must be balanced more effectively against the burdens and costs involved.
We fully appreciate that
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2 NRC resolution of the numerous safety and other regulatory issues
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involved in Par.t 30 -requires access to considerable amounts of inform:ation from licensees, contractors, operators, and others who would be engaged in nuclear activities.
At the same, time, NRC needs to improve its information collection activities to meet these needs.
Assuring the practical utility of the information for NRC will This means NRC help minimize burden on licensees and applicants.
should be collecting' only such data as it can use:
seeking only that level of detail needed; having it submitted no sooner than the likely time of' actual use; and precisely defining recorH:
keeping requirements and retentien periods, based on likely Once the data is obtained, periods of actual inspection and use.
NRC should be actually using it, following up promptly and conclusively with the respondent, as necessary.
As the Commission recently pointed out to NRC staff, however, formal NRC staf f communications with licensees (bulle tins, generic letters, circulars, notices, rule changes, NUREGs, and Regulatory Guides) have not been subject to central NRC review and cocraination.
Licensees and representatives of industry have complained that this lack of central coordination and control has resulted in duplicative and burdensome recordkeeping and reporting requirements--the submission of the same data both monthly 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 is subject to OMB review authority and approval under the Paperwork Reduction Act.
To work with you further in this ef fort to control paperwork, we request submission to us, by, January 15, 1982, of a detailed work The work plan should plan to implement needed improvements.staf f, organiration, planned target dates, and include projects, a schedule for reporting progress and accomplishments to us.
As a matter of OMB reports clearance, NRC should assure that notices, bulletins, and other documents calling for recordkeeping and reporting be made available an$ submitted for OMB review.
OMB approval of the use of the information collections set forth in 10 CFR Part 50 does not include approval of the recordkeeping and reporting requirements called for by any other NRC communications implementing Part 50 unless OMB has so agreed.
the public and OMB to review the total impact involved To pe rmit in related information collections, NRC should attempt to review such collections simultaneously rather than one af ter another.
To try to solve specific public complaints concerning information collection, NRC staff should be encouraged to continue to work with the Nuclear Recard Management Association, and equivalent groups, t6 th,e extent they can be of assistance.
the As 'a matter of NRC central control, we urge you to have Generic Requirements Review Committee (GRRC) assure that any recordkeeping or reports called for by regulatory requirements
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have pract'ical utility for the NRC, and do not duplicate others in place.
To help.do this, it appears that NRC also needs to adopt a more systematic methodology for evaluating the burden, timing and methods of implementation of an information collection--including a review of whether recordkeeping or reporting is the best means of implementation--and the appropriate degree' of formality and detail to be imposedr -
We look forward to continuing to work with you and your staff on this important effort.
Sincerely, A
Christopher DeMuth Administrator for Information and Regulatory Affairs 9.
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