ML20205K747

From kanterella
Jump to navigation Jump to search
Request for OMB Review & Supporting Statement Re 10CFR50, Domestic Licensing of Production & Utilization Facilities & 10CFR21, Reporting of Defects & Noncompliances. Combined Estimated Respondent Burden Is 2,666,178 H
ML20205K747
Person / Time
Issue date: 10/17/1988
From: Mcdonald W
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:
References
OMB-3150-0011, OMB-3150-0035, OMB-3150-11, OMB-3150-35, NUDOCS 8811010334
Download: ML20205K747 (13)


Text

~*  !

DESIGNAT,EC CUF 1L . >

Certif164 B7 -- _- h%

5's,d r.m s 3 '

1 v... pre- w u e Request for OMB Review important i Read instructions before completeg furm. Do riot use the same SF 83 Send three ccpies cf this form, the material to be reweed, and for  ;

to request octh an Liecutr.e Crder 12291 rev:ew af'd approval under paperwork-three coptet of the supportmg statement, to:

the Paperwork Reducten Act Answer alf c.cs!.cns in Part 1. If this ret.est is for reviian under C.0. Offica of Information and Regu!atory Aff airs 12291. comp' ele Part li ard ogn we regulatory cert.fication. If this Office of Ma iagement and Badget

request is for aper usi under the Paperwork Reduct on Act and 5 CFR Attention. oocket Ubrary. Room 3201 1320. shp Part li, cc.mp c;e Part lit and s gtt the paperwork certif<atio't. Washirgton, DC 2o5o3 PART l.-Complete This Part for All Requests.
1. Dewt, ertsagencs so B.reaJtice er g.nat ng request f Mencycoce l

U. S. Nuclear Regulatory Comission 3 1 5 0 p.oa e, nr -r.n e.rca ;TC%r esn ens restc.cs in s reccui wepnone nu.e c,er William R. Jones (301 1492-4442

(

Ci tie enninaten erect en e rme.-s ,

10 CFR 50, Domestic Licensing of Production and Utilization Facilities j I

i b. Lei s a." c .tr :1.r *e .n : . < ,* .7 av *. e t: ;e Jnaea 5:stes Gwe. P bt.c tan. c Enear..e 0 ceo

42 2201(o)  !

j _ _ . , L. - - _ _ . _ _ _ _ . . . _ . _ _ _

y 6.A v ,ac.x s : r:. n :N .. & 5[rert ai, c ,s o, eyp;o,m 1 0 :ne ve.4 s c nur 2 c, 3CIm 6 0 NonSrott inst 2tster's I 2 O state e ota gnerete-n a X] Ba aesses or etter 'o' orett 7 O Sc a l bus eesses cr organeaters j

-l PART ll.-Complete This Part Only if the Requestis le OMB Review Under Executive Order 12291 1  !

i 7. Regulaten ident.f e' NN'(5NN) i _ __. ___ _ _. - __ _ . o . hwa msned O ,

EType oi sr.imrsson (checa cae en eacn categerr) Type er reere.r regvesred .

, Classmcation Stage of development 1 C stancarg I I O us.or i O pre;eseo or e sti 2 O Pend ns [

2 O nonm,,or 2 O r e me,,,tu.enprerpropo a O tme<gex, -

l 3 C FM er derim fM. **t%A priur propnu a C Stat tary or 6,dd deadhre

~ r

! 9 (J A secticin atf ected i CFR

10. Does th s terwaten co .'.a n tet vteg o reco cAcerg recerements tr.at req +re OUB appeovat under the Paperwork Peoveten Act erid 5 CFR 1320' .

O ves O us -

[

! 11. It a maior ruos twre a eva'ary .mpact enaws attachev . ... , . 1 O ves 2 O sc l if"No." d.d. OMB na..e the ar'aws'

r/3 O ves 4 0 se I

Certif6 cation for Regulatory Submissions  ;

in submittms tna request for CMB re.ien, the ast$onced regeatory contact and the p'es'am ortic + crti y that the re<wrements of E o 12291 and any appi. cat,ie f

policy directivet kJte been compea w1M f

$ g 4ture of picg am oftec41 Cate [

1 I

f j 5g,atu,e of aanoreee repaiwr cortsct 1

8911010334 881017 _ - -

f

12. coa #8ve m 9 PDR ORG EU50MD  !

j PDC ,

S 83' '

eve a.aen me sitce St****'8 F *'mrt+4 Pesc 8 3 Le'r CV5 NsN Theo o0 634 4as4 S CFR 1520 r4 E c' 12291 ,

~

?

l , o PART lli.-Cernplete This Part Only if teve Roguest is for Approval of a Collection l ef inferenatten Under the C -d Reductlen Act and 5 CFR 1320.

as. Abstext-o crite needs, um and itfected evisc in so.oros = less

"Nuclear Facility Safety" r Proposed amendments to 10 CFR Parts 21 and 50.55(e) will eliminate dt.plicative reporting of defects establish less restrictive reporting thresholds for Part 21 and increase the a

! time frame between discovery and reporting of the defect.

