ML20199E971

Notice of OMB Review of Info Collection & Solicitation of Public Comment

ML20199E971
Person / Time
Issue date:	11/06/1997
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
NUDOCS 9711240056
Download: ML20199E971 (15)

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[759001-P]

U. S. NUCLEAR REGULATORY COMMISSION Agency Information Collection Activities: Sutsission for OMB Review: Comment Request AGENCY: U. S. Nuclear Regulatory Commission (NRC) /

ACTION: Notice of the OMB review of information collection and solicitation of public comment.

SUMMARY

The NRC has recently submitted to OMB for review the following proposal for the collection of information under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35). The NRC hereby informs potential respondents that an agency may not conduct or sponsor, and that a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number,

1. Type of submission, new, revision, or extension: Revision s A

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2. The title of the information collection: 10 CFR Part 54,

" Requirements for Renewal of Operating Licenses for Nuclear-Power Plants"

3. The form number if applicable: Not applicable

4. How often the collection is required: One-time submission of operating license renewals and occasional submissions for holders of renewed licenses.

S. Who will be required or asked to report: Commercial nuclear power plant licensees who renew operating licenses.

6. An estimate of toe number of responses: 1.33 responses (4 renewal applications during the 3-year clearance)

7. The estimated number of annual respondents: 1.33 respondents

3. An estimate of the total number of hours needed annually to complete the requirement or request: Approximately 89.333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br /> (85,333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br />'one-time-reporting burden and 4.000 recordkeeping burden)

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9, An indication of whether Section 3507(dh Pub. L 10413 applies- Not applicable

-10. Abstract: 10 CFR Part 54 of the NRC regulations,

" Requirements for Renewal of Operating Licenses for Nuclear Power Plants," specifies the procedures, criteria, and standards governing nuclear power plant license renewal, including information submittal and recordkeeping requirements, so that the NRC may make determinations necessary to promote the health and safety of the public.

A copy of the final supporting statement may be viewed free of charge at the NRC Public Document Room. 2120 L Street. NW (lower level) Washington. DC.

OMB clearance requests are available at the-NRC worldwide web site (http://www.nrc. gov) under the FedWorld collection link on the home page' tool bar. The document will be available on the NRC home pagE site for 60 days after the signature date of this notice.

4 Comments and questions should be directed to the OMB reviewer by (insert date 30 days after publication in the Federal Reaister):

Norma Gonzales Office of Information and Regulatory Affairs (3150-0155)

NE08-10202 Office of Management and Budget Washington, DC 20503 Comments can also be submitted by telephone at (202) 395-3084.

The NRC Clearance Officer is Brenda Jo. Shelton, 301-415-7233.

Dated at Rockville, Maryland, this M8 day of Ll /er 1997.

For the Nuclear Regulatory Commission.

WA .

Brenda Jo. SipffoMlearance Officer Office of th. hief Information Officer 1

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PAPERWORK REDUCTION ACT SUBMISSION Please read tbinstructions before completing this form. For additional forms or assitance in completing this form, contacs

- your egency's Paperwork Clearance Of ficer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of infonnation and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503 1, Agency / Subagency originating request 2, OMB control number _

U.S. Nuclear Regulatory Commission X a. 3150 0155 b. None d Type of informatten collection (check onel 4. Type of review requested (check onel

a. New collection X a. Regular submission c. Delegated X b. Revision of a currently approved collection b. Emergency . Approval requested by {dateh

c. Extenseon of a currently approved collection 5. Will this informaison collection have a a.Yes

- significant economic impact on a

d. Reinstatemerit, without change, of a previously approved substantial number of small entities? X b.No collection for whsch approval has expired

o. Reinstatement, with change, of a prevtously approved collection for which appeoval has expsred X a. Three years from approval date Requested _,,,

6 expiration date

f. Exionng collection in use without en OMB control number

7. Title -

10 CFR Part 54, Requirements for Renewal of Operating Ucenses for Nuclear Power Plants

8. Agency form number (s) (if appliceb/e/

N/A

9. Keywords Administrative practice and procedure, age-related degradation, incorporation by reference, nuclear power plants and reactors, reporting and recordkeeping requirements _

10. Abstract 10 CFR Part 54 of the NRC regulations, " Requirements for Renewal of Operating Licenses for Nuclear Power Plants," specifies the procedures, cr teria, and standards goveming nuclear power plant license renewal, t including information submittal and recordkeeping requirements, so that the NRC may make determinations necessary to promote the health and safety of the publia.

