Text

Request for OMB Review & Supporting Statement Re 10CFR50, Domestic Licensing of Production & Utilization Facilities. Estimated Respondent Burden Is -342,400 H
	ML20207G153
Person / Time
Issue date:	12/23/1986
From:	Norry P; NRC OFFICE OF ADMINISTRATION (ADM)
To:	;
References
	OMB-3150-0011, OMB-3150-11, NUDOCS 8701060358
	Download: ML20207G153 (112)
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PART lil'.--Compi;te This Part Cnly if the Request is for Appr val af a Collection c f inf 7rm' tion Under the Paperwork Reduction Act and 5 CFR 1320.

13. Abst'att-Deschbe needs uses and affected pubhc in 50 words or less uNuclear facilities, nuclear powerplant construction" 10 CFR 50 specifies technical information and data to be provided to the NRC by applicants and licensees for construction and or operation of nuclear powerplants.

1.. Type of information cohection (check only one) laformation collections not containedin rules 1 O Regular submission 2 C Emergency subwssion(cerrafcat#onattached)

Informatbon collections contained in rules 31 Existing reguistion (no chanEe o'orosed) 6 Finai or mtenm final mithout pnor NPRM 7. Enter date of en pectec or a:tur rec <

4 U Notice e,f proposed rulemaking(NPRM) A U Regalar sue nission Register pubhcation at this stage of ruiemaa r, 5 ] Fena', NPRM was previously pubbshed B C Emergency submission (certficationattached) (montA day. yea-) _

3. Type of review requested (cherli only one) 1 C New collection 4 C Reinstatement cf a previously approved cohect.on tot wh.cn at p" has espaed 2 % Revision of a currenty approved cobection 3 O Estension of the espiration date of a currently app'oved conection 5 C Existing collection in use without an oMB contro' ru-te wrthout A* y chaepe in the s$taece or in t' e method c' cohection ,

16. Agency report form number (s)(incluce standard / optional form ns.mber(s)) 22. Purpose of information cohection (check as ma rf as ap;,j 1 O Apphcatenforbenefits NA 2 C Program evaluatc-

17. Annual report #g or c:sclosure burcen

3 C Generalpurposestatistics 1 Number of respondents . 20_L 4 @ Reguiatoryorcompi.nce i % Der et respenses per resoc ce * ! 1_1

6 t [ Frog'am p'anang or managen e-t 3 Tctal ann.ai responses (1,ne 2 times ,,s, : I 2,386 ! s O Researen 4 Hours per response i 1,087.4 I 7: e s v e toww#,3 t-es ime o 12,594,433 6

18. Annua' recorceeeping Durden

i 23. F requency of recorakeeping or reporting (checa al. Piet app 9) 4 1 Number of recordmeepers 20_2 !' 1 I R,co,o eeping 2 Annuaihours pe'recordkeeper. ,_ _6_a605 neport,ng 3 Tcta' recordkeep:rg hoars (line I times Isne 2) i1s334.216 l 2 0 onoccasion 4 Recordbeepeng retention pened Lifeprs' 3 C Weendy

19. Totai annua' carden l 4 O Monthly I Requested (1,ne 17-5 plus itne 18 3; . !3.928 6_4_9 5 0 ovarteriy 2 in cu' rent oMB insentory I4.271.04_9 6 0 semiannaany 3 D.fference (ue .' tess lice 2; -342 190 : I A,nua%

bottnation of d/tterence l' L U Btn > shy 4 Frogram enarge -342.400 s O otne co,3ce.u; 5 Ad.ustmeat i I 2f . Cucent(rnest ' era-" OMB cont'o nerte c' comrne . numter i 24. Resporcents' obligation tocomply(check the stro Eestoffara tnJ:SN F 3150.-0011 1 g y, ,, ,,,

li.lequested empaat.on cate 2 O Required to obtain or retain a bener:t 12/31/89 3 0 Mandatory

25. Are the respondents pnmardy educagonal agencies or institutions or is the pnrnary purpose of the coheClion related to Federal educat.on programs? O ves .

26. Dots the agency use samphng to seiect respondents or coes tne agency re:ornmend o' presente the use of samphng or statistical ana ys : -

ty rssponcents? u lies 3 N

27. Pepatc > r. tner t 'e't*e r*c- aSo* co* erMn 10 cFR 50 ; or FR ; or,other(specify)-

gr Paperwork Certification ir s & tt 15s rewest 'N Ct/P a::p o.at the agency read t*e semc* c'f ra c' a authe' red res'esentatrve certifies that the rec;'e >e-ts c' 5 UP 1 .

Pr va:y Act. statistica'standarcs or crectmes. and any othee appicabfe iafermat en pohcy oirecti es have been comphed witn.

S.gnatu'e of p ora- c a ia; c Dax S gr.atre of agency hea . tne se'uor o" c e e' an author,ree rep'esentative Date Patricia G. Norry, Director j' N u /;1 .23 4f l Office of Administration ' 8 7 "%

o cpo r 1984 0 - 453-776

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NUCLEAR REGULATORY COMMISSION wasmwoTow, n.c.aoses I

SUMMARY

(o .,g *T[ Request for DMB Review Information Collection Requirements i 10 CFR Part 50 i , .

1 In accordance with Section 3507 of Public Law 96-511 and regulations of the i Office of Management and Budget, enclosed for OMB review are Standard Form-83 I and Supporting Statements covering reporting, recordkeeping and application j requirements of 10 CFR Part 50 " Domestic Licensing of Production and Utiliza-

tion Facilities." It is requested that OMB grant NRC a three year clearance following this review.

! 10 CFR 50 regulations are promulgated by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the

Energy Reorganization Act of 1974, as amended, to provide for the licensing i and regulation of production and utilization facilities. They contain the i reporting, recordkeeping and application requirements as they are generally j applied in the NRC's licensing and regulatory process. Specific requirements

for each licensee are contained in documents called " Technical Specifications" i that are issued for every utilization facility licensed to operate. (See 10 CFR50.36) Guidance on acceptable means of compliance with 10 CFR 50 is provided through publications called NRC " Regulatory Guides." These " Guides"

) often cite standards and other requirements established by national standards

bodies such as the American National Standards Institute (ANSI) and the

! American Society of Mechanical Engineers (ASME).

10 CFR 50 affects various types of facilities, including nuclear power plants, j research reactors and test reactors, at various stages in the licensing process, including application, construction, operation, amendment,

! suspension, renewal and shutdown. Therefore, the number of respondents

actually affected by each requirement varies depending on the number of

. licensing requests initiated and/or completed and the number of regulatory l

reports required by operating events and/or conditions.

! Reporting requirements obviously are directed toward licensees or applicants.

However, reporting requirements may not only be reactor specific, but they may be of a type that applies to a site which is occupied by one or more reactors that have different licensees. Other requirements may be utility specific and, thus, refer to several reactors at more than one site. These considerations may cause apparent conflicts in the use of the terms licensees, reactor sites, or facilities in our individual estimates of burden.

. For estimating purposes, we have assumed the following annual average number l of respondents:

l Operating Power Reactor Licenses - 105 Operating Research/ Test Reactors - 75 Construction Permits - 22 New Applications for Construction Permits - 0 New Applications for Operating Licenses - 0 Applications for Amendments - 1000 (total for 105 power reactor licenses and 2 testing facilities)

In those instances where a reporting /recordkeeping requirement applies to both power reactor and research/ test reactor licensees, we have calculated a combined cumulative average burden of compliance. For requirements that are event dependent, we have estimated frequency.

To facilitate your review of the submittal, we have grouped the pertinent sections of 10 CFR 50 into logical parts, each with a separate Supporting Statement. A Sumary of the Statements is enclosed for your use (Enclosure 2).

Unless contrary to the statements below, no information is provided in the Supporting Statements for each separate part for the following:

1. Tabulation and Publication Plans Application information submitted to NRC is used to prepare NRC's Safety Evaluation Reports. Reportable information provided by licensees is systematically evaluated by NRC and made available in the Public Document Rooms unless deemed proprietary.

2. Time Table for Data Collections and Publication Not applicable unless specified.

3. Consultants Outside the Agency All requirements of 10 CFR 50 have been (or are currently) the subject of rulemaking proceedin considered (or is considering) gs during public which the Commission comments.

4. Sensitive Questions Not applicable unless specified.

5. Practical Utility of Information Collection 10 CFR'50 affects various types of facilities at various stages in the licensing process. The requested infomation is reviewed and acted upon consistent with the governing NRC regulation or the Atomic Energy Act of 1954, as amended, whichever is appropriate.

For example, when a submittal can be completed without adjudication, the collected information can usually be acted upon within 1 to 6 months. However, submittals which result in litigation may not be completed for 2-8 years.

Justifications for the number of copies r equired for various submittals, recordkeeping and record retention requirements are not generally included in the separate Supporting Statements. Rather, generic justifications are provided below.

.~ . _ ~.

Copy Requirements

i. 10 CFR 50 contains varying requirements for submission of multiple copies. In some instances requirements for copies are unstated and left to a later

determination to te specified by the NRC [e.g., See 50.30 (c)(2)]. On

j. March 26, 1985 (50 FR 11882) NRC published a proposed regulation (10 CFR 50.4).

l The proposed.10 CFR 50.4 would establish the procedures for submitting corres- t pondence, reports, applications, or other written communications pertaining to

! the domestic licensing of production and utilization facilities. .The proposed f i rule would indicate the correct mailing address for delivery of the communica-i tions and specify the number of copies required to facilitate action by the j NRC. Moreover, it is expected to resolve a number of problems that have ,

developed during the past several years regarding the submittal of applications-and reports. In addition to clarifying the procedures, this rule would result in a reduction in reproduction and postage costs for the affected licensees. A

, copy of that proposed rule was enclosed with NRC's letter to 0MB dated July 10, q 1985.

When the final rule is published, a copy will be submitted to OMB for j inclusion in the 10 CFR 50 case file.

Recordkeeping Requirements ,

i Recordkeeping required by 10 CFR Part 50 is of two broad types.. The first

(

type is the simple maintenance of copies of reports, letters, and other written !

documentation that already exist because of a reporting requirement found l

! elsewhere in the regulations or in the license and technical specifications. !

! The second type of recordkeeping is the generation and storage of reports ,

i because the information in the reports may need to be referred to for i

assessments or sthsequent evaluations of occurrences at the facility.

The large volume of records which are kept for 10 CFR Part 50 are required primarily by the technical specifications, the quality assurance program, i reportsofchangesspecifiedin50.59(b)andenvironmentalqualificationof

equipment. Thus, a specific recordkeeping burden has been calculated for each i

} of these technical areas. For all other technical areas, the recordkeeping l

burden was estimated to be 10% of the total burden (recordkeeping plus l reporting).

i i Record Retention Periods j i

j Specific retention periods are in general not identified in 10 CFR 50. In :

i most instances record retention periods are established by reference in ,

, plant-specific Techncial Specifications which indicate that a constructor or ;

licensee will or has established a Quality Assurance Program in accordance [

with NRC's Regulatory Guides 1.28 (Revision 3) " Quality Assurance Program Requirements (Design and Construction)" and Regulatory Guide 1.88 (Revision 2)

" Collection, Storage, and Paintenance of Nuclear Power Plant Quality Assurance Records." These Regulatory Guides in turn reflect the standards adopted by ANSI and other standards-setting organizations. !

4 i

In some cases, however, record retention periods have been designated in 10 CFR 50 to be determined by NRC on a case-by-case basis. NRC is continuing its effort to develop a NUREG publication that will list all recordkecm ag i requirements that NRC imposes on its licensecsApplicants; and, in Lonjunction with this effort, will amend its regulations to ensure that recordkeeping requirements contain specific retention periods. The records would generally be retained 3 years, 5 years,10 years or life of the equipment, tennination of license, etc. Those records that are retained beyond three years have been determined by staff to be directly related to public health and safety. These are primarily records required of reactor licensees as they relate to safety procedures and employee exposures.

Additional Requirements This submittal incorporates three (3) finalized and one (1) proposed information collection requirement under 10 CFR 50 that have been approved by OMB since our last overall submittal for 10 CFR Part 50 dated July 10, 1985. These requirements are itemized below and are described in detail in the cognizant supporting statements.

50.34(h) -

Access Authorization Plan (Insider Rule) 50.55(a) -

ASME Code requirements, incorporation of various Addenda and Editions 50.64 -

Highly Enriched Uranium 50.63 - (Proposed)-StationBlackout This submittal does not address the information collection requirements specified in 10 CFR 50.73, " Licensee Event Reporting System". The burden associated with this regulation is encompassed within OMB Clearance No.

3150-0104.

In submitting this request for clearance of 10 CFR 50, the NRC realizes its importance and ccmplexity are such that our staff must work closely with yours. Mr. Barry Pineles of our Office of General Counsel (492-7688) is available to provide any legal clarification and Brenda Jo Shelton (492-8132) of our Reports Clearance Staff is available to arranje for the participation of any NRC staff member that OMB staff may feel is needed at any meetings.

Enclosures:

1. Standard Form 83

2. Summary of Statements

3. Supporting Statements (Parts 1-24)

_ _ _ - . .-. -. . - = - _ _

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SUMMARY

OF SUPPORTING STATEMENTS 10 CFR 50 Annual Annual Number of Annual Annual Total Total Cost to.

Burden Hours Responses Recordkeeping Reporting Annual Annual Cost Federal P:rt Subject Per Respondent Annually Burden Hours 1 Burden Hours Burden Hours To Industry Government 1 Applications 0 0 0 0 0 0 0 50.30, 50.30a, (new applications not expected for the next 3 years) 1 50.33, 50.34, 50.54(bb),

and 50.55(d) ,

! 50.34(h), Access 267 10 0 2,670 2,670 $160,200 $48,000 -

3 Auth. (Insider)

Rule 3

50.55b, 200 5 100 900 1,000 $60,000 $30,000 Const. Pe r-j mit Ext.

Appendix X 0 0 0 0 0 0 0 and 50.462; i 50.33a and Appendix L;

Appendicies M, N, 0 and Q; 50.34(f), TMI 50.36 and (delineated in Part 2 of the Supporting Statements) i j 50.36a, Tech Specs - '

i

!

Based on 10% of total burden, except in the areas of Technical Specifications (Part 2); QA (Part 3); ASME Code (Part 3a);

l 50.59(b) reports (Part 12); and EQ (Part 20). See supportive discussion in the cognizant statements and in the " Summary,"

Request for OMB Review, 10 CFR Part 50.

I 2See Part 24 which addresses ECCS burdens.

l

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SUMMARY

OF SUPPORTING STATEMENTS 10 CFR 50 .

Annual Annual Number of Annual Annual Total Total Cost to Burden Hours Responses Recordkeeping Reporting Annual Annual Cost Federal P:rt Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government 50.59(c), 152 105 1,600 14,400 16,000 $960,000 $1,020,000 50.90, and 50.91(a) and (b),

License Amend.

Appl.

Appendices A&B, 50.55a, 50.55(f)-QA (Delineated in Parts 3 and 3a of the Supporting Statements)

Records 50.54(cc),

50.54(dd), .

50.63 and (Burden will be imposed when the rules become final) 50.74 (pro-posed) 50.80(b) 0 0 0 0 0 0 0 50.82, 300 5 150 1,350 1,500 $90,000 $403,200 licensee termination 2 50.36, 2,068 180 213,375 158,810 372,185 $22,331,100 $957,600 Tech Specs 3 Appendices, 11,541 131 660,903 851,057 1,511,960 $90,717,600 $9,071,760 A&B, 50.55(f)-QA 3a 50.55a, 27 127 1,394 2,006 3,400 $214,000 0 ASME Codes

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SUMMARY

OF SUPPORTING STATEMENTS 10 CFR 50 ,

Annual Annual Number of Annual Annual Total Total Cost to Burden Hours Responses Recordkeeping Reporting Annual Annual Cost Federal Part Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government 4 50.71, Bul- 8,820 50 44,100 396,900 441,000 $26,460,000 $1,080,000 4

letins and Generic Letters 5 50.48, 144 105 1,512 13,608 15,120 $970,200 $31,500 Appendix R, Fire Pro-tection 6 50.54(p), 476 105 5,000 45,000 50,000 $3,000,000 $756,000 Security 7 50.54(q, r, 4,679 180 84,225 758,025 842,250 $50,535,000 $326,400 and t)

Appendix E, Emergency t

Planning 8 50.71(e) 1,000 105 10,500 94,500 105,000 $6,300,000 $31,500 Updated FSAR 9 50.54(f) 290 202 5,850 52,650 58,500 $3,510,000 $331,200 Dath or Affirm 10 50.72 10 105 105 945 1,050 $63,000 $6,245,600 Notification of Events 50.73, (LERs) (see OM8 Clearance No. 3150-0104) i -iii-

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SUPMARY OF SUPPORTING STATEMENTS 10 CFR 50 ,

Annual.

Annual Number of Annual Annual Total Total- Cost to, Burden Hours Responses Recordkeeping Reporting Annual Annual Cost Federal Part Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government 11 50.55(e) 500 22 1,100 9,900 11,000 $660,000 $294,000 i Design and ,

Const. Defi- ;

ciencies 12 50.59(b) 2,000 180 288,800 72,000 360,000 $21,600,000 $864,400 Reports 13 Appendices 242 127 3,082 27,738 30,820 $1,849,200 $86,400 i G and H;

50.60, 1 Fracture Toughness l

14 Appendix 244 105 2,562 23,058 25,620 $1,537,200 $4,200 J, Contain.

Leakage l 15 50.35(b) 0 0 0 0 0 0 0 Periodic

, Reports (see discussion in the Statement with respect to negligible estimates) 16 50.71(b) 1 127 13 114 127 $7,620 $7,620 1

and Appendix C, Financial 17 50.54(w)(4) 4 50 20 180 200 $12,000 $720 Property i

Damage In-surance

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SupmARY OF SUPPORTING STATEMENTS 10 CFR 50 . .

Annual Annual Number of Annual- Annual Total Total Cost to Burden Hours Responses Recordkeeping Reporting Annual Annual Cost Federal Part Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government

! 18 50.34(g) 0 0 0 0 0 0 0

! Implementa- (see discussion in the Statement with respect to negligible estimates) ,

tion of SRP 19 50.44(c) 1,500 6 900 8,100 9,000 $540,000 $345,000 i Hydrogen Control 1

20 50.49, 406 127 5,080 46,540 51,260 $3,097,200 $83,280, Environmental (Includes one-time cost

) Qualification to industry and Federal i 1

I Gov. as discussed in i

Part 20) 21 50.62 52 127 0 6,604 6,604 $396,240 $670,560 ATWS (one-time cost to Industry and the Federal Government);

) 22 50.61 35 66 233 2,100 2,333 $139,980 $155,000 Pressurized Thermal Shock 23 50.64 Highly 158 31 -492 4,428 4,920 $247,200 $332,000

Enriched (one-time Uranium burden) 24 Appendix K, 559 3 0 1,670 1,670 $100,200 $100,200 50.46, ECCS, '

l includes l proposed j revisions i

Totals: 35,650 2,386 1,334,216 2,594,433 3,928,649 $235,484,940 $23,275,740

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SUPPORTING STATEMENT FOR Application for Construction Permit or Operating License 10 CFR 50.30, 50.30a, 50.33, 50.33a, 50.34, 50.34a, 50.34c, 50.34d, 50.34(h),

50.36, 50.36a, 50.54(bb), Proposed 50.54 (cc) and proposed 50.54(dd),

50.55(o), 50.55(d), 50.59(c),

Proposed 50.63 and 50.74, 50.80, 50.82, 50.90, 50.91(a) and (b),

and Appendices A, B, K (including 50.46), L, M, N, 0 and Q to 10 CFR 50 JUSTIFICATION The Nuclear Regulatory Commission (NRC) is authorized by Congress to have responsibility and authority for the licensing and regulation of nuclear power plants, research and test facilities, fuel reprocessing plants and other utilization and production facilities licensed pursuant to the Atomic Energy Act of 1954. To meet its responsibilities, the NRC conducts a detailed review of all applications for licenses to construct and operate such facilities.

The purpose of the detailed review is to assure that the proposed facilities can be built and operated safely at the proposed locations, and that all structures, systems and components important to safety will be designed to

( withstand the effects of postulated accident conditions, without undue risk to the health and safety of the public. Applicants are required by the Atomic Energy Act to provide such technical information and data that the NRC may determine necessary to assure the public health and safety.

Before a company can build a nuclear power plant at a particular site, it must obtain a construction permit from the NRC. Subsequently, the company must obtain an operating license from the NRC before it can operate the plant. The i

decision by NRC as to whether to approve a company's application for a construc-tion permit or an operating license is based largely on the staff's detailed review of the information provided by the company as part of its application.

Information provided by the applicant as part of the application is crucial to the licensing process as it provides NRC with the information it needs to make a decision with regard to the proposed plant's impact on the public's health and safety. Information required by the NRC to be included in each applica-tion for a construction permit or an operating license is addressed in the specific 10 CFR Part 50 sections for which this Supporting Statement is written. .

" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants,"

Regulatory Guide 1.70, Revision 3, indicates the information to be provided in the Safety Analysis Reports and represents a format for SARs that is acceptable to the NRC staff. Conformance with the Standard Format, however, is not required.

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_ _ __. ._ ~ _ . _ .,

o 0 Safety Analysis Reports with different formats will be acceptable to the staff if they provide an adequate basis for the findings requisite to the issuance of a license or permit. However, because it may be more difficult to locate needed information, the staff review time for such reports may be longer, and there is a greater likelihood that the staff may regard the report as incomplete.

Upon receipt of an application, the NRC staff will perform a preliminary review to determine if the SAR provides a reasonably complete presentation of the in-formation that is needed to form a basis for the findings required before issu-ance of a permit or lic.ense in accordance with 10 CFR Section 2.101. The Stan-dard Format will be used by the staff as a guideline to identify the type of information needed unless there is good reason for not doing so. If the SAR does not provide a reasonably complete presentation of the necessary informa-tion, further review of the application will not be initiated until.a reasonably complete presentation is provided. The information provided in the SAR should be up to date with respect to the state of technology for nuclear power plants and should take into account recent changes in the NRC regulations and guides and in industry codes and standards, results of recent developments in nuclear reactor safety, and experience in the construction and operation of nuclear power plants. The Standard Format should be used for both Preliminary Safety Analysis Reports and Final Safety Analysis Reports; however, any specific item that applies only to the FSAR will be indicated in the text by adding (FSAR) at the end of the guidance for that item. An entire section that is applicable only to the FSAR will be indicated by including (FSAR) following the heading.

Applications must contain information in three major categories to permit a

(

complete evaluation by the NRC. These categories are general information, safety information and environmental information which is submitted in two phases through a Preliminary Safety Analysis report (PSAR) and a Final Safety Analysis Report (FSAR).

The section of the regulation that addresses each category of information for construction permit and operating license applications and NRC's detailed need within each category of information is outlined below.

1. Construction Permit:

Section 50.30(a) provides for the filing of an application for a construc-tion permit.

a. Contents of Applications:

General information (Section 50.33, 50.33(f) and Appendix C). Here the applicant is identified and his financial qualifications are detaile6.

Section 50.33(f) requires applicants to submit financial information that demonstrates reasonable assurances that required funds are available. Financial information is necessary because the NRC must make a decision as to whether the applicant's financial resources are adequate to permit construction of the plant in a safe manner and to permit implementation of safety-related programs described elsewhere in the application. Appendix C outlines the informaton to be fur-i nished by the applicant in the construction permit application to establish financial qualifications.

i

Information required for antitrust review must also be included in the construction permit application. The need for such information is addressed in the Supporting Statement for Section 50.33a.

b. Safety information (Sections 50.34,50.34a,50.34a(a),50.34a(b),

Appendix B, Appendix E). Safety information is provided by the applicant at the construction permit stage in the Preliminary Safety Analysis Report (PSAR). Section 50.34(a) outlines the minimum information that is necessary in the PSAR to permit the NRC to perform a safety evaluation. Included in the PSAR are the design criteria and preliminary design information for the proposed reactor and comprehensive data on the proposed site. The PSAR also dis-cusses situations and the safety features which will be provided to prevent accidents or, if they should occur, to mitigate their effects on both the public and the facility's employees.

The principal features of the staff's safety review of the infor-mation provided in the PSAR by the applicant can be summarized as follows:

(1) A review is made of the population density and use characteris-tics of the site environs, and the physical characteristics of the site, including seismology, meteorology, geology and hydrol-ogy. This review is necessary to determine whether these characteristics have been evaluated adequately and have been given appropriate consideration in the plant design and whether site characteristics are in accordance with NRC siting criteria.

(2) A review is performed of the facility design, and of programs for fabrication, construction and testing of plant structures systems, and components important to safety for the purpose of determining whether they are in accord with the NRC regulations and other NRC requirements.

