ML20133J162
| ML20133J162 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/1985 |
| From: | Triner E NRC OFFICE OF RESOURCE MANAGEMENT (ORM) |
| To: | Wilde R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20132B800 | List:
|
| References | |
| FRN-50FR34708, RULE-PR-73 AB46-1-36, NUDOCS 8510180301 | |
| Download: ML20133J162 (3) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMisslON
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NAR 2 51985 MEMORANDUM FOR:
Ralph M. Wilde, Program Assistant to the Director Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards FROM:
Edwin G. Triner, Director Division of Budget and Analysis Office of Resource Management
SUBJECT:
THE COST ANALYSIS GROUP'S (CAG) COMMENTS ON THE PEGULATORY IMPACT ANALYSIS OF THE PROPOSED REVISIONS TO 10 CFR 73.71 --
PEPORTING OF SAFEGUARDS EVENTS Please find attached CAG's comments on the regulatory impact analysis portion of the Revisions to 10 CFR 73.71 -- Reporting of. Safeguards Events. The analysis clearly shows cost reductions to both the NRC and industry resulting frem the proposed revisions. Our review concludes that no major changes are required. However, there are sore recommendations we effer which may be of use, even to your future inpact analyses.
Should you have any cuestions concerning this review, please contact Brian-Richter, X 27770.
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Edwin G'.
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Division of Eudget and Arclysis Office of Rescurce Montgement Attachrent:
As stated cc w/ attachment:
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~73 50FR34708 PDR
A8%-L THE COST ANALYSIS GROUP'S (CAG) COMMENTS ON THE REGULATORY IMPACT ANALYSIS OF THE PROPOSED REVISIONS TO 10 CFR 73 71 -- REPORTING 0F SAFEGUARDS EVENTS
.orepared by:
COST ANALYSIS GROUP 0FFICE OF RESOURCE MANAGEMENT l
t U.S. Nuclear Regulatory
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THE COST ANALYSIS GROUP'S (CAG) COMMENTS ON THE REGULATORY IMPACT ANALYSIS OF THE
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PROPOSED REVISIONS TO 10 CFR 73.71 -- REPORTING 0F SAFEGUARDS EVENTS This report is a review of the cost analysis portion of NMSS's value impact analysis of the Proposed Revisions to 10 CFR 73.71 -- Reporting of Safeguards Events. The report is provided under the direction of the Cost Analysis Group's (CAG) Charter.
The value impact analysis clearly shows cost reductions to both the NRC and industry resulting from the proposed revisions. Our review concludes that no major changes are required. There are, however, some recommendations we offer which may be of use, even to future value impact analyses.
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~First, there exist two handbooks which should be followed when preparing a value impact analysis. One is "A Handbook for Value-Impact Assessment,"
NUREG/CR-3568, and the other is "A Handbook for Cost Estimating," NUREG/CR-3971. Second, the analysis assumes there exist 48 sites. According to
" Licensed Operating Reactors," NUREG-0020, Vol. 8, No. 12, December 1984, there are presently 85 operating power reactors on 56 sites. We understand that your analysis of total industry cost is dependent upon the total number of industry reports made to the NRC, not the number of sites, hence this redification will have no change on your " bottom-line" estimate. Fourth, in confirming your calculations, we were unable to replicate one estimate. - On Page 3, under Leo Entries, you report the Industry cost / year to be $17.4K. We calculate the vaice to be $18K, but this has no significant impact on your results. Last, while paperwork cost burden is adecuately addressed in the ccst analysis, a specific statement should be included under 2. Statutory Considerations.
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