ML20126L789

Request for OMB Review & Supporting Statement Re Preparation of LER Forms.Estimated Respondent Burden Is 118,000 H

ML20126L789
Person / Time
Issue date:	07/23/1985
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0104, OMB-3150-104, NUDOCS 8508010031
Download: ML20126L789 (12)

Text

_.PM DESIGNATED OttIGINA!

5"a '*rm 8 3 Request for OMB Reseuk a,4wTm (

(Rev septembee i983)

Important Read instructions before completing form. Do not use the same SF 83 Send three copies of this form. the material to be reviewed. and f.

to request both an Executive Order 12291 review and approval under papes w 9th-three Copies of the supporting statement, to; the Paperwork Reducten Act.

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

Offaceofinformationand Regulatory Affairs 12291, complete Part 11 and sign the regulatory certification. If this Office of Management and Budget request is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 3201 1320, skip Part 11. complete Part til and sign the paperwork certification.

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

rtment agenc and Bureau inating te

2. Agencycode 1.Defice /or /nalysis/officeorEvaluativeston of Operational Data Of and U.S. Nuclear Regulatory Commission Washington, DC 20555 3

1 5 0

,3 ' ame of person who can best answer questions regarding thrs request Telephone number Frederick J. Hebdon (301 )492-4480

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4. Title of information collecten or rulemaking i

" Licensee Event Report (LER)"

5. Legai sutnonty tor informatson consection or ruie (cce United States Coce. Puoloc law. or Esecutive 0rcer)

Sections 103 and 1048, Atomic Energy Act of 1954, as amended.

use

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6. Affected public(cliecA aff thatapp'y) 5 0 rederaiagencies or empioyees 1 O individuais or househoids s O rarms s O Non-profitinstitutions 2 O stateo,iocasgovernments 4 E susinesses or einer for.p,ofit 7 O smaiibusinessesororganeations 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 O S. Type of submussson (ct'eck one on each category)

Type elrevoew requested

~

Classification stage of developmerrt 1 O standard 1 O ua,or i O eroposedordraft 2 O pending 2 O Nonmaior 2 O rinaiorenterimfinai.wtnpnarproposai 3 O Emergency 3 0 rinai or intenm f.nas, withmt pnor proposal 4 O statutoryorjudicialdeadhne

9. CrR section affected CFR

10. Does thrs regulation contain reportmg or recordkeeping requirements that require oM B approval under the Paperwork Reduction Act and 5 CFR 1320?

. O ves Or

11. lf a anator rule. is there a regulatory impact analysis attached?

1 O yes 20:

3 0 ves 40t-H"No." did OMB waive the analysis?

Certification for Regulatory submissions in submitting this request for oMB review, the authorued regulatory contact and the program official certify that the requirements of E.o.12291 and any apphcable,

pohey directives have been complied with.

Signature of program official Date Sature of authorsted regulatory c' PDR ORG EUSOMB PDR

12. (OMB use only) stanaava reem a3(Hev 9 8 Previous edateens obsolete g3 gog NSN 75400o 634 4034 P'N" bed t,y o' S Cr R I?20and r o 122

PART lli.-Compl:ta This Part Cnly if the Requ:st is for Appr:v:1 et a C:ll:ction ef informsti n Under th) P:perwork R:ducti:n Act e nd 5 CFR 1320.

13. Abstract-Desenbe needs, uses and af fected public in 50 words or less NRC collects reports of operational events at commercial nuclear power plants in order to incorporate lessons of that experience in the licensing process, and to feed back the lessons of that experience to the nuclear industry.

14. Type of information collection (check onry one)

Information collections not contained in rules 1 @ Regular submissson 2 O Emergency submission (certif cation attached) 1:Jormation collections containedin rules 3 @ Existing regulation (no change proposed) 6 Finalorintenm finalwithout poor NPRM

7. Enter date of espected or actual Federal 4 O Notice of proposed rulemaking(NPRV)

A O Regular submission Register publication at this stage of rulemaking 5 0 Fmal. NPRM was previously published 8 0 Emergeacy submission (cert,hcatsoa attached)

(moata der rear >

15. Type of review requested (check only one) 10 New coiiection 4 O Reinstatement of a previous >y approved coii cison for wnich approvai has empired 2 @ Revision of a currently approved coilection 3 O Extension of the emperation date of a currentty approved coilection 5

Existing collection in use without an OMS control number without any change in the substance or in the method of collection

16. Agency teport form number (s)(mclude standard /optionalform number (s))

22. Purpose of mformation cotiection (check ss many as apply) 1 O Appiscation for benefits NRC Forms 366, 366A, and 366B 2 @ Program evaluation

17. Annual reportmg or disclosure burden 3 @ General purpose statistics 4 @ Regulatoryorcompliance 1 Number of respondents.