I

14. Type of information con.ction (check oney arie) feesnenselse ecosselens nef coneedned h redes 1 O Re.Aer submesen 2 O tmers.acysus me n(certracetonart caed) k%rnestdan seasselens condedned h nds.

3O t t.ngrosa mn(riecAerwestep d) a rm.i or intenm fe.i .,tn.ut ener NpRu 7. toi., d.ie of e. ct.d or .cto.i r.d.r.i a 0 Notice of proceeed rol. making (NPRu) '

A O Regui.e suomes.en R esterpuwceton i 5 O Final, NPRM w.s previous'y pupsh.d e O tmers.ncy suomessen(certificaten ett caed) (maata. der.i++r) g* gp.ru l

l 1 S. Type of reven requested (caeck only one) i O New con.cten 4 O R nst i nt of a pr viously approv.o coii.cten for =*.cn approvei W empered 2 0 Reves,on of a currently approved conect,on 3 0. tat.nsen

.enout n,of toe eiceasen enane. date of in ene sunstance = inaene current m.tnod>y appte ed con.ction s O tates co i.cten m vs. .<nout an ous coatrei nummer of con.etion 1 s. Sqency report form numberts)(eclude stonderd/optenal form number (s)) 22. Purpose of .nformat.on conectnan(check as many as apply) l 1 O Appi4= ten for benefits l -WA 2 O Programevalusten

17. Annual reportg or dosclosure burden i O cenerai psepo e statistics 1 Namew of twoondents . . . . . . . , . 4 0 Regulatoryorcomphence 2 Numter of rnpoem per repondent . . Vas- 5 O Program piennrg or rnenagernent 3 Total annual responses (kne 2 temes boe 2) . . A*1 6 O Researen 4 wours per rapons. . . . . . Variet 7 O Audit

- _5 Tetai hoves nne 3 tan W o 2.594.178

18. Anevel recorcieepmg buroen 23. Fr quency of rworakeeping or reportes (casca eli that appry) 1 Namber of rworckeepers .

202 1 @ Recordweep.ng 2 Ann,.a: rears per eeco cheeper. V& Pies Reportsag 3 tetal recorenm..ng oours (w I rimes w 2) 1.107.461 2 3 on occase 4 Recarebeepeg 'etet on pened Li ferears 3 O weeoy 19 Totalannuaiburcen 4 0 pontm, 1 Reesested(lee 27 $ ptus kne 18 J) . 3,70L 639 _ 5 0 Quarter, 2 in current oMB mventory 3.70' 639._ e O sem..annuoy 3 oi'forence (Ane i dess kne 2) . . . . .

0 7 O Annuoy Draenetion of DIM.ronce g Q 8,enn ey 4 Prvam chaege . . . . 2 O other(sescno.).

5 AAvstment .

20. Current (most recent) oM8 control nwmter ar comment number 24. Respondents' ebi gation te cornpty (criecA rne stroegest o6tgete thaf sppJoes) 3150-0011 . O vo,,nte,,
21. na,ented eip.taten date 2 O Reasired to obtain or retain a benefit 12/31/89 3 8 uarmter,
25. Are tM respondents pr manty educattonal agences or institutens or is N 9nmary purpose of the cot'ection re4ted to Federat education prog,arns? O ves 0 No 26.eyooes enponce the asNats. use sampi.rtg to select respondents or does the agency cmmend or prescribe

. . . . . . Othe resuse 0 Noof sa

21. Regv6atory awtnority for toe eformaten colecten 10 crR._50  ; or rR  : or,otner(speces ):

Paperwork CertlMcetion in swtmttmg th s reqsest for oVB approssi, the agency head, the sensor offcal or an authorged reponentatne. co t.fies that the requirements of 5 CFR 1320. the Privacy A:t. stat.stest standa'ds or 6 rect:yes and any 9ther appiscabie informaten policy directives bate been compted with ignature of pryam offo" oate

