ML20128B869
| ML20128B869 | |
| Person / Time | |
|---|---|
| Issue date: | 06/09/1992 |
| From: | Thompson G NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19341G314 | List: |
| References | |
| FRN-57FR28642, RULE-PR-50 AD03-1-018, AD3-1-18, NUDOCS 9302030198 | |
| Download: ML20128B869 (10) | |
Text
_
A D03 -/ Oli Jane 9. 1992 1
MEMORANDUM FOR:
Brenda Shelton, IRM FROM:
Gina Thompson, AEOD
SUBJECT:
OMB CLEARANCE PACKAGE FOR PROPOSED RULEMAKING TO MODIFY POWER REAC10R EVENT REPORTING REQUIREMENTS - 10 CFR 50.72-AND 50.73 Enclosed is the OMB clearance package required for the proposed rulemaking to modify power reactor ovent reporting requirements pursuant to 10 CFR 50.72 and 50.73 (Enclosure 1).
We request your expedited review of this package.
To be able to meet the June 19, 1992 deadline for publication of the Notice for Proposed Rulemaking in the Federal Reaisttt (see the SRM, dated May 22 -
1992 - Enclosure 2), we need to submit the revised rulemaking package for the E00's signature by June 12, 1992.
As you are aware, for the proposed rule to be acceptable for publication in the fadn31 Reaister, the OMB clearance package requesting OMB review and approval of these information collection requirements must be forwarded to 0MB prior to submitting the Notice for Proposed Rulemaking for publication in the [1.dJral Reaistet.
Therefore, your-d approval of this OMB clearance package by June 10, 1992 will be greatly appreciated.
If you have any questions regarding this package, please contact Raji Tripathi at x24435.
5 Gina Thompson, AE00 Enclosu?cs: As stated Distribution:
E. Jordan D. Ross T. Novak J. Rosenthal P. Baranowsky JR;'Tripathi M. Harper i
G. Thompson DSP RF TPAB RF M. Lesar TFA0/DSP AC:D[i57fPAB C:1 AE00 4f g
qf RTFfpathi RTr1pathi P aranowsky GThompson 6/o/92 6/y/92 6/$P/92 6/j/92 9302030190 930129 PDR PR 50 57FR28642 PDR
f SUPPORTING STATEMENT FOR Proposed Hinor Rulemaking to Hodify Operating Reactor Event Reporting Requirements 10 CFR 50.72 and 50.73 (3150 0011 and 3150 0104) i.
3LQ1FICAT10N 1.
'leed for theJollection of Information Operational experience feedback is required to meet the NRC's statutory requirements for regulating the nuclear industry.
Events of the type described in 10 CFR 50.72 and 50.73 require immediate notification with written follow up within 30 days on NRC Forms 366, 366A, and 3668.
Examples of such events are shut downs required by the Tecnnical Specifications, deviations from the Technical Specifications, an event resulting in the plant being in a degraded condition, or an external event which poses a threat to plant safety.
The licensee is required to indicate the applicable section/ paragraph of 10 CFR 50.73 pursuant to which the event is being reported, or if the LER is a special report or a voluntary report.
Effective January 1, 1984, it became mandatory that all U.S.
nuclear power plant licensees holding operating licenses under Sections 103 and 104b of the Atomic Energy Act of 1954, as amended, immediatsiy notify the NRC and in some cases the state and local governn'.nts of certain operating reactor events pursuant to 10 CFR 50.72, and submit LERs for events reportable under the provision of 10 CFR 50.73, regardless of the plant conditions, The NRC staff's review of reactor operating experience over the past 7 years has shown that some event notifications and written reports are unnecessary, in addition, the NRC staff has identified a disparity and diversity concerning licensees understanding of the intent of the existing event reporting rules and, therefore, in the applications of these provisions.
The NRC Regulatory impact Study (Draft NUREG-1395) indicated a need for clarification of the intent of the existing event reporting rules and for additional guidance on event reporting, in the Fall of 1990, four workshops on event reporting were 3rganized by NRC.
The agency's staff interacted with licensees and industry-supported organizations to obtain feedback on their experience with event reporting under the existing rules.
Sub-secuently, a task group was organized to clarify the intent of the current rules in order to-improve the uniformity and completeness of operating reactor event reporting, in September 1991, NRC issued for comment a draft NUREG-1022, Rev. 1. " Event Reporting Systems 10 CFR 50.72 and 50.73 -- Clarification of NRC Systems and Guidelines for Reporting."
The comment period closed on January
- 31. 1992.
Following resolution of public comments, this NUREG aill contain improvea guidance for event reporting.
The NRC staff's continuing examination of the reported events during development of this document indicated that certain types of invalid engineered safety feature (ESF) actuations are not important to safety.
Based on reviews that indicated certain reportable occurrences are of minimal or no safety significance, the NRC :W f proposed to relax event reporting requirements, specifically, cers. k..arovisions in 10 CFR 50.72 (b)(2)(ii) and 10 CFR 50.73 (a)(2)(iv).