2 Number of responses per respondent b.ad @s. see $S} 26 5 @ Program planningormanagement 2,360 s @ Research 3 Total annuai responses (hne l times hne 2) 50 7 O Audit 4 Hours per response 5 Totat hours 0,ne 3 times hne o 118.000*

18. Annualrecordkeepingburden

23. Frequency of recordkeepeng or reportieg(check a# that appry) 1 Number of recordkeepers 1 O Recordkeeping N.P8FtI88 2 Annuat hours per recordkeeper..

3 Total recordkeeping hours (hne I times hoe 2) 2 @ onoccasgin 4 recordheeping retention penod years 3 O weekfy

19. Totsi annual burden 4 O Monthly 118.000 5 0 ovarterfy 1 Kequested(hoe 17 5 plus kne 18-3).

124.800 s O sem.-annuaisy 2 in current oMB inventory 6.800 7 O Annuaily 3 oifference(hne f less kne 2)

Esplanation alditterence 8 O Biennialty 9

other(describe):

4 Program change 6.800 5 Adjustment.

20. Current (most recent) oM8 control number or comment number

24. Respondents' obbgation to cornply (check the strongest 06 Agate that apphes) 3150-0104 1 O voiuntary

21. Requested esperation date 2 O Required to obtaen or retain a benefit 8-31-88 3 [1 uandato,y

25. Ar3 the respondents pnmarily educational agencies or institutions or is the primary purpose of the collection related to Federal educabon programst O ves

26. Does tne agency use sampling to select responttents or does the agency recommend or presenbe the use of samphng or statistical analysis

. O yes @ No by respondents?

27. Regulatory authority for the information collection 10 crR 50.73

or rR

or.other (spec,fy):

Paperwerk Certification in submittieg this request for oMB approval. the agency head, the senior official or an authonted representative, certifies that the requirements of 5 CFR 1320, the Pnvacy Act, statistical standards or directrves, and any other applicable mformation policy directives have been complied with.

oate signature of program of ficial signature of agency head.

s ior officus or an a inuriieo representative Date

<f 9

orrM, Office /of Administration 7/13'85 p Patricia G j

SUPPORTING STATEMENT FOR NRC FORMS 366, 366A and 366B, "LICENSEEEVENTREPORT(LER),"

10 CFR 50.73 1.

Justification a.

Need for the Information Collection The accident at TMI focused attention on the importance of an effective understanding and feedback of operating experience.of nuclear power plants. Studies of the TMI accident (e.g., Rogovin.

Kemeny) emphasized the importance of collecting and evaluating operational experience.

'This operational experience consists largely of frequent events of apparently low individual safety importance which are reported on NRC Forms 366, 366A, and 3668, " Licensee Event Report (LER)."

The assessment of such events, both individually and collectively, have led to understandings of how safety can be improved and have identified problems having the potential to seriously impact public health and safety.

b.

Practical Utility of the Information Collection The timely feedback of operating experience is clearly a vital and integral prerequisite to safety, and a strong NRC and nuclear industry commitment exists.to assess the significance and implications of operating events. The establishment of the NRC Office for Analysis and Evaluation of Operational Data (AE00), the industry Institute of Nuclear Power Operations (INPO), and the licensee operational data programs are a direct result of that commitment; as are the NRC

. i assignment of extensive resources and high priority to the review of operational data as a matter of Agency policy. Other countries with nuclear power programs, and international nuclear organizations are also committed to developing and imp;ementing programs to learn from operating experience. Major progress has been made in establishing systems for the international sharing of operational experience. The Nuclear Energy Agency (NEA) Incident Reporting System (IRS) is now operational and reports are being provided by all of the participating countries.

t j

Within the NRC, a formal and systematic program has been established for the collection, assessment, and feedback of operational experience.

This program, involving extensive resources, has resulted in an improved understanding of reactor performance', timely identification of important safety issues, and timely initiation of corrective or remedial actions such as issuing generic letters, revising license j

requirements, and issuing bulletins requesting licensee action.

In addition, formal and informal methods have been developed to couple the NRC's program with the industry's programs; thus, a close working 3

i relationship is maintained between the NRC and INPO.

i c.

Duplication With Other Collections of Information J

j The staff has reviewed numerous other NRC reporting requirements (e.g., Part 20 Part 21, Paragraph 50.55(e), Section 50.72, NUREG-0654, i

)

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, Section 50.73, Section 73.71) and has attempted, to the extent practical, to eliminate redundant reporting and to ensure that the various reporting requirements are consistent.

d.

