ML20059F918
| ML20059F918 | |
| Person / Time | |
|---|---|
| Issue date: | 10/28/1993 |
| From: | Cranford G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | |
| References | |
| OMB-3150-0002, OMB-3150-2, NUDOCS 9311050164 | |
| Download: ML20059F918 (13) | |
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Read m!'<etons before compieting form Do not use the same SF S3 Send tnree copies of this forrn. tne rnaterial to be renewed a,a fo' to request botn an Executive Order 12291 review and approval under paperwork-three Copies of the supportir g statement. to'
. the Paperwork Reduction Act Answer a!: questions in Part 1. If this request is for review under E.O.
Offtce of information and Regulatory Affairs 12291 ccmp,ete Part 11 and sign the regulatory certificaton. If this Office of Management and Budget reauest 6 for approval under the Paperwork Reduction Act and 5 CFR Attention. Docket Library Room 3201 1320. sk Prt il crampiete Pan til and sign the paperwors ce tification.
Washington. Dc 20503 PART l.-Complete This Part for All Requests.
' 1. Dep.vimem agency anc eseawott.ce oronanng req.3est
' 2. tsgency coca U. S. Nuclear Regulatory Commission 3 1 5 0 3 Nderte O pe's'." Who Cil" Dest ans.er auestions rega-o;ng tnis recaest Teieprone rusae Priscilla Dwyer
( 301 > 504-2478
- 4. Tit.e o' mtyr atto-cohettien or rulemaung 10 CFR Part 73 - Physical Protection of Plants and Materials 1
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PART lit -Compista This Ptrt Only if ths Request is for Appr:vricf a C:llecti:n
. cf Informitlin Under ths Paperwirk Reducti n Act End 5 CFR 1320.
, Igstra;t sende negs, usej andaffectedgr in 50 w ac1p1tySecurity,NuclearPowerFacilitySafeguards" s pr ss omic nergy ac1 1 les,,
ear
!The proposed rule would require nuclear power reactor licensees'to document and maintain records; of evaluations of barrier systems installed to protect vital areas and equipment against vehicle'
' bombs, and submit ~ a summary of the evaluations' results and, in some cases, proposed,. additional
- measures needed to meet the requirements.
- 10. h ow o? UCT C. WeCt On (Check only one) hiformat.c'i cc!!ections nt contained in rules aC44ue u as:ca 2 C Emergency submission (certification attaened)
' shrmation ccilect: ens contained in rules 3 C Esst-g r$atier mocnaqiieproposed) 6 Final or irterim final without pnor f4PRM
- 7. Enter date of expected or actual Federal 41 %xe y rcccse:cerravg (NPRM)
A C Regular submasion Register publication at this stage of rulemaking 5 0 brai FA aas recausty ossf ed B C Emergency submission (certifrcation attached)
(month. day < /eary t 5.- iype & m ew 'enaued Weck ody one) 1 C New conee e 4 0 Reinstatement of a preaousiy approved coiiection ior wn cn approvai 21 hws on of a cur'ently approved collection has expired 3 C bte-scr ce me exmration cate of a currently approved collection 5 0 Ecsting collection en use wrthout an oMB controt number etMout 3"y c9arge in the substance or in the method of ( ollection
.16. :ency report Wm nur-ber(s> (mctude standard / optional form rsumber(s))
- 22. Purpose of snformatson collectnon (check as many as apply) 1 O Application for benefits I
Not applicable 2 O Program evaivation
~ 17. Arnuapecorbrg cr disc!osure Durcen 3 0 Generalpurposestatr$ tics 7,300 4 Q Reguiatoryorcompiiance 1 Nur ber of respondents.
