ML20058N141

Request for OMB Review & Supporting Statement Re GL 91-02, Reporting Mishaps Involving LLW Forms Prepared for Disposal

ML20058N141
Person / Time
Issue date:	09/28/1993
From:	Cranford G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
GL-91-02, GL-91-2, OMB-3150-0156, OMB-3150-156, NUDOCS 9310080076
Download: ML20058N141 (8)

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Request for OMB Review. d_ x _c_,'.2, S" """"" a s

( (Rev.5eptember1983) frnpsrtant i

Read instructions before completing form. Do not use the same SF 83 Send three copies of tnis form, the material to be reviewed, and for i

to request both an Executrve Order 12291 review and approval under paperwork-tnree copies of the supporting statement. to:

l the Paperwork Reduction Act.

Answer all questions in Part 1. If this request is for review under E.O.

Office of Information and Regulatory Affairs 12291, complete Part 11 and sign the regulatory certification. If this Office of Management and Budget reouest is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Ubrary, Room 3201

..l 1320, skip Part it, complete Part 111 and sign the paperwork certification.

Washington. DC 20503 PART l.-Complete This Part for All Requests.

1. Department / agency and Bureau /otfice onginating request

2. Agencycooe l

U. S. Nuclear Regulatory Commission 3 1 5 0

3. Name of person who can best answer questions regaroingthis request Telepnone number f

John Thoma

( 301 1 504-3450

4. Title of information collection or rulemah,ing l

Generic Letter 91-02, " Reporting Mishaps Involving LLW Forms Prepared for Disposal I

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5. Lega! autnanty for intormation conection or ruie (cite Unitec States Coce. Pubhc Lan, or Executwe Oroer) 42 use 2201(o)

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6. Affected public(checA aff thatapp'y) 5 0 rederaragenc'esorempioyees 1 C indmdualsorhouseholds 3 O Farms 6 @ Non-profitinstitutions 2 O stateorlocalgovernments 4 $ Businesses or other for profit 7 @ sman businesses or organizations PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulation Identifier Number (RIN)

_ _ _ _ or. None assigned C B. Type of suomission (check one on each category)

Type of revsew requested Classification Stage of development 1 O standard 1 O uator i O proposed or craft 2 O eending l'

2 O Nonmajor 2 O rinaiorintenmfinai.witnanorproposai 3 0 cmergency 3 0 rinai or intenm fina!. wenout enor proposai 4 0 smutoryorjudicialdeadane

9. CF R section affected CrR

10. Does this regulation contain reporting or recordkeepit g requirements that require OMB approval under the paperwork Reduction Act and 5 CrR 13207

. O ves O No 11.11 a major rule is there a regulatory impact analysis attached?

1 O ves 2 O No if"No," did OM B waive the analysis?

3 O Yes 4 0 no Certification for Regulatory Submissions

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in submitting tnis request for OMB review, the authorned regulatory contact and tne program official certify that the requirements of E.o.12291 and any appiscable l

pohcy directives have been comphed with Signature of program officia!

Date Eignature of autnorgeo regulatory contact Date

12. TOMB use only) 070056 0

l stenaard Form 53 (Ret 9-83; Pteveoas roitions obsoete E3108 PDR ORG EUSOPfB

'7 sem13NnN102N 9310000076 930928 1

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9 PART lil.-C:mpl:t3 This Pcrt Only if tha R:qu:st is f;r Approci cf a C:ll;cti:n cf Inform 9ti:n Under tha Pcperwirk R;ducti:n Act rnd 5 CFR 1320.

Q #bdtract-Ee.sende *'fe. uses fnd Ma*3ed pubt c in 501oacIlve Tasfe l isposal, Nuclear Waste Manag s

44 ds I Ra ioac ive Ma ria,

Generic Letter 91-02 requests voluntary submittal of infarmation concerning mishaps to low-level radioactive waste (LLW) forms prepared for disposal. Waite form generators and processors are asked to notify the NRC within 30 days of a mishap.