Consultations Outside the NRC There have been no consultations since the last OMB approval of the LER forms. However, the NRC has given extensive consideration to the relationship between the LER system and the Nuclear Plant Reliability Data (NPRD) system.

In December 1980 the NRC decided that the reporting of operational experience data needed major revision and approved the development of an Integrated Operational Experience Reporting (10ER) system. The 10ER system would have combined and made mandatory the existing Licensee Event Report system and the NPRD system.

As a result of this decision, an Advanced Notice of Proposed Rulemaking (ANPRM) was published in the Federal Register on January 15, 1981 (46FR3541). That ANPRM explained why the NRC needed operational experience data, and described the deficiencies in the existing LER and NPRD systems.

While the NRC still believes that both types of data are essential to the NRC mission, subsequent events indicated that the NRC could obtain the needed reliability data without assuming direct responsibility for its collection.

On June 8, 1981 the INP0 Board of Directors decided that because of its role as an active user of NPRDS data, INP0

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would assume responsibility for management and funding of the NPRD system. Further, INPO developed criteria that are being used in their i

management audits of member utilities to assess the adequacy of NPRD j

system participation.

Consequently, the NRC decided that there was a reasonable likelihood j

that the NPRD system under INP0 direction would meet the NRC's need to collect reliability data. Consequently, the collection of detailed f

technical descriptions of significant events proceeded as a separate f

rulemaking (i.e.,10 CFR 50.73) to modify and codify the existing LER reporting requirements.

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2.

Description of the Information Collection i

a.

Number and Type of Respondents I

j LERs will be required from all holders of operating licenses for i

commercial nuclear power plants. There are currently approximately 1

L 92 such licensees, twelve fewer than the previous submittal to OMB. These licensees are generally large electric utilities that i

own and operate nuclear power plants licensed under Sections 103 and 104b of the Atomic Energy Act of 1954, as amended.

i b.

Reasonableness of the Schedule for Collecting Infomation I

l The NRC Fom 366 must be submitted within 30 days of discovery of l

the event so that the NRC can review the reports and take timely i

action to correct generic problems that are relevant to other plants l

with similar equipment and procedures.

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_.. _..... _.,., -. ~...., - _ _... _ _. _ _ _,, _.. _,,, -, _..,.. - _ _ _ _,.

c.

Method of Collecting the Information The NRC believes that the most practical method of collecting the information required to achieve this regulatory objective is through use of the LER forms.

I d.

Record Retention Period There is no record retention requirement.

e.

Reporting Period LERs are submitted at irregular intervals as reportable events occur.

f.

Copies Required to be Submitted The original is to be submitted to the U.S. Nuclear Regulatory Commission, Document Control Desk Washington, D.C.

20555, with a copy to the appropriate NRC Regional Office.

3.

Estimate of Burden 4

a.

Estimated Hours Required to Respond to the Collection The total annual burden to prepare the LER forms is 118,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

In 1984. 92 operating nuclear power plants submitted a total of '360 LERs.

Thus, the average level of reporting was approximately 26 LERs per unit.

It is estimated that each LER requires approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> to prepare. Thus, the total annual burden associated with LER reporting is approximately 118,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

I i i

This estimate is 12 fewer nuclear power plants in operation since l

our last submittal to OMB. The previous submittal was based on l

an assumption that 104 nuclear power plants would be in operation i

j by 1984. Currently there are 92 operating nuclear power plants.

i l

b.

Estimated Cost to Respond to the Collection i

The estimate annual burden to prepare the LER forms is $7,080,000 l

(118,000 x $60).

It is expected that the average level of reporting f

per unit will remain approximately constant; however, the total 1

burden will increase gradually as the number of operating nuclear power plants increases.

I b.

Source of Burden Data and Method of Estimating Burden 2

l These burden estimates are based on reporting rates in 1984 and 1

i the engineering judgment and experience of senior NRC personnel 3

who have extensive experience in the operation of nuclear power i

plants. These judgments have been confirmed by informal i

discussions with utility personnel familar with the LER program.

c.

Reasonableness of Burden Estimates i

i Based on the comments received and the NRC staff's LER assessments, 1

the staff has concluded that the estimates of burden are reasonable.

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4.

Estimate of Cost to the Federal Government The cost to the government is associated with editing, coding, and tabulating LERs and publishing results.

The NRC estinates that these activities, including overhead costs, amount to $481,200 (8020 hours0.0928 days <br />2.228 hours <br />0.0133 weeks <br />0.00305 months <br /> X

$60 per hour) plus approximately $1,600,000 in Program Support funding for various contractor and support activities, including funding for data base management, document processing, and publication. The total estimated government cost is $2,081,200.

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l Enclosures :

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