9.39 5 O Program planning or management 2 Norrcer of resocnses per resporcent 3 Tctal annual responses (6ne 1 times irne 2) 68,575 6 O Research 4 Hours per response b
- 7. O Audit i
S Tetai hours ame s tees /in, a) 41,849
- 18. Armual recor9enng Du' den
- 23. Frequency of recordkeeping or reporting (checA a/Ithat apply)
,300 1 d Recordkeeping 1 Number of recorckeepers 2 Annual hours per recorckeeper
- PorfirW 3 Total recardkeeping hours (!ine ) times hoe 2) 328,152 2
on occasion 4 RecordAcepirg retention per:odVar.i es--3 years to years 3 0 weekiy 19 Totai ann al b.rden Duration of 11 Cense 4 O Montniy o
370,001 5 0 ouarteriy -
1 Redested (/me J T5 prus Ime 18 3).
2 in carant OMB mventory 370,001 6
sembannuany i
0 7 O Annually 3 Ditterence (ve l iess hne 2) bpaanation of difference a O Bnennialfy a program cr'ange 9 $ other(desenbe): One time 5 Adjustment.
' 20. Carrent facst recent) OMS control number or comment number
- 24. Respondents' obligation to comply (check the strongest ochgation that apphes) 3150-0002 1 O voiuntary
- 21. Recuested exoiration date 2 O Required to obtain or retain a benefit 5/31 /96 3 DQ Mandatory
- 25. Are the resocndents pnmanly educational agencies or institutions or is the pnmary purpose of the collection related to Federal education progeams? O ves G No ;
- 26. Does the agency use sarrphng to select respondents or does the agency recommend or presenbe the use of sampling or statistical analysis Yes 3 No by responcents.
27.Re tory autnonty for the mformation collection Part 73 CFR
- or FR
- or.other(specif#
Paperwork Certification
- In submitt;rg this reQJest for OMB approval, the agency head, the senior official or an authonzed representative, certifies that the requirements of 5 CFR 1320. the~
Pnvacy Act, stat'stical standards or directives, and any other applicaole information pohcy directives have been complied with.
. Egnature of pregram officiai Date
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'f ' Gerald F Cranford,-
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2 i
e-SUPPORTING STATEMENT FOR AMENDMENTS TO 10 CFR PART 73 PROTECTION AGAINST MALEVOLENT USE OF VEHICLES AT NUCLEAR POWER PLANTS l
(3150-0002)
REVISION DESCRIPTION OF THE INFORMATION COLLECTION The Nuclear Regulatory Commission (NRC) is proposing to amend its physical protection regulations for operating nuclear power reactors.
The proposed amendments would modify the design basis threat for radiological sabotage to include use of a land vehicle by adversaries for transporting personnel, hand-carried equipment and/or explosives.
Proposed subsection 10 CFR 73.55(c)(7) requires applicable licensees to establish vehicle control measures and to design and install a vehicle barrier system to protect vital areas and equipment from unauthorized proximity by land vehicles.
Proposed subsection 73.55(c)(8) requires licensees to compare the vehicle control measures established in accordance with 10 CFR 73.55(c)(7) to the Commission's design goals and criteria for protection against a land vehicle bomb.
Each licensee shall either confirm to the Commission that the vehicle control measures meet the design goals and criteria specified, or propose alternative measures, in addition to the measures established in accordance with 10 CFR 73.55(c)(7), describe the level of protection that these measures would provide against a land vehicle bomb, and compare the costs of the alternative measures with the cost of measures necessary to fully meet the design goals and criteria.
In addition, proposed subsection 73.55(c)(9)(i) requires licensees to submit to the Commission a summary description of the proposed vehicle control' measures as required by 10 CFR 73.55(c)(7) and the results of the vehicle bomb comparison as required by 10 CFR 73.55(c)(8).
For licensees who choose to i
propose alternative measures as provided for in 10 CFR 73.55(c)(8), the submittal must' include the analysis and justification for the proposed alternatives.
Proposed subsection 73.55(c)(9)(iv) requires licensees to I
retain, in accordance with 10 CFR' 73.70, all comparisons and analyses prepared pursuant to 10 CFR 73.55(c)(7) and (8).
ri i
u finally, proposed subsection 73.55(c)(10) requires applicants for a license to-op'erate a nuclear power reactor to incorporate the. vehicle control program into the site physical security' plan.
