ML20207J615

Notice of OMB Review of Info Collection & Solicitation of Public Comment.Title of Info collection:10CFR54, Requirements for Renewal of Operating Licenses for Npps

ML20207J615
Person / Time
Issue date:	03/02/1999
From:	Shelton B NRC OFFICE OF THE CONTROLLER
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ML20207J608	List: ML20207J606 ML20207J615
References
NUDOCS 9903160333
Download: ML20207J615 (3)

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APbRWORK RbDUCTION ACfSUBMISSION g

PZee read the instmctions befora completing this form. For cddition11 forms or cssisttnce in compliting this form, cof act your agincy's P perwork Clrarcnca Officar. Sind two copiss of this form th3 collIction instrument to be ravi1wid. the Supporting Stitament, cnd any Edditionzl documintation to: Offica of intarmiti:n cnd R;gulittry Affilts, Offic2 cf Management and Budget. Docket Library, Room 10102,72517th Street NW, Washington, DC 20503.

1. Agency / Subagency onginating reqmst 2'~~OMB control number U.S. Nuclear Regulatory Commission 7 s.

3150-0155 b.None

3. Type of mformaton collecton (check one)

Type of revow requested (cneck one)

a. New collection g

a. Regular

c. Detgated

b. Revision of a currently approved colisction

b. Emergency. Approval requested by (date):

-g c. Extension of a currently approved collection

5. Will this information collection have a

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significant econce M impact on a

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d. gi ngt g, of viously approved substantial number of small entites?

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a. Three years from approval date col cto forw'h a e red Requested

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exPeman date

f. Existing collectirwi in use without an OMB control numner

b. Other (Specify):

7. rene 10 CFR Part 54, Requirements for Renewal Of Operating Licenses for Nuclear Power Plants

8. Agency form number (s) (if appleabde)

N/A

9. Keywords Administrative practice and procedare, age-related degradation, incorporation by reference, nuclear power pl:nts and reactors, reporting and recordkeeping requirements.

10. Abstract i;

10 CFR Part 54 of the NRC regulations specifies the procedures, criteria, and 7ttadsrds goversing nuclear i

power plant license renewal, including information submittal and recordkeeping requirements, so that the NRC

• i m:y make determinations necessary to promote the health and safety of the public.

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. Affected pubhc (usiapnmery wrn vaoms en emers mer ewy own *x >

12. Obhgetr.,n to respond sosia pnme,y wrn v enas orne<a tror egy wrn x >

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f[^ ]} b. Business or other for-profit

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a. Individuals or households

d. Farms

a. Volu itary

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e. Federal Govemment

b. Required to obtain or retain beneft.s

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c. Not-for-profit institutions

] f. State. Local or Tribal GovemmentT c. Mandatory f:,. ; Annual reportmg and recordkooping hour burden 15 Annual reportmg and recordkooping cot 5urden (m enousenas oransers; 4

s. Total annualized capital /startup costs

m. Number of respondents 1

b. Total annual costs (O&M)

b. Total annual responses

1. Percentage of tt.eee responses

c. Total annualized cost requested conected wiectroncany 0.0 %

d. current OMB inventcry

c. T7nt annual hours requested 89,333

e. Diflerence

d. Corrent OMB inventory 89,333 7

e. Difference 0

1. Program change

f. Explanation of difference

1. Program cheap

2. Adjustnant

2. Adjustment

15. Pu: pose of mformaton collecten

16. Frequency of recordkeepmg or renortmg (cnock a#ther appry)

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F* Pwnery we 'P"and a# omers snar apofy we T)

a. Recordkeepmg

b. Third-party disclosure

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'a. Apphcotion for benefits

e. Program plann6ng or mar - wnt

c. Reportmg

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2. Weekly

3. Monthly

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b. Program evoluebon

f. Reneerch

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c. General ourpose statstics T

g. Regulatory or compliance

4. Quarterly

5. Semi-ennually

6. Annually

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d. Audit

7. BonniaNy

8. Other (describe)

17. Statetcalmethods

18. Agency contact (person wno carr aest answer guesnons repescas me Does this inft rmetion conection employ statstical methods?