, Q Affacted putac rMar* prwaary w m *PLamt a# erews par acety wim 'Jri t2 obhgetion to respond IMart prwnaqr w,e *P* amp a# oiswa ther apety wefn x S a Inttevwfuels or households d F arms a Voluntary P b ausmess or other for-profit e n'ederei oovemtrent b Required to obtem or retam benefits c Not-for-profit anstituteons i State. Local, or Tnbet Govemment P c Mar.datory t3 Annual reportmg and recordkeepmg hour burden 14 Annual reportmg and recordkeepmg cost burden rne thousamre et ab#ars, a %mber of respondents 4 a Total annuanied capitsi/startup costs o b Total annual responses 1.) 3 b Total annual costs IO8.M) o

1. Percentage of these responses e Tolal annuahzed cost requested O j cottee:ed electronicedy 0  % d. Current OMB Inventory 0 c Total r.nnual hours requested 89.333 e oifference o d Current oMO mventory e4,5oo ' E"P enation i of difference e oifference 24,333 t Program change f Empianation of difference 2 Adi ustment 1 Program change 2 Adiustment 24,833 16 Purpose of information collection 16 Frequency of recordkeepmg or reportmg (Chect e# ther apply /

IAfert primary with *P* and e# ethers that apply with ** */ X e Recordkeeomg b Third party disclosuvo e Apphcation for benefits e Program plannmg or management X c Reporting

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b Progeam evaluation f Research X l 1 nn occasion 2. Weekly 3 Monthly

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e Genere) purpose statistics p g Regulatory or comphance 4 ousrterty 6 SentennuaHy 6 Annueuy d Audit 8 Other (describel 7 nA 17 Statistical trotnods t8 Agency contact / person who cert best answer euestions regardmg the l, content of this avbmssa,on) i ooms this information conection errway statist >ce6 methoos) l Name Roberta K. Ingram, NRR C Yes X No

, enone 301-415-1219 l

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FINAL SUPPORTING STATEHENT FOR 10 CFR PART 54

" REQUIREMENTS FOR RENEWAL OF OPERATING LICENSES FOR NUCLEAR POWER PLANTS" (OMB Clearance No. 3150-0155)

Extension Request with Revised Burden Estimate DESCRIPTION OF THE INFORMATION COLLECTION The /xomic Energy Act, which permits renewal of licenses, and 10 CFR 50.51,

" Continuation of 1.icense," do not contain specific procedures, criteria, and standards that must be satisfied in order to renew a license. Effective January 13, !992, the Nuclear Regulatory Commission (NRC) issued 10 CFR Part 54. This regulation establishes the requirements that an applicant for renewal of a nuclear power plant operating license must meet, the information that must be submitted to the NRC for review so that the agency can determine whether those requirements have in fact been met, the application procedures.

and recordkeeping requirements.

An amendment to 10 CFR Part 54, effeuive June 7,1995, clarified the requirements, eliminated unnecessary terminology, and simplified the integrated plant assessment. In addition, it reduced applicant burden. The final rule was published in the Federal Reaister on May 8, 1995 (60 FR 22461).

A. JUSTIFIC/d10B

1. Need for and Practical Utility of the Collection of Information The regulatory philosophy underlying 10 CFR Part 54 is founded on two key principles. The first principle of license renewal is that, with the possible exception of the detrimental effects of aging on the functionality of certain systems, structures, and components (SSCs),

and possibly a few other issues related to safety only during the i period of extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provide and maintain an acceptable level of safety so that operation will not be inimical to the public health and safety or the common defense and security. This regulatory process. modified for the

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[,  : period of extended: operation tolinclude the management of the.

a detrimental effects of: aging on the functionality of certain SSCs. -

M ensu'res that the licensing bases will_ provide and maintain an-

acceptable level of shfety. Part 54 focuses the. Commission's review on this:one 56fety issue but provides leeway for the Comission to-consider, on a case-by case basis, other issues unique to extended operation.

i The second and equally important principle is that each plant's current licensing basis (CLB) must be maintained during the renewal term, in part through a-proijram of age-related degradation management for certain SSCs as defined in 10 CFR Part 54.