~

5gv. ge y P ad 4 se

  • o' ca4 or sq astnorged eeor tatree Cate l

l M[, lam ral D PLAld, DirectM. Of f { ce nf Arimln{ ttration and Doeniteret Mat

. # CPo a 1964 0

  • 453-776

e

. . i 5"a,dr,msa (ner tene+w 1943)

Request for DMB Review l Importarit ,

Read instructons betore comp,et,rg form. Do t'ot use the same SF 83 Send three copies of this form. the material to be rey'eWed. and for to request both an Executae Order 1229; tev ew and approval under

. paperwork-three copies of the supportirg statement, to:

the Paperwork Reduction Act Answer all questions in Part I 11 t'ts request is for re iew under E.O. Offee ofInformation and Regulatory Affa rs 12291, comp'ete Pa't il and 5 g i tre regulatory certif: cation. If th:s Offee of Management and Bseget recuest is for approvat under tt e Paperwork Reduction Act and 5 CFR Attentien. Docket Library, Room 3201 1320, skip Part 11 cornp:ete Part 111 and 5 gn the pape wor k certification. WasNngton. 0C 20503 PART l.-Complete This Part for Ali Requests.

f bepetmentiagency and B<ew ewe or< nates reont 2. agency coo, l i

U. S. Nuchar Regulatory Comission 3 1 5 0 L

3. N,me e rein % c.ae but v.s.er e.nte regoc-g ir.. rewnt wepnone num, t

_ William R.J ones (301 ) 492-4442

4. t t.e of i-#ormate encte or reemars 10 CFR 21s Reporting of Defects and Noncompliances

(

f 5.ser: s. r ty t;r . G5 cc <:t en er eve tc re tmewers C.ce. Puenc Lan. or Estat .r 0' err)

I 42 ..

w 2201(o)

  • 1

. . - . I

- p

6. o ,; ; , c c c. , t-p n 5 C Federalageac es o' emp'03ees <

1 0 .nc. m a+$o'bcuseu ;s 3 C Far*hs 6 C Non profit ot; tat ons 2 O 5ta'e o* tocal go e rtre-:s r a E Busmesses or other fo' pref f 7 1 Small Dusenesses er orgat2ateet j PARTil.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. RegWatson ident.f er Ns* ber (RIN)

_ _ _ ~ _ _ _ _. or. None assped C l

[ Trw of wbmas on tchess ove e each cree ory) Type of revsew reevested Classification $tage of de rebopmerrt 4 Q stancarg  ;

i O Prorosedorcraft 2 Pending I O ua:or 2 C Nonmano, 2 O rirw ar e.ter,m rir,ai.-tn erer proposa- 3 O cme gency a O F.nai or everen est -two orer pr:cosa 4 0 siatutory or jud+aideadiene 978 secten atiecteo  ;

CFR _

10 Does (M re Waten certae re orteg or reconcieepirg reavirecrents that requne OM9 apnroval under trie Paperwor Redacten Act and 5 CFR 1 20?

. O vei ONo

11. If a maior rute. 4 two a regu ato*y unpact ansprs attached? ... . . .

. . 3 O v es 2 O no if Peo " d.d OMB ne..e the ana ps'

- 3 0 ves a O N:i C rtification foe Regulatory submissions in s.twettting tha req,+st for CV8 rev.ee. the asthorged regulatory contact and the prog *am ett.ciat ce tJy that the reew.reme,its of E O.12291 and any apphcable swicy ciroctses I se teen compted m'th Date bysture of pecvem o*toa Ipatwre of authorged ri g,tatory contact Date

12. t0h43 arse ontsI c m.4 tion ow<t.

~

, 63 tog '"* Q8M,N[g n NSN 754W6M40M s Cf R 1300 end t. C.10091

i PART lil,- -Complete This Part Only if the Request is for Approval of a Collection of Information Under the Paperwork Reduction Act and 5 CitR 1320,

13. Adstrect-oescribe needs, uses and affected pubhc in So words or less

, Nuclear Facility Safety, Proposed amendments to 10 CFR Parts 21 ana 50.55(e) will eliminate duplicative reporting of defects, establish less restrictive reporting thresholds for Part 21, and increase the time frame between discovery and reporting of the defect.