The reporting and recordkeeping requirements of 10 CFR 73.55(c)(10) include the burden associated with. incorporating the vehicle barrier system into the physical-security plan as addressed in Sect;cn 1.4 of.the Regulatory Guide DG-5006, " Protection Against Malevolent Use of Vehicles at Nuclear Power Plants."
In addition, the amendments to the contingency plans, as described in Section
'i 2.1.2(2) of the Regulatory Guide, require that if the screening analysis 1
conducted pursuant to Section 73.55 (c)(8) indicates that a detailed. analysis is required and damage control actions are considered, these actions should be-included in applicable station operating procedures and referenced in the safeguards contingency procedures.
Documentation of facility modifications resulting from implementation of the rule would be made through 10 CFR 50.54(p) changes (no decrease in security effectiveness),10 CFR 50.54(p) coupled with 10 CFR 50.59 changes (no change 1
in the technical specifications incorporated in the license or an unreviewed safety issue), or 10 CFR 50.90 (license amendment) changes.
l A.
JUSTIFICATION l
1.
Need for the Collection of Information l
- In the development of its physical protection programs, NRC uses the concept.
of a design basis threat to assure adequate protection. The design basis threat is a hypothetical threat that is not intended to represent a real threat. Notwithstanding, it serves three purposes: 1) it provides a standard' with which to measure changes in the real threat environment, 2) it is used to develop regulatory requirements, and 3) it provides a standard for. evaluation of implemented safeguards programs. The intent of the design basis threat for power reactors is to provide a physical protection system that protects against radiological sabotage.
To assure adequacy of the design basis threat, NRC continually monitors and evaluates the threat environment worldwide.
The Commission is also briefed i
periodically by agencies such as the Central Intelligence Agency and the Federal Bureau of-Investigation to keep ~ abreast of domestic and foreign intelligence concerning. threat. Although, based on current information, there is no significant change in the threat environment, the bombing at the World Trade Center demonstrated.that a large explosive' device could be ' assembled,-
delivered to % public area, and detonated in the United States without advance a
intelligence. ~ In ' addition, an unauthorized intrusion at the Three Mile Island nuclear power station demonstrated that a vehicle:could be used to gain quick
~
access to the protected area at a nuclear power plant.
NRC has concluded that there is no indication of an actual vehicle threat-l against the domestic commercial nuclear industry. However, based onrecent-events, NRC believes that a vehicle intrusion or bomb threat' to a nuclear power plant could develop without warning in the future. To maintain'a i
l 2
i
prudent margin between what is the current threat estimate (low) and the design basis threat (postulated as higher for conservatism), NRC is proposing to amend 10 CFR Part 73 to modify the design basis threat for radiological sabotage to include protection against malevolent use of vehicles at nuclear power plants.
The information collected as a result of these amendments is the minimum needed for NRC to make a determination that implemented programs meet the new requirements. As previously stated, the collected information consists of a letter that summarizes measures used to protect against unauthorized vehicle intrusion; the results of the site evaluation for protection against a vehicle bomb; and for a limited number of licensees (approximately 7 sites), a cost benefit analysis and information associated with 10 CFR 50.90 license amendments. The documentation and recordkeeping burden associated with 10 CFR 50.54(p) and 10 CFR 50.59 changes applies to repetitive recordkeeping requirements. OMB has previously approved recordkeeping requirements for 10 CFR 50.54(p) and 10 CFR 50.59 under OMB clearance number 3150-0011.
It is expected that the records associated with this proposed rule will be maintained by the licensee for three years as currently required under 10 CFR 73.70 (OMB Clearance Number 3150-0002).
2.
Aaency Use of Information NRC will use the licensee evaluations and implementations developed from this, proposed rulemaking to assure that licensees' programs adequately meet the intent of the regulations.
