ML20127F684

Request for OMB Review & Supporting Statement Re 10CFR50, Domestic Licensing of Production & Utilization Facilities. Estimated Respondent Burden Is 3,517 H

ML20127F684
Person / Time
Issue date:	05/13/1985
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20127F678	List: ML20127F674 ML20127F684
References
AA83-1, NUDOCS 8505200565
Download: ML20127F684 (8)

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s3 Request for DMB Review

,... standa,d ro,m

. - (Rev.septemtier 1983)

Important Read instructions before completing form. Do not use the sami SF 83 Send three copies of this form. the material to be reviewed, and it b request both an Executive Order 12291 review and approval under paperwork-three copies of the supporting statement, to:

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 request is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library Room 3201 1320, skip Part il, complete Part til and sign the paperwork certification.

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

1 Department / agency and Bureau /offace onginat ng request

2. Agency code U.S. Nuclear Regulatory Commission 3

1 5 0

Telephone number

3. Name of person who can best answer questions regarding this request 1 ( 301 3 443-7862 G. C. Millman

4. Trtie of information collection or rutemaking i

10 CFR 50, Domestic Licensing of Product' ion and Utilization Facilities

5. Legaf authority tor mformation collectuon or tule (cne United States Code. Public law. or Earecutive Order)

Atomic Energy Act of'1954, as amended use

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6. Affected pubhc (checA allthatapply) 5 0 rederaiagencieser ernproyees

• 1 O Individualsorhouseholds 3 0 rarms.

6 O Non-profitinstitutions 2 O stateorfocaigovernments 4 5 Businesses or other for-profit 7 O smaiibusmesses or organi1>tions PARTll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulation identifier Number (RIN)

_.__, or, None assigned O

8. Type of subtnnssion (check one m each category)

Type of review requested Classifiestion Stage of development 1 O standard 1 O ua,or m'.

' l O proposedo, draft 2 O pending 2 O Nonmajor

'2 O rinaiorintenmfinai.witnpriorproposai 3 0 cmergency 3 0 rinai or interim f.nai, without prior proposa 4 0 statutoryoriudiciaideadhne

9. CFR section affected

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10. Does this regulation contain reporting or recordkeeping requirements that require OMB approval under the Paperwork Reduction Act

.O ves O t-and 5 CFR 1320?

. 1 O ves 2 O t.

11. If a major rule. is there a regulatory impact analysis attached?

3 O ves 40s If"No.** ded oMB waive the nnalysis?

C:rtification for Regulatory Submissions

' in submitting this request for oMB review, the authorired regulatory contact and the program of f acial certify that the aequuements of E.O.12291 and any apphcab pohey directives have been comphed with.

Date signature of program off.cial

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8505200565 050513 PDR ORO EUSOMB PDR Signature of authnroed regulatory contact Date

12. (OMB us e only) standard roem 83 (Re. 9 i Prenous ed.tsans etnolete g3 gog P 5'nD'd b O' NsN 754000E34 4034 S CFR 132oard t O

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PARTlli.-Cornplete Thl:Part Cnlyif tfo Requxtis for Appriv:1cf a C.II:ctim ofInforrnation Under the Paperwork Reduction Act and S CFR 1320.

The NPRM updates existing references to specific

13. Abstract-Describe needs. uses and affected publicin 50 words or tesssections of the These requirements provide that nuclear power plant components are constructed and inspected.

The records can be used plant owners maintain records of certain safety related activities.The recordkeeping applies to the o by NRC to audit the performance of these activities.

of nuclear oower olants and does not affect the general oublic.

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14. Type of information collection (check only one) fnformation collections not contained in rules 2

Emergency submission (certiliCaffon attJched) 10 Regular submission Information collections contained in rules

7. Enter date of espected or actual Federal 6 Finalorinterim final without prior NPRM 3 O Eaisting regulation (no change proposed)

Register publication at this stage of rulemaking A O Regurarsubmission (month, day, year): May 1985 46 Notice of proposed rulemaking(NPRM)

B O Emergency submission (certification attached) 5 0 rinal. NPRM was previously published

' 15. Type of review requested (check only one) 4 O Reinstatement of a previousiy approved coriection for which approvai 1 O Newcairection has e,pired 2 U Revision of a currently approved collection 5

nisting collection in use without an ous contror number 3 O E, tension of the expiration date of a currentry approved correction without any change in the substance or in the method of cofrection

22. Putpose of information collection (check as many as apply)

16. Agency report form number (s)(include standardfoptionalform number (s))

1 O Appiication for benefits N/A 2 O Programevaluation 3 O ceneraipurposestatistics 17, Annual reporting or disclosure burden 4 6 Regulatory or comptiance I Numbe of respondents.