(3) A review is performed of the applicant's preliminary calcula-tions of the response of the facility to a broad spectrum of hypothetical accidents for the purpose of determining whether site acceptability guidelines are.catisfied.

(4) For the purpose of determining whether the applicant is techni-cally qualified to opercte the plant and whether he has estab-lished effective organizations and plans'for continuing safe operation of the facility, a review is made of the applicant's plans for:

(i) plant operations including. organizational structure, (ii) technical qualifications of operating and technical support personnel, (iii) planning for emergency actions to be taken in the event of an accident that might affect the general public

(

=

(elements of preliminary plannin0 that are required to be specified in the PSAR are set forth in 10 CFR 50.34(a) and Appendix E),

(iv) quality assurance (Appendix B) requires that the appli-cant provide in the PSAR, a description of the quality assurance program to be applied to the design, fabrica-tion construction, and testing of safety-related struc-tures, systems, and components.

(5) A review is made of the description of the preliminary design in systems to be provided by the applicant for control of radiological effluents from the plant. This review is neces-sary to evaluate the general adequacy of the systems proposed to control the release of radioactive wastes from the facility within the limits specified by the NRC regulations. Minimum information required by the NRC for this review is specified in Sections 50.34a(a) and 50.34a(b).

c. Environmental information. An Environmental Report, which provides a basis for the staff's evaluation of the environmental impact of the proposed plant, is specified as a requirement of the application for a construction permit in Section 50.30(f), but is justified as part of 10 CFR Part 51, " Licensing and Regulatory Policy and Proce-dures for Environmental Protection."

( d. If the proposed construction or modification of a facility is not completed by the latest completion date specified in the construc-tion permit, the permit shall expire and all rights thereunder shall be forfeited. However, if good cause can be shown by the applicant the Commission may extend the completion date for a reasonable period of time. The Commission will recognize, among other things, develop-mental problems attributable to the experimental nature of the facility or fire, flood, explosion, strike, sabotage, domestic violence, enemy action, an act of the elements, and other acts beyond the control of the permit holder, as a basis for extending the completion date. This requirement is specified in 10 CFR 50.55(b).

There are approximately 5 licensees who will be required to meet the regulations specified in 50.55(b) annually for the next 3 years.

Preparing and filing the information that NRC needs in order to com-plete its review of requests for extension of construction permits will involve approximately 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months per licensee annually. This represents an annual industry cost of $60,000 (200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months X 5 =

1,000 hours0 days 0 hours 0 weeks 0 months ; 1,000 hours0 days 0 hours 0 weeks 0 months X $60 = $60,000).

Based on experience, NRC estimates that 100 staff hours will be in-volved for reviewing each of the 5 requests for construction permit extensions. This totals up to 500 annual person hours. Thus, annual Federal cost is expected to be $30,000 (500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months X $60).

2. Operating License:

Pursuant to 10 CFR 50.55(d), at or about the time of completion of the construction or modification of the facility, the applicant' must file any

s -

1 additional information needed to bring the original application or li-cense up to date, and must' file'an application for an operating license or an amendment to an applicatior.,for a license to construct and operate the facility for the issuance of an' operating license, as appropriate, as specified in 50.30(d).

t Section 50.30(d) provides for the filing of an application for an operating license. The information provided in this application is essentially an update of the information categories (i.e., general, safety, and environ-mental) previously submittid in the application for a construction permit.

a. General information (Section 50.33). Except for electric utilities, Section 50.33(f) aTso requires applicants for operating licenses to submit financial information that demonstrates reasonable assurances that required funds are available. The applicant's financial quali-fications must be detailed as they were for the construction permit

-application, but'now the details must demonstrate that the applicant

, possesses or has reasonable assurance of obtaining the funds necessary to cover estimated operation costs for the period of the license, plus the estimated costs of permanently shutting the facility down and maintaining' it 'in a safe condition. The applicant shall submit

_ estimates for total annual operating costs for each of the first five

', years of operation of the facility and estimates of the costs to per-manently shut down the facility and maintain it in safe condition.

The applicant shall also indicate the source (s) of funds to cover

.these costs. An application to renew or extend the term of an operatidg license must include the same financial information as is k required in an application for an initial license.

b; Safetv information (Sections 50.34(b), 50.34(c), 50.34(d), 50.34a(c),

Appendix B, and' Appendix E). Safety information is provided by the applicsnt at the operating license stage in the Final Safety Analysis Report (FSAR). Section 50.34(b) outlines the minimum information that should be p'rovided in the FSAR to permit the NRC to perform a -

safety evaluation. This is essentially an update of information provided in the PSAR and allows the same editorial format. Among other things, the applicant must address the following items in the FSAR:.

l -

Pertinent details on the final design of the facility, including

~

final containment design of the nuclear core and waste handling system; the applicant's latest plans for operation of the facility, as well as substantive procedures for coping with emergencies (Appendix E provides elements of emergency planning to be considered in the FSAR); the quality assurance program (Appendix 8 requires that information pertaining to managerial and administrative con-

'l trols necessary to assure safe operation of the plant be provided in the FSAR).

l The final equipment design and procedures to be used by the appli-cant to control radiological effluents from the plant to permit the staff to' determine whether such systems can control the release of radioJctve wastes from the facility within the limits specified by NRC regulations. Information required by the NRC in the FSAR in this area'of review is specified in Section 50.34a(c).

s l 's s .,

l

_ u

., _c

.c. Physical Security-Plan (Section 50.34(c))

1 This plan describes the physical program that will be provided in accordance with the requirements of Section 50.34(c) to assure that the plant will la sufficiently protected against acts of sabotage that could cause releases of radioactive materials in amounts suffi-cient to represent a hazard-to the public health and safety. Also see Supporting Statement for 50.54(p).

Safeguards Contingency Plan (Section 50.34(d))

The Safeguards Contingency Plan, as provided for in 10.CFR 50 will provide a structured, orderly, and timely response to safeguards contingencies and will be an important segment of NRC's contingency planning programs. Licensee safeguards contingency plans will result in organizing licensees' safeguard resources in such a way that, in the unlikely event of a safeguards contingency, the re-sponding participants will be identified, their several responsi- i bilities specified, and their responses coordinated.

d. Environmental Information. Justified in the Supporting Statement for 10 CFR Part 51, OMB Clearance No. 3150-0021.

The staff reviews, in detail, applications for construction permits and operating licenses to determine if the public health and safety will be fully protected. These reviews are conducted in some 50 different techni-cal disciplines organized within the Office of Nuclear Reactor Regulation.

If any portion of an application is considered to be inadequate, the staff requests the applicant to make appropriate modifications or to provide needed additional information. In many cases, the staff review results in ,

modifications to the facility's design or operating procedures. The result of the staff review is provided in a Safety Evaluation Report. This report represents a summary of'the review and evaluation of the application by the staff relative to the anticipated effect of the proposed facility on the public health and safety. Safety Evaluation Reports are prepared for

+

both construction permit and operating license' applications. The public may obtain copies of Safety Evaluation Reports from the Public Document

Room.

j' No applications for construction permits or operating licenses are antici-pated during-the next three years.

Section 50.54(bb) requires that for operating nuclear power reactors, the licensee shall no later than 5 years before expiration of the reactor operating license, submit written notification to the Commission for its i

[ review and preliminary approval of the program by which the licensee in-tends to manage and provide funding for the management of all irradiated l

fuel at the reactor upon expiration of the reactor operating license until l

title to the irradiated fuel and possession of the fuel is transferred to

the Secretary of Energy for its ultimate disposal in a repository. Final Commission review will be undertaken as part of any proceeding for con-i tinued licensing under Part 50 or Part 72. The licensee must demonstrate i

to NRC that the elected actions will be consistent with NRC requirements

for licensed possession of irradiated nuclear fuel and that the actions will be implemented on a timely basis. Where implementation of such actions require NRC authorizations, the licensee shall verify in the notification that submittals for such actions have been or will be made to NRC and shall identify them. A copy of the notification shall be retained by the licensee as a record until expiration of the reactor operating license. The licensee shall notify the NRC of any significant changes in the proposed waste manage-ment program as described in the initial notification.

Negligible burden is anticipated for this regulation because no reactor licensee is expected to be required to meet this provision during the duration of this three year clearance.

3. Appendix K and Section 50.46 of 10 CFR Part 50, Emergency Core Cooling System (ECCS) Evaluation ModelsSection II of A ,pendix K delineates the documentation requirements for the Emergency ( are Cooling System (ECCS) evaluation models of Appendix K.

Section II-1.a requires that a description of each evaluation model be furnished and hat the description be sufficiently complete to permit technical reviEv of the analytical approach including the equations used, their approximations in difference form, the assumptions made, and the values of all parameters or the procedure for their selection. Section II-1.b. requires that the documentation be sufficiently detailed and specific such that changes to the model which result in a calculated fuel clad temperature different by more than 20 F from the temperature calcul-ated for a postulated Loss of Coolant Accident (LOCA) using the last previously accepted model shall be specified in amendments of the model description. Section II-1.c. requires a complete listing of each com-puter program in the same form as used in the evaluation model.

Section 11-2. requires that, for each computer program, convergency shall be demonstrated by modeling or noding studies and calculational time steps to provide sufficient data for a thorough review.

Section 11-3. requires that appropriate sensitivity studies be made for each evaluation model, to evaluate the effect on the calculated results of variations in noding, phenomena assumed in the calculation to predom-inate, including pump operation or locking, and values of parameters over their applicable ranges.

I Section II-4. requires that, to the extent practicable, predictions of the evaluation models, or portions thereof, be compared with applicable experimental information.

The reporting requirements delineated in Section II of Appendix K are needed to provide the NRC staff with sufficient information to judge the adequacy of the ECCS analysis and its compliance with the regulations.

The information provided under Section II-1.a. allows the NRC staff to assess the adequacy and validity of the overall technical approach used in a respondent ECCS evaluation model. Without this information, it l g would not be possible for the NRC staff to make such an assessment.

=

s The information provided under Section II-b. allows flexibility for small changes in an evaluation model while at the same time providing stability to an ECCS model. A change in an evaluation model that results in a calculated difference in the peak clad temperature of more than 20*F (approximately a 1% change in peak reactor power density) is considered by the NRC as being significant and, as such, should be documented in approved amendments to the model.

The information provided under Section II.l.c. allows the NRC staff to audit an evaluation model. This documentation is usually provided as a magnetic computer tape and is controlled by NRC to protect proprietary information.

The information provided under Section II-2, II-3, and II-4, allows the NRC staff to assess the mathematical stability of an evaluation model as well as its sensitivity to various physical phenomena and parameters ex-pected to occur during a LOCA. Comparison of model predictions with appli-cable experimental data permits the NRC staff to assess the technical validity of the calculational techniques and the accuracy of the predicted results.

Without the information required in Section II of Appendix K, the NRC staff would be unable to determine the adequacy of the calculational methods used to evaluate ECCS performance.

Burden for this provision is detailed in Part 24, which also includes supportive

, discussion for proposed revisions to ECCS rule.

4. 50.33a and Appendix L, Information Requested by the Attorney General for Antitrust Review Under the Atomic Energy Act as well as other laws to protect trade and commerce against unlawful restraints and monopolies, the NRC is required to report promptly to the Attorney General any information it may have with respect to atomic energy which appears to violate or to tend toward violation of antitrust laws or to restrict competition in private enter-prise. Further, upon request of the Attorney General, the NRC must furnish or cause to be furnished such information as the Attorney General determines to be appropriate for his advice on antitrust aspects of license applications for a utilization or production facility under section 103 of the Atomic Energy Act, as amended. The Attorney General's request is the basis for the NRC's antitrust reporting requirements.

During the effectiveness of this clearance, the NRC does not anticipate having to report antitrust information to the Attorney General. Thus, burden associated with this provision will be negligible.

5. 50.34(f) TMI Requirements Requires that applications for operating licenses contain the Three Mile Island related requirements relative to the way the requirements will be implemented or satisfied prior to issuance of an operating license.

These requirements include operational safety features, siting and i

e design,andemergencypheparednessandareintendedtoprovidesubstan-tial, additional protection in the operation of nuclear facilities based on experience from the accident at Three Mile Island and the various studies and investigations of the accident. Estimated burden for this requirement is zero because the NRC does not anticipate the submittal of applications for operating licenses during the duration of this clearance.

6. 50.36a Technical Specifications Requires each applicant for a license to operate a production or utiliza-tion facility to include in the application proposed technical specifica-tions. (Reference Part 2, " Technical Specifications" of the Supporting Statement for the burden associated with this requirement.) This section further requires that a summary statement of the bases or reasons for

! such specifications other than those covering administrative controls, be

~

included in the application, but shall not become part of the technical specifications.

6a. 50.34(h), Access Authorization Section 10 CFR 50.34(h) requires licensees to prepare Access Authorization Plans in accordance with criteria contained in Section 10 CFR 73.56 and sub-mit it to the Commission for review and approval.

The Commission's pursuit of an access authorization program is based upon the fact that the disoriented person and disgruntled employee, generic

! adversaries, are of primary safeguards concern because of their inside positions. Commission study has shown that the goal-oriented, technically sophisticated disoriented person, particularly the psychotic, is perhaps one of the most dangerous of the generic adversaries.2 Both the disoriented person and disgruntled employee may have inside access to restricted areas, files and sensitive security information. They are also privy to shop and loose talk and of ten have knowledge of critical and vulnerable areas of facility operation. Further, NRC records show that in 1984 out of a total of 111 safeguards event reported by licensees, 43 involved insiders. These events included drug-related incidents, vandalism, hoaxes, firearm incidents and other miscellaneous safeguards events.

The Access Authorization Plan will delineate how the licensee intends to implement the various requirements of this rule. The access program is discussed in the plan. It is anticipated that these (one-time only) provisions included in this rule will entail approximately 267 hours0.00309 days 0.0742 hours 4.414683e-4 weeks 1.015935e-4 months per 10 (site) respondents. Thus, a total of 2,670 hours0.00775 days 0.186 hours 0.00111 weeks 2.54935e-4 months are expected to be industry burden, at a cost of $160,200 (2,670 hours0.00775 days 0.186 hours 0.00111 weeks 2.54935e-4 months x $60).

Staff hours for this action are expected to be approximately 800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months .

Federal cost is, therefore, estimated to be $48,000 (800 staff hours x $60).

1NUREG 0459, Generic Adversary Characteristics Summary Report, U.S. Nuclear i Regulatory Commission, March 1979.

7. 50.59(c), 50.90, 50.91(a) and (b), Application for Amendment of License I

Section 50.59(c) requires the holder of a license authorizing operation of a production or utilization facility who desires a change in technical specifications, or who desires a change in the facility or procedures described in the safety analysis report, or who desires to conduct tests or experiments which involve an unreviewed safety question to submit an application for amendment of the license. Section 50.90 requires the application for amendment of license or construction permit to be filed with the Commission, fully describing the changes and following as far as applicable the form prescribed for original applications.

The requirement for the amendment of the license application is needed to enable the staff to evaluate any changes made at the facility or any new information concerning the facility that may potentially affect the safety of the facility and consequently the health and safety of the public. See the self-contained Supporting Statement prepared for 50.91(a) and (b), notification and State Consultation, for the burden associated with this regulation (page 15a).

7a. 50.63 (Proposed), Station Blackout The proposed 10 CFR 50.63 involves an issue concerning the reliability of the alternating current (AC) electrical power for essential and nonessential service in nuclear power plants. The AC electrical power is supplied pri-marily by the offsite (preferred) power supply; redundant onsite emergency AC I

power systems also are provided in the event that the preferred power source is lost. The loss of both the preferred and onsite emergency AC power sys-tems is called station blackout. This issue has been studied extensively by the NRC under Unresolved Safety Issue A-44, Station Blackout. As a consequence of these studies, the NRC is proposing to amend its regulations by adding a new Section 50.63 which would require that light water reactor nuclear power plants be designed to withstand a total loss of AC electrical power for a specified time duration and maintain reactor core cooling during that period. This proposed requirement is intended to provide further assurance that a station blackout will not adversely affect the public health and safety.

Burden will be imposed on the public when the rule is final.

8. 50.74 (Proposed), Licensee Notification to NRC Proposed 10 CFR 50.74 would require licensees of nuclear power facilities to notify the NRC within 30 days of a change in status of a licensed reactor operator. It is estimated that there will be up to 400 respon-dents a year, that will involve 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months each of staff effort. Thus, the total Federal cost is expected to be $24,000 ($60 X 400). Burden will be imposed on the public when the rule becomes final.

9. 50.80(b), Application for Transfer of Licenses NRC regulations in 10 CFR Part 50 establish requirements for the licens-(

ing of production and utilization facilities. The regulations were

issued pursuant to the Atomic Energy Act of 1954, as amended, and Tit 1e II

~

of the Energy Reorganization Act of 1974. Section 50.80, " Transfer of Licenses," specifies in paragraph 50.80(b) that an application for a transfer of a license shall include as much of the information described in sections 50.33 and 50.34 with respect to the identity and technical and financial qualifications of the proposed transferee as would be required by those sections if the application were for an initial license.

Section 50.80(b) also specifies that the Commission may require additional information, such as data with respect to proposed safeguards against hazards from radioactive materials, and the transferee's qualifications to protect against such hazards.

The requirements described above are needed to assure the transferee's financial capability to run the facility safely and to assure the trans-feree's technical capabilty to properly and safely operate the facility in a way that protects the health and safety of the public.

No aaplications for transfer of licenses are expected during the effective-ness of this clearance. Thus, burden associated with this provision will be negligible.

10. 50.82, Application for termination of licenses Section 50.82, Application for termination of licenses, specifies that any licensee may apply to the Commission for authority to surrender a license voluntarily and to dismantle the facility and dispose of its component parts. The Commission requires information, including information as to I proposed procedures for the disposal of radioactive material, decontami-nation of the site, and other procedures, to provide reasonable assurance that the dismantling of the facility and disposal of the component parts will be performed such that common defense and security and public health and safety will not be compromised.

The information provided by the licensee will be used by the NRC, staff to .

evaluate the safety and health aspects of dismantling the facility. Upon satisfactory evaluation, the Commission may issue an order authorizing such dismantling and disposal, and the termination of the license upon completion of such procedures.

Licensees for 15 plants plan to submit applications under the provisions of Section 50.82. This will result in approximately 5 applications annually for the next 3 years. It is estimated that licensee burden for preparing and filing information needed by NRC in order to complete its review of the requests for terminating license will involve approximately 300 hours0.00347 days 0.0833 hours 4.960317e-4 weeks 1.1415e-4 months per licensee annually. This represents an annual industry cost of $90,000 (300 hours0.00347 days 0.0833 hours 4.960317e-4 weeks 1.1415e-4 months x 5 = 1,500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months ; 1,500 x $60 = $90,000).

The NRC is currently reviewing 2 applications filed under Section 50.82.

The staff estimates that a total of 960 person hours will be required for completing the review of each of these applications and the 5 expected to be submitted annually. Thus, a total of 6,720 staff hours will be re-quired. Estimated cost to the Federal government is, therefore, expected to be $403,200 (60 X 6,720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months ).

4

10a. Decommissioning Rule (Proposed)

Licensing activities concerning decommissioning have been made on a case-by-case basis in direct response to licensee's requests to decommission and in current licensing hearing cases. This procedure results in a lack of uniformity of application, inefficiency on the part of the licensee and NRC in implementation, and finally a lack of timeliness and comprehensiveness that affects proper application of the ALARA principle in carrying out NRC licensing responsibilities.

In the case of a few non-fuel-cycle licensees, both a lack of avail-able funds to carry out decommissioning and improper termination procedures have occurred. This situation has potential for adverse effects on health and safety. The proposed rules would specify requirements for financial assurance, recordkeeping, and planning and termination procedures. Their implementation through the NRC licensing process would ensure that decommissioning would be handled by the licensee in a way that would result in minimal or even negli-gible impact on health, safety and the environment. This proposed rule encompasses Sections 50.33(k), 50.54(cc), 50.54(dd) and 50.82. Burden will be imposed on industry when the rule is final.

11. Appendix M, Standardization of Design Manufacture of Nuclear Power Reactors An application for a manufacturing license pursuant to Appendix M shall meet all the requirements of SS 50.34(a)(1)-(9) and 50.34a (a) and (b),

except that the preliminary safety analysis report shall be designated as

, a " design report" and any required information or analyses relating to site matters shall be predicated on postulated site parameters which shall be specified in the application. Such application also includes informa-tion pertaining to design features of the proposed reactor (s) that affect plans for coping with emergencies in the operation of the reactor (s).

Applications for this type of license are not anticipated during the dura-tion of this clearance. Therefore, estimated burden is zero.

12. Appendix N, Licenses to Construct and Operate Reactors of Duplicate Design at Multiple Sites This appendix sets out the particular requirements and provisions appli-cable to situations in which applications are filed by one or more appli-cants for licenses to construct and operate nuclear power reactors of essentially the same design to be located at different sites.

1. Except as otherwise specified in this appendix or as the context otherwise indicates, the provisions of this part applicable to' construction permits and operating licenses, including the requirement in S 50.58 for review of the application by the Advisory Committee on Reactor Safeguards and the holding of public hearings, apply to construction permits and operating licenses subject to Appendix N.

1

2. Applications for construction permits submitted pursuant to i g Appendix N shall include the information required by SS 50.33, 50.33a, 50.34(a) and 50.34a (a).

No applications for this type of license are anticipated during the du-ration of this clearance. Therefore, estimated burden is zero.

-(

13. Appendix 0, Staff Review of Standard Design The submittal for review of the standard design.shall be made in the same manner and in the same number of copies as provided in S 50.30(a), (c)(1) and (3) for. license applications.

This submittal shall include the information described in S 50.33(a)-(d) and the applicable technical information required by $$ 50.34(a) and (b),

as appropriate, and 50.34a [other than that required by 50.34(a)(6),

(a)(10), (b)(1), (b)(6), (i), (ii), (iv), (v), (b)(7), and (b)(8)]. The submittal shall also include a description, analysis and evaluation of the interfaces between the submitted design and the balance of the nuclear power plant. With respect to the requirements of $$ 50.34(a)(1), the submittal for review of a standard design shall include the site parameters postulated for the design, and an analysis and evaluation of the design in terms of such postulated site parameters.

Applications for this type of review are not anticipated during the dura-tion of this clearance. Therefore, estimated burden is zero.

14. Appendix Q, Pre-Application Early Review of Site Suitability Issues The submittal for early review of site suitability issue (s) shall be made j in the same manner and in the same number of copies as provided in !

( $ 50.30(a), (c)(1) and (c)(3) for license applications. The submittal includes sufficient information concerning a range of postulated facility design and operation parameters to enable the staff to perform the requested review of site suitability issues. The submittal contains suggested conclusions on the issues of site suitability submitted for

~

review and shall be accompanied by a statement of the bases or the reasons for those conclusions.

Estimated burden for this type of review is zero because no new requests are anticipated.

Consultations Outside the Agency Appendix L of 10 CFR Part 50 was developed in consultation with the Antitrust Division of the Department of Justice and has been amended twice at the request of the Department of Justice to refine the information needed for antitrust review.

Estimate Respondent Burden See the Summary Table for application for Construction Permit or Operating

License which follows.

Estimated Cost to the Government I

( The annual estimated cost to the Government is delineated at the end of the Summary Table which follows.

, -- - - - _ , , - . _ -w.- - ___ ,, ,---,_---.-m,y -y_. - -- -, -w--~~w__-__.w,--.,_-~ m.. -

..-__--,.-<r----,9m ., - - - -- -- ,

- e SUfe?ARY .ABLE .

Application For Construction Permit Or Operating License (Part 1)

Annual Annual Number of Annual Annual Total Cost to Burden Hours Respondents Recordkeeping Reporting Annual Annual Cost Federal i Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government I

l 50.30, 50.30a 0 0 0 0 0 0 0 l

50.33 50.34, (new applications not expected for the next 3 years)*

50.54(bb) and j 50.55(d)

I 50.34(h), Access (see Summary of Supporting Statements) i Auth. (Insider) Rule 50.55(b), const. 200 5 100 900 1,000 $60,000 $30,000 l permit ext.

1 O

Appendix K, (see Part 24 of the Supporting Statements) t i 50.46, ECCS i

] 50.33a and 0 0 0 0 0 0 0 l Appendix L*;

l Appendices M, N, 0 l cnd Q*

l 50.34(f), 0 0 0 0 0 0 0 TMI*

50.36a (see Part 2 of the Supporting Statements for Part 50)

! Tech Specs

~

Table (Continued)

Annual Annual Number of Annual Annual Total Cost to Burden Hours Respondents Recordkeeping Reporting Annual Annual Cost Federal Subject Per Respondent Annually Burden Hours Burden Hours Burden Hours To Industry Government 50.59(c) 152 105 1,600 14,400 16,000 $960,000 $1,020,000 50.90 and 50.91 (See page 15 for supportive discussion)

(a) and (b), .