Name:

Roberts K. Ingram, NRR Ye L No 301-415-1219

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a 11 FINAL SUPPORTING STATEMENT FOR 10 CFR PART 54

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

Extension Request DESCRIPTION OF THE INFORMATION COLLECTION 10 CFR Part 54 establishes the requirements that an applicant for renewal of a nuclear power plant operating license must meet, the information that must be submitted to the NRC for review so that the agency can determine whether those requirements have in fact been met, the application procedures, and recordkeeping requirements.

A.

JUSTIFICATION 1.

Need for and Practical Utility of the Collection of Information The regulatory p*stThy underlying 10 CFR Part 54 is founded on two key principles.

The first princir~

.,nse renewal is that, with the possible exception of the detrimental effects of aging on tne functionality of certain systems, structures, and components (SSCs),

and possibly a few other issues related to safety onl/ during the period of extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provide and maintain an acceptable level of safety so that operation will not be inimical to public health and safety or the common defense and security. This regulatory process, modified for the period of extended operation to include the management of the detrimental effects of aging on the functionality of certain SSCs, ensures that the licensing bases will provide and maintain an seceptable level of safety.

Part 54 focuses the Commission's review on this one safety is. sue but provides leeway for the Commission to consider, on a case-by-case basis, other issues unique to extended operation.

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

To determine the necessary actions that Le needed to cor.stitute aging management programs, renewal applicants must perform an integrated plant assessment (IPA). In this assessment, SSCs that are within the scope of license renewal are identified and screened to determine which SSCs require actions to manage the detrimental effects of age-related degradation. The required aging management actions are then identified, described, and justified. The applicant is required to report in its application the screening methods used, the list of structures and components requiring aging management for extended operation resulting from the screening, and the aging management actions that have been or will be taken, together with their bases. The NRC will review the application to determine the adequacy of the licensee a::tions taken and to be taken, as a basis for approval or denial of a renewed license. The inspection, *urveillance, testing, and malmnance actions involved

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in the aging management program include the requirement for recordkeeping and availability of those records to the NRC for review or audit as part of the NRC's regulatory oversight programs.

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

10 CFR 54.13(b) requires each applicant to notify the Commission of information identified by the applicant as having, for the regulated activity, significant implication for public health and safety or the common defense and security. Notification by the applicant must be i

made within two working days of identifying the information. The NRC needs this information so that it may take appropriate actions, as required, to protect the public's health and safety.

10 CFR 54.15, Specific Exemptions, permits, in accordance with 10 CFR 50.12, the NRC to grant exempt,lns from the req trements of 10 CFR 54 upon application by any interested person or upon its own initiative. The information specified in 10 CFR 50.12 is required so that NRC can determine whether an exemption is warranted.

i 10 CFR 54.17, Filing of Application, requires the filing of an application for a renewed license in accordance with Subpart A of 10 CFR Part 2 and 10 CFR 50.4 and 50.30. This section establishes the procedural aspects of the filing. The information to be included in the, application is addressed in 10 CFR 54.19,54.21,54.22 and 54.23, discussed below.

10 CFR 54.17(g) requires the applicant for a renewed license to agree in writing that it will not permit any individual access to Restricted Data or classified National Security Information until an investigation has been made and reported to the Commission on the character, association and loyalty of such individuals. This information is necessary to assist the Commission in determining that permitting such persons access to Restricted Data or classified National Security information will not endanger the common defense and security.

10 CFR 54.19, Contents of Application - General Information, requires applicants for license renewal to provide the general information specified in 10 CFR 50.33(a) through (e), (h), and (i). The application may incorpore's this information by reference. The NRu needs this information to establish the continued validity, during the renewal term, of general information applicable during the original license.

10 CFR 54.19(b) requires each application to include conforming changes to the standard indemnity agreement,10 CFR 140.92, Appendix B. This is needed to account for the expiration term of the proposed renewed license.

10 CFR 54.21, Contents of Application - Technical Information, requires applicants for license renewal to provide information as follows:

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

e Identify and list those SSCs subject to an aging management review.