5 O Program planningor management 2 Number of responses per respondent 6 O Research 3 Total annual responses (line I times line 2) 7 0 Audit

~ 4 pours per tesponse

$ Total hours ffine 3 times line 4)

23. Frequency of recordkeeping or reporting (check allthat apply)

18. Annualrecordkeepingburden 10 Recordkeeping I Number of recordkeepers ReporfIns 2 Annual heurs per recordkeeper.

2 D onoccasion 3 Total recordkeepmg hours (line I fimes line 2) years 3 0 weekly 4 Recordkeeping retention period 4 O Monthry

19. Total annualburden 6,008,370 5 0 Quarterty 1 Requested (line 17 SO/usline 18J).

6.008.370 6 0 semi-annuairy 2 in current oM8 inventory 0

7 O Annuaiiy 3 oifference(line Ilessline 2).

8 O Gsennialty bplanation of Etifference 9 0 other(desenbe):

4 Program change

24. Respondents

• obligation to comply (check the strongest abligation tha t a 5 Adlustment..

20. Cvrent (most recent) oMB control number or comment number 3150-0011 1 O voruntary 2 O Required to obtain or retain a benefit

24. Requested expiration date 3 0 Mandatory 6/85 Oyes G No

25. Are the respondents pnman f educational agencies or mstitidions or is the pnmary purpose of the coj

26. Does the agency use samplhg to select respondents or does the agency recommend or presenbe the use o by respondents?

21, Regulatory authonty for the ' nformation corection

- : or.other (specify);

50 CFR 50 55a

or FR Paperwork Certificatten t f 5 CFR 1320. the Privacy Act, statistral standards or directives, and any other applicable mform oate

%gnature of program official Date 5.gnature of agency head, tne senior ott cias or an aucnonted representative g

y.

Supporting Statement for Information Collection Requirements in 10 CFR t)50.55a 1.

Justification a.

Need for the Information Collection NRC Regulations in 10 CFR 50.55a incorporate by reference Section-III, Division 1, and Section XI, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). These sections of the ASME Code set forth the requirements to which nuclear power plant components are designed, constructed, tested and inspected.

Inherent in these requirements are'certain recordkeeping functions.

Incorporation of the Winter 1982 Addenda, Sumer 1983 Addenda, Winter 1983 Addenda, Sumer 1984 Addenda, and 1983 Edition for Section III, Division 1, of the ASME Code would add the following recordkeeping requirements.

Section III o-Winter 1982 Addenda NB-2125, Fabricated Hubbed Flanges - New provision for surface examination requires documentation of examination results.

o Sumer 1983 Addenda' No additional recordkeeping o

Winter 1983 Addenda NCA-3650, Design Documents for A)purtenances -

Requires Design Document for eac1 appurtenance that is to be attached to a component unless it is already included in the component Design Documents.

o Sumer 1984 Addenda NB/NC-7240, Review of (Overpressure Protection) Report After Installation - Addendum to report required to document any modification of the installation from that used for preparation of the Overpressure Pro-tection Report.

ND-7200, Overpressure Protection Report - Requires overpressure protection report for Class 3 components to define the protected systems and the integrated overpressure protection provided, and (ND-7240) documentation of any modification of the installation from

.that used for preparation of the Overpressure Protection Report.

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1983 Edition All requirements, except those for Winter 1982 Addenda, previously incorporated in separate anendments to 10 CFR s50.55a.

lThe 1983 Edition of Section III is equivalent to the 1980 Edition, as modified by the Summer 1980 Addenda, Winter 1980 Addenda, Sumer 1981 Addenda, Winter 1981 Addenda, Sumer 1982 Addenda, and the Winter 1982 Addenda.

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4 Incorporation of the Winter 1982 Addenda, Suncer 1983 Addenda, and the 1983 Edition of.Section XI, Division 1, of the ASME Code would add the following recordkeeping requirements.

Section-XI o

Winter 1982 Addenda IWA-6220(b), Preparation (of Records and Reports) - Requires preparation of Owner's Report for Repairs or Replacements (Form NIS-2).

o Summer 1983 Addenda No additional recordkeeping 2

o 1983 Edition All requirements, except those for Winter 1982 Addenda, previously incorporated in separate amendments to 10 CFR s50.55a.