, license amend.

appl.

50.63 and (Burden will be impnsed on the public ,>

j 50.74 when the rules become final) j (proposed)

~

.y 50.80(b)* O O O O O O O 4 trcnsfer of 4' l

license i i

) 50.82, license 300 5 150 1,350 1,500 $90,000 $403,200 j termination

! Proposed Decom- 0 0 0 0 0 0 0 l oissioning Rule l (50.33(k), 50.54(cc), (Burden will be imposed on the public

and 50.54(dd) when the rule becomes final)

Totals: 652 115 1,850 16,650 18,500 $1,110,000 $1,453,200 i

-15a-SUPPORTING STATEMENT

" Notice and State Consultation," 10 CFD 50.91(a) and (b).

Justification Under $$ 50.91(a)(1) and (b)(1) of Part 10 CFR 50 a licensee requesting an amend-ment must provide to the NRC and the State in which its facility is located its amendment application and its analysis about the issue of significant hazards.

To get a quick start on the public notification and State consultation procedures required by legislation, both NRC and the State need licensees' analyses and positions on significant hazards issues because licensees are in the best posi-tion to explain their amendment requests.

Description of Information Collection l

In addition to needing licensees' analyses of the license amendment requests, this section of the NRC's regulations also involves a reporting requirement con-cerning the issue of significant hazards consideration. The reporting require-ment does not overlap or duplicate any other NRC or Federal information collec-tion requirements. NRC needs licensees' analyses to quickly make and publish

! l for public comment its " proposed determination" on significant hazards issues; I and the States also need licensees' analyses in order to quickly consult with j NRC.

< Estimated Burden The rule applies to 105 operating nuclear power plants and to two (2) testing facilities. Licensees of these reactors request about 1000 license amendments per year. It is estimated that a licensee will spend approximately 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months per analysis under the examples and standards in Section 50.92, " Issuance of Amendment." For 1000 license amendment requests, the total burden on licensees would be 16,000 hours0 days 0 hours 0 weeks 0 months annually. Assuming an hourly rate of $60, an analysis request could cost a licensee about $960 (16 x $60). Thus, the total annual I cost to industry for 1000 amendment requests would be about $960,000.

Estimated Cost to the Federal Government NRC uses a licensee's analysis as a starting point for its significant hazards review. Including time spent in preparation of Federal Register publication, NRC estimates that a total of 17,000 staff hours will be expended on 1000 requests per year. This is derived from our estimate that 20 percent of the l

.0415 staff year per amendment request (17 hours1.967593e-4 days 0.00472 hours 2.810847e-5 weeks 6.4685e-6 months ) involves the significant I hazards review and noticing in the Federal Register. Assuming an hourly rate l of $60, for 1000 amendment requests the cost to the government is estimated at l $1,020,000.

k l

Part 2 T

SUPPORTING STA'EMENT FOR

10 CFR 50.36, 50.36a, 50.36b, and Appendix I* -

Reporting and Recordkeeping Requirements Contained in Technical Specifications Contained in Licenses to Operate Nuclear Power Plants" and Each licensee under 10 CFR Part 50 is required to perform reporting and re keeping requirements that NRC has approved as a part of the technical specl tions submitted as a part of original applications for Itcenses.

recordkeeping requirements are set forth as " administrative controls" in Sec-The r tion 6 of license. the Appendix A technical specifications appended to each facility

They are oesigned to assure operation of the facility in a safe manner.

The typical reporting and recordkeeping burdens with justifications are ex-plained below. NRC Regulatory Guide 1.16 (Revision 4 Information--Appendix A Technical Specifications", pro)vides the progra g used by the NRC staff in order to standardize the reporting requirements section of Appendix A technical specifications of all operating licenses.

i For licensees holding operating licenses without Appendix 5 environmental -

technical specifications or environmental protection plans, it may be neces to include those reports ideritified in Regulatory Guide 1.21, " Measuring, Eval ating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactiv -

Materials Plants," andin Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Pow

the Environs of Nuclear Power Plants," in the technical spec the unique reporting requirements section of the technical specifications.

1. Radioactive Effluent Report Section 50.36a of 10 CFR Part 50, specifies that to keep releases of achievable," each license authorizing operatton of a nuc reactor must include technical specifications.

The NRC staff has developed " Radiological Effluent Technical Specifications for PWRs" (NUREG 0472) and " Radiological Effluent Technical Specifications for SWR's" (NUREG 0473).

The contents of these two documents (as appitcable) and the reporting requirem,ents specified therein ,

new being are made operating part of the Appendix A technical specifications for Itcenses.

These same requirement.Lare.also being I

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Appendix ! to 10 CFR 50 consists of the numerical guides for design objectives and Ifmiting conditions for plant operation to meet the criterion "as low as is reasonably achievable" for radioactive material in light water cooled reactor effluents.

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i added to existirq operating licenses as license amendments. (Appendix A technical specifications are approved by the NRC, are incorporated in the facility operating ifcense, and are conditions of the license.) l Routine radioactive affluent release reports covering the operation of the unit during the previous 6 months of operation are to be ' submitted within 60 days after January 1 and July 1 of each year. This report includes a summary of the quantities of' radioactive ifquid and gaseous -

effluents released to the environment and solid waste shipped from the 4

site.

Special reports are required when certain conditions exist or parameters are exceeded, e.g. , when the radiation dose for any calendar quarter is i i

equal to or greater than one half the actual limit, or the annual dose

( exceeds twice the annual limit; when the liquid, gaseous or solid rad-waste treatment systems or the building ventilation systems are inoper-able for more than 31 days.

2. Startuo Report

~ l I Section 50.36, " Technical Specifications," of 10 CFR 50 "Oomestic Licensing of Production and Utilization Facilities," req,uires that each .

! applicant for a license authorizing operation of a nuclear power plant 1

include in its application proposed technical specifications. These technical specifications as approved by the NRC, are incorporated into

( the facility license and are conditions of the license. One of the reports report.

normally required by the technical specifications is a startup -

This report is submitted within (1) 90 days following completion of the startup test program, ment of commercial power opera (2)or tion, 90(3) days followingfollowing 9 months resumption or commence-initial criticality, whichever is earliest. The report addresses each test

' identified in the FSAR and should include a description of the test ard 1

the test conditions the measured values of the operating condition or i characteristics obtained during the test program, and a comparison of ,

these~ values with design predictions and specifications.

The startup report provides the staff with evidence that the plant systems are functioning as designed and can be expected to perform as 1 planned, in the safe operation of the plant.

i The report is necessary to identify design deficiencies, and to obtain l data on plant operation to verify (or provide a basis to modify) techni-

etl specification Ilmits for operation. The data is also necessary for guidance in determining core reload requirements based on physics data obtained in testing reveal areas where additional performance verifica-j tion testing is required or where further guidance is needed through additional regulatory guides or revision of existing guides.

There is no source for the required inf'ormatTon otheE than the licensees.

Sealed Source t.eakace Report j 3.

l Section 50.36, 10 CFR Part 50, requires licensees to adhere to technical 1 j specifications for the construction and operation of production and '

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18-utilization facilities. One specifically identified submission required of licensees by NRC under this authority is the Sealed Source Leakage Report, which includes technical specifications that establish require-ments for testing the integrity of sealed sources transferred and for recording and reporting the test results.

The reporting requirements on sealed sources Ifcensed under 10 CFR Part 50 are included as a Technical-Specification appended to the nuclear ,

facility license. For some nuclear facility licenses, the reporting requirements for failed sealed sources require that a special report be submitted within 90 days following a test in which the results indicate removable contamination levels greater than 0.005mCf. Other nuclear facility licenses require reporting of such test results only as part of an annual report. Most reporting will be made annually, since any _

license that requires more frequent reporting can be amended, at the

request of the licensee, to call for annual reports. "

The information on any sealed source which exceeds the limitation on removable contamination should be reported annually for the licensed

' , nuclear facility. If such information was not received, the quality 1 assurance record for sealed sources used in operating a nuclear facility would be incomplete and failures would not be reported. Thus, the manu-facturing process for maintaining the integrity of sealed sources under i

various operating conditions could be deficient, unknowingly.

The information obtained from nuclear facility licensees in Sealed Source l Leakage Reports reflects a special type of use for sealed sources and - ;

i provides further assurance that the manufacturing process can produce sealed sources with hign integrity. i 1

4. Monthly Coeratina Report

! Section 50.36, " Technical Specifications," of 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," requires that each applicant for a license authorizing operation of a commercial nuclear 4 power plant include in its application proposed technical specifications.

These technical specifications, as approved by the NRC, are incorporated :

, into the facility license and are conditions of the license. One of the j reports normally required by technical specifications is a report of j operating statistics and shutdown experience. This report is submitted to the Commission by the licensees on a monthly basis. Information is j submitted in the " Monthly Operating Report" regarding (1) Average Daily i

' Unit Power Level, (2) Operating Data; (3) Unit Shutdowns and Power Reduc-tions; and (4) Spent Fuel Storage Capacity.

Using the data from licensee's monthly reports, plus information received - !

from NRC regicnal offices, the NRC prepares a monthly report, entitled

" Operating Units Status Report." The report indicatts, for each licensed l

t unit, average daily power levels, opera ~ ting ~s'tatus, unit shutdowns and power reductions, and summaries for all nuclear plant operations, including ;

j the capability to off-load spent fuel, i' .! This monthly report is used by the NRC, the Department of Energy and other Federal and State agencies. This report is necessary for Federal O

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l and State agencies to keep abreast of current plant operating data, including plant availability, which is of particular use during periods of reduced power output from other energy sources. Copies of the report are sent to the utilities to share with them the operating experience of other operators of nuclear power plants. The report is also available to the public.

The information obtained from the utilities is not otherwise available to ,

the Federal Government on a current basis. Without this information Federal and State agencies could not keep abreast of current plant operations.

There is no source for the required information other than licensees.

5. Non-Routine Environmental Reports Environmental reviews of nuclear facilities often leave some questions only partially resolved. Data collection efforts authorized under 10 CFR Section 50.36 are intended to resolve these questions. Potentially

. significant environmental impacts (e.g. , fish kills, excessive chemical releases, habitat disruption) neet to be reported promptly so that appro-priate action can be taken. To au omplish this result, Non-routine Environmental Reports are generally required by the technical specifica-tions whenever an adverse effect may occur.

I The non-routine report provides information which specifies and quanti-fies the data concerning the unusual events and provides the basis for -

recommending appropriate action. It provides the data in a timely fashion

so that changes in operating procedures or design modifications can be implemented as soon as possible.

2 The NRC staff performs a detailed analysis of each event which warrants such study. The licensee report and the NRC analysis are placed in the public document room and sometimes a press release is prepared. The staff analysis may recommend mi.tigative action. -

There is no source for the required information other than Itcensees.

6. Annual Environmental Operatino Report i

Section 50.36 of 10 CFR Part 50 requires inclusion of technical specifi-cations, based on analyses in the Safety Evaluation Report, in eacn l license authorizing operation of a production or utilization facility.

Section 51.52 explicitly authorizes conditioning of a license to protect environmental values (e.g., commercial and sport fisheries, rare anc -

i endangered species, recreational land and water use). Nonradiological

, license conditions are generally incorporat.ed in__tht. license as Appendix B, i Environmental Technical Spe:ifications. The technical specifications dis-cussed in section 50.36 include requirements for an Annual Environmental Operating Report.

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The purpose of nonradiological environmental monitoring is to confirm tne environmental assessments presented in the Final Environmental 5tatement

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(FES) which described the impact of the proposed facility. The nonradi-

, ological programs are also designed to detect unanticipated adverse impacts (i.e., adverse impacts which exceed the predictions of the FES or were not predicted) soon enough to take appropriate action.

The operating procedures of'a plant are sometimes conditioned to protect i environmental values because of predictions in the FES that a potential !

] for significant adverse impact exists. Monitoring programs are usually incorporated to assess the actual magnitude of predicted adverse impacts.

If the impacts are different from those anticipated, the Itcensee or staff can take action to change the technical specifications or plant l j design or operating procedures to more adequately account for the actual effects of facility operation.

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! If the information in the annual reports were not available there would i

" be no information to assess the effectiveness of license conditions or to process requests for changes in those conditions. Unanticipated environ-l mental effects of operation would not be detected and appropriate action

' could not be taken if the information in the Annual Environmental Operating Report were not available.

There is no source for the required information other than licensees.

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7. Annual Radioloaical Environmental Coerating Recort I.

( Section 50.36 of 10 CFR Part 50 provides that reactor operating Ifcenses J will include technical specifications which NRC finds appropriate. Each -

1 reactor ifcense includes a technical specification requiring submission j of annual radiological environmental operating reports. -

1 i The annual radiological environmental operating reports include summaries.

interpretations, and an analysis of trends of the results of the radt-

! ological environmental surveillance activities for the report period, l including a comparison with preoperational studies, operational controls

! (as appropriate), and previous environmental serveillance reports and an

! assessment of the observed impacts of the plant operation on the environ- i ment. The reports also include tha ssults of land use censuses required i by the Technical Specifications. If narmful effects or evidence of 6

! irreversible damage are detected by the monitoring, the report provides ;

) an analysis of the problem and a planned course of action to alleviate !

i the problem.

2 1 The annual radiological environmental operating reports include summarized and tabulated results in the format of the table in the Radiological i Assessment tranch Technical Position, Revision 1, November 1979,* of all radiological environmental samples taken during the report period. In '

i the event that some results are not available for inclusion with the t l report, the report is submitted noting and explaining the reasons for the f

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, "This document pertains to the radioactive effluent reporting requirements discussed in paragraph 1.

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] t missing results. The missing data are submitted as soon as possible in a supplementary report. <

i The report also includes the following: a summary description of the radiological environmental monitoring program; a map of all sampling !

locations keyed to a table giving distances and directions from one reactor; and the results of licensee pirticipation in the Interlaboratory Comparison Program, required by the Tecnical Specifications. .

Reports range from around fifty pages to several hundred pages.

l t The reports provide a timely record of environmental 'adiation r around the plant. The reports are reviewed by the NRC staff to determine whether radioactive material released routinely by nuclear power plants may have ,

I resulted in excessive environmental radiation. Without the reports, the !

NRC staff could not provide adequate assurance that the public is being '

f protected from such environmental radiation.

. 4. Annual Radiation Exposure Reoort !

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Section 50.36, " Technical Specifications," of 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," requires that each

! applicant for a Itcense authorizing operation of a nuclear power plant '

include in its application proposed technical specifications. These

( technical specifications, as approved by the NRC, are incorporated into

the facility license and are conditions of the license. ,

The report on occupational personnel radiation exposure is submitted j

annually. The tabulation of occupational exposure data may be submittec '

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along with any report of facility changes, tests or experiments, requirec pursuant to 10 CFR 50.59(b), or as a separate submittal at the option of the licensee. . -

The information on occupational personnel radiation exposure submitted by

! ' the licensees is necessary to enable the NRC staff to analyze procedures

) and hareware radiation exposure problems associated with operation, outage, or maintenance. The information provides a basis for evaluation

! of new plant designs or for modifications to present plant designs with i respect to assuring that plants are designed for as low as reasonably l

! achievable occupational radiation exposure. '

! Using data submitted by the licensees, the NRC also prepares an annual i

) report entitled " Occupational Radiation Exposure at Commercial Nuclear l i Power Reactors" NUREG-0713). Included in the report is a compilation of 1

in-plant occupat onal exposure data by work and job function. The infor-l mation is required to establish trends among plants and within plants.

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9. Recordkeepina Recuirements l

j NRC Regulations in 10 CFR Part 50, Sections 50.36 and 50.36a establish ;

requirements for recording results of reviews of events reported to the t 3

Commission and requirements for recordkeeping as part of administrative I

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~22-controls. The regulations were issued pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the Energy Reorganization Act of 1974.

Section 50.36(c)(1)(1)(A) requires recording of the results of reviews of events in nuclear reactors in which a safety limit has been exceeded.

Section 50.36(c)(1)(1)(B) requires recording of the results of the reviews of events in fuel reprocessing plants in which a safety limit has been exceeded. Section 50.36(c)(1)(ii)(A) requires recording of the results of reviews of events in nuclear reactors in which an automatic safety system does not function as required. Section 50.36(c)(1)(ii)(B) requires recording of the results of reviews of events in fuel reproces-sing plants in which an automatic alarm or protective device does not function as required. Section 50.36(c)(2) requires recording the results of reviews of events in nuclear reactors and fuel reprocessing plants in which a limiting condition for operation is not met. Each of the above records of review is required to include the cause of the condition and the basis for corrective action taken to preclude reoccurrence. Section 50.36(c)(5) requires administrative controls, including recordkeeping, in technical specifications of a production or utilization facility as necessary to assure operation of the facility in a safe manner. Details of recordkeeping are delineated in Section 6.10 of Standard Techni' cal Specification, NUREG-0123 for General Electric boiling water reactors, NUREG-0212 for Combustion Engineering pressurized water reactors, NUREG-0103 for Babcock and Wilcox pressurized water reactors and NUREG-0452 for Westinghouse pressurized water reactors, k The records required by Section 50.36(c)(5) involve such matters as:

a. Records and logs of facility operation covering time interval at each power level.

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related ?.o -

nuclear safety.

c. All Reportable Events.

d. Records of surveillance activities, inspections and calibrations required by the Technical Specifications,

e. Records of changes made to Operating Procedures.

f. Records of Radioactive shiptrents.

g. Records of sealed source and fission detector leak tests and results.

h. Records of annual physical inventory of all sealed source material of record,

i. Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis

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Report.

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j. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

k. Records of facility radiation and contamination surveys.

1. Records of radiation exposure for all individuals entering radiation control areas.

m. Records of gaseous and liquid radioactive material released to the environs,

n. Records of transient of operational cycles for various facility components.

o. Records of reactor tests and experiments,

p. Records of training and qualification for current members of the plant staff.

q. Records of in-service inspections performed pursuant to the Technical Specifications.

r. Records of Quality Assurance activities required by the QA Manual.

s. Records of reviews performed or changes made to procedures or equip-ment or reviews of tests and experi. Tents pursuant to 10 CFR Part 50,

( Section 50.59.

t. Records of meetings of safety review groups.

u. Records of the service lives of all snubbers required by the Technical Specifications.

v. Records of secondary water sampling and water quality.

w. Records of analyses required by the Radiological Environmental Monitoring Program.

These records are used by the licensees, the NRC and other Federal, State and local government agencies for the review of a variety of activities in the facility, many of which affect s:.fety. The records are also historical in nature and provide data on which future activities can be based. NRC Inspection and Enforcement personnel can spot check the records required by 50.36 to determine, for example, if (1) plant modifi-cations were performed satisfactorily, (2) the plant was operated within the technical specifications, (3) personnel training has been kept current, (4) plant effluents have been kept within allowable values, etc.

Because of the multiple-use nature of many of the records, NRC has estimated only the incremental burden.

There is no source for the required information other than licensees.

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DESCRIPTION OF SURVCY PLAN There are 105 operating power reactors.

There are 75 operating /research/ test reactors licensed to operate.

ESTIMATE OF RESPONDENT REPORTING BURDENS

1. Radioactive Effluent Reports:

These include reports on (a) Exceeding Design Objective Doses, (b)

Inoperable Radwaste Equipment, (c) Dose Contribution from Effluents, (d)

Unplanned Radioactive Release, (e) Exceeding 10 CFR Part 20 Release Limits and (f) Exceeding Ci Content in Liquid or Gaseous Tanks or Ci Release Rate for Offgas System (BWR), which individually affect fewer than 10 licensees annually, which result in a negligible burden and, a Semi-Annual Effluent Report which requires each on 105 licensees of 140 hours0.00162 days 0.0389 hours 2.314815e-4 weeks 5.327e-5 months per report for a total burden of 29,400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months annually.

2. Startup Report This reporting requirement affects less than 10 licensees annually with a average burden of 100 hrs or 1000 hrs.

3. Sealed Source Report

{ Since the licensee will be required to report only those sealed source test results which exceed the removable contamination limit, burden will be negligible, less than 10 licensees are affected. (160 staff - hrs assuming 16 hrs / report).

4. Monthly Operatino Report One hundred five (105) licensees each submit 12 reports annually, each report imposing a burden for preparation of 50 staff-hours.

105 X 12 X 50 staff hours total 63,000 staff-hours.

5. Non-routine Environmental Report An average of about one report is received from each licensee annually; thus, the preparation burden (50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months per report) upon each respondent is negligible. Total annual burden assuming 45 sites (50 X 45) would be 2250

. staff-hours. ,

6. Annual Environmental Operatino Report and Annual Radiological Environ-mental Operatino Report Licensees will submit reports for an estimated 45 sites in response to this requirement. Each report causes a preparation burden of 1400 man-hours.

Man-hours per report will be reduced as water quality requirements are deleted from existing licenses.

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45 sites X 1400 staff-hours - A total annual burden for all licensees of 63,000 staff-hours.

7. Annual Radiation Exposure Report The estimated burden upon each power reactor licensee for the preparation of one report is 40 staff-hours.

105 X 40 staff-hours totals 4,200 staff-hours.

The total for reporting burden for all licensees: 158,810 staff-hours ESTIMATE OF RESPONDENT RECORDKEEPING REQUIREMENTS These recordkeeping requirements are subject as follows:

P 105 operating reactors 75 research test reactors The burden annually for an operating power reactor is estimated to be approximately 1,975 starf-hours.

One Hundred Five (105) operating power plants X 1,975 staff-hours totals 207,375 staff-hours.

The burden annually for a research or test reactor is estimated to be

( approximately 80 staff-hours.

Seventy-five (75) research or test reactors X 80 staff-hours totals 6,000.

Total for recordkeeping burden of all licensees: 213,375 staff-hours.

TOTAL BURDEN Total burden for all reporting /recordkeeping requirements for technical specifications is 372,185 staff-hours. The total cost to industry at $60 per staff-hour is $22,331,100/yr.

ESTIMATE OF COS1 TO FEDERAL GOVERNMENT

1. Radioactive Effluent Reports Total Burden Report Reports /yr Staff-hour / report Staff-hour /yr

1. Exceeding Design 3 50 150 Objective Doses I

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. 8. Annual Radiation Exposure Report The cost to the Federal Government is approximately 50 staff-hours.

These estimate's are based on professional staff experience and incorporate professional staff time to review submitted reports.

TOTAL COST TO FEDERAL GOVERNMENT:

Costs estimates are $60 per hour 15,960 staff-hours X $60 = $957,600/yr.

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27 Part 3 SUPPORTING STATEMENT FOR QUALITY ASSURANCE RECORDS Called for in 10 CFR 50.55a,* 50.55(f), Appendix A (Criterion 1), and in Appendix B.

JUSTIFICATION Licensee burden hours will be spent on QA records development and maintenance, which pertain to the following list of activities (i.e. disciplines):

1. Management: QA manual, procedures, and instructions

2. Qualification and training of personnel

3. Design

4. Procurement, items identification / control, acceptance status l 5. Manufacture, installation / testing

6. Handling, storage and shipping

7. Inspection, testing and qualifying, including inspection status

8. Calibration

9. Special processes i

10. Operation l ( 11. Maintenance

12. Modification and repair

13. Audits

14. Non-conformance, corrective actions QA records associated with the above activities are used by the licensee, the National Board of Boiler and Pressure Vessel Inspectors, insurance companies and the NRC in the review and confirmation of quality related activities. Most states and all nuclear insurers already require that the ASME B&PV Code (Sec-tion III) be used in the design, construction, testing and inspection of nuclear power reactor, which imposes many of the above record keeping requirements.

Appendix B requires records for " Safety-related" items that are usually found on a plant-specific Q-list. These record requirements were the basis for the ,

burden hours reported in the last Part 50 to allow for the additional QA records reqaired by Appendix A (but not prescribed by the NRC) in connection with items ,

"important-to-safety" but not " safety-related". ;

l *See Part 3a, separate Supporting Statement for information collection require-ments specified in 10 CFR 50.55a, which incorporate by reference the Winter l 1982 Addenda, Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addenda ,

and 1983 Edition of Section III, Division 1, and the Winter 1982 Addenda, Summer 1983 Addenda, and 1983 Edition of Section XI, Division 1 of the ASME t Code.

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28 Regulatory Guide 1.28 (Rev. 3), " Quality Assurance Program Requirements (Design and Construction)" and Regulatory Guide 1.33 (Rev.3), " Quality Assurance Pro-gram Requirements (Operation)" describes an acceptable method for complying with QA records requirements in accordance with 10 CFR Part 50. Except for a few regulatory positions in these Regulatory Guides, they endorse the common industry standard ANSI /ASME NQA-1-1983, " Quality Assurance Program Requirements for Nuclear Facilities". Maintenance of records as specified above is necessary so that evidence can be furnished to show that activities affecting quality have been accomplished in accordance with NRC regulations. Records required to be maintained for a specific activity are specified in the license applica-tion, license condition or permit, or NRC-approved documents. These records, ,

some of which will be kept for the life of the facility, are available for in-spection by the NRC, and are reviewed and examined to ascertain whether the activities affecting quality have been accomplished in accordance with NRC requirements. Also, in case of malfunction or failure of an item affecting safety, availability of plant records is necessary to aid in the determination of the cause of the failure. In addition, records maintenance is necessary for other important specific functions such as providing baseline data for inservice inspection and providing data for trend analysis. .