4. Type of information coHection (check onry one)

Information collections not containedin rules 11 Regular submission 2

Emergency suomission (cerrihcat;on attachec)

Information collections contained in rules 3 C Ersting regulation (no cnange proposed) 6 Final or intenm hnal ethout pnct NPPM

7. Enter cate of expected or actual Federal A C Notice of proposed rutemaking(NPRM)

A U Regular submession Register publication at this stage of rulemaking 5

Final. NPRM was previously pubbsbed B C Emergency submission (cerechcation attached >

(rnonta dar.r**r>:

' 5. Type of rev,ew reauested (check only one) 1 C New collection 4 C Reinstatement of a previously approved collection for which approval 21 Revision of a currently approved coHection has expned 3 C Extension of the expiration cate of a currently approved co:lection 5 C Existing conection in use without an oMB control number without any change in the substance or m the method or cohection

.$. Agency report form number (s)(onctuoe stancard/ optional forth number (s))

22. Purpose of irformation cof% tion (check as rnany as apply)

N/A 1 C Application for benefrts 21 Program evaluation

'.7. Annual reportmg or disciosure burden 3 C Generalpurposestatistics 1 Number of respondents.

4 C Regulatory or compliance 2 Nuraber of responses per respondent 1

5 C Program planning or management 3 Total annual responses (Irne 1 fu es hoe 2)

M 6 C Research 4 Hours per response O

7 C Audit 5 Total hors thne 3 fees !me o 272 t8. Annual recorcheeping burcen

23. f recuency of recordkeepeng or reporting (checx all that apply) 1 Number of recorckeepers 1 C Reco'ckeep: rig 2 Annual hours per recorcneeper Reportmg 3 Total recordkeep.ng hours (One 1 times hne 2) 21 Cn occasion A Recorcheepmg retent:en period

{

years!

3 C '/deeWy

9. Total annual turde" j

4 C Montnty I Recuested (hne 17-S olus leie 1S 3) 5 C Quarterry 2 in current CMB mveatory 320 6 LJ Semi-annupy r

3 Dit'erence pne 11ess ime 2)

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7 C Annually hplanation of difference B C B,ennialty 4 Program charge I

9 C other(desenbe):

5 Adjustment.

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?O. Current (most recent)OMB centref number or comment number

24. Pes poncents' obhgation to comply (check the strongest obhgation that apphe s) 1 3150-0156 1 y) voiuntary

21. Requested expiration cate 2 C Pequired to obtain or retain a benefft 3 years from approval date l'

3 C uaneatory t

25. Are the respondents pnrnanty educational agencies or institut;ons or is tre Dnrnary purpose of the collection related to Federal education programs?

Yes C No

'S. Does the agent use sampung to seiect responcents or does the agency recommerc or prescnde the use of samphng or statistical analysis by responderts

. O yes G No

7. Regu:atory autnor.ty for the information coilection 10 cre Put M

. or FR

or. other (spec,ty>r

'cparwork Certification i suomrtting th:s request +or CMB approva!. tne agency head, the senior off c al or an author:ed representative. certifies that the requirements of 5 CFR 1320, the vacy Act. stattst. cal standares or d-ect ves. and any cther anchcase rfor at:on :,obcy caect:ves have been compned with.

r anature of proram orf,c,ai Date i

Al A gr.mt{e of sency rea @e se ar or*, er an autnonzec r se entatae Date GeraY % rar r'

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a SUPPORTING STATEMENT FOR k

GENERIC LETTER 91-02

" REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR DISPOSAL" (3150-0156)

EXTENSION REQUEST Description of the Information Collection NRC is requesting the extension of a previously approved information collection. The information collection burden is being adjusted downward to reflect a decrease in the expected number of reports, based on the number of reports received during the previous clearance period. Burden estimates for Agreement State licensees have been added to this request.