The Winter 1982 Addenda of the ASME Code references ANSI /ASME NQA-1-1979,

" Quality Assurance Program Requirements for Nuclear Power Plants."

NQA-1-1979 is based upon the contents of ANSI /ASME N45.2-1979, " Quality Assurance Program Requirements for Nuclear Facilities" and seven daughter standards. These standards are referenced in Regulatory Guides 1.28, 1.58, 1.64, 1.74, 1.88, 1.123, 1.144, and 1.146 as providing methods acceptable for implementing certain NRC quality assurance program requirements. NQA-1-1979 incorporates no recordkeeping beyond that originally required by the N45 standards upon which it is based. There is, therefore, no additional recordkeeping burden associated with the endorsement of NQA-1-1979.

b..

Practical Utility of the Information Collection

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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 generally 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 proper inservice examination test methods were utilized.

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c.

Duplication With Other Collections of Information ASME requirements are-incorporated to avoid the need for writing equivalent NRC requirements. The final rule will not duplicate the information collection requirements contained in any other generic regulatory requirement.

d.

Consultations Outside the NRC No consultations, j

2The 1983 Edition of Section XI is equivalent to the 1980 Edition, as modified by the Winter 1980 Addenda, Winter 1981 Addenda, and the Winter 1982 Addenda.

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Other Supporting Information NRC' applicants and licensees have been complying with the information collection requirements of the ASME Code since 1971.

No problems with these information collection requirements have

~been identified to the NRC.by the applicants or licensees.

' Description of the Information Collection:

2.

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. Number and Type of Respondents

.In general, the.information collection requirements incurred by s50.55a.through endorsement of the Code apply to the owners of the 34 nuclear power plants under construction and to the owners of the 93 nuclear power plants in operation. The actual _ number of plants that would implement the. edition and addenda addressed

by the proposed revision, and thereby be affected by their

'information collection requirements, is dependent on a variety

'of_ factors._ These factors include whether the application is

-for.Section III or Section XI, the class and type of components involved,ithe dates of the construction permit and construction permit application, the schedule of the inservice inspection program, and whether the plant voluntarily elects to iq)1ement updated editions and addenda of the ASME Code.

.b.

Reasonableness of the' Schedule for Collecting Information

'The.information is generally not collected, but is retained by the licensee to be made available to the NRC in the event of an NRC inspection or audit.

c.

Method of Collecting the Information See Item 2(b).

d.

Adequacy of the Description of the Information The ASME' Code'provides listings of information required and specific' forms to assist, where necessary, in documenting

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required information.-

e.

Record Retention Period The retention period for information is in accorda7ce with a schedule provided in Table NCA-4134.17-1 of the ASME Code. The retention periods for information keeping requirements specified

-in Item 1.a above are:

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Information Retention Period (3)

Design document for appurtenances Lifetime

. Overpressure protection report Lifetime Reports for repair and replacement Lifetime Final nondestructive examination report Lifetime.

Lifetime retention of-the_above records is necessary to ensure adequate historical information on the design and examination of components and systems to provide a basis for evaluating degra-dation of.these components and systems at any time during their service lifetime.

3.

Estimate of Burden-a.

Estimated Hours

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The information collection requirements inherent in incorporating

-by reference the latest edition and addenda of Section III, Division 1, and Section XI, Division 1, of the-ASME Code are identified in Item 1.a above. These_ requirements may be categorized'in terms of Section III requirements that document component / system design and the results of construction examinations, and Section XI requirements that document repairs and replacements.

The additional Section II'I requirements incur a one-time burden on plants-under construction. The information collection requirerwnts associated with the proposed edition and addenda are generation of the design documents for appurtenances and

-the overpressure protection report.. Section 50.55a specifies that the Code Edition, Addenda, and optional Code Cases to be applied to reactor coolant pressure boundary, and Quality. Group B and Quality Group C components must'be determined by the provisions of paragraph NCA-1140 of Subsection NCA of Section III of.the ASME Code. NCA-ll40 specifies'that the owner (or his designee) shall establish the ASME Code edition and addenda to be included'in.the Design Specifications, but that in no case.

snall the Code edition and addenda dates established in the~

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Design Specifications be earlier than three years prior to the date_that the nuclear power plant construction permit is docketed. 'NCA-ll40 further states that later ASME Code editions and. addenda may be used by mutual consent of the Owner (or his designee) and Certificate Holder.

