ML20209B316

Notice of Pending NRC Action to Submit Info Collection Request to OMB & Solicitation of Public Comment

ML20209B316
Person / Time
Issue date:	06/16/1999
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
NUDOCS 9907060380
Download: ML20209B316 (10)

Text

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2.

[7590-01-P]

U. S. NUCLEAR REGULATORY COMMISSION Agency Information Collection Activities: Proposed Collection; Comment request l

I AGENCY:

U. S. Nuclear Regulatory Commission (NRC)

ACTION:

Notice of pending NRC action to submit an information collection request to OMB and solicitation of public comment.

SUMMARY

The NRC is preparing a submittal to OMB foi review of continued approval of information collections under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35).

Information pertaining to the requirement to be submitted:

1.

The title of the information collection:

Generic Letter 91-02, " Reporting Mishaps involving LLW Forms Prepared

- for Disposal" 2.

Current OMB approval number: 3150-0156 9907060300 990616 PDR ORG EUSOMB PDR

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How often the collection is required: Reports are made only when the licensee or waste processor experiences a mishap that is reportable under the guidelines described in the Generic Letter.

4.

Who is required or asked to report: Nuclear power reactor licensees and Agreement State and non-Ag7 ament State waste processors and disposal site operators.

5.

The number of annual respondents: 34 6.

The number of hours needed annually to complete the requirement or request: 272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> (an average of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per response).

7.

Abstract: Generic Letter 91-02 encourages voluntary reporting (by both waste form gLnerators and processors) of information concerning mishaps to low-level radioactive waste (LLW) forms prepared for disposal.

The inforrnation is used by NRC to determine whether follow up action is necessary to assure protection of public health and safety.

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, Submit, by (insert date 60 days after publication in the Federal Reaister), comments that i

address the following questions:

1.

Is the proposed collection of information necessary for the NRC to properly perform its functions? Does the information have practical utility?

2.

Is the burden estimate accurate?

3.

Is there a way to enhance the quality, utility, and clarity of the information to be collected?

4.

How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms of information technology?

A copy of the draft supporting statement may be viewed free of charge at the NRC Public

. Document Room,2120 L Street NW (lower level), Washington, DC. OMB clearance requests are available at the NRC worldwide web site (http://www.nrc. gov /NRCiPUBLIC/OMB/index.html). The document will be available on the NRC home page site for 60 days after the signature date of this notice.

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Comments and questions about the information collection requirements may be directed to the NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 E6, Washington, DC,20555-0001, by telephone at 301-415-7233, or by Intemet electronic mail at

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BJS1@NRC. GOV.

Dated at Rockville, Maryland, this e'd day of Am 1999.

For the Nuclear Regulatory Commission.

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BREida o. Sheitsfi,'Wiearance Officer Office of Chief Information Officer i

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PM Comments and questions about the information collection requirements may be directed to the i

NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 E6, Washington, DC,20555-0001, by telephone at 301-415-7233, or by internet electronic mail at i

BJS1@NRC. GOV.

Dated at Rockville, Maryland, this day of 1999.

For the Nuclear Regulatory Commission.

Brenda Jo. Shelton, NRC Clearance Officer Office of the Chief Information Officer

• See previous concurrences DOCUMENT NAME: P:\\OMB\\FRN_GL91.02 Te receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE NMSS/IMNS l

NMSS/IMNS NMSS OClO/RMB NAME JMMcCausland FACardile JWNHickey BJSt)e%ifR_

DATE-05/*/99 05/*/99 05/*/99 06/ f/(,, /99 OFFICIAL RECORD COPY u.

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1 Comments and questions about the information collection requirements may directed to the NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory C mission, T-6 F33, Washington, DC,20555-0001, by telephone at 301-415-7233, or b nternet electronic mail at BJS1 @NRC. GOV.

Dated at Rockville, Maryland, this day of

.1999.

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,/ For the Nuclear Regulatory Commission.