I f i.'.a proposed amendments are published as a final rule, relaxation of so m ted ESF actuations will have no impact on the ability of the NRC to carry its mission to protect public health and safety.
Therefore, the Commission approved initiating a rulemaking that would require certain ESF actuations to be no longer be reportable.
Under 10 CFR 50.72 (b)(2)(ii),1-hour notifications to NRC, and under 10 CFR 50.73 (4)(2)(iv) written follow up reports on NRC form 366, NRC proposes to eliminate reporting requirements for the following types of events:
(1) events in which an invalid ESF or RPS actuation occurs when the system is already properly removed from service if all requirements of plant procedures for removing equipment from service have been met.
(2) events in which an invalid ESF or RPS actuation occurs nfter the safety function has already been completed (e.g., an invalid containment isolation signal while the containment isolation valves were already closed, or an invalid actuation of the RPS when all rods were fully inserted.)
(3) events in which an invalid ESF actuation occurs that involves only a limited set of ESFs (i.e., when an invalid actuation, isolation, or realignment of only the reactor water clean-up (RWCU) system, or any of the following four ventilation systems: control room emergency ventilation (CREV) system, reactor building ventilation system, fuel building ventilation system, auxiliary building ventilation system, or their equivalent ventilation systems occurs];
invalid actuations that involve other ESFs not specifically excluded would continue to be reportable.
(4) events that involve actuations of ESF components (which have both protective (ESF) and non-protective (non-ESF) actuation circuitry) and the actuation results from a signal originating in the non-ESF circuitry.
ticensees would continue to submit LERs if a deficiency or condi-tion associated with any of the invalid ESF actuations of the RWCU or the CREV systems, or reactor building ventilation system, fuel ruilding ventilation system, auxiliary building ventilation system
.or other equivalent ventilation systems) satisfies any reportability criteria under 550.72 and 550.73.
2.
h qv Use of Information S
The events reported events under 50.72 and 50.73 are assessed both individually and collectively to determine their safety significance and their generic implications and to identify any safety concerns with the potential to seriously impact the public health and safety.
The evaluation of these events provides taluable insights _ on improving reactor safety.
The event reporting being eliminated by this rulemaking has been determined to have no safety significance.
3.
Deduction of Burden Throuah Information Technoloav The NRC has no objection to the use of information technologies that would reduce the burden associated with this information collection and moreover, encourages their use.
4 Efforts to identify Duolication The LER forn, is constructed to eliminate redundant reporting by allowing many reporting requirements to be addressed on one form.
The Information Requirements Control Automated System (IRCAS) was searched for duplication, and none was found.
5.
Efforts to_Use Similar Information Not Applicable.
6.
Effort to Reduce Small Business Burden These reporting requirements only affect nuclear power reactor licensees.
Therefore, there is no burden on small businesses.
7.
Consecuences of less Frecuent Collection Less frequent data collection would, ln general, degrade the NRC's ability to assess operating experience and feed back the lessons learned in a timely manner, including corrective actions to prevent recurrences.
This rulemaking eliminates reporting of certain types of events.
3.
Circumstances Which Justify Variation from OMB Guidelinei Not applicable to this rulemaking.
9.
Consultations Outside the NRC The NRC sponsored four regional workshops on event reporting turing September to November 1990 to provide a mechanism for
- iscussions between the NRC and industry, and to receive industry feedback on licensee experience with event reporting under the sxisting rules.
In October 1991, the NRC also published for
- ublic comment draf t revised guidance for event reporting, Public
- Teents received on this dratt document are oeing currently
resolved and will be considered in the Proposed Rulemaking when public comments, specifically, on relaxation of certain LER requirements will be solicited.
10.
Confidentiality of Information NRC provides no pledge of confidentiality for this collectinn of information, 11.
Justification for Sensitive Questions No sensitive information is requested.
12.
Estimated Annualized Cost to the Federal Government 50.72 Hotifications Currently, an estimated 40 immediate notifications are annually made by each of the 112 operating reactor licensees.
The burden for each phone call is about 15 minutes.
However, the relaxation of nearly 150 notifications will not result in proportionate savings to the Federal Government as the NRC's Incident Response Center will continue to be staffed at the present level.
50.73 Reports LERs are required to be stbmitted as the events occur.
Frequency of LER submittal varies among the licensees of operating nuclear power plants, depending on the frequency of events.
In 1990, 111 operating nuclear power plants submitted 2,120 LERs; i.e., total responses.
The proposed relaxation of reporting requirements for some events involving certain ESF actuations will result in 150 fewer LERs per year.
The current LER review, coding and processing costs are as follows:
(1)
An estimated I staff-year or 2,100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per year are spent by NRC staff members (headquarters, regional, and resident inspectors) on various tasks including but not limited to the review of 50.73 reporting practices, review of plant operating history and licensee practices, and evaluation of the adequacy of the existi.ng rule.
