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iER S 533 ATTACHMENT 3 Regulatory Analysis 8511210301 851022 PDR FOIA PDR BELL 85-361
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WR 8 425 REGULATORY ANALYSIS 1.
PROPOSED ACTION 1.1 Description The Commission proposes to revise 10 CFR Part 73 to clarify and improve the. reporting requirements for safeguards events.
This effort includes con-forming amendments to 10 CFR Parts 70 and 74.
- 1. 2 Backaround of and Need for Prooosed Action In 1973, the Commission established safeguards reporting requirements in order to be kept informed of events potentially inimical to public health and safety. These requirements solicited specific reports of unaccounted for ship-ments, incidents and attemp' ts of theft or unlawful diversion of special nuclear material, or. incidents and attempts of sabotage.
It was determined, however, at a later date, that the Commission required reports of events that represent a loss of safeguards capability or are indicative of an overall plan to commit an act of theft or sabotage. The Commission was concerned that a substantial safety hazard could occur as a result of a deficiency in the safeguards system.
In response to this concern, an amendment to 10 CFR S 73.71 was proposed in October 1979 (44 FR 60743) requiring reports of events threatening or lessening the effectiveness of the safeguards system.
This amendment was published in January 1981 (46 FR 4858) as a new paragraph (c) to S 73.71.
The purpose of paragraph (c) is to provide information concerning security system failures whereby the NRC could identify recurrent safeguards problems and generic issues.
The intention is to keep pertinent NRC Offices informed of prcblems at facil-ities, so that security problems can be identified and eliminated.
Since the promulgation of S 73.71, licensees have commented that the reporting requirements are confusing.
This has led to inconsistencies in what is reported and the level of detail provided. Without some level of uniformity _
and detail, the usefulness of such reports is limited because an adequate data base cannot be established for generic analysis.
To reduce this confusion, the 1
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MAR R 1555 NRC is proposing revisions to SS 70.52, 73.71, and 74.11 and issuing a revised regulatory guide (5.62) to assist licensees in determining what should be reported and to provide a format for doing so.
f 1.3 Value Imoact of Proposed Action 1
1.3.1 NRC Operations The proposed revisions and associated guidance will facilitate analysis of safeguards events by requiring standardized reporting. NRC costs will be decreased because of the decrease in number of telephonic and written reports notwithstanding an increase in time to analyze more detailed written reports.
Reports of transportation / import / export events are so infrequent (comprising
.5% of the events) that a separate cost a'nalysis was not done.
These events are included as part of the 600 safeguards event reports received annually by the NRC.
Current NRC headouarters costs are estimated to be:
Documenting and analyzing reports (600 telephonic reports /yr/
0.5 hr/ report x $60/hr) + (600 written reports /yr x 1.0 hr/
report x S60/hr) + (600.10g entries /yr/0.5 hr/ entry x $60/hr)...... $72K NRC costs after revisions to 10 CFR S 73.71 are estimated to be:
(assuming an 80% reduction in telephonic and written reporting, and a 20% reduction in log entries) (120 telephone reports /yr/
0.5 hr/ report x.560/hr) + (ICQ written. reports /yr x 4.0 hrs /
report x' S60/hr) + (480 log entries /yr x 0.5 hr/ entry x $60/hr)....
546.8K*
1.3.2 Industry Ooerations The proposed revisions to 10 CFR S 73.71 are expected to reduce the burden on the licensees due to the reduction in telephonic and written report notwith-standing an increase in written report content.
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^The 525.2K dif ference represents less than 0 5 man years of effort distributed over headquarters IE, NMSS, AE00, and the Regions.
Therefore this amendment should not require formal changes to office budgets.
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Current Costs to the Industry (Assuming 600 reports made annually to the NRC pursuant to S 73.71 divided by 48 sites--approximately 12.5 reports / site / year are filed.) The number of reports made by other licensed facilities and carriers is negligible.
Telechonic Reoorts (Assuming 1.5 hrs / report x 12.5 reports / site x $60/hr) site cost / year...........................................
$ 1.1K Industry Cost / year....................................... $54K Written Reoorts
.. (Assuming 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> / report X 12.5 reports / site X $60/ hour) site cost / year...............................
$18.8K Industry Cost / year.......................................
$900K Log Entries (Assuming 0.5 hrs / report x 12.5 reports / site x 560/hr)
I site cost /yr...................................................
$0.4K
-Industry cost /yr...............................................
$17.4K Total Costs / Site.~...................................................
$20.3K Total Co s ts (Indus t ry).............................................. ' $971. 4K llew Estimated Costs to the Industry Telechonic Recorts
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-(Assuming an 80% reduction in telephonic reports -
2.5 reports / site x 1.5 hrs x $60) site cost / year...............
$0.2K Industry Cost /yr........
...................................... $10.8K
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e 9.AR 81555 Written Reports (Assuming an 80% reduction in written reports and 40 hrs /
report - 2.5 repor~ts/ site x 40 hrs x $60) site cost /yr.........