To determine the necessary actions that are needed to "onstitute aging management programs, renewal applicants must perform an integrated pl. ant assessment (IPA).

In this assessment. SSCs that are within the scope of license renewal are' identified and screened to determine  :

which SSCs require actions to manage the detrimental effects of age-related degradation. The required aging management actions are then identified, described, and justified. The applicant is required to report in its application the screening methods used, the list of structures and components requiring aging management for extended operation resulting from the screening, and the aging management actions that have been or will be taken, together with their bases.

The NRC wi'l review the application to determine the adequacy of the licensee actions taken and to be taken, as a basis for approval or denial of a renewed license. The inspection, ';urveillance, testing, and maintenance actions involved in the aging management program include the requirement for recordkeeping and availability of those records to the NRC for review or audit as part of the NRC's regulatory oversight programs.

The specifics of the information~ collections and the reasons for them are as follows:

c 10 CFR 54.13(b) requires each applicant to notify the Commission.of '

.information identified by the applicant as having, for the regulated activity, significant implication for public health and safety or the common defense and security. Notification by the applicant must be

-made within two working days of identifying the information. The NRC needs this information 50 that it may take appropriate actions, as 2

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i required. to protect-the public's health and safety.

10 CFR 54!17. Filing _of Application, requires the filing of an -

- application for a renewed license in accordance with Subpart A of 10 -

CFR Part 2-and 10 CFR 50.4 and 50.30, This-section establishes the

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procedural aspects of the filing. The information to be included. in- ,

the application is addressed in 10 CFR 54.19, 54.21 and 54.-23.

discussed below.

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10 CFR 54.17(g) reautres the. applicant for a renewed license to agree in writing that it will_not permit any individual-access to-Restricted f ' Data until an investigation has been made and reported to the

^ -Commission on the character. association and loyalty of such individuals. This information is recessary to. assist the Commission in determining that. permitting such persons access to Restricted Data will notl endanger the common defense and security. .

10 CFR 54.19. Contents of Application - General Information, requires '

applicants for license renewal to provide the general information '

j .specified in 10 CFR 50.33(a) through (e) (h), and (1). The 1 application may incorporate this information by reference. The NRC needs this information to establish the continued validity, during the renewal term, of general information applicable during the original license, o

10 CFR 54.19(b) requires each application to include conforming changes to the standard indemnity agreement, 10 CFR 140.92. Appendix

8. This is needed to account for the expiration term of the proposed renewed license.

L 10 CFR 54.21. Contents of Application - Technical Information. -

requires applicants for license renewal to provide information as n ~follows:

L 10_CFR 54.21(a) requires an IPA. The IPA must:

• Identify and. list those'SSCs subject to an aging' management review.-

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Describe and justify the methods used to identify those SSCs that

-require aging management review. The NRC needs tMs information 3

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to be able to conclude tnat additionaliaging_ management attention.

is directed;to SSCs-that' require it becauseithey_are'important-

and can~ undergo age-related degradation that-is.new or different -

-or not previously evaluated for-the' renewal. term.

-* Otmonstrate the adequacy of actions _ taken or to be taken to manage the detrimental effects of age-related degradation on functionality. - The NRC needs this information to be satisfied that the actions will be effective in assuring the_ continued safe operation of the plant.

-10 CFR 54.21(b) requires the application to contain CLB changes during NRC review of_the application. Each year following submittal of the o

license renewal application and at least 3 months before scheduled completion of the NRC review, the applicant must subtit an amendment to the renewal application that. identifies any change to the CLB of the facility that materially affects the contents of the license renewal application, including the FSAR supplement. The NRC needs this information to determine the acceptability of these changes from the pertinent safety standpoints.