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e Describe and justify the methods used to identify those SSCs that require aging management review. The NRC needs this information to be able to conclude that additional aging management attention is directed to SSCs that require it because they are important and can undergo age-related degradation that is new or different or not previously evaluated for the renewal term.

e Demonstrate the adequacy of actions taken or to be taken to manage the detrimental effects of aging on functionality. The NRC needs this information to be satisfied that the actions will be effective in assuring the continued safe operation of the plant.

10 CFR 54.21(b) requires the application to contain CLB changes during NRC review of the application. Each year following submittal of the license renewal application and at ! east 3 months before scheduled completion of the NRC review, the applicant must submit an amendment to the renewal application that identifies any change to the CLB of the facility that materially affects the contents of the license renewal application, including the FSAR supplement. The NRC needs this information to determine the acceptability of these changes frcm the pertinent safety standpoints.

10 CFR 54.21(c)(1) requires the applicant to provide a list of time-limited aging analyses for SSCs that conform to the definition provided in 10 CFR 54.3 and a demonstration that the analyses remain valid for the period of extended operation, that they have been projected to the end of the period of extended operation, or the effects of aging on the intended function (s) will be adequately managed for the period of extended operation. The NRC needs this informatior, to determine whether those SSCs meet the requirements for license renewal.

10 CFR 54.21(c)(2) requires a listing of all plant-specific exemptions granted pursuant to 10 CFR 50.12 and la affect that are based on time-limited aging analyses as defined in 10 CFR 54.3. An evaluation must be provided that justifies the continuation of these exemptions for the period of extended operation. The NRC needs this information to determine whether cainuing these exemptions is justified.

10 CFR 54.21(d) requires applicants to include in the application an FSAR supplement for the facility. This supplement must contain a summary description of the programs and activities for managing the effects of aging and the evaluation of time-limited aging analyses for the period of extended operation as determined by 54.21(a) and (c). The NRC needs this informat;on to determine whether the lic6 wee's actions for managing the effects of aging provide reasonable assurance that the facility's operations during the extended period of operation can be conducted without endangering public health and safety.

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

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10 CFR 54.23, Contents of Applicatio.. F.nvironmental Information, requires each i

application for license renewal to include a supplement to the environmental report that complies with Subpart A of 10 CFR Part 51. The NRC requires this information to determine whether the environmental consequences of the continued operation of the i

facility during the renewal term will continue to be acceptable. The burden associated with the environmental data is incorporated under the burden for 10 CFR Part 51.

l 10 CFR 54.37, Additional Records and Recordkeeping Requirements, establishes retention j

and update requirements.

l 10 CFR 54.37(a) requires holders of renewed licenses to retain in hn auditable and retrievable form for the term of the renewed operating license, all information and g

documentation required to document compliance with 10 CFR Part 54. The NRC needs

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access to this information for effective continuing reculatory oversight.

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10 CFR 54.37(b) requires, after the tenewed license is issued, licensees to include in the j

FSAR update required by 10 CFR 50.71(e) any SSCs newly identified that would have been subject to an aging management review or evaluation of time-limited aging analyses in accordance with 54.21. This FSAR update must describe how the effects of aging will be j

managed such that the intended function (s) will be effectively maintained during the period j

of extended operation. The FSAR update contains information on all of the changes made i

by the licensee to the plant since the original FSAR was submitted or, as appropriate, since the last FSAR was submitted. The NRC needs access to this information for effective j

continuing regulatory oversight.

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2. Acency Use of the Information i

The information will be used by the applicants for and holders of renewed nuclear power i

plant operating licenses as a basis for the establishment and conduct of their aging management programs. The NRC will use the information in it a regulatory oversight to determine whether the continued operation of the nuclear power plants during the renewal term will provide reasonable assurance of the adequate protection of public health and safety and the common defense and security.

3. Reduction of Burden Throuah Information Technoloav There is no legal obstacle or any obstacle in 10 CFR Part 54 to licensees reducing the burden associated with this information collection by use of information technology or otherwise. At present,10 CFR 50.4(c),' Form of communications," provides for the submittal of copies in electronic form by allowing for exceptions to the requirements for copies to be typewntten, printed or otherwise produced in permanent form on unglazed paper.