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Brenda Jo. Shelton, NRC Clearance Officer Office of the Chief Information Officer 9

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DOCUMENT NAME: P:\\OMB\\FRN_GL91.02 Ta receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with cttachment/ enclosure "N" = No copy

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OFFICE NMSS/IMNS NMSS/IMNSj N@

e) OClO/lRMB NAME JMMcCauslan@ Jr FACardile74 J$$ickey BJShelton j

DATE 05/21/99 05//v/99 "

0$d//99 05/

/99 OFFICIAL RECORD COf6y i

u DRAFT SUPPORTING STATEMENT FOR GENERIC LETTER 91-02

" REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR DISPOSAL" (3150-0156)-

EXTENSION REQUEST Descriotion of the Information Collection NRC is requesting the extension of a previously approved information collection.

The Nuclear Regulatory Commission (NRC) issued Generic Letter 91-02 to encourage voluntary submittal (by both waste form generators and processors) of information conceming mishaps to

' low-level radioactive waste (LLW) forms prepared for disposal. This Generic Letter also reminds licensees of their obligation to report defects and deviations in accordance with NRC requirements in 10 CFR Part 21.

A.

Justification 1.

Need for and Practical Utility of the Collection of Information Prior to the issuance of Generic Letter 91-02, NRC collection of information concerning reported mishaps to LLW forms prepared for ultimate disposal in a licensed LLW disposal facility was conducted through indirect and informal means. Examples of mishaps that were reported included: (1) chemical reactions which occurred in low-level waste shipping containers storing dewatered synthetic organic materials (such as resins), (2) a chemical reaction between a

- chemical detergent and a waste solidification agent resulting in a boiling of the mixture, and (3) multiple incidents where cement-solidified bead resin wastes have either not solidified properly or disintegrated over a period of time following solidification. The purpose of Generic Letter 91-02 was to ensure that all such events are voluntarily reported to the NRC with adequate information to determine if follow up action is necessary.

2. '

Aaency Use of information j

A waste form mishap experienced by one reactor licensee or waste processor may raise the possibility of a generic problem. In that case, an NRC Information Notice or Bulletin would be issued to advise all power reactor licensees, low-level waste processors, and the sited-disposal States of the potential hazard (s) and to encourage (or, in the case of a Bulletin, to request)

' licensees to take the appropriate precautions to ensure the protection of public health and safety.:

.3.

Reduction of Burden throuah Information Technoloav There are no legal obstacles to reducing the burden associated with this information collection by the use of information technology. NRC encourages the use of such technologies. The sporadic nature of the mishaps to be reported, however, does not lend itself to the use of such information technologies. Consequently, the current percentage of electronic submissions is zero.

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Effort to identify Duplication and Use Similar Information The Information Requirements Control Automated System (IRCAS) was searched to identify duplication. None was found. There is no known information available to the Government that is similar to the information identified in the Generic Letter. Information is only provided if a mishap occurs.

5.

Effort to Reduce Small Business Burden w

A majority of the reports from waste processors are from commercial nuclear power reactor licensees, which are not small entities. Some responses may be received from waste processors that are small businesses. However, since the consequences to public health and safety from waste form mishaps are the same whether reported by a large or a small entity, it is not possible to reduce the burden on small businesses by less frequent or less complete reporting.

6.

Consecuences to Federal Prooram or Policy Activities if the Collection is not Conducted or is Conducted Less Frecuently This is a one-time voluntary submittal when a mishap occurs. It is not possible to permit reporting less frequently. If the information were not collected, NRC would not be able to identify and evaluate a waste form mishap that might raise the possibility of a generic concern, and would be unable to notify other power reactor licensees, waste processors, and sited-disposal States of the potential hazards so that they could take appropriate precautions to protect public health and safety.

7.

Circumstances Which Justifv Variation from OMB Guidelines Mishaps to LLW forms prepared for disposal should be reported to the NRC within 30 days so that NRC can determine whether (1) waste form requirements of 10 CFR S 61.56 are met prior to disposal, (2) other waste processors need to be notified of processing problems, and (3) changes to the processing methods are needed.