10 CFR 54.21(c)(1) requires the applicant to provide a list _of time-limited aging analyses for SSCs that conform to the definition provided in 10 CFR 54,3 and a demonstration tnat the analyses remain valid for the period of extended operation, that they have been projected to the end of the period of extended operation, or the effects of aging-on the intended function (s) will be' adequately managed for the period of extended operation. The NRC needs this information to determine whether those SSCs meet the requirements for license renewal.

10 CFR 54,21(c)(2) requires a listing of all plant-specific exemptions granted pursuant to 10 CFR 50.12 and in effect that are based on time-limited aging analyses-as defined in 10 CFR 54,3. An evaluation must be provided that justifies the continuation of these exemptions for the period of extended operation. The NRC needs this information to determine whether continuing'these exemptions is justified.

10-CFR 54,21(d) requires applicants. to include in the application an FSAR supplement ~for the facility, This supplement must contain a summary description of the programs and activities for managing the 4

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e effects of aging and the evaluation of tine-li:aited aging analyses for the period of extended operation as determined by 54.21(a) and (c).

The NRC needs this information to determine whether the licensee's actions for managing the effects of aging provide reasonable assurance that the facility's operations during the extended period of operation can be conducted without endangering public health and safety.

10 CFR 54.22. Contents of Application - Technical Specifications, requires applicants to include in the renewal application any technical specification changes or additions nccessary to manage the effects of aging during the period of extender 1 operation. The justification for these changes or additions must be contained in the license renewal application. The NRC needs this information to determine the acceptability of these ch wges from the pertinent safety standpoints.

10 CFR 54.2d, Contents of Application Environmental Information, requires each application for license renewal to include a supplement to the environmental report that complies with Subpart A of 10 CFR Part 51. The NRC requires this infcrmation to determine whether the environmental consequences of the cantinued operation of the facility during the renewal term will continue to be acceptable. The burden associated with the environmental data is incorporated unoer the burden for 10 CFR Part 51.

10 CFR 54.3'/ Additional Records and Recordkeeping Requirements.

establishes reteation and update requirements.

10 CFR 54.37(a) requires holders of renewed licenses to retain in an auditable and retrievable form for the term of the renewed operating license, all information and documentation required to document compliance with 10 CFR Part 54. The NRC needs access to this information for effective continuing regulatory oversight.

10 CFR 54.37(b) requires, after the renewed license is issued, licensees to include in the FSAR update required cy 10 CFR 50.71(e) any SSCs newly identified that would have been subject to an aging management review or evaluation of time-limited aging analyses in accordance with 54.21. This FSAR update must describe how the effects of aging will be managed cuch that the intended function (s) will be effectively maintained du. J the period of extended operation. The 5

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j TSAR update contains information on all of the changes made by the licensee to the plant since the original FSAR was submitted or, as  ;

appropriate, since the last FSAR was submitted. The NRC needs access to this information for effective cont %uing regulatory oversight.

2. Aaency Use of the Information The information will be used by the applicants for and holders of renewed nuclear power plant operating licenses as a basis for the establishment and conduct of their aging management programs and by the NRC in its regulatory oversight to require reasonable assurance that the continued operation of the nuclear power plants during the renewal term will provide reasonable assurance of the adequate protect'c of the public health and safety and the common defense and security.

3. Ikduction of Burden Throuah Information Technoloav There is no legal obstacle or any obstacle in 10 CFR Part 54 to licensees reducing the burden associated with this information collection by use of information technology or otherwise. Moreover.

NRC encourages its use; however. at the current time, no responses are submitted electronically.

4. flfD.tt to identify Duolication and Use Similar Information Information collection requirements of 10 CFR Part 54 do not duplicate other federal information collection requirements and are not available from any source other than applicants or licensees. The Information Requirements Control Automated System (IRCAS) was searched to identify duplication: none was found.

r, . Effort to Reduce Small Business Burdgu Not applicable.