The type of records identified specifically in Criterion XVII of Appendix B to 10 CFR Part 50 are of particular importance to provide adequate evidence that licensee activities affecting quality have been accomplished in accordance with NRC regulatory requirements. Other records pertaining to items important-to-l safety are not detailed in any specific NRC requirements document, but are, nevertheless, expected to be available for inspection and audit by the NRC in accordance with Criterion 1 of Appendix A to 10 CFR Part 50.

Reporting of changes to the QA program pursuant to 10 CFR Part 50.55(f) became a new requirement, effective March 1983. The licensee's QA Program plan, after l

acceptance by the NRC, is now considered a license condition. Any changes to ,

this plan must now be reported to the NRC like other license conditions of a similar nature. It is estimated that each licensee / applicant will initiate two such changes per year, and that each such change requires approximately 20 staff hours.

Estimated Reporting Burden:

Each of 22 plants under construction generates a licensee burden of 20,000 burden hours 22 x 20,000 = 440,000 hrs /yr Each of 105 operating reactors generates a licensee burden of 10,000 burden hours per year 105 x 10,000 = 1,050,000 hrs /yr Each of four large test reactors causes the licensee to expend 250 staf f hours per year; 4 x 250 = 1,000 hrs /yr Total for Appendix B 1,491,000 hrs /yr

. Reporting changes, to the QA Program, 131 licensees x 160 burden hours 20 960 hrs /yr I Total Burden Hours 1,5 M hrs /yr Cost is based on $60,00 per hour for licensee; therefore, cost to industry = $90,717,600

a 29 Estimated Recordkeeping Burden A comprehensive system of planned and periodic audits must be carried out by licensees to verify compliance with all aspects of the quality assurance progr6m and to determine the effectiveness of the program. The audits are performed in accordance with quality assurance program procedures. Based on NRC's experience ,

and in light of the magnitude of records required for the audits and the overall program during construction, it is estimated that 41% of the tot'al industry re-porting burden (1,511,960 hours0.0111 days 0.267 hours 0.00159 weeks 3.6528e-4 months ) encompasses hours expended annually for record-keeping requirements. Recordkeeping requirements are, therefore, estimated to involve 660,903 hours0.0105 days 0.251 hours 0.00149 weeks 3.435915e-4 months annually.

Estimated Cost to the Federal Government:

QA records are generated and maintained by licensees. The incremental cost for NRC audits and inspection of QA records is a small part of the total NRC inspec-tion program, consisting of the resident inspectors, the regional inspections, and the special inspections which include, among others, Construction Assessment Team (CAT), Performance Appraisal Team (PAT), and Independent Design Inspection (IDI). It is estimated that 10 percent of the licensee's burden hours are neces-sary for NRC audit and inspection ( 10 X 1,511,960 = 151,196 staff hours). This estimate is based on 5 years of experience involving follow-up discussion between i

the NRC staff representative and Team Leaders for CAT, PAT, and 101.

Therefore, the estimated Federal cost is expected to be $9,071,760

($60 X 151,196).

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29a Part 3a SUPPORTING STATEMENT

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FOR 10 CFR 50.55a (ASME COD:i) e

1. Justification

a. Need for the Information Collection >

NRC Regulations in 10 CFR 50.55a incorporate by reference Section III, Division 1, and Section XI, Division 1, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. These sections of the ASME Code set forth the requirements to which nuclear power plant components are designed, constructed, tested and inspected.

Inherent in these requirements are certain recordkeeping functions.

Incorporation of the Winter 1982 Addenda, Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addenda, and 1983 Edition for Section III, l

Division 1, of the B&PV Code adds the following recordkeeping requirements.

Section III o Winter 1982 Addenda

' ( NB-2125, Fabricated Hubbed Flanaes - New provision for surface examination requires documentation of examination results.

o Summer 1983 Addenda No additional recordkeeping o Winter 1983 Addenda NCA-3650, Design Documents for Appurtenances -

Requires Design Document for each appurtenance that is to be attached to a component unless it is already included in the component Design Documents.

o Summer 1984 Addenda l NB/NC-7240, Review of (Overpressure Protection) Report After Installation - Addendum to report required to document any modification of the installation from that used for preparation I

of the Overpressure Protection Report.

l NO-7200, Overpressure Protection' Report - Requires overpressure l protection report for Class 3 compunents to define the protected systems and the integrated overpressure protection provided, and (ND-7240) documentation of any modification of the installation l

from that used for preparation of the Overpressure Protection Report.

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29b o 1983 Edition 1 All requirements, except those for Winter 1982 Addenda, pre-viously incorporated in separate amendments to 10 CFR 50.55a.

Incorporation of the Winter 1982 Addenda, Summer 1983 Addenda, and the 1983 Edition of Section XI, Division 1, of the ASME Code adds the following recordkeeping requirement.

Section XI o Winter 1982 Addenda IWA-6220(b), Preparation (of Records and Reports) - Requires preparation of Owner's Report for Repairs of Replacements (Form NIS-2).

o Summer 1983 Addenda No additional recordkeeping o 1983 Edition 2 All requirements, except those for Winter 1982 Addenda, pre-viously incorporated in separate amendments to CFR 50.55a.

The Winter 1982 Addenda of the ASME Code references ANSI /ASME 4 NQA-1-1979, " Quality Assurance Program Requirements for Nuclear Power Plants." NQA-1-1979 is based upon the contents of ANSI /ASME N45.2-1979,." Quality Assurance Program Requirements for Nuclear Facil-ities" and seven daughter standards. These standards are referenced in Regulatory Guides 1.28, 1.58,.1.64, 1.74, 1.88, 1.123, 1.144, and 1.146 as providing methods acceptable for implementing certain NRC quality assurance program requirements. NQA-1-1979 incorporates no recordkeeping beyond that originally required by the N45 standards upon which it is based. There is, therefore, no additional record-keeping burden associated with the endorsement of NQA-1-1979.

b. Practical Utility of the Information Collection These records are used by the licensees, National Board inspectors, insurance companies, and the NRC in the review of a variety of activities, many of which affect safety. The records are generally historical in nature and provide data on which future activities can be based. NRC Inspection and Enforcement personnel can spot check the records required by the ASME Code to determine, for example, if proper inservice examination test methods were utilized.

1The 1983 Edition of Section III is equivalent to the 1980 Edition, as modi-fied by the Summer 1980 Addenda, Winter 1980 Addenda, Summer 1981 Addenda, Winter 1981 Addenda, Summer 1982 Addenda, and the Winter 1982 Addenda.

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2The 1983 Edition of Section XI is equivalent to the 1980 Edition, as modified by the Winter 1980 Addenda, Winter 1981 Addenda, and the Winter 1982 Addenda.

.29c i,

c. Duplication With Other Collectionc of Information ASME requirements are incorporated to avoid the need for writing equivalent NRC requir~einents. The final rule will not duplicate the information collection requirements contained in any other generic regulatory requirement.

d. Consultations Outside the NRC No consultations.

e. Other Supporting Information NRC applicants and licensees have been complying with the information collection requirements of the ASME Code since 1970. No problems with these information collection requirements have been identified to the NRC by the applicants or lict.nsees.

2. Description of the Information Collection i a. Number and Type of Respondents In general, the information collection requirements incurred by

( 650.55a through endorsement of the Code apply to 22 plants under con-struction and to 105 nuclear power plants in operation. The actual number of plants that would implement the edition and addenda addressed by the proposed revision, and thereby be affected by their infurmation collection requirementsc is dependent on a variety of factors. These factors include whether the application is for Section III or Section XI,' the class and type of components involved, the dates of the' construction permit and construction permit application, the schedule of the inservice inspection pro-gram, and whether the plant voluntarily elects to implement updated editions; and addenda of the Code.

b. Reasonableness of the Schedule for Collecting Information 3 s The information is gene' rally not collected, but is retained by the licenske to be made available to the NRC in the event of an NRC inspection or audit. The preservice and inservice inspection plans 1 are, however, submitted to the NRC for review as part of the appli-cation for an operating license,

c. Method of Col'ecting the Information See Item 2(b).

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d. Adequacy of the Description of the Information 1

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The ASME Code provides listings of information required and specific forms to assist, where necessary, in documenting required information.

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e. Record Retention Period The retention period for information is in accordance with a schedule provided in the ASME Code. The retention periods for the more signif-icant information keeping requirements specified in Item 1.a above are:

Information Retention Period 3 Design document for appurtenances Lifetime Overpressure protection report Lifetime Reports for repair and replacement Lifetime Final nondestructive examination report Li fetime Lifetime retention of the above records is necessary to ensure ade-quate historical information on the design and examination of compo-nents and systems to provide a basis for evaluating degradation of these components and systems at any time during their service lifetime.

3. Estimate of Burden a(1) Estimated Hours The information collection requirements inherent in incorporating by reference the latest edition and addenda of Section III, Division 1, and Section XI, Division 1, of the ASME Code are identified in Item 1.a above. These requirements may be categorized in terms of Section III requirements that document component / system design and

+he results of construction examinations, and Section XI require-

. ants that document repairs and replacements.

The additional Section III requirements incur a one-time burden on plants under construction. The information collection requirements associated with the proposed edition and addenda are generation of the design documents for appurtenances and the overpressure protec-tion report. Section 50.55a specifies that the Code Edition, Addenda, and optional Code Cases to be applied to reactor coolant pressure boundary, and Quality Group B and Quality Group C components must be determined by the provisions of paragraph NCA-1140 of Subsection NCA of Section III of the ASME Code. NCA-1140 specifies that the owner (or his designee) shall establish the ASME Code edition and addenda to be included in the Design Specifications, but that in no case shall the Code edition and addenda dates established in the Design Specifications be earlier than three years prior to the date that the nuclear power plant construction permit is docketed. NCA-1140 further states that later ASME Code editions and addenda may be used 3 Service lifetime of the compenent or system.

- -.. . .. _. . _. .. . - - _ _ = - - - - . -

29e by mutual consent of the Owner (or his designee) and Certificate Holder. The earliest Section III addenda being addressed in the pro-

posed rule is the Winter 1982 Addenda, since the last plant to be

docketed that is still under construction was docketed in October 1974 (Palo Verde Units 1, 2, 3), there is no plant under construction for which implementation of the Section III edition and addenda spe-cified in the proposed rule is a requirement. Plants may implement these improved rules on a voluntary basis, but unless they make that choice, there is no additional paperwork burden associated with

. incorporating the proposed Section III edition and addenda.

The additional Section XI requirements incur a burden associated with the documentation of component repairs and replacements. To facili-j tate this documentation,Section XI provides Form NIS-2, "0wners' Report for Repairs or Replacements." Information required by this form relates to identifying the owner and facility; identifying the components repaired or replaced or replacement components; identify-ing the type of work, the repair organization and by whom the work

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was performed; and identifying the type of tests conducted. 'A por-tion of this information, such as that to identify the owner, facility and components is already required by Form NIS-1, "0wners' Data Report for Inservice Inspections," (Form NIS-1 was part of an addenda previously incorporated by reference into Section 50.55a).

Most of the remaining information required by Form NIS-2 can be obtained from the previously prepared component work / repair order.

It is estimated that the time required to complete the required documentation on Form NIS-2 is one hour.

Nuclear power plants are required to update their inservice inspec-

!' tion programs by incorporating into their initial 120-month.inspec- .

tion interval requirements of the latest edition and addenda of Section IX, Division 1, that have been incorporated by reference i into 550.55a as of 12 months prior to the date of issuance of operating license; and by incorporating into successive 120-month inspection intervals requirements of the latest edition and addenda of Section XI that have been incorporated by reference as of 12 months prior to the start of a 120-month inspection interval.

! On this basis, most plants will at one time be required to imple-ment the Section XI, Division 1, edition and addenda specified in the proposed rule. The number of plants that will be implementing the specified edition and addenda will grow gradually as each plant updates it inservices inspection program at the 10 year interval.

Therefore, conservatively, the total number of plants that may ultimately be required to implement the specified edition and addenda is 127 (i.e., 105 operating plants and 22 plants under

{ construction).

Inservice inspections are typically performed at the time of refuel-ing (i.e., approximately every 18 months). The need to complete an

NIS-2 form would occur as a result of a repair required by the results

29f i

i of an inservice inspection, or as a result of an unanticipated repair between refuelings. Typically, 2 NIS-2 forms are completed for repairs resulting from the inspection and 2 for repairs required during opera-tion. Assuming applicability to 127 plants, and the completion of 4 NIS-2 forms by each plant every 18 months, with ten hours required to collect information and complete each form, it is estimated that the total time required by all utilities to complete the NIS-2 form is approximately 3400 hours0.0394 days 0.944 hours 0.00562 weeks 0.00129 months / year.

a(2) Estimated Recordkeeping Burden Based on the magnitude of records required for the overall inservice inspection program, it is' estimated that 41% of the total industry re-porting burden (3,400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months ) encompasses hours expended annually for recordkeeping requirements. Recordkeeping requirements are, there-fore, estimated to involve approximately 1,394 hours0.00456 days 0.109 hours 6.51455e-4 weeks 1.49917e-4 months annually.

b. Estimated Cost Required to Respond to the Collection Based upon the hours specified in Item 3.a, it is estimated that the cost of responding to the information collection required by the Section III, Division 1, and Section XI, Division 1, edition and addenda specified in the proposed amendment to $50.55a is a total of

$214,000/ year (3400 hrs x $60/hr) for 127 plants.

c. Source of Burden Data and Method for Estimating Burden Estimates of the number of NIS-2 forms that are completed during a year and the time required to collect the necessary information and to complete the forms, were obtained from utility staff inservice inspection specialists and NRC staff in the Office of Inspection and Enforcement (regional and headquarters) engaged in inservice inspec-tion activities.

d. Reasonableness of Burden Estimate The estimate of the burden is considered reasonable because of the reliable source of the burden data.

4. Estimate of Cost to the Federal Government NRC inspection personnel who audit plant quality assurance records would include in their audit verification of the proper implementation of the NIS-2 form. The time associated with NRC inspectors verifying use of the NIS-2 form would be extremely small when the activity is performed as part of a normal quality assurance audit.

4 Part 4 i

SUPPORTING STATEMENT for Bulletins and Generic Letter Program 10 CFR 50.71 Justification The Bulletin and generic letter program is an adjunct to the NRC regulatory over-sight program and functions as an extension of the reporting requirements under

. 10 CFR 50.71 which require each licensee and each holder of a construction permit to maintain such records and make such reports, in connection with the licensed activity, as may be required by the conditions of the license or permit or by the rules, regulations, and orders of the Commission in effectuating the purposes

( of the Act, including section 105 of the Act. NRC periodically issues Bulletins and generic letters to communicate with industry on matters of generic importance or serious safety significance; i.e., if an event at one reactor raises the possi- -

bility of a generic problem, an NRC Bulletin or generic letter may be issued requesting licensees and/or permit holders to take specific actions and to submit a written report describing actions taken and other information NRC may need to assess the need for further actions to assure public health and safety.

These Bulletins and generic letters generally require one-time action and reporting.

They are not intended as substitutes for revised license conditions or new regu-latory regirements. Most Bulletins and generic letters identify the regulatory requirements that are currently contained in 10 CFR 50. Prior to proposing the Bulletin or generic letter, the staff considers the potential additional burden caused by either having the NRC inspectors collect the information or having the licensees / applicants provide the information in a report. Having considered both options, NRC deems it more practical to obtain the necessary information via licensee reporting.

Proposed Bulletins and generic letters that request a response are routinely reviewed by the NRC's Committee to Review Generic Requirements (CRGR), except in those rare instances where it is judged by the Director, Office of Inspection and Enforcement (IE), or the Director, Office of Nuclear Reactor Regulation that an immediate emergency action is needed to protect the health and safety of the public. In those circumstances, no review by the CRGR is necessary and the Office Directors have the authority to issue the Bulletin or generic letter.

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( Each proposed Bulletin or generic letter to be reviewed by CRGR that does not require emergency action is categorized as either Category 1 or 2 requirements.

Category 1 requirements are those which are needed to overcome problems requiring priority resolution or to comply with a legal requirement for immediate or near term compliance.

Category 2 requirements are those which do not meet the criteria for emergency

( action or designation as Category 1. These are to be scrutinized carefully by the CRGR on the basis of written justification submitted by IE or NRR. Upon notice to the members of the CRGR, and without objection, the CRGR Chairman may exempt any Category 2 proposal from review on tha grounds that he concludes that it involves only an insignificant effect on the NRC staff and on licensees.

Based on two years of experience and data, the NRC believes that a reliable estimate of the annual impact of Category 1 and 2 Bulletins and generic letters is possible and that this burden is logically included in 10 CFR 50.71.

Tabulation and Publication Plans Responses to Bulletins and generic letters are made available for public inspec-tion in the NRC's Public Document Rooms.

Time Schedule for Data Collection and Publication The time schedule for reporting is defined in each Bulletin or generic letter, however, licensees and/or permit holders will not be required to respond in fewer than 30 days under this clearance requirement.

Consultations Outside the Agency When appropriate, prior to issuing a Bulletin or generic letter, the NRC seeks comments on the matter from the industry (utilities, Atomic Industrial Forum, nuclear steam system suppliers, vendors, etc.) This technique has proven effec-( tive in bringing faster and better responses from licensees.

Estimate of Respondent Reporting Burden The number of licensees and/or permit holders actually affected by a particular Bulletin and generic letter and the associated burden varies in each specific instance; however, an estimated annual average would include approximately one half of the operating reactor licensees (e.g., 50 respondents) to each of 12 Bul-letins and 6 generic letters,* each imposing an average burden of 245,000 hours0 days 0 hours 0 weeks 0 months .

This amounts to a total annual burden of 441,000 hours0 days 0 hours 0 weeks 0 months or an individual licensee and/or permit holder burden for each response of 8,820 hours0.00949 days 0.228 hours 0.00136 weeks 3.1201e-4 months , which represents an annual industry cost of $26,460,000 (560 X 441,000). While an increase is reflected in this statement, note that the generic letters discussed in Part 9, 50.54(f) have decreased.

Estimate of Cost to Federal Government Estimate of cost to the Government, which includes preparation of the Bulletin or generic letter obtaining all necessary clearances, mailing, and analysis of responses is estimated at 1,000 hours0 days 0 hours 0 weeks 0 months per Bulletin or generic letter or 18,000 hours0 days 0 hours 0 weeks 0 months annually. The total annual estimated cost to the Government is $1,080,000 (12 bulletins and 6 letters annually X 1,000 = 18,000 hours0 days 0 hours 0 weeks 0 months @$60).

These 6 generic letters recognize the 4 generic letters estimated in Part 9, i Supporting Statement for 50.54(f).

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PART 5 1

SUPPORTING STATEMENT 10 CFR 50.48 AND APPENDIX R TO 10 CFR 50 Fire Protection JUSTIFICATION 10 CFR Part 50.48 amends the regulations to require certain provisions for fire protection in operating nuclear power plants. This action was undertaken to upgrade fire protection at nuclear power plants licensed to operate prior to January 1,1979, by requiring resolution of certain contested generic issues in fire protection safety evaluation reports. The program on which this part is dependent is Appendix R - Fire Protection Program for Nuclear Power Facilities

- Operating prior to January 1,1979, which makes requirements of certain items of fire protection guidance that have been used by the staff since the Browns Ferry fire on March 22, 1975, to evaluate the adequacy of fire protection programs at operating nuclear power plants.

Section 50.48(a) requires that each operating nuclear power plant have a fire

' protection plan that satisfies Criterion 3 of Appendix A to 10 CFR 50. This fire protection plan must describe the overall fire protection program for the -

facility, identify the various positions within the licensee's organization that are responsible for the program, state the authorities th.at are delegated to each of these positions to implement those responsibilities, and outline the plans for fire protection, fire detection and suppression capability, and limit-ation of fire damage. The plan must also describe specific features necessary to implement the program described above, such as administrative controls and personnel requirements for fire prevention and manual fire suppression activit-i fes, automatic and manually operated fire damage to structures, systems, or l components important to safety so that the capability to safely shutdown the plant is ensured. Present licensed cpe sting plants have already met the requirement for a plan, therefore, there is no immediate burden.

Section 50.48(c)(5) requires licensees to submit plans and schedules for meeting the provisions of paragraphs (c)(2), (c)(3) and (c)(4) within 30 days after the i effective date of this section and Appendix R of 10 CFR 50.

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Section 50.48(c)(5) requires licensee to submit design descriptions of modifi-cations needed to satisfy Section III.G.3 of Appendix R to this part within 30 days after the effective date of this section and Appendix R of 10 CFR 50 (2/17/81).

Both of these requirements have already been satisfied by all licensees.

Therefore, there is no additional burden.

k Appendix R - Fire Protection Program for Nuclear Power Facilities Operation, requires manual fire fighting capability at each plant. It states that a fire l brigade of at least five persons on each shift shall be maintained at each

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nuclear power plant unit. In addition, the rule requires certain minimum levels of training for each brigade member, and training and drills for each brigade as a team.

The rule also requires maintaining certain records of the tra'ning and drills provided for the brigades and brigade members. The record keeping requirements have already been agreed to by most licensees as part of the license amendments that resulted from the staff's fire protection review of each plant. These records are required to enable the staff to evaluate the effectiveness of each training program and thus determine the expected effectiveness of each fire brigade to cope with any fire emergency which may occur. The two specific record keeping requirements are:

A. "Section III.I.3.d."

At three year intervals, drills shall be critiqued by qualified individuals independent of the licensee's staff. A copy of the written report from such individuals shall be available for NRC review.

B. "Section III.I.4" Individual records of training provided to each fire brigade member, in-cluding drill critiques, shall be maintained for at least three years to ensure that each member receives training in all parts of the training program. These records of training shall be available for review. Re-taining or broadening training for fire fighting within buildings shall i

be scheduled for all those brigade members whose performance records show deficiencies.

Description of fire protection plan These requirements will not affect the nuclear power plants that were licensed to operate prior to January 1, 1979 and that already have the Appendix R require-ments identified in their safety evaluation reports. 50.48(a) does not affect presently licensed plants since they have already completed these requirements with their approved fire protection programs. 50.48(a) will apply to new licensees on a case-by-case basis as applications are submitted to the NRC. No special requirement for a format or form is being imposed with this rule. Each licensee is free to develop the method and forms that best suit its individual operation. No new applications are anticipated in the next three years.

Estimate of Respondent Burden No. of Respondents Staff Hours Annual Appendix R affected per response Burden Section III.I.3.0 105 24 2,520 Section III.1.4 105 120 12,600 Total Annual Burden 15,120 i

Therefore, the estimated cost to industry is expected to be $907,200 ($60.00 X 15,120).

Estimate of cost to Federal Government We estimate that the average review time of fire brigade drill and training records per plant is 5 staff-hours. One Hundred Five (105) are expected to comply with this requirement annually for a total annual cost of $31,500 to the Government (105 plants x 5 staff hours / plant = 525 staff hours; 525 staff hours x $60/hr = 31,500).

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Part 6 SUPPORTING STATEMENT FOR SECTION 50.54(p)

Physical Security and Safeguards Contingency Plans

1. JUSTIFICATION

a. Need for and Practical Utility of the Information Collection Paragraph 50.34(c) of Title 10 of the Code of Federal Regulations provides for the submission of a physical security plan by each licensee who is authorized to operate a production or utilization facility. These plans are for the Pur-pose of protection against acts of industrial sabotage and protection of special nuclear material against theft by establishment and maintenance of a physical protection system.

Section 50.34(d) of 10 CFR Part 50 specifies that each application for a license to operate a production or utilization facility shall include a licensee safe-guards contingency plan in accordance with Appendix C to 10 CFR Part 73.

Section 50.54(p) requires that each licensee prepare and maintain safeguards contingency plan procedures in accordance with Appendix C of 10 CFR Part 73. A licensee desiring to make a change which would decrease the effectiveness of a

( security plan prepared pursuant to Section 50.34(c), Part 73,~or a licensee safeguards contingency plan (except for implementing procedures) prepared pur-suant to Section 50.34(d) or Part 73, as applicable, must obtain prior appro-val from NRC by submitting an application for an amendment to the license pur-suant to Section 50.90. A licensee desiring to make such a change shall submit an application for an amendment to his license pursuant to Section 50.90. Sec-tion 50.54(p) also states that a licensee shall maintain records of changes to the plans, made without prior NRC approval, for a period of two years from the date of the change, and shall furnish to the NRC a report containing a descrip-tion of each change within two months after the change is made.