8.

Consultation Outside the NRC Opportunity for public comment on the information collection requirements will be published in the Federal Reoister.

9.

Pavment or Gift to Respondents Not applicable 10.

Confidentiality of the Information None, except for proprietary information.

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Sensitive Questions None.

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Estimated Burden and Burden Hour Coj l~

The actual burden on the licensee or processor is difficult to estimate because only a few of I

these mishaps have been reported. An average mishap report would be about one to three pages la length. The average time to prepare such a report is estimated to be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This request includes burden estimates for Agreement State licensees. The burc!en estimate is provided in the following table.

l Number of Burden Hours Respondent Total Annual Respondent Responses /Yr Per Response Burden (Hrs)

Burden (Hrs)

NRC Agreement NRC Agreement States States Waste 7

14 8

56 112 168 Processors Disposal Site 3

10 8

24 80 104 i

Operators Total 10 24 80 192 272

. Experience to date has shown the number of responses to be less than 10 per year. Therefore, as a conservative upper bound, the number of responses is estimated to be no more than 10 per year. This is assumed to be distributed so that three fourths would come from waste processors and one fourth would come from disposal site operators. The estimate of the number of Agreement State waste processor responses is based on the assumption that the number of such waste processors is j

approximately double the number of NRC waste processors, hence the number of responses will also i

be double (2 x 7).

At a rate of $140 per hour, the cost to respondents would be $38,080 (272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> x $140/ hour).

13.

Estimate of Other Additional Costs i

None.

14.

Estimated Annualized Cost to the Federal Govemment The collection and processing of the information requires approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of NRC staff time per report (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for headquarters staff and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the regional offices). It is estimated that up to 10 reports will be received per year from non-Agreement-State respondents. It is estimated that up to 24 reports will be received per year from Agreement State respondents. At $140 per hour, the annual cost to the Federal government would be $76,160 (34 reports x 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> / report x $140). This cost is fully recovered by fee assessments to NRC licensees pursuant to 10 CFR Part 171.

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15 Reasons for Chance in Burden or Cost There is no change in burden. The cost estimate has increased because of an increase in NRC's cost l

' recovery fee rate from $120 to $140 per hour.

16.

Publication for Statistical Use

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None.

17.

Reason for Not Disolavino Exoiration Date j

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This information collection is contained in a Generic Letter which was distributed to potential respondents in 1991 and still remains in effect. Revising and redistributing Generic Letter 91-02 merely to update the expiration date unnecessarily expends scarce agency resources.

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Exceptions to the Certification Statement

' There are no exceptions.

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B. Collection of Information Emolovino Statistical Methods Statistical methods are not used in this collection of information.

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UNITED STATES E

'k NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

%,..... f 7 ' 2 i 1990 TO:

ALL OPERATORS OF LOW-LEVEL RADI0 ACTIVE WASTE (LLW) DISPOSAL SITES, WASTE PROCESSORS, AND ALL HOLDERS OF LICENSES FOR NUCLEAR FUELS, NUCLEAR MATERIALS AND NUCLEAR POWER REACTORS

SUBJECT:

REPORTING MISHAPS INVOLVING LtW FORMS PREPARED FOR DISPOSAL (GENERIC L TTER 91-02)

Purpose:

For the reasons presented below, the Nuclear Regulatory Commission (NRC) has decided to rely on voluntary submittal of informational reports by both waste form generators and processors regarding mishaps to LLW forms prepared for disposal. This Generic Letter is intended to encourage this action on such mishaps. Licensees are also reminded of their obligation to report defects and deviations in accordance with NRC requirements in 10 CFR Part 21.

Discussion:

Background -

NRC has incomplete information on mishaps to LLW forms prepared for disposal.