-6. Consecuences to Federal Proaram or Policy Activities if the Collect 10D is Not Conducted or is Conducted Less Freauently The records generated as_ a result of 10 CFR Part 54 would be partly provided at the time of application for renewal and made partly 6

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available on a continual basis during the period of extended operation. Reporting of information is required only as identified under A.1, above. Less frequent collection would increase the risk i that programs for age related degradation management would r.ot be i sufficiently current to assure maintenance of the current licensing basis during the period of extended operation.

l 7. Circumstances Which Justify Variation from OMB Guidelines The two day reporting period required by 10 CfR 54.13(b) varies from OMB guidelines but is necessary so that the Commission is informed promptly of information having a significant implication for public health and safety or the common defense and security.

The recordkeepir.g requirements of 10 CfR Part 54.37 exceed OMB's requirements by mandating that records be kept for the duration of the renewed license. A retention period for the full term of the renewed license is necessary to ensure that data are available for establishing equipment aging trends.

8. Consultat1Dns Outside the NRC Opportunity to comment on the collection was published in tne [ eden 1 Realster on August 8. 1997 (62 FR 42844). Comments were received from the Nuclear Energy Institute (NEI). In summary NEl agreed that the collection of information is necessary: that the burden estimate for preparing the applicaticn will vary from plant to plant and will probably decrease as more experience is gained; that enhancing the quality. utility, and clarity of the information that is collected is always an objective and that after the experience of the first applications. NEl will be in a better position to make specific recommendations. Further. NEl commented on ways the burden of information collection can be minimized by suggesting a significant reduction in the number of Iard copies required of the application and supporting documentation.

The NRC agrees in principle with NEI's comments and is working toward a reduction in hardcopy submittals. Eventually. the NRC will be replacing hardcopy submittals with electronic subn.ittals.

l Presently, we do not have that technology in place, but are l

progressing toward that end for the near future. Applicants and l

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licensees are advised to consult the appropriate sections of Title 10 of the Code of federal Regulations for current copy requirements,

9. Payment of Gift to Resoondents Not applicable.

10. Confidentiality of Information None except for proprietary information which would be handled in accordance with 10 CFR 2.790 of NRC's regulations.

11, Justification for Sensitive Questions Not applicable.

12. Estimated Industry Burden and Burden Hour Cost it is anticipated that the paperwork burden will vary widely among nuclear power plant licensees. As licensees learn more about age-related degradation management, the burden on licensees will likely be reduced. All nuclear plants are somewhat different and the programs employed by individual plants, while similar, are not exactly the same. Nevertheless, it is estimated that, on average, under 10 CFR Part 54 each licensee who submits an application for license renewal will incur approximately 94,000 staff-hours of paperwork burden to satisfy NRC's review requirements. Of this amount, approximately 64,000 staff hours are attrited ta one-time implementation actions (reporting) and the remainder, 30,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, represents a recurring annual recordkeeping burden. This recordkeeping burden, when considered over an assumed 30 year period from the time of application submittal to the end of the renewal term, amounts to about 1,000 staff-hours per year. These estimates capture the licensee's engineering and management licensing reviews, and clerical activities identified in 10 CFR Part 54.

It is estimated that during this 3-year clearance period the NRC will receive 4 license renewal applications. Based on this estimated number of applications and the estimated burden / cost, the total annualized burden to industry is expected to be 89,333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br /> at a cost 8

of $11.7 million (4 applications x 64,000 one time reporting burden hours + 3 years + 4,000 [1,000 annual recordkeeping burden hours x 4 applicationsJ x $131/ hour),

13. Estimate of Other Additional Costs None.

14. Estimated Annualized Cost to the federal Government The NRC paperwork burden for 10 CFR Part 54 is estimated to be about 45,000 staff-hours per nuclear power reactor. Of this amount, about 7,300 staff-hours are expected to be incurred as part of the review of the licensee's application submittal. The balance of the NRC's estimated effort, about 38,000 staff-hours, will be incurred on a continuing basis starting cs soon as the renewed license is granted (assumed to be approximately 3 years after receipt of the application) and continuing to the end of the license renewal term. This equates to an annual burden of roughly 1,300 staff hours per reactor. This effort would be expended to review licensees' ongoing aging assessments and aging management activities.