14. Type of :ntormation collecton (check only one)

Information conectione net centained he rules 10 Resuiersubms sion 2 O tmersency submession(certification attached)

Information conectione contained he rules 3 O Existeg resuisten (no chacee proposee) e rmal or eterim feel without pner NPRM 7. Enter date of espected or actual Federal 4 $ Notice of proposed rulemalung(NPRM)

  • A O Regutar submissen Register putAcaten at this stage of rulemakeg 5 0 Fmal. NPRM e ss pree ousiv published 8 0 tmersency submissen(cert,r< sten attechee) (monta aer ree'>:_.0 c t . 1988
15. Type of rev4 requested (check only one) 4 O Reinstatement of a previouser caeroved coiiecton ior .hich aparevei 1 O No.coriection .'as espired 2 @ Revisen of a currentty approved collecten 3 O t> tens.on of the e=p ration este of a curre, tty approved corecten 5 O taisiing coli cten in wie -ithout en oMe coatros numter without any change m tee substance or e the method of conection
16. Agency report form number (s)(incluce standard /optenal form number (s)) 22. Purpose of information conect2on (check as ma 9y as apprp)
O Appi+caton for benet.ts O Progra n esatuaton a
17. Annual reporting or d'Sciosure burden 3 O ceneraipuronestatist.

5 Ad astmeet .

24. Responcerts' otAgsten to comp'y (chec4 t%e strorgesi oclgafron that app 6es) ,
20. Current (mest rece-t) OMS coetroi num ter or eomment number 1 O wuntary

_ 3150-0035

21. Ra@nted esp at.on date 2 O Required to octa.n or retati a benet.t t 3 G M*ndate"r

__11/30/8A

25. A
  • the responderts ontrari ie s ducat'onal agenc.es or mst,tutens or is the primary purpose of the coliecten retated to Fede al educat.on pregram
26. Does t** agencg use sampi.rg to setect respondents or dcurs the agency recommead or prescribe tne use of sampMg . CorYes statistical h No ana by responcerts 2 7. l'egulatory authority for tSe informaton cobecton CF R .,31  ; or FR  : ot Ather / spec #fy).

10

' Paperwork Certification le subm.tti g th.s rea,est for CMS ac roial the agency head, tre sener cif cial or en authonted representatne certifes that t%e reqwrements of 5 CFR 1320. th Pr.tacy Act. stat'stical standards ce d.rectnes, and any other apptcable informaton poity directves bait teen comphed irt*i Date

$gnature el preg *am o*t ciel tat ve Date 5 g- W ar I pai or am avtmor; red ret ,

Wil.liam G. Mcdonald, Director, Office of Administration and Resources Mgt.

J

  • CFO 199 4 0 - 45 3-7y6 L

j OMB SUPPORTING STATEMENT FOR PROPOSED AMENDHENTS TO 10 CFR PART 21 "REPORTING OF DEFECTS AND NONCOMPLIANCE" AND 10 CFR 50.55(e), "REPORTING OF DEFECTS IN  :

DESIGN AND CONSTRUCTION f

,escr D pi tion of the Infomation Collection 10 CFR Part 21 requires directors and responsible officers of fims and  ;

organizations building, operating, owning or supplying safety-related compo-4 nents to NRC licensed facilities, or conducting NRC licensed activities, to l 1

report defects in components and failures that could create a substantial  !

safety hazard, 10 CFR 50.55(e) requires the holder of a facility construction l pemit to report any defect found in construction, any defect found in the  !

final design, or any significant breakdown in the quality assurance program, i A. Justification

1. Need for the Collection of Infomation. Part 21 was designed to l implement Section 206 of the Energy Reorganization Act of 1974(42 l U.S.C. 5846). Section 206 requires directors and responsible 3 officers of fims constructing, owning, operating, or supplying the 4 components of any facility or activity licensed under the Atomic Energy Act to report to the Comission the discovery of "defects" in "basic components" that could create a "suostantial safety hazard." '

! The purpose of Section 206 was to assure that the Commission has  ;

i prompt infomation concerning safety defects. In addition to 6

imposing obligatinns on the directors and responsible officers of NRC l licensees, Section 206 also imposes obligations on the directors and  !

responsible officers of nonlicensees that supply certain safety- f related components to licensed facilities or activities.

l Section 50.55(e) of 10 CFR Part 50, originally promulgated as a final l

.l rule on March 30,1972 (37 FR 6459), established unifom requirements 1

for reporting deficiencies occurring during the design and construc-1 tion of nuclear power plants. The rule was intended to enable the l NRC to receive pror?t notification of deficiencies and to have timely  !

j information on which to base an evaluation of the potential safety i consecuences of the deficiency and determine if further regulatory action is required. Therefore, the holder of a permit for the con-  !

struction of a nuclear power plant is recuired to notify the Comis-sion of each significant deficiency fount in the processes of design, manufacture, fabrication, installation, construction, testing, and

[

inspection, which if it were to have remained uncorrected, could have i adversely affected the safety or operations of the nuclear power plant at any time throughcut the expected lifetime of the plant.