Except for licensees whose evaluations show they do not fully meet the Commission's design goals and criteria for protection against a vehicle bomb, licensee detailed evaluations will be maintained on site and will not be required to be submitted to NRC.
Licensees would, however, be required to submit summaries of the analyses.
Further, NRC will need to review and approve evaluations from those licensees that choose to use alternative measures to protect against a vehicle bomb.
3.
Reduction of Burden Throuah Information Technoloov There are no legal obstacles to use of information technology for reducing the burden associated with this information collection.
Although this is a one-time requirement, licensees are encouraged to use modern information technologies to collect, analyze, and store the information required under these provisions of 10 CFR Part 73.
4.
Effort to Identify Duolication The Information Requirements Control Automated System (IRCAS) was searched to identify duplication.
None was found. The evaluation to determine the adequacy of protection of vital equipment from malevolent use of vehicles, including vehicle bombs, at operating nuclear power reactor sites is a new requirement.
Therefore, this information does not duplicate nor overlap other information collections by NRC or other government agencies.
3
5.
Effort to Use Similar Information During the development of this rulemaking, staff conducted rudimentary analyses, on a site-by-site basis, similar to what will be expected from licensees in the evaluations they will be required to perform.
This staff work was performed to develop costs for the regulatory analysis for the proposed rule. Data was derived from security plans, available maps, and NRC site contacts ;nd represent best data available to NRC.- This data, however, is not considered sufficient in determining precise measures that might be needed to counter a vehicle bomb, which would include precise calculations ~of available standoff distances or, in some instances, determination of building structures and material.
6.
Effort to Reduce Small Business Burden The respondents are not small businesses or small entities as that term is defined in the Regulatory Flexibility Act. The proposed amendments affect only those utilities that operate commercial nuclear power reactors; none of-these organizations are considered small businesses or entities.
7.
Consecuences of Less Freouent Collection The information required under the proposed amendment is a one-time report and record that will be maintained by the licensee for a period of three years.
8.
Circumstances Which Justify Variation From OMB Guidelines The information collections in this rule contain no variation from the OMB Guidelines.
9.
Consultations Oglside the NRC During the development of these amendments, staff con'sulted with several Federal agencies and personnel involved with development and construction of vehicle barrier systems including the United States Army Corps of Engineers and the Treasury Department.
In addition, the NRC sponsored a public forum on May 10, 1993 to obtain comment on all aspects of a revised design basis threat from public interest groups, affected licensees and other interested parties.
The proposed rule will be published in the Federal Reaister for comment.
- 10. Confidentiality of Information Confidentiality will be insured because the results of the analysis to be collected will be protected as Safeguards Information. Any information pertaining to specific physical security system details at a commercial reactor site are required to be protected as Safeguards Information under 10 CFR 73.21.
Some specific details of the Design Basis Threat areas are classified and any discussions associated with this subject would have to be protected, as appropriate.
4
4
- 11. Justification for Sensitive Questions There are no sensitive questions.
12.
Estimated Annualized Cost to the Federal Government Inspection of the total sites is estimated to require 1 FTE.
Reviewing licensee proposals for alternative measures and 10 CFR 50.109-type analyses would require approximately an additional 1 FTE and $40K for technical assistance. The total estimated cost to the government, calculated at a rate of $132 per hour, is $589,120 (2 x 2080 x $132 + 40K).
13.