Four incidents have been reported in which pressurization resulted from chemical reactions in LLW shipping containers storing dewatered synthetic organic materials, such as resins (NRC Information Notices 83-14, "Dewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical Reaction," March 21,1983; 84-72, " Clarification of Conditions for Waste Shipments Subject to Hydrogen Gas Generation," September 10,198a; 90-50, " Minimization of Methane Gas in Plant Systems and Radwaste Shippir.g Containers," August 8,1990).

Another incident was reported in which, during solidification of the waste, a violent reaction occurred between a chemical detergent and a vendor's waste solidification agent (NRC Information Notice 88-08, " Chemical Reactions with Radioactive Weste Solidification Agents," March 14,1988). This reaction resulted in boiling of the mixture so that it overflowed the liner, then hardened, and had tc be chipped away. Other problems have been encountered in the use of cement to solidify and stabilize bead resin wastes. Thus, there have been multiple incidents in which cement-solidified bead resin wastes have either not solidified properly or have disintegrated over a period of time after solidification. Although mishaps such as these generally have been made known to regulatory authorities, mainly through indirect and informal means, there is presently no established method to encourage the reporting of such events and the providing of adequate information on them.

A-0130022.

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Current Practice -

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l All three currently-sited Agreement States hevada, South Carolira, and

. Washington) have established requirements in the State' licenses for the h

reporting of waste form and container deficiencies identified by.the site operators.in wastes shipped Ao the sites'for disposal.

In addition, all three facilities have on-site State inspectors who inspect the condition of shipments received by the disposal-facility o'perators. This inforraation is provided to NRC as part of the NRC/ Agreement State exchange of. information program.

The staff. further notes, however, that neither the Agreement States nor NRC have specific regulatory requirements that apply to all licensees for reporting of waste form ~or container deficiencies. Therefore 'the States do report what they find, but they may not find some of these problems, because they have no requirement to 'look for all such events at their disposal facilities, ard they do not presently have the means to be informed routinely of mishaps t:..t occur at NRC-licensed facilities.

Existing reporting. requirements contained in 10 CFR 20.403,'50.72, 50 73 and 61.80 do not require reporting-of waste form mishap information. The reporting requirement.in 10 CFR Part 21 is associated with safety-significant defects or noncompliances, and may not be interpreted by some to. cover mishap information.

' Classes of Needed Information -

The staff has identified three classes of useful information that interest NRC and could be reported. These three include:

1.

The failure of high-integrity containers used to ensure a stable waste

- form.. Container failure can be evidenced by changed container dimensions, cracking, or damage resulting from mishandling-(e.g., dropping or.

impacting-against another object).

2 2.-

The misuse of high-integrity containers, evidenced by a quantity of free liquid greater than 1 percent of centainer volume, or by an excessive void space within the container.

Such misuse is prohibited by 10 CFR 61.56.

3.. -The production of a solidified Class B or C waste form that has any of the following characteristics

- Conta, ins free liquid in quantities exceeding 0.5 percent of the i

volume of the waste.

Contains-waste'with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the j

regulatory agency, which could lead to errors in assessment of waste class.

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Contains a significantly different waste loading than that used in qualification testing acceptea by the regulatory agency.

Contains chemical ingredients no'. present in qualification testing j

accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product.

Shows instability evidenced by crumbling, cracking, spalling, voids, sof tening, disintegration, nonhomogeneity, or dimensional changes.

Evidence i processing phenomena that exceed the limiting preessing conditions identified in applicable topical reports on process control plans, e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material.

Bases for Needed Information -

The voluntary reporting of the three classes of information outlined above would allow the staff access to information on field experiences with LLW forms and to determine when modifications to test criteria are necessary, 10 CFR Part 61 establishes certain " minimum"(61.56(a)) and " stability" (61.56(b))

Nquira.ients for LLW, whereas Part 20 (Section 20.311) requires waste generators and processors to certify that the waste satisfied the requirements of Part 61. The Nuclear Material Safety and Safeguards (NMSS) staff reviews topical reports and other documents provided by vendors and licensees to ensure that the waste-form requirements of Part 61 will be met and to provide a vehicle with which the certification requirements of Part 20 can be satisfied (by reference).