Additionally, Section 50.54(p) requires that the licensee review the safeguards contingency plan annually and maintain records documenting the conduct and results of the annual review along with any recommendations derived from the review. These records are to be available at the plant for inspection by NRC personnel for a period of twc years.

b. Practical Utility of the Information Collection Physical Security Plans include generai performance requirements which recognize explicitly the need to provide protection from potential threats originating either externally or.from within a licensed facility. The NRC staff utilizes these licensee security plans as it conducts a continuous review to identify the changing kinds and degrees of threats and the vulnerabilities of reactors to such threats. This continuing reactor safeguards program provides a high I

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level of assurance to the NRC and the public that malevolent acts against opera-ting nuclear power plants will not result in undue risk to public health and safety.

c. Duplication of Other Collections of Information There are no valid alternatives to the licensee providing the Physical Secu-rity Plans and the Safeguards Contingency Plans and updating them by amendments or other documented changes. The plans are sensitive and are not widely dis-seminated. The applicant is the obvious party to supply the required data and no reasonable alternative reporting procedure exists. These requirements duplicate no other requirements and the reports are not provided by the licensee to any other Federal agency.

d. Consultations Outside The NRC DOE has been consulted on the requirements.

2. Description of Information Collection

a. Number and Type of Respondents The rule applies to each licensee who is authorized to operate a nuclear power reactor, enrichment or fuel reprocessing plant. There are 105 licensed nuclear power reactors and no enrichment or reprocessing facilities. Thus, 105 respon-dents are subject to the information collection requirements of 10 CFR Sec-tion 50.54(p).

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b. Reasonableness of the Schedule for Collecting Information If the licensee desires to make changes that do not decrease safeguards effectiveness, then he has two months from the time of making such changes to report them to the NRC. This is reasonable since the time only begins to run once the changes are implemented. His yearly review is reasonable since this corresponds with NRC inspection periods. Retention of the Changes for two years is reasonable since this insures that the information on the changes will be available for at least one inspection.

c. Method of Collecting the Information The licensee must review the safeguards contingency plan annually and maintain records documenting the conduct and results of the annual review along with any recommendations derived from the review. He can do this by any procedure he so desires. In addition, the licensee can collect the information necessary for reporting or requesting an amendment by any method he so desires. The licensee must keep records of any changes and notify NRC by mail within 2 months of any changes under Section 50.54(p).

d. Record Retention Requirements The licensee must retain records of any 50.54(p) changes for two years from the date of the change. The licensee must retain annual reviews of the 50.54(p)

, changes and recommendations that result from those reviews for a period of two years. This information is necessary for plant inspections by NRC personnel.

e. Reporting Period Reports are to be submitted at irregular intervals as amendments are made.

f. Copies to be Submitted The safeguards reporting rule requires that the licensee submit the original to the Regional office and a copy to Headquarters of the 50.54(p) changes.

3. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection The NRC estimates that approximately 250 50.54(p) notifications are made annually to the NRC by the Licensees. It is estimated that, on the average, 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months

, are required to prepare, notify NRC, keep records, revise and file each 50.54(p) amendment for a current industry burden of 50,000 hours0 days 0 hours 0 weeks 0 months per year.

b. Source of Burden Data and Method of Estimating Burden The burden estimates were developed using a review of past 50.54(p) amendments made to the NRC by the industry. Using $60.00 per staff hour gives an industry cost of $3,000,000.

c. Reasonableness of Burden Estimates

( The burden estimates were derived from consultation with licensee staff responsible for making safeguards reports and NRC staff experienced in documenting and analyzing 50.54(p) amendments.

4. Estimate of the Cost to the Federal Government The annual cost to the government is associated with analyzing and assessing the 50.54(p) amendment reports and reviews. .The NRC estimates that accomplish-ing these activities would require approximately 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months per plant. Thus,

12,600 staff hours (105 plants x 120) are anticipated annually for this effort.

Therefore, at $60.00 per staff hour, Federal cost is expected to be $756,000 per year.

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PART 7 SUPPORTING STATEMENT FOR 10 CFR Part 50.54(q, r, t) and Part 50, Appendix E

! Emergency Planning JUSTIFICATION The Nuclear Regulatory Commission requires that all production and utilization t

facility licensees shall, as a condition of their license, submit emergency plans for NRC review and approval, and maintain the emergency plans up to date.

The Commission's interest in emergency planning is focused primarily on situa-tions that may threaten to cause radiological risks affecting the health and safety of workers or the public. The Commission and the public have recognized the increasing importance of emergency planning. Emergency plans should be

, directed toward mitigating the consequences of emergencies and should provide reasonable assurance that appropriate measures can and will be taken to protect ,

the public health and safety in the event of an emergency. Although it is not i

possible to develop a completely detailed plan encompassing every conceivable type of emergency situation, advance planning can create a high order of pre-j' paredness, including provisions of necessary equipment, supplies, and services, and ensure an orderly and timely decisionmaking process at times' of stress.

Emergency plans are required to be submitted as part of the PSAR [10 CFR 50.34 (a)(10)] and FSAR or final license application [10 CFR 50.34 (b)(6)(v)]

to address the elements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50. In addition, copies of State and local government radiological emergency response plans are required to be submitted [10 CFR 50.33 (g)].

Section 50.54(q) authorizes licensees to make changes to their emergency plans if such changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet 10 CFR Part 50. It also requires that 1 copy of these changes be sent to the appropriate NRC Regional Office and 2 copies be sent to the Document Control Desk, NRC within 30 days after the change is made. Proposed

, changes that decrease the effectiveness of the emergency plans are to be sub-l mitted to and approved by the Commission prior to implementation and 3 copies of t

such proposed changes are to be submitted. The changes must be submitted with-in thirty days in order to permit the NRC to review such changes as quickly as possible. Without a quick review, changes'could be made to the emergency plans which might adversely affect adequate assurance of public health and safety, i

Part 50, Appendix E,Section V requires each licensee to submit to the NRC changes to emergency plan implementing procedures. One copy shall be submitted to the appropriate NRC Regional office and 2 copies shall be submitted to the Document Control Desk, NRC.

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Section 50.54(r) requires that each licensee who is authorized to possess and/or operate a research reactor facility under a license of the type specified in Section 50.21(c) and who had not obtained Commission approval of an emergency plan, as described in Section 50.34(b)(6)(v), prior to obtaining an operating license shall submit such a plan to the Commission for approval as part of the application for a renewal of the operating license. Each licensee who is autho-rized to possess and/or operate any other production or utilization facility who has not obtained Commission approval of an emergency plan, as described in Sec-tion 50.34(b)(6)(v), prior to obtaining an operating license, shall submit such a plan for approval.

Section 50.54(t) requires each licensee to provide for the development, revision, implementation, and maintenance of its emergency preparedness program, which shall be reviewed at least every 12 months.

The NRC staff will review new and updated emergency plans and implementing pro-cedures to determine whether or not licensees have devised an effective program for handling emergency situations. NRC Regional Offices will conduct periodic checks at licensee's facilities to assure that the plans and procedures are up-dated to reflect changing conditions.

There is no source for the required information other than licensees.

Practical Utility of Information Collection The NRC must find that the emergency plans conform to the requirements of 10 CFR Part 50, and that the plans provide reasonable assurance that, in the event of an emergency, appropriate measures can and will be taken to protect public health and safety. The time frame for completing this determination is usually contingent upon adjudicatory actions encompassing the operating license review process and could involve 2-4 years of staff effort.

Estimate of Burden The burden for maintaining the emergency preparedness program is estimated to be 8,000 person-hours per year for each of 105 power reacter licensees (840,000 hours0 days 0 hours 0 weeks 0 months ) and 30 person-hours for each of 75 research/ test reactor licensees' (2,250 hours0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months ) for a total of 842,250 hours0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months annually. The cost to licensees for the maintenance of their emergency preparedness program is, therefore, $50,535,000 (842,250 x $60).

Estimate of Cost to the Federal Government NRC estimates 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months per year for each of 68 sites for review of revised power reactor emergency plans and procedures. This results in a total of 5,440 person-hours at a cost of $326,400 to the Federal Government annually.

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Part 8 SUPPORTING STATEMENT FOR 10 CFR 50, SECTION 50.71(e)

Periodic Update of the Final Safety Analysis Record (FSAR)

JUSTIFICATION The NRC, through adoption of section 50.71(e) amended its regulation to require each nuclear power reactor licensee to submit at least annually to the Commis-sion revised Final Safety Analysis Report (FSAR) pages that reflect changes in information and analyses submitted to the Commission or prepared as a result

-of a Commission requirement. The amendment is being made to provide an updated reference document to be used in recurring safety analyses performed by the licensee, the Commission, and other interested parties.

The FSAR required to be updated by the rule is the original FSAR submitted as part of the application for the operating license. It would not include the

( subsequent supplements and amendments to the FSAR or the license that may have been submitted either in response to NRC questions or on the applicant's or -

licensee's own initiative following the original submittal. These various supplements and amendments must be appropriately incorporated into the original FSAR to create a single, complete and integral document. The initial revision to be filed will contain those pages from the originally submitted FSAR that are still applicable plus new replacement pages that appropriately incorporate ,

the effects of supplements, amendments and other changes that have be'en made.

This will result in a single, complete document, being filed, that can then serve as the baseline for future changes.

This rule is n'ecessary because the volume of written information in the docket files of operating power reactors is large and is increasing at a rapid rate.

By the time a power reactor has been in operation for a few years, much of the information in the FSAR has been modified, supplemented or superseded. This comes about by the applicant's submittal of designs and analyses supporting requested license amendments or technical specification changes, replies to regulatory requests, incident reports, and annual reports describing design and procedural changes. Consequently, it is difficult for anyone, including an NRC staff member, the licensee, or the public to be certain of the current status of a facility's design and supporting analyses.

To properly execute their respective responsibilities, the NRC staff and the licensee must work with accurate information. Problems stemming from a lack of accurate reference documents have existed for somd time, but are becoming greater with the passage of time and the addition of new operating plants.

i i In general, the older a facility is, the more difficult it is to identify the correct information. The newly licensed facilities are not presently a problem,

1 i i but they would become so in a few years without this new update procedure for licensee FSAR sets. In addition, as new staff members and licensee employees are assigned to plants with extensive licensing history and are involved in analyses and decisions affecting facility operation, the volume of reference material involved, due to lack of a single organized reference, is staggering.

In such an event, the possibility of error, due to reference to. outdated or incorrect material, is increased and the. resultant risk to the public is like-wise affected.

An existing regulation, Paragraph 50.30(c)(2) of 10 CFR Part 50, recognized the need by requiring that the applicant for a construction permit update its application, which includes the Preliminary Safety Analysis Report, to eliminate superseded information and provide an index of the updated application when an Atomic Safety and Licensing Board is appointed prior to public hearing by the Atomic Safety and Licensing Board. If an operating license hearing is held, the application must be updated at that time. After the operating license is issued, various sections of Part 50 (Section 50.59, for example) require that additional safety analyses be performed for individual facility changes that '

affect facility safety. The present regulations, however, do not require that such changes be incorporated into the FSAR.

All changes to the technical specifications are now treated as license amenc-ments and it would be appropriate to have an updated FSAR available at all times. Additionally, safety evaluations after operation of the facility has been initiated, required by proposed license amendments, technical specifica-

{ tion changes and other reasons, warrant at least the same supporting documen-tation as does the hearing process. -

In addition to the uses of FSARs previously discussed, FSARs are currently being used for a variety of other reasons such as:

a. To evaluate proposed changes, tests or experiments made pursuant to Sec-tion 50.59 and to determine the existence of unreviewed safety questions.

b. To supply adverse operating experience to current safety reviews.

c. For operator training by licensees,

d. For project manager training, orientation, and reassignment by the Commission.

e. A reference document by management and by safety review committees.

f. By IE inspectors to assist in their facility inspections.

g. By licensing examiners to prepare exams for facility operators.

h. In planning emergency responses.

i. To evaluate operating data by NRC technical reviewers.

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The NRC staff will utili:e the updated information supplied by licensees in response to the reporting requirement of section 50.71(e) as a primary reference

source to be employed during the numerous safety studies undertaken by licensees, the Commission, and other interested parties.

There is no source for the required information other than licensees.

Description of the Survey Plan This reporting requirement would affect 105 licensees.

Consultations Outside the Agency On November 8,1976, the Nuclear Regulatory Commission published in the FEDERAL REGISTER (41 FR 49123) a notice of proposed rule making inviting written suggestions or comments on the proposed rule by December 23, 1976. A notice of correction and extension of comment period was published in the FEDERAL REGISTER on December 27, 1976 (41 FR 56204) in which the comment period was extended to January 26, 1977. The notices concerned proposed amendments to 10 CFR Part 50, " Licensing of Production and Utilization Facilities," to require each applicant for or holder of a power reactor license which would be or was issued after January 1,1963 to periodically submit to the Commission revised pages for its Final Safety Analysis Report (FSAR) that indicate changes made in the facility or the procedures for its operation and any analyses affected by these changes.

In response to the comments received, the Commission modified the rule to (a) extend its applicability to all power reactors licensed to operate, (b) exclude applicants for operating licenses, (c) clarify the wording of the rule, (d) reduce its impact on power reactor licensees by relaxing some of the time requirements, and (e) require the initial revision to be a complete FSAR.

Estimation of Respondent Reporting Burden Approximately 105 licensees will be affected by this reporting requirement.

The average burden per licensee for the updating is estimated to be 1,000 staff-hours. Therefore, the annual burden for all licensees is 105,000 staff-hours. The estimated cost to the licensees is expected to be $6,300,000

($60 x 105,000).

The revision to Section 50.4 (51 FR 40303, November 6, 1986), which has been submitted for clearance in a separate package, specifies the number of copies to be submitted under this section.

Estimate of Cost to the Federal Government The NRC anticipates that approximately 5 staff hours will be involved annually in the handling and document control / filing systems of the updated FSAR. Thus, annual estimated cost to the Federal Government is expected to be $31,500 (5 staff hrs x 105 plants = 525 staff hours; $60/hr x 525 staff hours = $31,500).

Part 9 l SUPPORTING STATEMENT i FOR SECTION 50.54(f) l Collection of Information Under Oath or Affirmation JUSTIFICATION I NRC regulations, 10 CFR Part 50, Section 50.54(f), adopted January 19, 1956 (21 FR 355), provide that the licensee upon request by the Commission, submit written statements under oath or affirmation to enable the Commission to deter-i mine whether a license should be modified, suspended, or revoked. When the

staff has identified a potential health, safety, or environmental problem at a 4 particular plant or series of plants, the staff may require the licensee or licensees to submit information to evaluate the particular situation and to make i a determination whether the situation is serious enough to require that the license be modified, susper.ded, or revoked. t The time allotted the licensee to respond to the request for information depends upon the perceived risk associated with the potential problem. Most responses will be requested within a 30 to 90 day period. Occasionally, the

, urgency of the problem or complexity of the response will require the staff to

specify a shorter or longer response period.

Periodically there are equipment failures, construction problems, and issues i discovered or raised by the technical staff during the safety review and brought ,

to the attention of the NRC through licensee reporting procedures, the safety '

j review process itself, and by the NRC inspection staff.

! Since many of the flaws and malfunctions which are detected are novel, there is j little data available which would enable the NRC to predict, with certainty, !

j what the consequences might be. To develop a reliable data base, accurately

appraise the potential long-term significance of the anomaly, and determine '

! what, if any, corrective measures may be necessary, NRC must obtain information ,

l from licensees. Should the information provided by the licensees show that ,

j- there is only minor safety significance associated with the problem / situation, '

j the facility license would not be modified, suspended, or revoked. On the other hand, the Commission may issue an Order that does modify, revoke, or suspend the license to operate a nuclear reactor.

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l Without the information provided in the licensee's written statements, timely 4

staff action could not be taken and unsafe conditions could continue to exist, j thereby potentially endangering the public health and safety.

! The Commission requests specific information either from one licensee, on a problem or situation believed to be unique to a particular facility, or from i more than one licensee on a problem or situation believed to be generic in na-

! ture, i.e., that may affect more than one facility. Before licensees are re-

! quested to provide such information, the staff will have identified the problem or situation as one having potential safety or environmental significance.

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Based on the information obtained from licensee, or applicants and the staff's evaluation of the problem, new regulatory requirements may be identified. De-pending upon the nature of the problem and its resolution, these new require-ments could be imposed by regulation, or they could be imposed on affected facilities individually by amendment to the technical specifications or condi-tions of their construction permit or operating license (see 50.109, Back-fitting). In addition, the NRC could issue a Regulatory Guide which would describe the nature of the problem and the method or methods found adequate by the regulatory staff for its resolution.

There is no source for the required information other than licensees.

Description of survey plan This reporting requirement can affect any of about 200 licensees and construction permit holders. There are 105 operating power reactor licensees, 75 research/

test reactor licensees, and 22 construction permit holders.

Estimation of respondent reporting burden The burden is made up from the sum of the burden for requests of one licensee for a plant-specific concern and for requests of a generic nature which could apply to a category of licensees or applicants.

Plant-Specific Concern It is estimated that perhaps as many as five requests to a single licensee will be made each year. Our estimate of the burden is that on the average each request would require several people about 2 weeks to answer. There-fore, 300 hours0.00347 days 0.0833 hours 4.960317e-4 weeks 1.1415e-4 months per request for each of five requests totals 1500 hours0.0174 days 0.417 hours 0.00248 weeks 5.7075e-4 months .

Generic Considerations A review of the list of generic letters sent to the industry that requested information shows that not only does the annual number of letters vary, but so does the number of respondents and the level of effort required to pre-pare the different responses. It is estimated that there will be four*

generic letters / year. Of the four, one is likely to be minor, but affect a large number of licensees.

I letter x 50 licensees x 120 hrs / letter = 6,000 hrs One significant request is likely.

1 letter x 25 licensees x 600 hrs / letter = 15,000 hrs Three average requests to utilities with operating or soon-to-operate power reactors 2 letters x 90 utilities x 200 hrs = 36,000 hrs

These 4 letters recognize the 6 [non-50.54(f)] generic letters estimated in 50.71, Part 4 of the Supporting Statements.

The total respondent burden is 58,500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months . Therefore, the cost to the respondents is $3,510,000 (58,500 hrs x $60).

Estimate of cost to the Federal Government Prior to requesting information from the respondents, the NRC staff assesses the potential problem and identifies the needed information and how the infor-mation is to be used. This is estimated to take 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months for each plant spe-cific request and 640 hours0.00741 days 0.178 hours 0.00106 weeks 2.4352e-4 months for each generic letter. Each specific generic letter request for information is carefully justified prior to review by the NRC Committee to Review Generic Re:1uirements. In addition, staff review of the responses will require an additional 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months for the plant-specific informa-tion and 640 hours0.00741 days 0.178 hours 0.00106 weeks 2.4352e-4 months for the generic letters. This corresponds to 400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months for each of 5 plant-specific letters and 1280 hours0.0148 days 0.356 hours 0.00212 weeks 4.8704e-4 months for each of 4 generic letters or a total of 5,520 hrs. The total Federal cost is (5,520 hrs x $60) $331,200.

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Part 10 SUPPORTING STATEMENT FOR 10 CFR 50.72(a), (b), and (c), 50.54(z)

Notification of Significant Events JUSTIFICATION

, Following the accident at Three Mile Island on March 28, 1979, the NRC staff

acted to ensure the timely and accurate flow of information from licensees of

, operating nuclear power plants following significant events. Dedicated tele-phone lines were installed at all operating power plants to facilitate direct and rapid communications between ifcensees and the NRC Operations Center (and Regional Offices). A line is located in each control room with provisions made for extensions to be located at other specified locations at the facility.

When these phones are picked up to report significant events, they automatically ring at the NRC Operations Center and can be held open as long as needed.

I i NRC's Office of Inspection and Enforcement (OIE) issued Bulletins and sent -

letters to each licensee asking that current procedures for notification of NRC following significant events be reviewed carefully. The letters were intended to ensure that the licensees would promptly notify NRC when a reactor was determined to be in an uncontrolled or unexpected condition of operation.

g After this notification, a continuous communication channel was to be established

and maintained between the licensee and NRC.

The NRC staff evaluated licensees' responses to 0!E's letter and Bulletins and determined that the reporting procedures were not providing the prompt notifications expected by the Commission. The Bulletins issued to licensees by OIE did not impose reporting requirements and as a result, in several in- t stances licensees did not notify NRC promptly. The Commission, therefore, deter-mined that in order to protect the health and safety of the public, a rule was required. Rulemaking was initiated immediately thereafter, and resulted in an immediately final regulation (10 CFR 50.72) published in the Federal Recister on February 29, 1980 (45 FR 13435). Meanwhile, the Congress provided for l prompt notification in Section 201 of the Nuclear Regulatory Commission Authori-zation Act for Fiscal Year 1980 (Pub. L. 96 - 295) by amending Section 103 of the Atomic Energy Act of 1954 with a new subsection f at the end as follows:

"f. Each license issued for a utilization facility under this section or sec-tion 104 b. shall require as a condition thereof that in case of any accident i which could result in an unplanned release of quantities of fission procucts in j excess of allowable limits for normal operation established by the Commission, g

the licensee shall immediately so notify the Commission. Violation of the s condition prescribed by this subsection may, in the Commission's discretion, constitute grounds for license revocation. In accordance with section 187 of this Act, the Commission shall promptly amend each license for a utilization

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facility issued under this section or section 104 b. which is effect on the date of enactment of this subsection to include the provisions required under this subsection."

The Conference Report accompanying Pub. L.96-295 stated that the conferees recognized the need for predictability by licensees in determining those situa-tions which would require immediate notification. The conferees further in-tended that the Commission establish specific guidelines for the identification of accDients which could result in an unplanned release of radioactivity in excess of allowable limits, and that the immediate notification requirement would take effect when such guidelines were established. H. Conf. Rep.

No. 96-1070, 96th Cong., 2d Sess., 30 (June 24, 1980).

Although the regulation, 10 CFR 50.72, was published as immediately effective withNt a prior public comment period, the public was invited to submit its views and comments. Therefore, in response to the above Congressional actions and after obtaining the experience about receiving notification as required by the rule, the Commission published in the Federal Register a notice of proposed rulemaking on December 21, 1981 (46 FR 61894) and invited public comment. The proposal was made to meet two objectives; Change 10 CFR 50.54 to implement section 201 of the NRC's 1980 Fiscal Year Authorization Act and change 10 CFR 50.72 to more clearly specify the significant events requiring licensees to immediately notify NRC. These changes were published in the Federal Register on August 29, 1983, (48 FR 39045).

Section 50.54(z) requires that each licensee with a utilization facility

( licensed pursuant to sections 103 or 104b of the Act shall immediately notify the NRC Operations Center of the occurrence of any event specified in S 50.72.

The NRC staff will evaluate the information transmitted to the Commission in response to these reporting requirements and make the timely decisions required to provide adequate assurances regarding actual or potential threats to public safety. There is no source for the required information other than licensees.

Description of the Information Collection Examples of events requiring notification:

a) Declaration of emergency situations as required by the Site Emergency Plan; b) Any deviation from the plant's Technical Specifications; c) Any natural phenomenon (forest fire, earthquake, tornado, hurricane) that poses a threat to the plant; d) Injury or illness of personnel involving radioactive contamination; and e) Initiation of a plant shutdown required by plant Technical Specifications.

These reporting requirements will affect 105 operating nuclear plants.

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Estimation of Burden It is estimated that 40 reports annually will be received from each of 105 operating plants in response to the reporting requirement of 50.72.

The burden for each phone call is estimated to be 15' minutes. Therefore, the total annual burden for all licensees covered by this reporting requirement is estimated to be:

105 plants x 40 reports per year = 4,200 reports 4200 reports x .25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months = 1,050 person hours Cost to industry is, therefore, estimated to be $63,000'(1,050 person hours x

$60).

Estimate of Cost to the Federal Government Events Analysis The cost to the Federal government is estimated as follows:

1. Office of Nuclear Reactor Regulation - 3 person years (2,080 person hours /

per year x 3 person years = 6,240 person hours)

2. Office of Inspection and Enforcement - 7 person years (2,080 person

( hours x 7 person years = 14,560 person hours)

3. Five Regional Offices - 1 person year each (2,080 person hours x 5 =

10,400 person hours)

Event Report Receipt

1. 7 Persons to man the Operations Center around the clock (2,080 X 7 =

14,560 staff hours) 14,560 X $60 = 873,600

2. Cost of the Emergency Notification System line for reporting events $3.5 million

. Based on the above, annual Federal cost for events analysis associated with these regulations is estimated to be (31,200 annual person hours x $60)

$1,872,000. When this is added to the Federal . Cost involving the receipt of the event report, the total annual cost to the Federal government is expected to be $6,245,600.