Estimate of Industry Burden There are approximately 67 commercial nuclear power reactor sites that will be affected by the proposed rule. Of these, based on staff rudimentary analyses, approximately 40 sites will be able to provide adequate protection against a vehicle bomb through placement of a vehicle barrier system protecting vital areas of the facility. NRC estimates the one-time burden for these licensees to meet the new requirement to be:
REPORTING RE0VIREMENTS H0VRS Development and coordination of implementation letter and 20 summary of site evaluation (10 CFR 73.55(c)(9))
Subtotal burden 20 RECORDKEEPING RE0VIREMENTS HOURS
- a. Reviewing instructions, notices, regulatory guides and NUREGs 80 (10 CFR 73.55(c)(7) and (8))
- b. Searching existing data sources, gathering information 100 (10 CFR 73.55(c)(7) and (8))
- c. Performing site evaluation (10 CFR 73.55(c)(7) and (8))
120
- d. Coordination and documentation of site evaluation 40 (10 CFR 73.55(c)(8))
- e. Development and implementation of Physical Security 60 changes (no approval required by NRC)
- f. Maintenance of summary report and full evaluation 20 (10 CFR 73.55(c)(9))
- 9. Maintenance of Security Plan Amendments 20 (10 CFR 73.55(c)(10))
Subtotal burden 440 Total subset burden 460 For this subset of licensees, the total estimated burden is 18,400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> (460 hrs. x 40 respondents). At a rate of $132 per hour, the total cost to licensees would be $2,428,800 (18,400 x $132/hr.).
5
r An estimated 20 sites will meet the Commission's design goals and criteria through implementation of additional measures. NRC estimates the one-time burden for these licensees to meet the new requirement to be:
REPORTING RE0VIREMENTS HOURS Development and coordination of implementation letter and summary of site evaluation (10 CFR 73.55(c)(9))
20 Subtotal burden 20 RECORDKEEPING RE0VIREMENTS 110@J
- a. Reviewing instructions, notices, regulatory guides, and 80 NUREGs (10 CFR 73.55(c)(7) and (8))
i
- b. Searching existing data sources, gathering information
'100 (10 CFR 73.55(c)(7) and (8))
- c. Performing site evaluations (10 CFR 73.55(c)(7) and (8))
160
- d. Coordination and documentation of site evaluation 40 (10 CFR 73.55(c)(8))
- e. Development and implementation of Physical Security Plan 60 changes (no approval required by NRC) (10 CFR 73.55(c)(10))
- f. Maintenance of summary report and full evaluation 20 (10 CFR 73.55(c)(9))
- g. Maintenance of Security Plan Amendments 20 (10 CFR 73.55(c)(10))
Subtotal burden 480 Total subset burden 500 for this subset of licensees, the total estimated burden is 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> (500 hrs. x 20 respondents). At a rate of $132 per hour, the total cost to licenseeswogdbe$1,132,000(10,000x$132/hr.)
The estimated remaining ~7 affected sites will not be able to fully meet the Commission's design goals and criteria for protection against a vehicle bomb by the measures designed to protect against vehicle intrusion. These licensees will have to assess and propose alternative measures. This approach will call for additional evaluation and documentation. NRC estimates the one-time burden for these licensees to meet the new requirement to be:
6
e REPORTI E FOUIREMENTS HOUR _S.
Develop."
and coordination of implementation letter 20 and sL ;..ary of site evaluation (10 CFR 73.55(c)(9))
Subtotal burden 20 RECOR0 KEEPING RE0VIREMENTS HOURS
- a. Reviewing instructions, notices, regulatory guides and NUREGs 80 (10 CFR 73.55(c)(7) and 8))
- b. Searching existing data sources, gathering information 100 (10 CFR 73.55(c)(7) and (8))
- c. Performing site evaluation (10 CFR 73.55(c)(7) and (8))
120
- d. Coordination and documentation of site evaluation 40 (10 CFR 73.55(c)(8))
- e. Perform additional evaluation for alternative measures 120 (10 CFR 73.55(c)(8))
- f. Develop and coordinate licensing action - Amendments 160 to Security Plans (10 CFR 73.55(c)(10)
- g. Maintenance of summary report, full evaluation, and 40
^
cost / benefit analysis (10 CFR 73.55(c)(8 and (9))
- h. Maintenance of Security Plan Amendments 20 (10 CFR 73.55(c)(10)
Subtotal burden 680 Total subset burden 700 For this subset of licensees, the total estimated burden is 4,900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> (700 hrs. x 7 respondents). At a rate of $132 per hour, the total' cost to licensees would be $646,800 (4,900 hrs. x $132/hr.).