The earliest Section III addenda being addressed in the proposed rule is the Winter 1982 Addenda. Since the last plant to be docketed that is still under construction was docketed in October 1974 (Palo Verde Units 1, 2, 3), there is no plant under construction for which implementation of the Section III edition and addenda specified in the proposed rule is a requirement. Plants may implement these. improved rules ~on a voluntary basis, but unless they make that choice, there is no additional paperwork burden associated with incorporating the proposed Section III edition and addenda.

3Service lifetime of the component or system.

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.i The additional Section XI requirements incur a burden associated with_the documentation of. component repairs and replacements.

To facilitate this. documentation,Section XI provides Form

.NIS-2,:"0wners' Report for Repairs or Replacements."

Information required by this form relates to identifying the

- owner and facility;. identifying the components repaired or replaced and replacement components; identifying the type of work, the repair organization and by whom the work was~

performed; and identifying the type of tests conducted. A portion:of this information, such as that to identify the owner,-

facility and_ components is already required by Form NIS-1,

" Owners' Data Report for Inservice Inspections," (Form NIS-l_was part of an addenda previously incorporated by reference into s50.55a). Most of the remaining information required by Form 4

NIS-2 can be obtained from the previously p_repared component work / repair order.

It is estimated that the time required to 4

complete the required documentation on Form NIS-2 is ten hours.

t Nuclear power plants are required to update their inservice inspection programs by incorporating into their initial 120-month inspection interval requirements of the. latest edition and addenda of Section XI, Division 1, that have been incorporated by reference into 50.55a as of 12 months prior to the date of issuance of the operating license; and by incorporating into successive 120-month inspection intervals requirements of,the latest edition and addenda of Section XI that have been. incorporated by reference as of.12 months prior to the start of a 120-month inspection interval. On this basis, many plants will at one time be required to implement the Section XI, Division 1,. edition and addenda specified in the proposed rule. The number of plants that will be implementing thespecifiededit$onandaddendawillgrowgraduallyaseach E

plant updates its inservice inspection program at the 10-year interval. Therefore, conservatively, the total number of plants that may ultimately be required to implement the specified edition and addenda.is 127 (i.e., 93 operating plants and 34 plants under construction).

Inservice inspections are typically performed at the time of refueling (i.e., approximately every 18 months). The need to complete an NIS-2 form would. occur as a result of a repair required by the results of an inservice' inspection, or as a e

- result cf an unanticipated repair between refuelings.

It is estimated that 2 NIS-2 forms are completed for repairs resulting from the inspection and 2 for repairs required during operation.

Assuming applicability to 127 plants, and the completion of 4 NIS-2 forms by each plant every 18 months, with ten hours required to collect information and complete each form, it is c

estimated that the total time required by all utilities to complete'the NIS-2 form is approximately 3400 hours0.0394 days <br />0.944 hours <br />0.00562 weeks <br />0.00129 months <br /> / year (i.e.,

4 forms x 127 plants = 508 forms per 18 months, 508 forms x 2 =

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1016 forms per 3 years, 1016 forms / 3 = 339 forms per year, 339 forms x 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per form = 3390 hours0.0392 days <br />0.942 hours <br />0.00561 weeks <br />0.00129 months <br /> per year). The time required to maintain these repair and replacement records for i

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the period noted in-Item 2.e is estimated to be 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> / year for-each plant. _ Thus, the total tire required by all utilities to completeandmainjaintheNIS-2formisapproximately3517 hours / year.

-b.

Estimated Cost Required to Respond to the Collection Based upon the hours specified in Item 3.a. it is estimated that the cost of responding to the information collection required by the Section III, Division 1, and Section XI, Division 1, edition and addenda specified in the proposed amendment to s50.55a is a total of $211,020/ year (3517 hrs x $60/hr) for 127 plants.

c.-

Source of Burden Data and Method for Estimating Burden Estimates of the number of NIS-2 forms that are completed during a year and the time required to collect the necessary information and to complete the forms, were obtained from utility staff inservice inspection specialists and NRC staff'in the Office of Inspection and Enforcement (regional and headquarters) engaged in inservice inspection activities.

d.

Reasonableness of Burden Estimate The estinate of the burden is considered reasonable because of.

the reliable source of the burden data.

4.

Estimate of Cost to the Federal Government

-NRC inspection personnel who audit plant quality assurance records would include in their audit verification of the proper

-implementation of the NIS-2 form. The time associated with NRC inspectors verifying use of the NIS-2 form would be extremely small when the activity is performed as part of a normal quality assurance audit.

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