Further, the NRC identified its Agencywide Documents Access and Management System (ADAMS) as an initiative that is being tracked by OMB under its Capital Planning and investmer:t Control activities (CPIC). This is a major information technological initiative that will enable the NRC to transition from a paper-based environment to an electronic

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environment, thus allowing the NRC to receive and disseminate licensing information electronically. ADAMS is scheduled to be fully deployed by October 1,1999. NRC is currently contemplating rule changes which would explicitly authorize licensees to make submittals to the NRC either electronically or in paper format, even before ADAMS is implemented.

4.

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

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Effort to Reduce Small Business Burden Not applicable.

6. Consecuences to Federal Proaram or Policy Activities if the Collection is Not Conducted or is Conducted Less Freauentiv The records generated as a result of 10 CFR Part 54 would be partly provided at the time of application for renewal and made partly available on a continual basis during the period of extended operation. Reporting of information is required orily as identified under A.1, above. Less frequent collection would increase the risk that programs for managing the 1

effects of aging would not be sufficiently current to assure maintenance of the current licensing basis during the period of extended opt ration.

7.

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

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

8.

Consultations Outside the NRC Opportunity to comment on the 10 CFR Part 54 information collection requirements was published in the Federal Reaister on December 1,1998 (63 FR 66207). No comments were received.

9. Epvment of Gift to Resoondents Not applicable.

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10. Confidentialfv of Information I

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

11. Justification for Sensitive Questions i

1 Not applicable.

12.' Estimated Industry Burden and Burden Hour Cost l

It is anticipated that the paperwork burden will vary widely among nuclear power plant licensees. As licensees leam more about managing the effects of aging, the burden on licensees will likely be reduced. All nuclear plants are somewhat different and the programs employed by individual plants, while similar, are not exactly the same.

l Nevertheless, it is estimated that, on average, under 10 CFR Part 54 each licensee who submits an application for license renewal will incur approximately 94,000 sta#-hours of 1

paperwork burden to satisfy NRC's review requirements. Of this amount, approximately 64,000 sta#-hours are attributed to one-time implementation ections (reporting) and the remainder,30,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, represents a recurring annual recordkeeping burden. This recordkeeping burden, when considered over an assumed 30-year period from the time of application submittal to the end of the renewal term, amounts to about 1,000 staff-hours per year. These estimates capture the licensee's engineering and management licensing reviews, and clerical activities identified in 10 CFR Part 54.

It is estimated that during this 3-year clearance period the NRC will receive 4 license l

l renewal applications. Based on this estimated number of applications and the estimated burden / cost, the total annualized burden to industry is expected to be 89,333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br /> at a cost of approximately $11.1 million (4 applications x 64,000 one-time reporting burden hours + 3 years + 4,000 [1,000 annual recordkeeping burden hours x 4 applications) x

$124/ hour).

13. Estimate of Other Additional Costs None.

14. Estimated Annod=4 Cost to the Federal Govemment The NRC paperwork burden for 10 CFR Part 54 is estimated to be about 45,000 sta#-hours per nuclear power reactor. Of this amount, about 7,300 staff-hours are expected to be incurred as part of the review of the licensee's application submittal. The balance of the NRC's estimated eWort, about 38,000 staff-hours, will be incurred on a continuing basis 4 -

starting as soon as the renewed license is granted (assumed to be approximately 3 years after receipt of the application) and continuing to the end of the license renewal term. This equates to an annual burden of roughly 1,300 staff-hours per reactor. This effort would be i

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expended to review licensees' ongoing aging assessments and aging management activities.

The staff estimates that during this 3-year clearance period the NRC will receive 4 license renewal applications. It is also assumed that two licensa renewals will be granted in 2001, thus incurring, during this clearance period, a burden of 2,600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> for one year. Based on this estimated number of applications and the burden / cost estimated above, the total annualized Federal cost is expected in be $1.3 million (4 applications x 7,300 one-time reporting burden hours + 2,600 continuing burden hours x $124/ hour + 3 years).

- These costs are fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

15. Reasons for Chanaes in Burden or Cost There is no change in the estimated burden per application for industry.

16. Publication for Statistical Use None.

17. Reason for Net Disolavina the Exoiration Date l

The requirement is contained in a regulation. Amending the Code of Federal Reaulations to display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.

18. Exceotions to the Certification Statement Not applicable.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.

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