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i Part 11 4

1 SUPPORTING STATEMENT FOR

10 CFR 50.55(e)

Reporting of Significant Design

and Construction Deficiencies Justification

" Quality Assurance Criteria for Nuclear Facilities" as an Appendix B to 10 CFR Part 50, " Licensing of Production and Utilization Facilities," requires an 4

2 applicant for, or holder of a license to construct or operate, a nuclear power plant to establish a quality assurance program. This program is to assure, among other things, that all conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance, are promptly identified and, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , reported to the appropriate Regional Office. The requirements of 10 CFR Section 50.55(e) were ,

added to the regulations in 1972 to ensure that the more significant of these deficiencies be reported to the Commission. Without the reporting requirement of 10 CFR Section 50.55(e), the Commission would only be notified of defi-ciencies occurring during the design and construction of nuclear power plants through its Inspection during the design and construction of nuclear power plants through its Inspection staff or through reports submitted by holders of construction permits,'either voluntarily or as requested by the Commission on a case-by-case basis.

The reports submitted under Section 50.55(e) are necessary to ensure that the i staff is promptly informed of deficiencies identified in design and construc-i tion so that a timely inspection and evaluation of the deficiency can be made.

Timely evaluation is necessary to adequately protect public health and safety l from the potential consequences of the deficiency at the plant reporting and from other similar plants, should the deficiency be generic. Specific uses i made of the data reported under Section 50.55(e) include evaluation of impact

! of the deficiency on the quality of construction and of the adequacy of planned

, corrective action, identification of generic problems, inspection and enforce-ment personnel, and identification of problems in management or implementation of the quality assurance program.

There is no source for the required information other th q licensees.

Description of the Information Collection i This reporting requirement affects approximately 22 plants under construction.

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, . _ _ _ - ,.__.___ .___, _,__,_m.__.__ __ __,m-._,____.... ...... .,,. .-- _ -___- __, _ .

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Estimation of Burden i The preparation burden per plant is approximately 500 staff-hours. 22 x 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months = A total annual burden for all licensees of 11,000 hours0 days 0 hours 0 weeks 0 months at a cost of

$660,000 ($60 x 11,000 hours0 days 0 hours 0 weeks 0 months ).

Estimate of Cost to the Federal Government NRC's burden is expected to be 4,900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months at a cost of $294,000 ($60 x 4,900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months ).

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Part 12 SUPPORTING STATEMENT FOR 10 CFR 50.59(b)

REPORTS AND RECORDS FOR CHANGES, TEST AND EXPERIMENTS JUSTIFICATION Section 50.59 of NRC regulations allows a holder of a license authorizing operation of a production or utilization facility (1) to make changes in the facility as described in the Safety Analysis Report, (ii) to make changes in procedures as described in the Safety Analysis Report, and (iii) to conduct tests or experiments not described in the Safety Analysis Report, without prior Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or an un-reviewed safety question.

The records are used by licensees to interrelate subsequent changes and to pre-pare reports concerning changes, tests or experiments as required by this Section

( of the Regulation.

These records are also frequently used by NRC regional inspectors. The records provide background information needed by the NRC inspector during his visit to a licensed facility. He uses these records to confirm the appropriateness of changes, tests or experiments, or during evaluation of abnormal occurrences.

The records and reports assist the NRC staff in evaluating the potential effects of these changes in relation to the health and safety of the public. The ulti-mate value is received in the form of assuring the health and safety of the public and is well worth the cost of collecting, storing, and reporting the data.

Description of the survey These recordkeeping and reporting requirements affect 105 power reactors and 75 research/ test reactor licensees.

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Estimation of Recordkeeping Requirements Based on the staff's experience and in light of the extensive records which have to be maintained on site to meet the requirements specified in 10 CFR 50.59(b),

the staff estimates that licensees for 180 facilities evaluate approximately 100 changes a year. It is also estimated that approximately 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months of burden is required for records associated with the analysis of 100 changes annually.

Thus, recordkeeping burden encompassed within 50.59(b) is estimated to be (1,600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months x 180 plants) 288,000 hours0 days 0 hours 0 weeks 0 months . Accordingly, annual recordkeeping cost to industry will be ($60 x 288,000) $17,280,000.

Estimation of Respondent Reporting Burden The reporting burden consist of 180 licenseas submitting a summary of the changes, that have been evaluated annually. It is expected that approximately 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months are required to summarize and prepare reports for approximately 100 changes per year. Thus, the reporting burden for this provision of the regu-lation is expected to involve 72,000 hours0 days 0 hours 0 weeks 0 months annually (400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months x 180 plants).

The annual cost to industry is, therefore, expected to be (72,000 hours0 days 0 hours 0 weeks 0 months x $60) =

$4,320,000.

Total industry burden annually would, therefore, be 360,000 hours0 days 0 hours 0 weeks 0 months ; total annual cost would be $21,600,000 ($60 x 360,000).

The revision to Section 50.4 (51 FR 40303, November 6, 1986), which has been submitted for clearance in a separate package, specifies the number of copies to be submitted under this section.

I Estimate of Cost to the Federal Government There is an additional burden to the Federal Government of 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months per licensee; (105 power reactor licensees and 75 research/ test reactor licensees); 180 licensees x 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months = 14,400 staff-hours. Therefore, the cost to the Federal Government is expected to be $864,000 ($60 x 14,400). .

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Part 13 SUPPORTING STATEMENT FOR 10 CFR 50, APPENDIX G AND APPENDIX H, SECTION IV; 50.60 Fracture Toughness Tests, Surveillance and Reports JUSTIFICATION Appendix G to 10 CFR Part 50 specifies minimum fracture toughness requirements for the reactor coolant pressure boundary of water-cooled power reactors. Sec-tion V specifies how radiation damage to the reactor beltline is to be accounted for in the fracture control plan for the reactor. Paragraph V.C. requires that certain extra steps be taken in the event that the normal fracture analysis requirements specified in Paragraph V.B cannot be satisfied. Paragraph V.D.

requires a thermal anneal of the reactor vessel beltline if the procedures of Paragraph V.C. do not indicate the existence of an adequate safety margin.

Paragraph V.E. requires that the proposed programs for satisfying the require-( ments of Paragraphs V.C. and V.D. be reported to the Director of Nuclear Reactor Regulation for review and approval at least three years prior to the date when the predicted fracture toughness levels will no longer satisfy the requirements of Paragraph V.B.

The information in the report required by Paragraph V.E. will be used by the staff to perform a safety evaluation of the reactor vessel. This evaluation will be the basis for approval to continue operation for a specified time and for approval of the additional procedures that will be required to continue operation beyond that time. The three year lead time is needed to provide time to obtain supplemental fracture toughness data on archive material that has been subjected to accelerated irradiation, and to evaluate the fracture analyses that willl be submitted which use that data.

Section III.B contains the materials test requirements for the Charpy V-notch tests and drop weight tests. Paragraph III.B.5 specifies that records are to be kept on (1) the test results, with traceability to the material in each component, (2) the qualification of test personnel, and (3) the calibration of test equipment.

The records maintained by licensees for the life of the facility in response to this requirement are available for inspection by the staff to determine compliance with Appendix G. There is a continuing requirement that certain pieces of the data will be needed to support a licensee's fracture control plan or fracture analysis for some component in an operating plant. The data will be used by the NRC staff in making its safety evaluation of the licensee's submittal. Material properties of the actual material in the component are

( an essential input to such evaluations.

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. The records that must be retain [d per' A;ipendix G are of considerable value to

' v the plant owner in the event o'f some sort of material deterioration problem or the discose'ry of a flaw that re4uires a fracture analysis. The frequency

of. occurrence'of such situations for a given plant is difficult to estimate -

perhaps ones everf three years on the average. The value to the plant owner lies 'in the ability to provide a sound basis for estimates of material toughness 3 , thaD are an essential part.of the fracture analysis.

The' impact of not obtainGg the *hformation from records would be that the fracture Analyses would have to be based on conservative estimates derived from

" the published data base of; typical material properties. The impact of an overly-conservative analysis could be;the removal of some unimportant defect found in inspection with considerable economic loss due to the power outage and

., unnecessary exposure of maintenance personnel to radiation.

l There n

is no source Yor tf(e required information other than the licensees.

Appendix H of 20. CFR Part 50 regt: ires a material surveillance program for each

, reactor vessel 6 monitor changes in the fracture toughness of the reactor vessel beltline materials resulting from their exposure to neutron irradiation 1 and the thermal environment.' Paragraph IV requires: (a) the test results obtained from the specimens contained in each surveillance capsule shall be reported to the Difactor of Nuclear Reactor Regulation, NRC, for each capsule withdrawal,'and (b)-new pressure; temperature operating limits for the reactor, based on the' surveillance test results, shall be reported.

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'4 Surveillar.ce reports are reviewed by Division of Licensing staff, whose evalua-tion is the basis for approval of the proposed pressure-temperature operating limits for the reactor.

The impact of not obtaining the reports required by Paragraph IV would be that the pressure-temperature limits for the reactor would have to be checked against conservative estimates of radiation damage such as those given in Regulatory Guide 1.99, Revision 1. At the present time there are too many uncertainties in the assessment of radiation damage to a reactor vessel to permit a licensee l~ to forego monitoring radiation damage and reporting the surveillance test results to the NRC. Without the information required by Paragraph IV of Appen-

, dix H there would be insufficient basis for approval of continued operation 3 beyond a few years' life.

b li L.Section 50.60, acceptance criteria for fracture prevention measures for light water nuclear power reactors for normal operation, provisions are as follows:

, 3 (a) Except as provided in peragrapti(b) of 50.60, lightwater nuclear power reactors must meet the fracture toughness and material surveillance program i,

requirements for the reactor coolant pressure boundary set forth in Appendices G

, and H. (b) Proposed alternatives to the described requirements in Appendices G and H may be used when an exemption is granted by the Commission.

~

In addition,

/ the applicant must demonstrate that (1) compliance with the specified require-ments would result in hardships or unusual difficulties without a compensating increase in the level of quality and safety, and (2) the proposed alternatives would provide an adequate level of quality and safety. This information is needed to assure that the reactor vessel does not exceed radiation embrittlement

(' limi',s and meets the requirements of General Design Criterion 31 and 32, speci-s fiec/in Appendix A to 10 CFR Part 50.

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.... . ~__-. - - - _ .4 ._ _ _ _. ..._ _ ...,,a __,___ _ . . _ . . _ . . . . . _ _ - _ . _ . . . - ,

There is no source for the required information other than the licensees.

Description of the Survey Plan The reporting and recordkeeping required affect 5 licensees for Appendix G Section V.E., 105 for Section III.8, and 127 for Appendix H.

Estimation of Respondent Reporting Burden Appendix G Section V.E. Negligible Section III.B 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months , 105 X 100 = 10,500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months annually Appendix H 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months , (per report), 127 X 160 = 20,320 hours0.0037 days 0.0889 hours 5.291005e-4 weeks 1.2176e-4 months annually.

Thus, estimated industry cost is (30,820 hours0.00949 days 0.228 hours 0.00136 weeks 3.1201e-4 months X $60) $ 1,849,200.

Cost to the Federal Government Appendix G Section V.E. roquires 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months per report 160 x 5 = 800 staff-hours at a total cost of $48,000 ($60 X 800).

Section III.B is negligble

( Appendix H requires $38,400 based on staff experience.

Therefore, the total estimated Federal cost is $86,400 ($48,000 + $38,400).

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Part 14 t

SUPPORTING STATEMENT FOR 10 CFR 50, APPENDIX J Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors JUSTIFICATION 10 CFR 50, Appendix J, " Primary Reactor' Containment Leakage Testing for Water-Cooled Power Reactors," provides for preoperational and periodic verification, by tests, of the leakage integrity of the primary reactor containment and sys-tems and components which penetrate cot.iinment of water-cooled power reactors.

Tests are conducted upon completion of construction of the primary reactor containment building (containment), periodically during each 10 year service period (approximately every 3-1/3 years) for the entire containment system, and during shutdown for refueling (approximately every 18 months but in no case at intervals greater than 2 years for individual valves and penetrations). The Appendix also establishes acceptance criteria for such tests. One of the con-(

ditions of all operating licenses for water-cooled power reactor is that primary reactor containments shall meet containment leakage test requirements set forth in 10 CFR 50, Appendix J.

Section V.B., " Inspection and Reporting of Tests," requires submission to the NRC of a summary technical report, " Reactor Containment Building Integrated Leak Rate Test," approximately 3 months after the conduct of each preopera-tional and periodic test. Furthermore, such reports must include a separate accompanying summary report analyzing and interpreting the test data for any tests that failed to meet the acceptance criteria of Appendix J. Results and analyses of the supplemental verification test employed to demonstrate the validity of the leakage rate test measurements are also required to be included.

The primary reactor containment is designed to contain any operational or post accident releases'of radioactivity within specified limits. Calculations of the impact of a radiological release on public health and safety are depen-dent upon predictable leakage from containment. The required tests make sure that the containment is built and maintained as designed, and that leakage limits are not exceeded.

Reports of preoperational leakage tests are needed by the NRC (Inspection and Enforcement and the Office of Nuclear Reactor Regulation) since these tests are the only means by which it can be verified that these structures have in fact been built within the leakage levels specified as a condition of licensing by the NRC. Information included in the report is reviewed to determine the results achieved, as well as to judge the accuracy and validity (reliability) t of the data.

The reports of the periodic leakage tests are needed by the NRC (IE and NRR) in order to verify that containment leakage is maintained below the specified level throughout its operational life. Periodic information is needed for the same reasons as preoperational test information, but in addition, is compared with that in the preoperational test report and previous periodic test reports.

If the preoperational or a periodic leakage test was not successfully completed, operation of the reactor would not be permitted.

There is no source for the required information other than licensees.

Description of the Survey Plan Out of 105 operating reactor licensees, the NRC anticipates 70 reports

annually.

Estimation of Respondent Reporting Burden The burden on licensees for preparation of each report is estimated to be 366 hours0.00424 days 0.102 hours 6.051587e-4 weeks 1.39263e-4 months .

Approximately 70 reports are submitted annually.

70 x 366 man hours = A total annual burden for all licensees of 25,620 man-hours. Therefore, estimated industry cost is expected to be $1,537,200

($60 X 25,620).

Estimate of Cost to the Federal Government

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The cost to the Federal Government for the review of each report is estimated to be $60.00.

Approximately 70 reports are submitted annually:

70 x $60.00 = $4,200.

Each licensee submits a report on the average of every 18 months.

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PART 15 SUPPORTING STATEMENT FOR 10 CFR 50.35(b)

Periodic Research and Development Reports JUSTIFICATION Section 50.35 Issuance of Construction Permits, specifies in paragraph 50.35(b) that "The Commission may, in its discretion, incorporate in any construction permit provisions requiring the appifcant to furnish periodic reports of the progress and results of research and development programs designed to resolve safety questions". This procedure allows the Commission, by special reference in a facility construction permit, to request information concerning ongoing R&D activities that are in support of a construction permit. However, reports are not currently being filed uncer Section 50.35(b).

These reports would keep the staff apprised of the progress and findings of licensee R&D programs and increase the likelihood that any safety problems would be resolved in a timely manner.

The NRC Staff would evaluate the results obtained from licensee R&D programs.

The staff would then determine what, if any, corrective measures were acprocriate ,

and develop regulatory procedures including revisions to existing review processes and possible facility modification, if necessary.

There is no source for the required information other than licensees.

Description of the survey plan -

This reporting requirement is not currently being utilized to obtain informatien from licensees.

Estimation of resconcent reoortino burden This reporting requirement is not being employed by NRC to obtain information from licensees at this time and therefore imposes no respondent burden. NRC requests renewal of the clearance for this section, however, in orcer to receive l timely information from licensees on potential new technological oevelcoments i for both power reactor and fuel reprocessing systems. Ongoing R&D programs throughout the industry create the possibility of safety-related issues arising at any time. The NRC staff must be able to obtain information from licensees concerning current research projects in orcer to make informed judgements acout the effects of current research on future licensing actions.

Estimate of cost to the Federal Government Negligible l.

Part 16 SUPPORTING STATEMENT FOR 10 CFR 50.71(b) snd APPENDIX C Annual Financial Report and Financial Requirements JUSTIFICATION The requirement for the annual financial report, including the certified finan-cial statements, arises from the Atomic Energy Act of 1954, as amended, Sec-tion 182 " License Applications." Section 182(a) provides, among other things, that each application or a license shall state such information as the Commis-sion, by rule or regulation, may determine to be necessary to decide such of the financial qualifications of the applicant as the Commission may deem appro-priate for the license.

( Section 10 CFR 50.71(b) provides for the filing of annual financial reports, including certified financial statements, of facility licensees with the Commission. The fundamental purpose of the financial qualifications provision is the protection of the public health and safety and the common defense and security. An applicant's financial qualifications may affect his ability to meet his responsibilities on safety matters.

The Commission reserves the right to require additional financial information during the operation of a facility, particularly in cases which the nuclear power plant will be commonly owned by two or more existing companies, or in which financial depends upon long-term arrangements for the sharing of the electric power output of the facility by two or more electric power generating companies. The annual financial report is the only financial document routinely filed by a license after a construction permit has been issued for a nuclear power plant.

The annual financial reports are used by NRC staff for financial monitoring of the respondents. If it appears that any respondent is experiencing financial difficulties, this information is provided to NRC management for their consi-deration. The information is also placed in NRC docket files and Public Document Room, and thereby made available for inspection by the public.

On September 12, 1984, the Commission promulgated a final rule which eliminates j requirements with respect to financial qualifications for electric utility applicants for a license to operate a production or utilization facility as presribed in Section 50.21(b) or Section 50.22. (See Appendix C.)

( There is no source for the required information other than licensees.

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Description of the Survey Plan This reporting requirement affects approximately 127 licensees annually.

Estimation of Respondent Reportina Burden The annual burden per licensee is estimated by the staff to be 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

127 x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months = A total annual burden for all licensees of 127 hours0.00147 days 0.0353 hours 2.099868e-4 weeks 4.83235e-5 months .

This is based on staff's experience. Therefore, industry cost is estimated to be ($60 x 127) $7,620.

Estimate of Cost to the Federal Government The annual burden is estimated to be 1 staff-hour / report 127 x 1 = 127 staff-hours total for a total cost of $7,620 ($60 x 127 staff nours).

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Part 17 EUPPORTING STATEMENT FOR Property Damage Insurance 10 CFR 50.54(w)(4)

Justification Licensees of commercial nuclear power plants are required to submit annually proof that they carry onsite property damage insurance available from private sources in an amount specified in 10 CFR 50.54(w)(1) or as established by Com-mission in response to a request for exemption. This reporting requirement arises out of a Commission regulation promulgated on March 31, 1982 that such insurance be obtained. The information submitted by licensees is used by the NRC staff to assure that licensees are complying with the requirement to main-tain onsite property damage insurance.

Description of Survey Plan Reporting requirement affects approximately 50 licensees.

Tabulation and publication plans There are no plans to publish the data.

Time schedule for data collection and publication

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Information will be collected from licensees as long as they remain licensees and the insurance and reporting requirement remains in effect. The information will not be published as such.

Consultations outside the agency Regulation received public comment during proposed rule stage.

Estimation of respondent reporting burden Average reporting burden to each licensee is a letter to NRC of usually no more than one paragraph indicating both the amount of onsite property damage insur-ance being carried by the licensee and the insurer (s) from whom the insurance was obtained. Time to complete this is estimated to be no greater than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per licensee. No significant variation in burden among licensees is expected.

There are currently 50 licensees affected by the reporting requirements. Thus, the current annual burden is 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months . The estimated industry cost is $12,000

($60.00 x 200).

j Sensitive questions Not applicable.

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Estiraate of Cost to Federal Government Staff review time of 15 minutes / licensee is expected. Total staff review time per year is 15 min 0tes/ licensee x 50 licensees = 12+ staff hours. Given the assumption of salary per hour of $60.00, the total dollar cost to the Federal government is expected to be $720 annually, t

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1 Part 18 SUPPORTING STATEMENT FOR

" Guidance for Implementation of the

Standard Review Plan Rule (10 CFR 50.34(g)) NUREG-0906"

1. JUSTIFICATION The Nuclear Regulatory Commission (NRC) is authorized by Congress to have responsibility and authority for the licensing and regulation of nuclear power plants. To meet this responsibility, the NRC conducts a detailed review of all applications for licenses to construct and operate such facilities. In

, March 1982, the NRC adopted a final rule, 50.34(g), which requires the appli-cants for a construction permit (CP), operating license (OL), preliminary design approval (PDA), or final design approval (FDA) provide, as part of the material currently required by 10 CFR 50.34, an evaluation of the differences from the Standard Review Plan (NUREG-0800) acceptance criteria, for those i applications docketed after the effective date of the rule. NUREG-0906, the subject of this statement, is proposed guidance to applicants to assist them (j

in complying with the rule.

The Standard Review Plan (SRP) reflects the NRC's detailed interpretations of the acceptable means to satisfy the applicable regulatory requirements, which l

assure that the proposed facilities can be constructed and operated without any undue risk to the health and safety of the public. Because of limitea resources, the NRC staff conducts audit reviews of the Safety Analysis Reports (SARs) submitted in accordance with an application, in accordance with the review procedures in the SRP.

The material currently found in SARs does not land itself to ready identifica-i tion of the differences from the SRP acceptance criteria. These differences are often found in responses to staff questions or during meeting discussions.

Consequently, a concern has been raised regarding the thoroughness of the staff's review and the degree to which the plants conform to the applicable regulatory requirements. Differences from the SRP acceptance criteria do not necessarily imply nonconformance with regulatory requirements; however, they do reflect a departure from accepted practice that should receive a thorough 4

staff review.

The objective of the requirement contained in 10 CFR 50.34(g) and of the imple-menting guidance of NUREG-0906 is to allow the limited NRC staff resources to quickly focus on those areas invclving differences from the SRP acceptance cri-i teria in order to make the most effective use of the staff's resources.

Experience has shown that such differences usually involve issues of safety j significance and require the greatest amount of time to resolve. Since the applicants are intimately familiar with their plant's designs, they are in a I

4 e better position to identify the differences from the SRP acceptance criteria during the normal course of preparing the technical supporting information for an application.

2. DESCRIPTION .

Section 50.34(g) requirements.would affect all'new applications for cps, Ols, and PDAs, and FDAs, .

There is no requirement for a separate report; the reporting requirement is satisfied by additional information in the SAR, a document required as part of the application.

3. ESTIMATE OF BURDEN AND COSTS Over the next three year period, the NRC does not expect any new CP, OL, PDA or FDA applications. Thus, burden and cost associated with this regulation is expected to be negligible for the next 3 years.

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} Part 19 SUPPORTING STATEMENT FOR HYDROGEN CONTROL REQUIREMENTS 10 CFR 50.44(c) 4

1. JUSTIFICATION The accident at Three Mile Island, Unit 2 (TMI-2) resulted in a severely damagec or degraded reactor core, a concomitant release of radioactive material to the primary coolant system, and a fuel cladding-water reaction which resulted in the generation of a large amount of hydrogen. The Nuclear Regulatory Commission

- has taken numerous actions to correct the design and operational limitations revealed by the accident. Included in these actions are several rulemaking i

proceedings intended to improve the hydrogen control capability of light-water nuclear power reactors. On October 2, 1980, the Nuclear Regulatory Commission i published in the Federal Register (45 FR 65466) a notice of proposed rulemaking on " Interim Requirements Related to Hydrogen Control and Certain Degraded Core

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Considerations" (Interim Rule). The notice concerned proposed amendments to 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," to -

improve hydrogen management in light-water reactor facilities and to provide specific design and other requirements to mitigate the consequences of accidents resulting in a degraded reactor core.

On March 23, 1981, the Commission published in the Federal Register (46 FR 18045) i a notice of proposed rulemaking on " Licensing Requirements for Pending Construc-i tion Permit and Manufacturing License Applications." The notice propcsed a set of licensing requirements applicable to construction permit applications that stemmed from lessons learned from the TMI-2 accident. On May 13, 1981, the Commission published in the Federal Register (46 FR 26491) a notice of proposed

' rulemaking on " Licensing Requirements for Pending Operating License Applications" (OL Rule).