The proposed revision of the existing regulations focuses on the {

following objectives:  ;

a. Eliminate duplicative evaluation and reporting i li More clearly and unifomly define the deviations that need to be

! b. l reported; j

] i s

., ', c. Establish uniform time limits for reporting; and

d. Establish a uniform content for reporting.

These revisions will reduce the amount of time expended by industry on complying with existing reporting and evaluation requirements, while still ensuring that deviations are identified and evaluated in a timely manner. The changes from the current CFR for accomplishing the above objectives are discussed below,

a. Eliminating Duplicative Reporting Requirements As noted above, Comission regulations contain several safety deficiency reporting requirements. Although distinctions exist between these requirements, staff expertence indicates a need to eliminate any duplication in reporting or evaluation among Port 21, 650.73,and550.55(e). A number of instances have occurred where the same deficiency in a component was evaluated by two different crganizations, one attempting to satisfy the criteria of Part 21, and the other attempting to meet the differently worded criteria of

$50.55(e). Although the original intent was for reporting under only one of these requirements to satisfy the other reporting require-ments, in reality, this intended method of reporting has not occur-red. In addition to the fact that the reporting criteria are different for each requirement, the lack of any explicit language in the regulations that addresses the duplicative reporting issue has led to duplication of both licensee (CP & OL) and NRC staff effort.

The proposed revisions to $21.2 would explicitly relieve the holders of construction permits under Part 50 frcm the Part 21 reporting requireeents because previously unreported defects discovered by the holder of a construction pemit are to be reported by holders of construction permits under 550.55(e). Similarly, proposed $21.2 would explicitly relieve the holders of operating licenses under Part 50 from the Part 21 reporting requirements because previously unreported defects discovered by a holder of an operating license are to Le reported by holders of operating licenses under $50.73 or 573.71. In addition vendors subject to the reporting requirements of Part 21 are relieved of reporting under Part 21 if a 50.55(e) or 150.73 report has been previously submitted for a particular defect.

Section 50.55(e)(8) is being revised to relieve the holders of construction permits under Jart 50 from reporting a defect under 1 550.55(e) if a report has been previously submitted under Part 21 for that particular defect. It should be noted that the contents of the reports under Part 21 and 550.55(e) will be structured in such a way as to ensure that the Comission is notified of the generic and plant-specific implications of any reported defect.

One alternative would be to incorporate all safety defect reporting by the holders of construction permits and operating ifcenses under l Part 50 now combined in Part 21, 150.55(e), 550.72, and 550.73 into a single regulation to be codified in 10 CFR Part 50. This alternative was rejected because each of these rules is ditected to different entities in the nuclear industry and as such incorporation would not

l result in any substantial improvement to the regulatory framework.

It is further believed that one regulation might be overly cumbersome and difficult to implement by the reporting parties.

b. Defining Defects To Be Reported Section 206 of the Energy Reorganization Act requires the reporting of "defects which could creat: a substantial safety hazard."

Existing $21.3(k) defines substantial safety hazard as "a loss of safety function to the extent that there is a r.ajor reduction in the degree of protection provided to public health and safety for any facility or activity licensed, other than for export, pursuant to Pa rts 30, 40, 50, 60, 70, 71, or 72 . . . ." In addition, the supple- ,

mentary information for the original Part 21 final rulemaking con-tained the following guidance on what constitutes a "substantial safety hazard":

- Moderate exposure to, or release of, licensed material;

- Major degradation of cssential safety-related equipment; and

- Major deficiencies involving design, construction, inspection, test, or use. l Section 50.55(e) requires the reporting of deficiencies in design and construction which could adversely affect the safety of operaticns of a nuclear pcwer plant and which represents:

- A significant breakdown in any portion of the quality assurance program; or

- A significant deficiency in a final design; or

- A significant deficiency in the construction of, or significant '

damage to a structure, system, or component requiring corrective action involving extensive effort; or

- A significant deficiency from perfomance specifications requiring corrective action invniving extensive effort.