The Nuclear Regulatory Commission (NRC) issued Generic Letter 91-02 to encourage voluntary submittal (by both waste form generators and processors) of information concerning mishaps to low-level radioactive waste (LLW) forms i

prepared for disposal.

This Generic Letter also reminds licensees of their obligation to report defects and deviations in accordance with NRC requirements in 10 CFR Part 21.

A.

Justification Need for the Collection of Information Prior to the issuance of Generic Letter 91-02, NRC collection of information r

concerning reported mishaps to LLW forms prepared for ultimate disposal in a licensed LLW disposal facility was conducted through indirect and informal means.

Examples of mishaps that were reported included: (1) chemical reactions which. occurred in low-level waste shipping containers storing dewatered synthetic organic materials (such as resins), (2) a chemical reaction between a chemical detergent and a waste solidification agent resulting in a boiling of the mixture, and (3) multiple incidents where cement-solidified bead resin wastes have either not solidified properly or disintegrated over a period of time following solidification.

The purpose of Generic Letter 91-02 was to ensure that all such events are voluntarily reported to the NRC with adequate information to determine if followup action is necessary.

Aaency Use of Information A waste form mishap experienced by one reactor licensee or waste processor may raise the possibility of a generic problem.

In that case, an NRC Information Notice or Bulletin would be issued to advise all power reactor licensees, low-level waste processors, and the sited-disposal States of the potential hazard (s) and to encourage (or, in the case of a Bulletin, to request) licensees to take the appropriate precautions to ensure the protection of public health and safety.

Reduction of Burden throuah Information Technoloav There are no legal obstacles to reducing the burden associated with this information collection by the use of information technology. NRC encourages the use of such technologies. The sporadic nature of the mishaps to be reported, however, does not lend itself to the use of such information technologies.

.i.

v Duplication of Other Collections of Information The Information Requirements Control Automated System (IRCAS) was searched to identify duplication. None was found.

i Effort to Use Similar Information There is no known information available to the Government.that is. similar to the information identified in the Generic Lette.

Information is only provided if a mishap occurs.

Effort to Reduce Small Business Burden A majority of the reports from waste processors are from commercial nuclear power reactor licensees, which are not small entities. Some responses may be received from waste processors that are small businesses. However, since the consequences to public health and safety from waste form mishaps are the same.

whether reported by a large or a small entity, it is not possible to reduce the burden on small businesses by less frequent or less complete reporting.

Conseauences of less Frecuent Collection This is a one-time voluntary submittal when a mishap occurs, it is not possible to permit reporting less frequently.

Circumstances Which Justify Variation from OMB Guidelines Mishaps to LLW forms prepared for disposal should be reported to the NRC within 30 days so that NRC can determine whether (1) waste form requirements of 10 CFR S 61.56 are met prior to disposal, (2) other waste processors need to be notified of processing problems, and (3) changes to the processing methods are needed.

Consultation Outside the NRC l

There have been no consultations outside the agency since the previous clearance of this information collection request.

Confidentiality of Information None, except for proprietary information.

Sensitive Questions j

None.

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e Estimate of Cost to the Federal Government t

The collection and processing of the information requires approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of NRC staff time per report (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for headquarters staff and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the regional offices).

It is estimated that up to 10 reports will be received per year from non-Agreement-State respondents.

It is estimated that up to 24 reports will be received per year from Agreement State respondents.

l At $132 per hour, the annual cost to the Federal government would be $71,808 (34 reports x 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> / report x $132). This cost is fully recovered by fee assessments to NRC licensees pursuant to 10 CFR Part 171.

a I

. Estimate of Burden The actual burden on the licensee or processor is difficult to estimate because only a few of these mishaps have been reported. An average mishap report would be about one to three pages in length. The average time to prepare such a report is estimatzd to be eight hours.

The burden estimate is provided in the following table.