$6.0K Industry cost /yr...............................................
$288.0K Loq Entries (Assuming an 20% reduction in log entries and 0.5 hrs / entry -
10 entries / site /0. 5 hr/ entry x $60) site cost /yr...............
$0.3K 4
1 Industry cost /yr.......................................,,,,,,,,
314,4g
. To ta l Co s t/S i te....................................................., $ 6. 5 K Total Costs (Industry)..............................................
$313.2K JTotal Decrease (Industry /yr)...................................
$658.2K
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1.3.3 Other Government Agencies The proposed action is not expected to affect other government agencies.
j 1.3.4 The Public The benefit to the public is reduced cost and better protection of nuclear power facilities because the NRC's ability to assess generic short-comings of securi.ty systems and thereby recommend or initiate improvement is
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- 1. 4 Decision on Procosed Action The benefit to be derived from this action is (1) a reduction in burden to the industry and (2) a more uniform and detailed data analysis system which-would provide-feedback to the industry for improving their safeguards systems.
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NAR S 1985 2.'
STATUTORY CONSIDERATIONS 2.1 NRC Authority The Atomic Energy Act of 1954, as amended, Section 161(8) provides author-ity for the Commission to prescribe regulations designed to protect the public health and minimize danger to life or property.
- 2. 2 Need for Environmental Assessment 5
i This proposed rule is the type of action described in categorical exclusion 10 CFR 51.55(c)(3).
Therefore, neither an environmental impact statement nor an environmental assessment has been prepared for this proposed rule.
- 2. 3 Relationshio to Other Existing or prooosed Reaulations These proposed regulations have been developed to be consistent and compatible with the preseni, event reporting requirements for power reactors i
(10 CFR 50.72 and 50.73) and to establish a comparable level for licensees authorized to utilize or possess SNM.
Evolving proposed NRC regulations have been considered to the extent practicable.
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MAR 8 :s55 ATTACHMENT 4 Dyaft Publ.ic Announcement e
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MAR 8 ng5 NRC PROPOSES TO CHANGE REPORTING REQUIREMENTS FOR SAFEGUARDS EVENTS The Nuclear Regulatory Commission is proposing amendments to its regulations to clarify requirements which govern the reporting of safeguards events--incidents involving the physical security of certain licensed nuclear facilities and activities.
The purpose of these reports is to keep the NRC informed of incidents which potentially could enJanger the public health and safety. They also provide an information base which is useful in identifying and analyzing physical security problems which may be common to more than one facility cr activity.
As proposed, licensees would be required to report to the NRC, by telephone and within one hour, significant events such as the theft of special nuclear mate-rial, acts of destruction against nuclear material and facilities, and the failure of major physical security systems. Written follow-up reports would have to be submitted to the NRC within 30 days.
Less significant events would be recorded in a licensee event log and copies of the log would have to be provided to the NRC every three months.
The current requiremen't that all safeguards events be reported to the NRC by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,with written follow-up reports to be submitted within five days would be dropped.
In addition to the proposed changes in reporting times, a new format for the reports is being proposed. Use of the proposed format would standardize reports from different licensees and would improve the quantity and quality of information available to the NRC.
Written comments on the proposed changes to Parts 70, 73, and 74 of the NRC's.
regulations should be received by (date). They should be addressed to the Secretary of the Commission, Nuclear Regulatory Ccmmission, Washington, DC, 20555, Attention: Docketing and Service Branch.
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ATTACHMENT 5 Draft Congressional Letter b
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!!AR 8 325 DRAFT CONGRESSIONAL LETTER
Dear Mr. Chairman:
i Enclosed for your information is a copy of proposed revisions to 10 CFR Parts 70, 73, and 74 which are to be published in the Federal Register.
The Nuclear Regulatory Commission is proposing to amend its regulations to clarify and improve the safeguards event reporting system. The proposed revi-sions will help the NRC establish a better data base for studying safeguards
. issues, decrease the licensee's reporting burden (number of reports made to the NRC) and decrease the licensee's cost for meeting the requirements.
Concurrent with the issuance of the proposed rule, the NRC staff is issuing a revision to the companion Regulatory Guide for public comment.
Both the proposed revisions and the Regulatory Guide will undergo a 90-day public l
comment period.
Sincerely,-
Enclosure:
- 1. Federal Register Notice
- 2. Revised Regulatory Guide I
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G TUR 8 %5 ATTACHMENT 6 Draft Daily Staff Notes Item
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,,. '. :. A, MAR 3 55 WEEKLY REPORT TO THE COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Procosed Rule to be Sicned by EDO On
, 1985, the Executive Director for Operations approved a proposed rule that would amend 10 CFR Part 73, " Physical Protection of Plants and Materials" to improve the clarity and effectiveness of the,present require-ments for the reporting of safeguards events of S 73.71.
The proposed rule also contains conforming amendments to 10 CFR Parts 70 and 74.
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