NRC experience with both Part 21 and 150.55(e) reports has indicated that clarification of the type of deviation that is required to be  ;

reported would be helpful. Consequently, the proposed reporting >

threshole in 150.55(e) will be raised to that of 10 CFR Part 2L ,

c. Establishing Time Limits for Reporting and Evaluation l The )roposed revision to 150.55(e) would extend initial notification of tie Commission from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to two days. Part 21 proposed revisions would extend the followup written report time limit from 5 ,

days to 30 days. Note that the proposed deadlines appl to all entities within the scope of Part 21 and Section 50.55(y) e including materials licensees.

4 1

n. __ _ _ _ _ _ _ _ _ _

4 4

d. Reporting Content Both the Part 21 and 550.55(e) revisions establish a unifom content for the information that needs to be reported to the Comission.

Note that the proposed Part 21 and Section 50.55(e) required content applies to all entities within the scope of these rules including materials licensees.

These revisions will ensure that the Comission obtaine all the information necessary to evaluate and take corrective action in reference to a particular defect.

It should also be nsted that bth proposed 521.51 and 50.55(e)(7) clarify the specific records that must be maintained to ensure compliance with Part 21 and 550.55(e).

The infonnation collection requirerer.ts in the proposed rules are the following:

a. Section 21.21(b)(3)(1) requires individual directors or responsible officers subject to the regulations to notify the Comission by telefax or telephone within two days of identification, of defects or failures to comply wi+h applicable statutory or regulatory require-ments. Initial telefax or phone notification is necessary to ensure that the Comission is notified of any potential safety hazards that may require imediate attention,
b. Proposed section 21.21(b)(3)(ii) requires the submission of a written report to the Commission within 30 days of identification containing full infonnation on the nature of the defect or failure to comply.
c. Section 21.51 establishes recordkeeping requirements, with specific retention periods as follows:

(1) evaluations of deviations (necessary to ensure that deviations have beenSection five years, correctly evaluated))must 21.51(a)(1 . be retained for a minimum of (ei) notifications sent by vendors to affected purchasers or j licensees in relation to components with defects (necessary to l asture that purchasers and licensees have been alerted to l potential safety hazards) must be retained for a minimum of five

' years,Section21.51(a)(2).

(iii) lists of purchasers of basic components must be maintained for the lifetime of the component. Section 21.51(a)(,1).

l I

d. Section 50.55(e)(5)(1) requires the holder of a construction permit for a nuclear power plant to notify the Comission by telephone of defects within two days of identification. This initial notification is necessary to ensure that the Comission is promptly notified of any defects which may require innediate attention.

r . _ _ . . _ - _ _ __ _ _- _ . . _ _ -

5-

e. Section 50.5S(e)(5)(ii) requires the holder of a construction permit for a nuclear power plant to submit a written report to the Ccamission and a copy to the verdor of the product or service affected if the defect is determined by the licensee to be caused by or to be related to a vendor process, within 30 days of identification containing full information on the nature of the defect, i

Section 50.55(e)(5)(111) requires the submission of a written interim report to the Consiission within 30 days after determination that a deviation will not be fully evaluated in the initial 30 day period, containing all available information on the deviation.

f. Section 50.55(e)(7) establishes recordkeeping requirements, with specific retention periods as follows:

(i) procurement documents (necessary to ensure that background I specifications are available in order to evaluate >ctential defects) must be retained for the lifetime of the >asic j component,Section50.55(e)(7)(1),

(11) evaluations of deviations (necessary to ensure that deviations have been correctly evaluated) must be retained for a minimum of five years, Section 50.55(e)(7)(ii).

2. Agency Use of Information. The Part 21 and Sectir,n 50.55(e) reports have contributed to improve safety of nuclear power plants and have resulted in NRC bulletins, circulars and infonnation notices. All i reports received by the Comission are evaluated and acted upon
promptly.
3. Reduction of Burden Through Information Technolony. There are na legai obstacles to reducing the burden associated with this informa-tion collection, in fact industry organfrations (INPO, AIF) are urged to share and distribute such information to all affected parties as
it becomes available. The NRC further disseminates significant j generic information to all affected parties via Bulletins and Infor-l mation Notices and encourages elimination of duplicate reports.

l Automated systems for tracking reports are being developed by NRC and l

industry and are being utilized to the extent possible, j 4. Effort to Identify Duplication. Cossiissicn regulations contain

, several safety de"iciency reporting requirements. Although distinc-

! tions exist between these requirements, instances have occurred where i the same deficiency was evaluated by two different organizations, one l attempting to satisfy the criteria of Part 21 and the other

, attempting to meet the differently worded criteria of 10 CFR I 50.55(e). Although the original intent was for reporting under only one of these requ' rements to satisfy the other reporting l

I requirements, in reality, this intended method of reporting has not occurred.