The staff estimates that during this 3 year clearance period the NRC will receive 4 license renewal applications. It is also assumed that one license renewal is granted in 2001, thus incurring, during this clearance period, a burden of 1.300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> for one year. Based on this estimated number of applications and the burden / cost estimated above, the total annualized federal cost is expected to be $1.3 million (4 applications x 7,300 one-time reporting burden hours + 1.300 continuing burden hours x $131/ hour + 3 years).

These costs are fully recovered through fee assessments to NRC licensees pursuant '/ .0 CFR Parts 170 and/or 171.

15. Reasons for Chances < Burden or Cost There is no change in the estimated burden per application: however, we anticipate receiving 4 applications instead of 3 during this clearance period. Therefore, the overall burden represents a 33-1/3 increase from 67,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to 89,333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br />.

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16. PJ1blication for Statistical _111e None.

17. Reason for l{ot Disolavina the Exoiration Date The requirement is contained in a regulation. Amending the Code of federal Recu]ations to display information that. in an annual publication. could become obsolete would be unduly burdensome and too difficult to keep current.

18. Excentions to the Certification Statement Not applicable.

8. COLLECTION Of INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.

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October 7,1997 Ms. Brenda Jo Shelton NRC Clearance Officer U.S. Nuclear P.egulatory Commission, T-6 F33 Washington, D.C. 20555-0001

SUBJECT:

Notice of Pending NRC Action t<, Submit an Information Collection Request to OMB and Solicitation of Public Comment (62 Esd Heg.

42844)

Dear Ms. Shelton:

In response to the subject Federal Register Notice, the Nuclear Energy Institute (NEI)' is submitting comments for the NHC's consideration.

The Federal Register Notice informed the public that the NRC is preparing a submittal to the Office of Management and Budget (OMB) for review of continued approval ofinformation collections under the provisions of the Paperwork Reduction Act of1995. The NRC's submittal pertains to information that nuclear power plant. licensees will have to provide pursuant to 10 CFR Part 54,

" Requirements for Renewal of Operating licenses for Nuclear Power Plants."

Specifically, the notico solicited comments on four questions. The first question is whether collection of the information is necessary, We believe it is. Renewing the operating license requires the submittal ofinformation which ultimately will serve as the foundation for the NitC's decision to issue the renewed license.

The second question is whether the NRC's burden estimate of 89,333 man hours to complete the application is accurate. Preparing a renewal application involves a significant number of supporting activities, such as technical reviews, that are summarized in the application. These supporting activities and preparation of the

' NEl is the organtration responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including regulatory aspects of generie operational and technical issues. NEl members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, maior architect /engineenng firms, fuel fabrication facibues. materials licensecs, and other organtantions and ladwiduals involved in the nuclear energy industry.

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Notice of Pending MC Action October 7,1997 '

Page 2 application will vary from plant to plant because of unique plant design or the number of plants involved (e.g., one unit sites versus two unit sites).

Also, no renewal applications have been prepared or submitted. Therefore, it is difficult to estimate the number of person hours for completing an application. Our expectation is that the person hours required will probably decrease as more applications are submitted due to the benefit of the experience gained from die first license renewal application.

The third question in the Federal Register Notice asks about enhancing the quality, utility, and clarity of die information that is collected. Enhancing the attributes of the information is tdways an objective. , We will be in a better position to make specific recommendations in this area aller the experience of the first applications.

The final question in the Federal Register Notice solicits input on how the burden of information collection ctm be minimized. Presently, the regulations require submiltJll of 38 hard copics of the application. The license renewal application includes a supplement to the Environmental lleport. Pursuant to 10 CFR Part 51, 25 copies of the supplement must be submitted with the application; and 125 copies must be retained by the applicant for subsequent distribution. These numbers can be reduced significantly if only one or two hard copies of the application are submitted accompanied by an electronic version. A savings in person hours also may be realized if electronic filings are permitted in response to requests for additional information. Again, once the first applications are processed, a better estimate of this effort will be available.

We appreciate the opportunity to comment and trust this input is useful to the NRC.

Sincerely, .

) k' ( Wyb Anthony R. Pietrangelo t

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