As a follow-up to the October 2,1980 notice of proposed rulemaking, the Com-I mission published a notice of final rulemaking on December 2, 1981 (46 FR 58484) on hydrogen control requirements related to inerting of Mark I and II boiling water reactors, hydrogen recombiner capability and high point vents, i

The Commission has considered the ability of all light-water nuclear power re-actors, particularly pressurized light-water reactor facilities with ice conden-ser type containments and boiling light-water reactor facilities with Mark III type containments', to withstand an accident with the concomitant generation of large amounts of hydrogen, such as the type which occurred at Three Mile Island, Unit 2 (TMI-2). As a result, three new amendments to the regulations were pro-

posed for public comment on December 23, 1981 (46 FR 62231). The final amenc-ments reouire: (a) improved hydrogen control systems for boiling water reactors

k with Mark III containments and pressurized water reactors with ice condenser l

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j type containments:

(b) that those light-water nuclear power reactors not relying upon an inerted atmosphere for hydrogen control show that certain important safety systems must be able to function during and following hydrogen burning; and finally (c) analyses to be submitted to justify the hydrogen control systems selected and to provide assurance that containment structural integrity will be maintained and important safety systems will continue to function following a hydrogen burn, for those plants in (a) and (b) above.

The subject of this supporting statement is the requirement that analyses should be submitted under (c) above. The information contained in the analy-ses is necessary to permit the NRC staff to perform an evaluation to determine if the requirements for hydrogen control and safety equipment functioning during a hydrogen burn are met.

Without this information the NRC staff could not evaluate the design of the hydrogen control systems selected or determine whether burn.

or not needed safety equipment could indeed function during a hydrogen

2. DESCRIPTION OF THE INFORMATION COLLECTION

- The requirements to submit analyses for both the hydrogen control system and the demonstration of survivability during a hydrogen burn would apply to Mark III BWRs and ice condenser PWRs in various stages of the licensing process.

Due to the similarities between plants, it is estimated that six reports will

-be received from power reactor licensees, on a site basis.

t The requirement for submittal of the analyses would be on a one time only basis and would not be repeated except to correct deficiences in the reports. .

3. ESTIMATE OF COMPLIANCE BURDEN The reporting of the design and survivability analyses for the six plants (three Mark III BWRs and three ice condenser PWRs) will require apprcximately 1,500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months per plant for a total of 9,000 burden hours annually. Therefore, cost to industry is expected to be $540,000 ($60 X 9,000 hours0 days 0 hours 0 weeks 0 months ).

4. ESTIMATES OF COST TO FEDERAL GOVERNMENT The evaluation of the reports by the NRC staff will require 960 hours0.0111 days 0.267 hours 0.00159 weeks 3.6528e-4 months for each Mark III BWR and ice condenser PWR for a total of 5'60 (staff hours) or $345,600 annual cost (at 60.00 per hour professional staff time.)

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67-Part 20 SUPPORTING STATEMENT FOR 10 CFR 50 Section 50.49 -

Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants Justification '

Nuclear power plant equipment important to safety must be able to perform its safety functions throughout its installed life. The final rule is designed to assure the NRC that the electrical equipment will be able to perform its accident mitigation functions under the postulated environmental conditions.

To accomplish this objective, the rule requires licensees and applicants to qualify the essential electrical equipment.

's Qualification methods include

, testing test dataasorthe primaryexperience.

operating method and analysis in combination with partial type By its Memorandum and Order CLI-80-21, dated May 23, 1980, the Commission directed that the " DOR

Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors," an Electrical Equipment," form the basis for the requirements licensees and

l k applicants, cal equipment. respectively, must meet for environmental qualification of electri-

'! This Memorandum and Order also included certain reporting and

~] plants are required to comply.recordkeeping requirements with which license The recordkeeping requirements, in general terms, are contained in Sections XI and XVII of 10 CFR 50, Appendix B. The rule codifies the Commission's current requirements for the qualification of electrical requirements.equipment and explicitly states the reporting and recordkeeping The information collection requirements contained in the rule consist of the following:

A. 50.49(d):

establishment of records listing all electrical equipment covered by the rule, its performance characteristics, its electrical characteristics, and the environmental conditions in which it must operate.

{ B. 50.49(g):

identification of the electrical equipment already qualified prior to the effective date of the rule and submission of a schedule for qualifying or replacing the remaining electrical equipment.

C. 50.49(h):

that may re notification of any significant equipment qualification problems discovery. quire extension of the completion date within 60 days of its g

This stands for Division of Operating Reactors, which is currently known as the Divisions of Pressurized Water Reactor Licensing A.and B and the Division of Boiling Water Reactor Licensing.

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D. 50.49(i): submission of an analysis by an applicant for an operating license to ensure that the plant can be safely operated pending completion of the environmental qualification of electrical equipment.

E. 50.49(j): maintenance of records of electrical equipment qualified under these regulations, retained for the entire period during which the item is installed or stored for future use. These records must be maintained in an auditable form for the entire period during which the covered item is installed in the nuclear power plant or is stored for future use to permit verification that each item of electric equipment important to safety covered by this section:

(1) Is qualified for its application; and (2) Meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

These records must be maintained by the applicant or licensee for meeting the requirements specified in 50.49(d). This regulation requires the applicant or licenseee to prepare a list of electric equipment important to safety, and to include the following information for electric equip-ment important to safety in a qualification file:

(1) The performance specifications under conditions existing during and following design basis accidents.

(2) The voltage, frequency, load, and other electrical characteristics for which the performance specified.

(3) The environmental conditions, including temperature, pressure, hu-midity, radiation, chemicals, and submergence at the location where the equipment must perform.

Description The rule applies to 105 operating power reactor licensees and 22 construction permit holders (127 respondents).

Consultations Outside the Agency NRC staff participates in the development of national IEEE standards. Since 1975, these IEEE standards have included specific requirements for qualification documents.

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Estimato ef Burden .

Annual Compliance Burden For 105 Operating For 22 plants under construc-Reporting Nuclear Power Plants tion, 10 to be licensed each Requirements (h/ plant) year (h/ plant)

To To To To Licensees Govt. Applicants Govt.

50.49(d) Development of list of electrical Completed 2000 40 equipment and its characteristics (one time !

only) 50.49(g) Submission of a schedule for qualification and Completed N/A N/A and replacement (one time only) 50.49(h) Reporting of significant qualification problem 20 4 20 4 (Average 2 respanses annually per plant)

In 50.49(i) Submission of a safety analysis report N/A N/A N/A N/A 1)

(one time only)

Sub Total Licensee / Applicant Burden 20 h/ plant 2,020 h/ plant Total Licensee / Applicant Burden: 20 h/ plant x 2,020 h/ plant x 105 plants = 22 plants =

2,100 + 44,440 = 46,540 hours0.00625 days 0.15 hours 8.928571e-4 weeks 2.0547e-4 months 2,100 h 44,440 h Sub Total Burden to Government 4h/ plant 44 h/

plant Total Burden to Government: (4 h/ plants x (44 h/ plant 105 plants) = x 22 plants) 420 + 968 = 1,388 hours0.00449 days 0.108 hours 6.415344e-4 weeks 1.47634e-4 months 420 h = 968 h Estimates of Cost to Industry The total cost to industry is estimated to be (46,540 hr x $60) $2,792,400 [ includes annual cost (60 x 20 x 127) =

$152,400]

Estimates of Cost to Federal Government The total cost to the Government is estimated to be (1388 hr x $60) $83,280 [ includes annual cost (60 x 4 x 127) =

$30,480]

I Estimata cf Burden ,

Annual Compliance Burden For 105 Operating For 22 plants under construc-Recordkeeping Nuclear Power Plants tion, 10 to be licensed each i Requirements (h/ plant) year (h/ plant)

To To To To Licensees Govt. Applicants Govt.

50.49(j) Maintain records which demonstrate 40 N/A 40 N/A qualification

, Sub Total Licensee / Applicant Burden 40 h/ plant 40 h/ plant 3

Total Licensee /A ilicant Burden: 40 h/ plant x 40 h/ plant x 105 plant = 22 plants =

4,200 + 880 = 5,080 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months 4,200 h Total 880 h i e Sub Total Burden to Government N/A N/A S; Total Burden to Government: N/A N/A i None l Estimates of Cost to Industry j The total annual cost to industry is estimated to be (5,080 hr x $60) $304,800.

Estimates of Cost to Federal Government The total annual cost to the Government will be negligible.

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O Part 21 SUPPORTING STATEMENT FOR ANTICIPATED TRANSIENT WITHOUT SCRAM 10 CFR 50.62

1. Justification A. Need for the Information Collection An anticipated transient without scram (ATWS) is an expected operational transient (such as a loss of feedwater, loss of condenser, or loss of offsite power to the reactor) which is accompanied by a failure of the reactor trip system (RTS) to shut down the reactor. The reactor trip system consists of those power sources, sensors, initiation circuits, logic matrices, bypasses, circuit breakers, interlocks, racks, panels and control boards, and actuation and actuated devices, that are required to initiate reactor shutdown, and includes the control rods and control rod mechanisms as well. That portion of the RTS exclusive of the control rods and control rod mechanisms is referred to as the scram system. ATWS accidents are a cause of concern because under certain postulated condi-tions they could lead to severe core damage and release of radioactivity to the environment. The ATWS question involves safe shutdown of the

( reactor during a transient, if there is a failure of the RTS. There have been precursors to an ATWS; the latest being failure of the auto-matic portion of the RTS at the Salem 1 nuclear generating station on February 25, 1983, although manual shutdown was accomplished after 30 seconds, and no core damage or release of radioactivity occurred. The Commission has amended its regulations to require improvements in the design and operation of nuclear. power plants to reduce the likelihood of failure of the reactor protection system to shut down the reactor following anticipated transients, and to mitigate the consequences of anticipated transients, and to mitigate the consequences of anticipated transients without scram events. This will significantly reduce the risks i of nuclear power plant operation.

The rule requires the installation of certain equipment in nuclear power plants, in order to prevent and mitigate ATWS events. The licensee for a i nuclear power plant will be required, by 10 CFR 50.62(c)(6), to submit a copy of the design and installation plans to the NRC to ensure that the design and installation of the equipment will perform its intended safety function.

In addition, 10 CFR 50.62(d) requires the licensee to submit a schedule to the NRC for implementing the requirements of the rule. This provision allows the establishment of implementation schedules that are tailored to the safety priority needs and resources of the individual licensee.

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l B. Practical Utility of the Information Collected The NRC would review a proposed design to ensure that it will perform its intended safety function.

C. Duplication With Other Collections of Information The rule does not duplicate the information collection requirements contained in any.other generic regulatory requirement.

D. Consultations Outside the NRC On November 24, 1981, the Commission invited comments on three alternative proposed rules related to ATWS (46 FR 57521). Each of the three alterna-tive proposed rules had the objective of reduction of risk from ATWS and each had its own approach of achieving that objective. One alternative emphasized individual reactor evaluation to identify needed improvements.

The second alternative emphasized reliability assurance and would have also required certain hardware modifications. The third alternative, proposed by the Utility Group on ATWS (PRM 50-29), prescribed specific changes that were keyed to the type of reactor and its manufacturer. The industry proposal provided considerable information on alternative requirements and costs of implementation. A number of negative comments

were received from the industry on an alternative involving extensive reporting requirements in the form of a reliability assurance program.

This alternative was not selected.

2. Description of the Information Collection A. Number and Type of Responses The reporting requirement will apply to 105 operating nuclear power ,

plants and 22 plants to be licensed in the future, for a total of 127 respondents.

B. Reasonableness of the Schedule The scheduling requirements in 10 CFR 50.62(d) allows licensees to propose schedules keyed to their individual operating situation.

C. Method of Collection The licensee will submit a copy of all plans and specifications to the NRC.

D. Adequacy of the Description of Information l The designs which are required to be submitted for review are specified in the rule.

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E. Record Retention Period None (No recordkeeping required).

F. Reporting Period One-time only.

G. Copies In order to reduce the time spent in reviewing the licensee submittal, ten copies are required. This will allow simultaneous review by the relevant organizations within NRC.

3. Estimate of Burden A. Estimated Hours Required to Respond Each respondent must submit a copy of all drawings and diagrams for the required equipment, plus a short explanatory narrative. This will take sixteen hours of professional staff time and four hours clerical time for a total of 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months per respondent. Total burden would be 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months x 127 respondents or 2,540 hours0.00625 days 0.15 hours 8.928571e-4 weeks 2.0547e-4 months . The scheduling report required by 10 CFR 50.60(d) will entail 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months per i respondent, for a total burden of 4,064 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months . Total annual reporting hours for the entire rule are 6,604.

B. Estimate of the Information Collection At fifty-two hours per response, the total annual industry cost is estimated to be $396,240 (127 responses X 52 hours6.018519e-4 days 0.0144 hours 8.597884e-5 weeks 1.9786e-5 months / response = 6,604 hour0.00699 days 0.168 hours 9.986772e-4 weeks 2.29822e-4 months s: 6,604 hours0.00699 days 0.168 hours 9.986772e-4 weeks 2.29822e-4 months X $60/ hour = $396,240).

C. Reasonableness of Burden Estimates The estimates are in the same range as the hours expended to comply with similar requirements i.e., submittal of design information.

4. Estimate of Cost to Federal Government Approximately 10 days will be required to review the designs submitted under 10 CFR 50.62(c)(6) for a cost of $4,800 (80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months x $60).

Approximately one day will be required to review the proposed implementation schedule submitted under 10 CFR 50.62(d), for a cost of

$480 (8 x $60).

Total Government costs per response are $480 + $4,800; or $5280. Total

Government costs are $5280 x 127, or $670,560.

Part 22 i

SUPPORTING STATEMENT FOR 10 CFR 50.61, FRACTURE TOUGHNESS REQUIREMENTS FOR PROTECTION AGAINST PRESSURIZED THERMAL SH0CK (PTS) EVENTS

1. Justification (a) Need for the Information Collection The issue of pressurized thermal shock (PTS) arises because in pressurized water reactors (PWRs) transients and accidents can occur that result in severe overcooling (thermal shock) of the reactor pressure vessel, concurrent with or followed by repressurization.

In these PTS events, rapid cooling of the reactor vessel internal surface results in thermal stress with a maximum tensile' stress at the inside surface of the vessel. The magnitude of the thermal stress depends on the temperature profile across the reactor vessel wall as a function of time. The effects of this thermal stress are compounded by pressure stresses if the vessel is pressurized.

Severe reactor system overcooling events which could be accompanied k by pressurization or reoressurization of the reactor vessel (PTS events) can result from'a variety of causes. These include system transients, some of which are initiated by instrumentation and control system malfunctions including stuck open valves in either the primary or secondary system, and postulated accidents such as small break loss-of-coolant accidents, main steam line breaks, and feed-water pipe breaks.

As long as the fracture resistance of the reactor vessel material is relatively high, such events are not expected to cause vessel failure. However, the fracture resistance of reactor vessel materials decreases with exposure to fast neutrons during the life of a nuclear power plant. The rate of decrease is dependent on the metallurgical composition of the vessel wall and welds. If the fracture resistance of the vessel has been reduced sufficiently by neutron irradiation, severe PTS events could cause propagation of fairly small flaws that might exist near the inner surface. The assumed initial flaws might initiate and propagate into a crack through the vessel wall of sufficient extent to threaten vessel integrity and, therefore, core cooling capability.

The data collection aspects of the proposed 10 CFR 50.61, " Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock (PTS) Events" are as follows:

1 50.61(b) to require each PWR licensee to determine the lant RT (Reference Temperature for Nil Ductility Transition accordh to a method uniformly defined for all plants;

50.61(c) to require analyses of flux reduction options that will prevent or delay the plant from operating above the defined RTNDT; and 50.61(d) to require plant-specific PTS risk analyses be submitted before operation beyond the defined RT NDT is considered.

Collection and analysis of the information is necessary to identify needed corrective actions before operation above the identified RT NDT value can be considered.

(b) Practical Utility of the Information Collection The information and analyses will be reported on the plant's docket through the NRC Licensing Project Manager (LPM). The LPM will coordinate review of the information and analyses by the appropriate branches (depending upon technical subjects covered) leading to a coordinated NRC staff recommendation to the Commission regarding necessary corrective actions before plant operation can be considered at RT values above the screening value. The review will be perfobdbythestaffonaschedulethatwillensureadequatetime for implementation of any corrective requirement prior to reaching the screening criterion.

( (c) Duplication with Other Collections of Information There are no other NRC requirements regarding analyses for flux reduction or plant PTS safety analyses. However, materials infor-mation leading to calculation of a RT value for the reactor vesselissubmittedinresponsetothUDfequirementsofAppendices G and H, 10 CFR Part 50. For new plants, it appears in the FSAR.

During the operating life, the information is updated by the individual plant submittals that support requests for changes in the pressure-temperature limits given in Technical Specifications.

The new request for materials ihformation (RT values) contained in this proposed regulation is required becau E (1) the calcula-tion of RT for PTS involves a new trend curve formula that containsnMelasonevariable,andthisrepresentsachangefrom past practice which has yet to be adopted for normal operation; and (2) the calculation of RT for PTS purposes requires precise, updated data obtained in b y cases by the licensee in response to NRC concerns regarding PTS. In normal operation, there are cases where upper-bound estimates are used in the absence of complete data. For PTS, this can, in some cases, be unnecessarily conserva-tive, and an extra effort to obtain the data is required. For plants where complete data were available initially, this request will result in a verification (with quality assurance acceptable for PTS use) of earlier submittals.

i (d) Consultations Outside NRC We have reviewed our overall PTS recommendations on several occasions with the Advisory Committee on Reactor Safeguards (ACRS),

including the information gathering aspects. The ACRS was in basic agreement with our recommendations (letter to Nunzio J. Palladino, Chairman, NRC, from P. Shewmon, Chairman, ACRS, October 14, 1982).

We have also reviewed our recommendations with consultants under contract with us at Pacific Northwest Laboratories. Their recommendations are similar to ours. (NUREG/CR-2837, July 1982).

(e) Other Supporting Information None

2. Description of Information Collection (a) Number and Type of Respondents The licensees of all PWR plants would be subject to the regulation.

With respect to the three data collection aspects of the proposed regulation, it is estimated that forty seven plants would be affected by item (1), RT assessment; approximately fifteen plants would be

( affectedbyitegDf2),fluxreductionanalyses;andbetweenoneand four plants would be affected by item (3), plant specific analyses.

(b) Reasonableness of schedule for Collecting Information The schedule is stated in 10 CFR 50.61.

50.61(b) The initial RT determination "must be submitted (three monthsaftertheefEtivedateoftheregulation)andmustbe updated whenever changes in core loading, surveillance measurements, or other information indicate a significant change in projected values."

We feel that it is vital to quickly assess, with reliable information, which PWR plants are nearest the screening criterion so that we know as early as possible which plants most quickly need to complete the flux reduction analyses (see 50.61(c)) and the safety analyses (see 50.61(d)) which results in identification of necessary corrective actions. Appendix H,

" Reactor Vessel Material Surveillance Program Requirements,"

10 CFR Part 50, requires monitoring the change in the reactor beltline region resulting from exposure to neutron irradiation and thermal environment. This information is available to both the licensee and the Commission. It would require only verification by the licensee and submittal to the NRC by letter l to the docket. Therefore, the proposed schedule is reasonable.

(

50.61(c) "For each pressurized water nuclear power reactor for which the value of RT is projected to exceed the PTS screeningcriterionb$Nretheexpirationdateoftt.a operating license, the licensee shall submit by (six months after the effective date of the reaulation) an analysis and schedule for implementation of suc1 flux reduction programs as are reasonably practicable to avoid exceeding the PTS screening criterion."

The flux reduction option must be implem'ented as soon as possible for maximum effectiveness. Without this early reporting of flux reduction analyses, when the PTS safety analyses (see 50.61(d)) are submitted, it may be too late to make use of this option.

Due to their own interest in safety and economy, licensees will have already analyzed flux reduction options before this rule is promulgated. Therefore, the schedule proposed to prepare and submit a report on the docket is reasonable.

50.61(d) "For each pressurized water nuclear power reactor for which the analysis required by 50.61(c) indicates that no reasonably practicable flux reduction program will prevent the values of

{ RT from exceeding the PTS screening criterion before the exhationdateoftheoperatinglicense,thelicenseeshall submit a safety analysis to determine what, if any, modifica-tions to equipment, systems, and procedures are necessary to provide acceptable protection against potential failure of the reactor vessel as a result of postulated pressurized thermal shock events. This analysis shall be submitted at least three years before the value of RT is projected to exceed the PTS screeningcriterionorby(oNTyear after the effective date of the regulation) whichever later."

This is the final step to which all others lead, the identification of needed corrective actions. We believe the three year " lead time" before the screening criterion RT IS

N exceededrepresentstheminimumtimenecessarytoreviewNe analyses, recommend actions, promulgate a requirement by Commission action (if necessary), and have the licensee implement the necessary corrective actions. If less than three years are allowed and the required actions are not completed, plant shutdown could be necessary. Since this would be a plant-specific analysis, we believe a report on the plant's docket to be the most efficient submittal.

(c) Method of Collecting the Information The data and analyses are plant-specific and plant-unique and must be required from each plant. They are vitally necessary for the NRC

staff's use in evaluating a potential safety concern and identifying corrective actions that may be required to alleviate that concera.

The staff members that will perform the evaluation are in the Washington, D.C. (NRC Headquarters) area and are in several different NRC organizational units. Reports filed on the plant docket and subsequently distributed to the reviewers appear to be the most efficient method. The flux reduction analyses and the RT analyses wouldprobablybeperformedbydifferenttechnicalpersonNhIwithin the licensee's (or vendor's) organization. If the licensee wishes to combine the two reports into a single report with two major sections, that would be acceptable. This would require, however, that the entire report be submitted on a schedule compatible with the schedule of the RT assessment (the earliest due section). We would distributh0[opiesofthepropersectionstotheappropriateNRC organizations.

(d) Record Retention Period Compliance to the requirements of Section IV, " Report of Test Results" of Appendix H of 10 CFR Part 50 ensures that the RT history is retained for the life of the plant. Therefore,tNN regulation will not impose an additional licensee burden.

( The flux reduction and safety analyses should also be retained until and unless the analyses are modified or revised.

(e) Reporting Period The RT and flux reduction information would be re-reported only whenshificantchangesareindicated,asalreadydiscussed.

(f) Copies Required to Be Submitted The required analyses will be prepared by the licensees and the report submitted for the docket. If additional copies are required of portions of the report (s) due to the number of reviewers involved, then they would be made internally.

3. Estimate of Licensee Burden The licensees of all PWR plants would be subject to the regulation. Our estimate is that forty seven plants would be subject to RT a andfifteenplantswouldbesubjecttofluxreductionanalhs.ssessmentDepending on the success of these analyses, we estimate that from one to four plants would be subject to PTS safety analyses. The estimates shown below apply only to costs due to the actual reporting requirements. That is, they do not include costs of performing the assessments which would still be necessary even if there were no requirements to submit reports to the NRC.

(a) Estimated staff-hours

1) RT assessment - 100 staff hours per plant - (47 x 100 = 4,700 stNIbourstotal).

2) Flux reduction analyses - 100 staff hours per plant - (15 x 100 =

1,500 staff hours total).

3) PTS safety analyses - 400 staff hours per plant (Estimate 2 plants = 800 staff hours).

Therefore, our total estimated annual staff hours will be 2,333 based on a total estimated staff hours expenditure of 7,000 staff-hours distributed over a three year period.

(b) Estimated cost

1) RT assessment - $5,000 per plant - $235,000 total

2) Fl$Treduction analyses - $5,000 per plant - $80,000 total

3) PTS safety analyses - $20,000 per plant - from $20,000 to $80,000 (average of $40,000 for two plants).

Therefore, our estimated annual cost will be $118,300 based on a total expenditure of $355,000 distributed over a three year period.

4 The annual recordkeeping burden is included in our estimate.

(c) Source and method for estimating:

RT assessment and flux reduction analyses.

NDT The basic information is available to each licensee through ongoing reactor vessel integrity and surveillance programs. The method for estimating is based on engineering judgment by the NRC staff and our understanding of the assessment of the integrity of the vessel. The cost estimate is based on $100,000 per staff year.

PTS safety analysis The estimate is based on the use of existing computer codes and modeling procedures. The estimate is based on the use of ten man years, plant-specific modeling time, and twelve transient calculations. Engineering judgment by the NRC staff and their consultants was the method used for the estimates.

(d) Reasonableness of estimate TheestimatesgivenaboverepresentthebestjudgmentoftheNRC staff, and are based on actual experience with the cost of such PTS analyses now being performed by NRC/RES contractors at ORNL, INEL,

( and LANL.

o l 4. Estimate of Cost to Federal Government The submittals by tha licensee will be evaluated by the staff, at the estimated cost given below. Our estimate is based on the use of a l charge of $100,000 per staff man year, an average currently used by the national laboratories for estimation purpose.

1) RT assessment NDT We estimate that an RT determination will be submitted by forty sevenlicenseesthreeNbthsaftertheeffectivedateoftheregula-tion. An RT assessment was completed by the staff as part of the l PTSprojectUdreportedinA l ofPressurizedThermalShock,gpendixFofthe"NRCStaffEvaluation November 1982.