The staff is planning to revise the regulations to eliminate this duplication. The intent of the proposed revisions is to establish

6-the filing of one report for each defect, with the reporting obligation resting on the entity that discovers the deffetency.

5. Effort to Use Similar Infomation. 10 CFR Part 21 was designed to implement section 206 of the Reorganization Act of 1974(42U.S.C 5846). As such it is the only regulation which currently requires directors and responsible officers of firms and organizations building, operating, or owning NRC licensed facilities, or conducting NRC licensed activities, to report defects in components and failures to comply with regulatory requirements which could create a substan-tial safety hazard. As such, similar usable infomation is not cur-rently available within NRC or industry to accomplish the intended purpose of Section 206 of the reorganization Act of 1974.
6. Effort to Reduce Small Business Burden. Approximately 12,000 organizations, licensees, and non-licensees, are under the scope of Part 21. Approximately 450 reports are submitted to the NRC annually under Part 21 by approximately 100 respondents. A majority of these respondents are not considered small businesses. The NRC has studied the possibility of reducing the burden on small businesses and has concluded that it would not be possible to lessen the burden on small businesses and still receive reports required by Section 206 of the Energy Reorganization Act.
7. Consequences of less Frequent Collection. This rule requires reporting of defects which could create a substantial safety hazard.

As such it has no specific period for reporting but rather requires reporting as the need arises. Less frequent collection of such infomation could reduce the NRC effectiveness in the areas of assessing potential generic safety issues and in disseminating such infomation to affected parties.

8. Circumstances Which Justify Variation from OMB Guidelines. Records are required to be retained beyond the 3 year limit established by OMB. This longer record retention is required in order to protect the health and safety of the public. It is necessary to be able to verify that deviations have been correctly evaluated or that poten-tial defects can be evaluated through specifications in procurement docuhants, etc. Therefore, records are to be retained for either 5 years or the life of the equipment component.
9. Consultations Outside the NRC. The staff has utilized comments from the industry on the existing Part 21 and Section 50.55(e) reporting system in developing the proposed revision. In addition, the recom-mendations of the Presidential Commission on the Accident at Three Mile Island (Kemeny Commission) on the safety defect reporting system have also been taken into account.
10. Confidentiality of Information. Infomation which is identified as proprietary or confidential, which by being disclosed will do substantial harm to an organization's competitive position, could be withheld from disclosure under a Freedom of Infomation Act request if the Cosmission determines that it is in the public interest to withhold it.
11. Justification for Sensitive Questions. This rule does not request sensitive information.
12. Estimated Annualized Cost to the Federal Government. Cost is based on 560 per hour,
a. Section 21.21(b)(3)(1) telephone notification will involve an hour per response. With 300 responses, total staff time is 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />, for a cost of $18,000,
b. Section 21.21(b)(3)(ii) written notifications will involve 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> per response. With 300 responses, total staff time is 3300 hours0.0382 days <br />0.917 hours <br />0.00546 weeks <br />0.00126 months <br />, for a cost of $198,000.
c. NRC review of Section 21.51 records will amount to approximately 1260 hours0.0146 days <br />0.35 hours <br />0.00208 weeks <br />4.7943e-4 months <br /> annually for all respondents. Total annual cost is

$75,600.

d. NRC staff will devote approximately one hour to each Section 50.55(e)(5)(1) telephone notification. Total staff time is 675 hours0.00781 days <br />0.188 hours <br />0.00112 weeks <br />2.568375e-4 months <br /> annually. Total annual cost is $40,500,
e. NRC staff will devote approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per response on each Section 50.55(e)(5)(ii) and (iii) written report. Total staff time will be 4725 hours0.0547 days <br />1.313 hours <br />0.00781 weeks <br />0.0018 months <br />. Total annual cost is $283,500,
f. NRC review of Section 50.55(e)(7) records will amount to 9000 hours0.104 days <br />2.5 hours <br />0.0149 weeks <br />0.00342 months <br /> annually for all respondents. Total annual cost is

$54,000.