The total estimated industry burden for all sites is 33,300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />. (18,400 +
10,000 + 4,900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />). The total estimated industry cost, at $132 per hour, is $4,395,600.
- 14. Reasons for Chanae in Burden The burden increase reflects the one-time recordkeeping requirement and the information collection for the licensees to document site-specific evaluation required by 10 CFR 73.55(c)(8) and (9) and the amendments to the Security Plan required by 10 CFR 73.55(c)(10).
- 15. Publication for Statistical Use This information is not published for statistical use.
B.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods.are not used in the collection of information.
7
k o
ESTIMATE OF COMPLIANCE BURDEN REPORTING REQUIREMENTS Total Annual No. of Burden per Annual Cost at Section Licensees Licensee Burden
$132/hr 73.55(c)(8)(i)&(ii) 67 Burden included in 73.55(c)(9) 73.55(c)(9) 40 20 800 105,600 l
20 20 400 52,800 7
20 140 18,480 TOTAE REPDRTING BURDEN:
1340
$ 176,880 RECORDKEEPING REQUIREMENTS Total Annual No. of Burden per Annual Cost at Record Section Licensees Licensee Burden
$132/hr Retention 73.55(c)(7) 67 Burden included in 73.55(c)(8) 3 yrs 73.55(c)(8) 40 340 13,600 1,795,200 3 yrs 20 380 7,600 1,003,200 7
480 3,360 443,520 73.55(c)(9)(iv) 40 20 800 105,600 3 yrs 20 20 400 52,800 l
7 20 140 18,480 73.55(c)(10) 40 80 3,200 422,400 3 yrs 20 80 1,600 211,200 7
180 1,260 166,320 TOTAL RECORDKEEPIflG BURDEN:
31,960 54,218,720 i
4
[7590-01]
NUCLEAR REGULATORY COMMISSION Documents Containing Reporting or Recordkeeping Requirements: Office of Management and Budget (0MB) 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 th,e 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:
Amendments to 10 CFR Part 73
" Protection Against Malevolent Use of Vehicles at Nuclear Power Plants" 3.
The form number if applicable: Not applicable.
4.
How often the collection is required: Submittals are only required once. Records would be retained by the licensee for three years.
5.
Who will be required or asked to report:
Nuclear power reactor licensees.
6.
An estimate of the number of responses annually:
67
2 7.
An estimate of the total number of hours needed annually to complete the requirement or request: 33,300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> (an average of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per response and 477 hours0.00552 days <br />0.133 hours <br />7.886905e-4 weeks <br />1.814985e-4 months <br /> per recordkeeper).
8.
An indication of whether Section 3504(h), Pub. L.96-511 applies:
Applicable.
P 9.
Abstract: The amendments to 10 CFR Part 73 would require commercial nuclear power reactor licensees to document and maintain records of evaluations of barrier systems installed to protect vital areas and equipment against vehicle bombs, and submit a summary of results of evaluations and, in some cases, proposed additional measures needed to meet requirements. The.
information will be used by NRC to make a determination whether implemented programs meet the new requirements for protection against vehicle bombs.
Copies of the submittal may be inspected or obtained for a' fee from the NRC Public Document Room, 2120 L Street, N.W. (Lower Level), Washington, DC.
Comments and questions may be directed by mail to the OMB reviewer:
Tim Hunt Office of Information and Regulatory Affairs (3150-0002)
NE0B-3019 Office of Management and Budget Washington, DC 20503
4 3
Comments may also be communicated by telephone at (202) 395-3084.
The NRC Clearance Officer is Brenda Jo. Shelton, (301) 492-8132.
DatedatBethesda, Maryland,this2[
day of [ b /s h 1993.
I For the Nuclear Regulatory Commission 1
. Gerald F. Cranford g
Designated Senior Official for Information Resources Management
)
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