At $115 per hour, this amounts to $241,500.
(With this amendment, there will be proportionate savings in this expense category).
(2) program support cost, contractor cost, etc., is about
$3,500,000.
(With this amendment, there will be proportionate savings in this expense category).
1)
Nearly 37 staff years involving occasional to full-time effort of 250 NRC personnel are expended in LER review and follow-uo actions each year.
The efforts include cvent analysis, inspection, enforcement, feeoback to the industry
4.
and the world nuclear community,,and possible reassessment of the regulatory requirements.
Proposed changes-in_the LER rule are expected to result.in about-150 fewer LERs.
These selected events arezaiready determined to have no safety significance, therefore, there is very little time expended in reviewing these events, and there-is virtually no follow up actions on these_ events'.
(With this amendment, there will be no proportionate savings in-this expense category).
There will be the following estimated savings to the Government in processing, coding and information storage activities related to these events, as follows:
Staff estimates that it requires an average of 2,100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> to review 2,120 LERs-submitted annually or approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per LER.
The type of events being eliminated by this rulemaking:are estimated to require only 2/3 hour to review.
150 x 2/3
= 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> or, at $115 per hour
= $11,500 Program cost savings
$3,500,000 x (150/2120)
= $248,000 Total annual savings
= $11,500 + $248,000
= $260,000 13.
Estimate of Industry Burden The proposed amendments will eliminate approximately 150 notifications under 50.72 and 150 LERs under 50.73.
The burden reduction is estimated as follows:
50.72:
0.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> x 150 = 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />
[
50.73:
50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> x 150
= 7,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> Total burden reduction
= 7,537 hours0.00622 days <br />0.149 hours <br />8.878968e-4 weeks <br />2.043285e-4 months <br />.
However, in response to the proposed amendments, estimated reduction in-burden is being elicited from the licosees along with their comments.
14 Peasons for Change in Rurden Reviews af Mactor operational experience over the-past several years have.ndicated that certain reportable occurrences of minimal er no safety significance are currently being reported.
NRC has initiated rulemaking efforts to relax certain event reporting requirements.
This amendments to 10 CFR 50.72 and 50.73 rulemaking erforts, wnen implemented,-are expected to result in a
'k e
___E_______..___~____________._______
e decrease of about 150 LERs per year._ The result would be a further reduction in-licensee burden of about 7.537 hours0.00622 days <br />0.149 hours <br />8.878968e-4 weeks <br />2.043285e-4 months <br />, 15.
Publication for Statistical Use
.Not applicable.
B.
Collections of Information Ecolovina Statistical Methods The collection of information does not employ _ statistical methods, it
- [
(7590-01]
HUCLCAR REGULATORY COMMISSION Documents Containing Reporting or Recordkeeping Requirements: Office of Management and~ Budget Peview AGENCY:
Nuclear Regulatory Commission (NRC).
ACTICH:
flotice of the Office of Management and Budget Review of Information Collection.
SUMMARY
The Nuclear Regulatory Commission has recently submitted to the Office of Management and Budget (OMB) for review the'following proposal for collection of information under the provisions of the Paperwork Reduction Act-(44 U~.S.C. Chapter 35)..
1.
Type of submission, new, revision or extenston: Revision.
2.
The titi of the information collection: 10 CFR 50.72 and' 50.73, Proposed Minor Rulemaking to Modify.0perating ' Reactor Event Reporting Requirements.
3.
The form number if applicable: NRC Forms: 366, 366A, and 3668.
4 "Jw often the collection is requirea: On Occasion.
5.
Who will be required or asked'to' report: Holders.:of Operating Licenses for Commercial Nuclear Power Plants.
6.
An estimate of the number of responses:~1t.-is estimated that annually this rulemaking would eliminate the notification of 150 events under 50.72, and the submittal of 150 LERs under 50.73.
7 An estimate of the total number of hours needed annually to complete the requirement or request: It is estimated that annually this rulemaking would eliminate 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> of reporting under 50.72 and 7,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of reporting under 50.73.
8.
Section 3504(h), Pub. L.96-511. applies: Applicable.
9.
Abstract: This rulemaking would eliminate notification requirements under 50.72 and LER submittal under 50.73 for certain invalid engineered safety feature (ESF) actuations that are of no safety significance.
ll.
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, D.C.
Comments and questions can be directed by mail-to the OMB reviewer:
fi..
Ronald Minsk Office of Information and' Regulatory Affairs (3150-00ll and -0104).
NE08-3019 Office of Management and Budget Washington. D.C.
20503 Comments can also be submitted by telephone at (202) 395-3084.
The NRC Clearance Officer is Brenaa Jo. Shelton, (301) 492-8132.
Dated at Bethesda, Maryland this day of 1992.
For the Nuclear Regulatory Commission.
Gerald F. Cranford Designated Senior Official for Information Resources Management 4