Number of Burden Hours Respondent Total Annual Respondent Responses /Yr Per Response Burden (Hrs)

Burden (Hrs)

NRC Agreement NRC Agreement States States Waste 7

14 8

56 112 168 Processors Disposal Site 3

.10 8

24 80 104 Operators Total 10 24 80 192 272 At a rate of $132 per hour, the cost to respondents would be $35,904 (272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> x

$132/ hour).

Reasons for Chanae in Burden The burden estimate reflects a decrease in the number of anticipated responses from NRC licensees, and an increase from the addition of burden estimates for Agreement State licensees, which were not previously included. The overall estimate is a net decrease in burden. Originally, NRC estimated it would receive approximately 40 reports per year.

However, experience to date has shown the number of responses to be less than 10 per year. Therefore, as a conservative upper bound, the number of responses is estimated to be no more than 10 per year. This is assumed to be distributed so that three fourths would come from waste processors and one fourth would come from disposal site operators.

The decrease in cost is somewhat offset by an increase in the NRC fee structure. However, the overall burden and cost for NRC licensees is still less than previously estimated.

For Agreement State licensees, the estimated number of reports for disposal site operators is based on the number of reports received by the Agreement State regulatory agencies for the year 1992.

The actual number of reports received was eight, but an estimate of 10 has been used for conservatism.

The estimate of the number of Agreement State waste processor responses is based on the assumption that the number of such waste processors is approximately double the number of NRC waste processors, hence the number of responses will also be double (2 x 7).

publication for Statistical Use None.

B.

Collection of Information Emolovina Statistical Methods Statistical methods are not used in this collection of information.

7

[7590-01]

NUCLEAR REGULATORY COMMISSION f

Documents Containing Reporting or Recordkeeping Requirements: Office of Management and Budget (OMB) Review AGENCY:

U. S. Nuclear Regulatory Commission (NRC)

ACTION:

Notice of OMB review of information collection.

SUMMARY

The NRC has recently submitted to OMB for review the following proposal for the collection of information under the provisions of the Paperwork Reduction Act of 1980 (44 U.S.C. Chapter 35).

1.

Type of submission, new, revision, or extension:

Revision.

2.

The title of the information collection:

Generic Letter 91-02, " Reporting Mishaps Involving LLW forms Prepared for Disposal" 3.

The form number if applicable: Not applicable.

4.

How often the collection is requirea.

Reports are made only when the licensee or waste processor experiences a mishap that is reportable under the guidelines described in the Generic Letter.

5.

Who will be required or asked to report: Nuclear power reactor licensees and Agreement State and non-Agreement State waste processors and disposal site operators.

6.

An estimate of the number of responses annually: 34 1

I

k f

2 7.

An estimate of the total number of hours needed annually to i

complete the requirement or request:

272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> (an average of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per response).

8.

An indication of whether Section 3504(h), Pub. L.96-511 y

applies:

Not applicable.

9.

Abstract: Generic Letter 91-02 encourages voluntary reporting-( by both waste form generators and processors) of information concerning mishaps to low-level radioactive waste (LLW) forms prepared for disposal. The infornation is used by NRC to determine whether followup action is necessary to assure protection of public health and safety. The revision reflects a decrease in burden because of a lower number of reports i

received than had been previously estimated.

i Copies of the submittal may be inspected or obtained for a fee from the NRC 2

Public Document Room, 2120 L Street, N.W. (Lower Level), Washington, DC.

Comments and questions may be directed by mail to the OMB reviewer:

j Tim Hunt Office of Information and Regulatory Affairs (3150-0156) j NE0B-3019

)

Office of Management and Bsidget Washington, DC 20503 j

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Comments may also be communicated by telephone at (202) 395-3084.

The NRC Clearance Officer is Brenda Jo. Shelton, (301) 492-8132.

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Dated at Bethesda, Maryland, this M/b day of b

l993.

for the Nuclear Regulatory Commission

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Gerald F. Cranford

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Designated Senior Official for Information Resources Management 1

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