The submittal will be evaluated in the areas of materials engineering and core performance. The total review time is estimated at 400 staff i

hours at an estimated cost of $20,000. The expenditure will be equally divided in FY-83 and FY-84.

2) Flux reduction It is estimated that an analysis and schedule for implementation of flux reduction programs will be submitted by fifteen licensees six

$ months after the effective date of the regulation.

The submittals will be reviewed and evaluated in the areas of core performance with assistance from NRC Consultants and its materials l engineering staff. The total review time is estimated to be 600 staff hours at a cost of $33,000. The expenditure will be made in FY-84.

3) PTS safety analysis It is estimated that a PTS safety analyses will be submitted by from one to four licensees three years prior to the reactor vessel reaching the screening criterion or one year after the effective date of the regulation, whichever is later.

1 l

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o The PTS safety analyses will be reviewed and evaluated by staff members involved in areas of core performance (CP), materials engineering (MTE),

reactor systems (RS), reliability and risk assessment (RRA), and procedures and test review (PTR). We estimate the total review time for one sub-mittal as follows:

NRC Staff Staff Hours Consultant Total CP 240 $ 50,000 $ 30,000*

MTE 100 -

5;000 RS 1,500 $100,000 195,000**

RRA 500 -

25,000 PTR 100 5,000 Total 2,440 $150,000 $260,000

$3,000 computer time

- $40,000 computer time

The expenditure will be made in FY-85 at an estimated cost from

$260,000 to approximately $1,000,000 depending on the number of submittal for review.

! In summary, we estimate the annual cost to the Government at $155,000, based on a total estimated expenditure of $463,000 distributed over a three year period.

The total cost to the government is $463,000.

NRC Staff Staff Consultant . Total -

Task Staff Hours Cost Cost Cost RT Abssment HTE/CP 400 $20,000 -

$20,000 Flux Reduction CP/MTE 600 $33,000 $33,000 PTS CP 240 $30,000* $50,000 $80,000*

MTE 100 5,000 -

5,000 RS 1,500 195,000 100,000 295,000**

RRA 500 25,000 -

25,000 PTR 100 5,000 -

5,000 TOTAL 3,440 $313,000 $150,000 $463,000

"Plus $3,000 computer time.

- Plus $30,000 computer time.

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' Part 23 N OMB SUPPOP71NG STATEMENT q s

}, 10 C7R 50.64 Limiting the Use of Highly Enriched Uranium in Research Reactors

(- 1. Justification -

t' A. Need for the Collection of Information

~

s The Commission has amended its regulations to limit the use of highly s enriched uranium (HEU) fuel in research and test reactors (nuclear non power reactors). The amendment, which is encompassed within 10 CFR.50.64, generally requires that new non power reactors use low enriched uranium (LEU) fuel and that existing non power reactors re-place HEU fuel with LEU fuel when available.

A Commission policy statement published August 24, 1982 (47 FR 37007),

explains NRC's interest in reducing the use of HEU in research reactors.

This interect stems from NRC's licensing responsibility for both

' domestic use and for export of HEU and concern about risks of theft L or diversion of this material.

The policy statement:aiso describes a continuing program to develop

, , and demonstrate the technology that will facilitate the use of re-i duced enrichment fuels. The reduced enrichment for research and

. test reactors (RERTR) program was initiated by the Department of Energy (DOE) and is managed by the Argonne National Laboratory. Its

' ,i ,

objective is to prove the ability of new LEU fuels to replace existing HEU fuel without significant' changes to existing reactor cores or

, facilities, or significant decrease in performance characteristics

( of the reactors.

Information considered to date' indicates that conversion of most non power reactors from HEU' fuel,to LEU fuel will be technically fea-i / sible prior to or upon completion of the RERTR program. The informa-tien al w shows that a major consideration is the cost of conversion.

. NRC shat ts the licensees' expressed view that conversion costs should l '

largely or entirely be financed by the Federal government. Histor-ically, the DOE and its predecessor agencies have provided signifi-cant support to research and test reactor programs. The availability I of Federal support will be considered in determining the availability of LEU fuel and final schedules for conversion.

The RERTR prograta's progress and anticipated success have encouraged

~

NRC to undertake a rulemaking proceeding which would cause reduction 3

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Part 23 in the use of HEU fuel in nuclear non power reactors. In this pro-ceeding, the Commission considers that licensed non power reactors now using HEU fuel are operated without significant risk to the health and safety of the general public and improved reactor safety is not~the objective. The proceeding is intended only to cause replacement of HEU. This reduction is desirable because HEU, in appropriate form and quantity, can be used to make an explosive device. LEU has relatively little value for this purpose.

This regulation is intended only to reduce the risk of theft or diversion of HEU fuel used in non power reactors. The reduction in domestic use of HEU fuel may encourage similar action by foreign research reactor operators, and thereby reduce the amount of HEU fuel in international use.

NonpowerreactorsarereguiredtouseLEUfueloruseHEUfuelof enrichment as close to 20 as is available and acceptable to the Commission. Section 50.64(d)(1) of the rule states that any request with supporting documentation for a determination that a reactor has a unique purpose must be submitted within 6 months of the effective date of the rule. Section 50.64(d)(2) of the rule requires each non-power reactor licensee authorized to possess and use HEU fuel to de-velop and submit, within 12 months of the effective date of the rule, to the NRC's Director of the Office of Nuclear Reactor Regulation a proposed schedule for conversion to LEU fuel or to use HEU fuel as close to 20% as is available and acceptable to the Commission. This proposed schedule will be based upon the availability of replacement fuel acceptable to the NRC and consideration of other factors such as the availability of shipping casks, financial support, and reactor usage. A final schedule will then be determined by the Director.

Section 50.64(d)(3) states that in cases where replacement of HEU fuel with LEU fuel does not change the technical specifications incorporated in the license or involve an unreviewed safety question, that licensee shall maintain records and furnish reports as specified in 10 CFR 50.59(b). In those cases in which conversion to LEU changes the technical specifications incorporated in the license or -

involves an unreviewed safety question, the licensee shall file an amendment in accordance with 10 CFR 50.90.

B. Practical Utility of the Collection of Information A respondent is required to submit a request with supporting informa-tion pursuant to 10 CFR 50.64(d)(1) to the Director of the Office of Nuclear Reactor Regulation. The Director will use the information to make a determination that the nuclear non power reactor has a unique purpose as defined in 10 CFR 50.64(b)(3).

A respondent will develop and submit to the Director of the Office of

[ Nuclear Reactor Regulation pursuant to 10 CFR 50.64(d)(2) a proposed l

l

s Part 23 schedule for meeting the requirements of 10 CFR 50.64(c)(2) or (3).

The proposed schedule must be based upon availability of replacement

, fuel acceptable to the Commission and consideration of other factors such as the availability of shipping casks, financial support, and reactor. The Director will use the proposed schedule plus the results of the successful accomplishment of the tasks set out in DOE's RERTR program and the development of commercially available replacement fuel to determine a final schedule.

C. Duplication of Other Collections of Information A rulemaking is under consideration on 10 CFR 73.67, addressing the problem of improving physical security provisions at non power reactors using HEU, as an interim measure, until such time as those non power reactors are converted to LEU. However, information collected under

$50.64 will not duplicate information collected under $73.67.

D. Consultations Outside the NRC None for the final rule currently in place. During the development of the proposed rule, NRC considered extensive comments from the U.S.

State Department, the Department of Energy, and the non power reactor owners. Implementation of the final rule required extensive coordi-

{. nation between NRC, DOE, and the affected licensees.

2. Description of the Information Collection A. Number and Type of Respondent The NRC anticipates 31 respondents _on a one-time basis during the 1 year time period following the effective date of the rule. Each of these non power reactor owners will also have the option of applying for an exemption from converting to LEU fuel based on the unique pur-pose of the non power reactor. It is anticipated that between 2 to 6 respondents will request a unique purpose determination [S50.64(d)(1)]

and all of the 31 respondents will submit a proposed schedule for con-version to LEU fuel or for use of HEU fuel of enrichment as close to 20% as is available and acceptable to the Commission [$50.64(d)(2)].

B. Reasonableness of the Schedule for Collecting Information Request for unique purpose under 10 CFR 50.64(d)(1) will require an evaluation of facility purpose against the definitions in 10 CFR 50.64(b)(3). Six months is believed to be a reasonable schedule for comparing existing facility " purpose" against 10 CFR 50.64(b)(3) provisions.

The proposed schedule for meeting the requirements of 10 CFR 50.64(c)(2) or (3) will require a comparison between the licensee's existing fuel design and fuels developed or projected for development under the

Part 23 documented RERTR program. Coordination with NRC to formulate proposed schedules for regulatory review and with DOE to develop fuel procure-ment and supporting equipment schedules will be required. Twelve months is considered a' reasonable time for development of the proposed schedule.

C. Method of Collecting the Information Subnission of a letter with supporting documentation or a proposed schedule is the only perceived method of transmitting the required information that will allow careful and complete review.

D. Format of Information to be Maintained or Submitted The information will be submitted in letter form.

E. Records Retention Period The records referenced in S50.64(d)(3) have a retention period that is specified in 10 CFR 50.59(b) for the holder of a license authoriz-ing operation of a utilization facility.

F. Reporting Period l

These requests and proposed schedules will be submitted once during the facility operating lifetime prior to meeting the requirements in 10 CFR 50.64(c)(2) or (3).

G. Copies Reouired to be Submitted The NRC will accept one original copy to allow the Director to make the determinations in 10 CFR 50.64(d)(1) and (2) of the rule.

3. Estimate of Burden A. Section 50.64(d)(1). Approximately 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months per response for each of between two and six respondents will be required to develop the request with supporting documentation for a " unique purpose" deter-mination to be submitted to the Director of the Office of Nuclear Reactor Regulation. This is a one-time response within 6 months of the effective date of the rule, so the total burden for the respon-dents is between 400 and 1,200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months . Total cost at $60 per hour is between $24,000 and $72,000.

B. Section 50.64(d)(2). Approximately 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months per response for each of approximately 31 respondents will be required to develop the proposed schedule and submit the proposed schedule to NRC. This is a one-time response within 12 months of the effective date of the rule, so the total burden is approximately 3,720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months . Total cost'at 560 per hour is $223,200.

Part 23 C. Section 50.64(d)(3). This section references information collection requirements (recordkeeping and reporting requirements in 10 CFR 50.59(b) or application for an operating license amendment pursuant to 10 CFR 50.59(c) and 10 CFR 50.90) that have been approved by the Office of Management and Budget under approval number 3150-0011. The approval covers information collection burdens for all holders of licenses authorizing operation of a utilization facility.

D. Burden estimates based on discussions with NRR staff who have been throughthelicensingprocesswiththesereac{.orspreviously.

4. Estimate of Cost to the Federal Government A. Section 50.64(d)(1). NRC staff time for making a determination for each of the two to six " unique purpose" reactor requests will require approximately 600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months . The total staff time for the (estimated) two to six requests would be between 1,200 and 3,600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months . Total cost at $60 per hour would be between $72,000 and $216,000.

B. Section50.64(d)(2). NRC staff time for consideration of a schedule proposed by a non power reactor licensee and determination of a final schedule will require approximately 140 hours0.00162 days 0.0389 hours 2.314815e-4 weeks 5.327e-5 months for each of approxi-mately 31 licensees for a total of 4,340 hours0.00394 days 0.0944 hours 5.621693e-4 weeks 1.2937e-4 months . Total cost at $60

( per hour is $260,400.

C. Section 50.64(d)(3). This section references information collections for which costs to the Federal an operating license amendment) havegovernment (review been approved by theof applications Office of for Management and Budget under approval number 3150-0011.

Total cost for the Federal government is, therefore, estimated to be approximately $332,000 (1,200 + 4,340 hours0.00394 days 0.0944 hours 5.621693e-4 weeks 1.2937e-4 months x 60).

= . - _ . .. - _ , .

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- 85a - Part 24 OMB SUPPORTING STATEMENT FOR THE REVISION OF THE ECCS RULE CONTAINED IN APPENDIX X AND SECTION 90.46 0F 10 CFR PART 50 Description of the Information Collection The proposed Emergency Core Cooling System (ECCS) Rule affects the existing infomation collection requirements (OMB Control Number 3150-0011) presented in 10 CFR Part 50 in the following manner:

1. The proposed rule would provide an alternate method of meeting the requirements contained in Appendix K and Section 50.46 of 10 CFR Part

50. It would permit licensees or applicants to analyze ECCS perfor-mance using realistic calculations. This method of calculation may remove some operating restrictions and thus motivate licensees to submit realistic analyses for Nuclear Regulatory Commission (NRC) review. The current rule does not have this feature, therefore this aspect of the revised rule represents a voluntary information collec-tion burden to the industry. Realistic analyses are not required of licensees not electing this option. -

2. The proposed rule would require that all errors in, or changes to, an acceptable evaluation model (EM) be submitted to the NRC for review.

a. If the change or error results in a calculation of the limiting transient that exceeds the safety criteria presented in 6 50.46(b), the licensee is required to promptly submit a report ~

to the NRC [50.46(a)(3)(ii)].

b. If the change or error results in a 50*F or greater change in the limiting transient's calculated peak clad temperature, as bpposed to the current requirement of 20*F, a report and a pro-posed schedule for completing the actions needed to comply with the applicable re

-[50.46(a)(3)(ii)]quirements must be submitted for NRC review

3. Computer listings for each modified EM exceeding the 50 F limit stat-ed earlier will no longer be mandatory; but submitted only when NRC determines that such infomation is needed to perform its review [10 CFR Part 50 Appendix K.II.1.b.].

A. JUSTIFICATION

1. Need for the Collection of Infomation. The regulations in 10 CFR part 50 are promulgated by the NRC of 1954, as amended (68 Stat. 919)and pursuant Title IItoof thethe Atomic EnergyEnergy Reor- Act ganization Act of 1974 (88 Stat. 1242) to provide for the licensing of production and utilization facilities. In order to determine licensee compliance with the regulations set forth in Appendix K of

- 85b -

10 CFR Part 50, the NRC needs to know what models and methods have been used to assess ECCS performance.

2. Agency use of Information. The information identified earlier will be used by the Office of Nuclear Reactor Regulation (NRR) to deter-mine licensee compliance with the requirements of Appendix K and 5 50.46(b) of 10 CFR Part 50 and thus ensure that the reactor operates within the limits required to protect the public health and safety.

If not in compliance, the information will allow NRR to assess how and when compliance to the applicable requirements will' be achieved.

3. Reduction of Burden Through Information Technology. There are no legal obstacles to the reduction of information collection require-ments through information technology. However, the limited frequency makes it impractical to reduce the burden through the use of technology.

4. Effort to Identify Duplication. The Federal Information Locator Sys-

, tem was searched to determine NRC and other Federal agency duplica-tion. No other agency presently collects this information.

5. Effort to Use Similar Information. No similar information to that required is currently available.

( 6. Effort to Reduce Small Business Burden. -The proposed rule does not affect small businesses.

7. Consequence of Less Frequent Collection. The frequency with which this information is collected is determined by how often the accepted ECCS EM is modified and whether these changes significantly affect the calculated peak clad temperature. Less frequent collection could adversely affect the public nealth and safety.

! 8. Circumstances Which Justify Variation From OMB Guidelines. Contrary to OMB guidelines, the licensee may be required to submit proprietary information so that NRC may assess compliance with the requirements of Appendix K. This information is needed to ensure that the reactor

! operates within the limits required to protect the public health and

! safety. NRC Manual Chapter 2101 describes procedures to protect I

classified, proprietary and other sensitive information. Also con-trary to OMB guidelines; the licensee may be required to submit modi-l fied EM results more often than quarterly in the event that significant errors are discovered in their EM causing the plant to be noncompliant with the safety requirements set forth in Appendix K. l I

9. Consultations Outside the NRC. Dr. L. Hochrieter of the Westinghouse '

I l Corporation was contacted concerning industry information collection l requirements. The proposed rule revision will be published in the I l Federal Register for public coment. The coment period will be 180

! days. All comments concerning information collection requirements and their affect on the final rule will be considered.

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10. Confidentiality of Information. The NRC will protect classified, proprietary and sensitive information according to the guidelines provided in NRC Manual Chapter 2101.

11. Justification for Sensitive Questions. No sensitive infonnation is requested.

12. Estimated Annualized Cost to the Federal Government. It is expected that three generic calculations using realistic models will be sub-mitted by the industry within the first three years following rule issuance. Staff review of either a modified EM-or generic analysis of ECCS performance will require an average of one staff-year per submittal. The cost for each review, at a labor cost of $60. per staff hour, would be $125,000. The number of reviews performed per year as a result of the rule revision is estimated as follows:

Modified EM Submittals: 0.6/yr (3 submittals over 5 years)

Generic Model Submittals: 1.0/yr Total: 1.6/yr The annualized cost to the NRC would be $125,000 for the generic ana-lyses and $75,000 for modified EM submittals. The total annualized cost to the NRC for both generic and modified submittals is estimated as $200,000.

I' The revised rule will require that a schedule for completing the ac-tions needed to comply with applicable Appendix K and 5 50.46(b) re-quirements be submitted to NRC with each analysis. Schedule review would require four hours of staff time per submittal. At $60. per hour and 1.6 submittals per year, the annualized cost to the NRC would be $384.

The total cost to the NRC is therefore $200,384. annually.

13. Estimate of Burden.

a. The estimated annual burden to industry for modified EM submit-tals, realistic generic model submittals, schedule and computer ~

printout submittals is 4014 hours0.0465 days 1.115 hours 0.00664 weeks 0.00153 months . Attachment A provides a break-down of the information collection burden.

b. The average cost to industry of performing an analysis of ECCS performance is $150,000. This dollar amount was obtained from the Westinghouse Corporation and includes labor hours. The annu-al industry cost would be $90,000 (based on .6 submittals per year) for modified EM submittals and $150,000 (based on 1 sub-mittal per year) for generic submittals using realistic models.

It is also estimated that preparation and submittal of a schedule as required by the proposed would cost industry $768 per year. Therefore the total cost to industry would be t $240,768 per year.

l l

- 85d -

14. Reasons for Change in Burden. These figures represent a change to current Part 50 information collection burdens in the following areas: ,

a. Modifications to an accepted EM will only be submitted for NRC review when the calculated peak clad temperature differs from the previously accepted EM calculation by more than 50*F, as opposed to the current 20*F requirement. As a result, it is ex-pected that the number of submittals due to changes made to an accepted EM will decrease by 10%. The current annual burden to industry for modified EM submittals is 1667 hours0.0193 days 0.463 hours 0.00276 weeks 6.342935e-4 months . This is based on current estimates of .66 submittals per year (i.e., 2 submittals over 3 years) and an industry burden of 2500 hours0.0289 days 0.694 hours 0.00413 weeks 9.5125e-4 months per submittal. The revised rule represents a reduction in in-dustry information collection burden of 167 hours0.00193 days 0.0464 hours 2.761243e-4 weeks 6.35435e-5 months per year.

b. The revised rule gives the licensee or applicant the option of performing an ECCS analysis using realistic methods. It is ex-pected that industry will voluntarily submit one generic ECCS analysis each year using realistic models. This represents an increased voluntary information collection burden to licensees of 2500 hours0.0289 days 0.694 hours 0.00413 weeks 9.5125e-4 months per year.

c. The proposed rule requires preparation and submittal of a sched-ule for completing an ECCS analysis. This represents an in-( creased burden to industry of approximately 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months per year (i.e., 8 staff-hours / submittal X 1.6 submittals/yr)

d. The proposed rule will no longer require a computer listing of changes to an EM. This represents a reduction in industry bur-den of approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months ' per year (i.e., 2 hrs / submittal X 1.6submittals/yr).

Attachment A provides a summary of the burden changes that may result due to implementation of the proposed rule.

15. Publication for Statistical Use. The information being collected is not expected to be published for statistical use.

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

a

_s.

e ATTACHMENT A OMB STATEMENT FOR THE REVISION OF THE ECCS RULE CONTAINED IN APPENDIX K AND SECTION 50.46 0F 10 CFR PART 50 ANNUAL INDUSTRY BURDEN Section Total Responses Modified EM Realistic EM Schedule EM Printout Total Per Year Submittals Submittals Submittals Submittals Hours (Hours) (Hours) (Hours) (Hours)

CURRENT RULE: 50.46 *0.66 1667 0 0 3 1670 PROPOSED RULE: 50.46 **1.60 1500 2500 13 1 4014 E

DIFFERENCE: 0.94 -167 2500 13 -2 2344 n,

. i

2 submittals over 3 years

- 8 submittals over 5 years

. REFERENCE PUBLICATIONS Document Number Document Title Un-numbered Lists Regulatory Guides NUREG-0642 Revision 1 A Review of NRC Regulatory Processes and Functions Regulatory Guide 1.70 Rev. 3 Standard Format and Safety Analysis Report for Nuclear Power Plants (LWR Edition)

NRC Form 366 Licensee Event Report Regulatory Guide 1.28 Quality Assurance Program Require-Revision 2, and ments (Design and Construction)

Revision 3 (Proposed)

Regulatory Guide 1.88 Collection, Storage, and Mainte-Revision 2 nance of Nuclear Power Plant Quality Assurance Records NUREG-0660, Volumes 1 and 2, NRC Action Plan Developed as a Revision 1 Result of the TMI 2 Accident NUREG-0737, and Supplement 1 Clarification of TMI Action Plan Requirements NUREG-0546 Technical Specifications Regulatory Guide 1.16 Reporting of Operating Information Revision 4 Appendix A, Technical Specifica-tions Regulatory Guide 1.21 Measuring, Evaluating, and Reporting Revision 1 Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants Regulatory Guide 4.1 Programs for Monitoring Radioac-Revision 1 tivity in the Environs of Nuclear Power Plants NUREG-0472 Draft Radiological Effluent Tech-Revision 3 nical Specifications for PWR's NUREG-0473 Draft Radiological Effluent Tech-Revision 2 nical Specifications for BWR's

. REFERENCE PUBLICATIONS (Continued)

Document Number Document Title Issued by letter Branch Technical Position, Revi-dated November 27, 1979 sion 1, dated November 1979 from W. Gammill, NRC, to (Radiological Assessment)

All Power Reactor Licensees NUREG-0161 Instructions for Preparation of Data Entry Sheets for Licensee Event Report (LER) File Regulatory Guide 4.8 Environmental Technical Specifi-cations for Nuclear Power Plants NUREG-0713 Volume 1 Occupational Radiation Exposure at Commerical Nuclear Power Reactors 1979 NUREG-0654 Revision 1 Criteria for Preparation and Evalua-tion of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants NUREG-0452 Revision 4 Standard Technical Specifications for Westinghouse Pressurized Water Reactors 4

NUREG-0212 Revision 2 Standard Technical Specification (STS) for Combustion Engineering Pressurized Water Reactors (PWR) ,

NUREG-0103 Revision 4 STS for Babcock and Wilcox PWR NUREG-0123 Revision 3 STS for Boiling Water Reactors (BWR/5)

NUREG-0799 For Comment Draft Criteria for Preparation of Emergency Operating Procedures NUREG-0800 Standard Review Plan NUREG-0906 Guidance for Implementation of Standard Review Plan Rule 50.34(g)

Regulatory Guide 1.99 Effects of Residual Elements on Revision 1 Predicted Radiation Damage to Reactor Vessel Materials CRGR Charter NUREG-1070 Severe Accident Policy

REFERENCE PUBLICATIONS (Continued)

Document Number Document Title NUREG-0588 Interim Staff Position on Environ-Revision 1 mental Qualification (EQ) of Safety-Related Electrical Equip-ment.

Regulatory Guide 1.89 EQ of Safety-Related Electrical

~

Revision 1 Equipment Regulatory Guide X.XX Guidance and Acceptance Criteria (Draft Final) regarding the Pressurized Ther-mal Shock Rule, 10 CFR 50.61 NUREG-1055 Improving Quality and the Assurance (proposed) of Quality in the design and Con-struction of Nuclear Power Plants NUREG-0844 NRC Integrated Program (Draft) for the Resolution of Unresolved Safety issues A-3, A-4, and A-5 Regarding Stear. Generator Tube Integrity

( NUREG/CR-3137 Guidelines fer Seismic and Dynamic (unpublished) Qualificat'un of Safety related Electrical t.nd Mechanical Equip-ment.

NUREG-1061 Report of the U.S. Nuclear Volumes 1-5 Regulatory Commission Piping

_ Review Conmittee NUREG/CR-3226, Technical Reports by NRC consultants 2989, 3992 at Sandia National Lab and Oak

/

Ridge National Laboratory with respect to the proposed Station Blackout rule NUREG-1032 Evaluation of Station Blackout Accidents at Nuclear Power Plants NUREG-1109 Regulatory Analysis for the Resolution of USI A-44, Station Blackout NUREG-0459 Generic Adversary Characteristics Summary Report, U.S. NRC, March 1979

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