The total annual cost to the Federal (kvernment is estimated at 11,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> or $669,600.

13. Estimate of Burden
a. Section 21.21(b)(3)(1). The telephone notification will involve a > proximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per response. With 300 annual responses, tie total burden is 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />. Total cost at $60 per hour is

$18,000 annually,

b. Section 21.2(b)(3)(11) written notifications will involve approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per response. With 300 annual responses, the total burden will be 24,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Total cost at

$60 per hour is $1,440,000 annually.

The total burden to respondents for reporting under Part 21 is estimated to be 24,300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> at a total cost of $1,458,000 per year.

c. Section 21.51 recordkeeping costs are as follows:

(1) 521.51(a)(1)willinvolveretaining8evaluationsper respondent per year with a burden of 0.375 hours0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br /> per evaluation. Total burden per respondent is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />

. ', per respondent. With 60 respondents, total burden is 180 i

hours or $10,800 per year.

(ii) 521.51(a)(2) will involve retaining five notifications sent to affected purchaser or licensees per respondent at a

' burden of 0.375 hours0.00434 days <br />0.104 hours <br />6.200397e-4 weeks <br />1.426875e-4 months <br /> per not < tication, for a per respondent annual burden of 1.88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br />. With 60 respondents total burden is 112.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> or $6750 per year.

(iii) 621.51(a)(3) will involve retaining 250 documents listing purchasers of basic components at a burden of 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> per respondent. With 60 respondents, the total burden is 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br /> or $115,200 per year.

The total burden to respondents for recordkeeping under Part 21 is estimated at 2212 hours0.0256 days <br />0.614 hours <br />0.00366 weeks <br />8.41666e-4 months <br /> or $132,720 per year.

5 Thus, the total burden torespondents for 10 CFR Part 21 is 52,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> or $3,132,000,

d. The450.55(e)(5)(1)telephonsnotificationwillinvolve j approximately 675 responses per year at one hour per response for a burden of 675 hours0.00781 days <br />0.188 hours <br />0.00112 weeks <br />2.568375e-4 months <br />. Total cost is $40,500 annually.

4

e. The650.55(e)(5)(ii)and(iii)writtennotificationswill
involve approximately 657 responses per year at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per j response, for a burden of 16,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />. Total annual cost is 4 therefore $972,000 annually.

Thus,totalburdentotherespondentsforreportingunder550.55(e)

! is estimated to be 16,875 hours0.0101 days <br />0.243 hours <br />0.00145 weeks <br />3.329375e-4 months <br /> and $1,012,500 annually.

i

f. The 650.55(e)(7) recordkeeping requirements impose the following
burden

1

! (1) 550.55(e)(7)(1) procurement documents involve retaining j approximately 1000 documents per respondent per year at a burden of 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br />. With 15 respondents, the total annual l burden is therefore 1875 hours0.0217 days <br />0.521 hours <br />0.0031 weeks <br />7.134375e-4 months <br /> or $112,500.

l (ii) 550.55(e)(7)y(11), retention approximatei 160 records of evaluation per respondent records at a burden of involves

0.125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> per record per year. Total burden per respondent is 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. With 15 respondents, total annual burden is 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> or $18,000.

Total burden to respondents for recordkeeping under 550.55(e) is thus, estimated to be 2175 hours0.0252 days <br />0.604 hours <br />0.0036 weeks <br />8.275875e-4 months <br /> or $130,500 per year.

j The total burden to respondents for $50.55(e) is, thus, estimated to be 19,050 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> or $1,143,000 per year.

14. Reasons for Chance in Burden. The burden estimated here represents a j programmatic decrease in the burden estimated under the current i

u

l clea rance. This is due to reduced number of duplicate reports compared to those historically submitted under the current rule. .

This decrease is due to the eliminateion of duplicate reporting.

Also, the estimate more accurately represents burden to respondents based on discussions with respondents and includes a correction and re-estimate of the actual burden imposed by current CFR requirements.

Additionally, there has been a historic decrease in the number of responses under both 10 CFR part 21 and $50.55(e). This decrease is reflected in the Section 13 estimates.

15. Publication of Statistical Use. Data collected through this tvle provides the input for generic inforvation notices and bulletins.

Each report is tabulated in t computerized data base and tracked to i resolution. The data contained in the computerized system is not  ;

published except as it is reflected in notices and bulletins.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in the collection of infonnation.  ;

i l

>