In a parallel effort, the Office of Nuclear Reactor Regulation (NRR) staff reviews information on waste-processing equipment and procedures to ensure that 10 CFR Part 50, App. A " General Design Criteria for Nuclear Power Plants," is satisfied. The NRC staff findings of acceptability and adequacy of process-control provisions affecting the characteristics of the waste-form produced may require modification, if subsequent experience in the field reveals that the bases for the approvals are being exceeded or are no longer relevant. Therefore, to make informed decisions on regulatory action, to inform licensees of events that may have generic implications, and to make inspectors a' ware of the reported information, the staff needs to have quantitative information on the nature and frequency of occurrence of mishaps regarding waste form and packaging fc. disposal.

It is suggested that the voluntary submittal of information regarding waste-form mishaps be reported within 30 days of the incident to NRC's Director

.of the Division of Low-Level Waste Management and De:onissioning and to the designated State disposal-site regulatory authority.

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anc is::4: erece *luncer:

i This recuest *s :overec :.

':a " "co:er:-ae e c' a ed average burden is 315C-0156 wnten e<3 res lovsm er... ~. 0 2.

i approximately 5 person-hours per licersee response,1r.:iuding visual

' observation of the waste form misnao, drafting a description of the observation, and preparirg a final mishap report 'or submittal to NRC.

Comments on the accuracy of this estimate and sugges:ioas tc re.ouce the burden may be directed tc the Office of the Manageracn and Budget, Room 3208, New Executive'0ffice Building,. Washington, D.C. 20503, and the U.S. Nuclear Regulatory Commission, Information and Records flanagement Branch, Office of Information Resources 11anagement, Washington, D.C. 20555.

If.you have any q'uestions a, Jut this. letter,'please direct them to'the technical contoct listed below or to the appropriate regional off*ce.

Sincerely,

?

( (,,,,,1 L

/ t;ga ri,0 RichardL.Bangart,Directdr Division of Low-Level Waste Management ar.d Decommissioning,flMSS Technical

Contact:

Michael Tokar, NMSS (301) 492-0590 i

Enclosure:

List of Recently Issued Generic Letters j

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7' CF 4ECENTLY !SS','ED 'ENEP': LE"E 5 Gener::

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Letter %.

L:;en _

nuance

ssuac ~o 91-01 REM 0iAL OF THE SCHEDULE FOR 31/04/91 ALL HOLDERS OF OLs THE WITHDRAWAL 0F REACTOR OR cps FOR NUCLEAR VESSEL MATERIAL SPECIMENS POWER PLANTS FROM TECHNICAL SPECIFICATIONS 90-09 ALTERNATIVE REQUIREMENTS FOR 12/11/90 ALL LIGHT-WATER SNUBBER VISUAL INSPECTION REACTOR LICENSEES INTERVALS AND CORRECTIVE AND APPLICANTS ACTIONS 89-10 CONSIDERATION OF THE RESULTS 10/25/90 ALL LICENSEES OF SUPP. 3 0F NRC-SPONSORED TESTS OF OPERATING NUCLEAR MOTOR-0PERATED VALVES POWER PLANTS AND HOLDERS OF CONSTRUC-TIUN PERMITS FOR N!' CLEAR POWER PLANTS 90-08 SIMULATION FACILITY 08/10/90 ALL HOLDERS OF EXEMPTIONS OPERATING LICENSES OR CONSTRUCTION PERMITS FOR NUCLEAR J

POWER REACTORS 90-07 OPERATOR LICENSING NATIONAL 08/10/90 ALL POWER REACTOR EXAMINATION SCHEDULE LICENSEES AND APPLICANTS FOR AN OPERATING LICENSE 89-10 AVAILABILITY OF PROGRAM 08/03/90 ALL LICENSEES OF SUPP. 2 DESCRIPTIONS OPERATING NPPs AND HOLDERS OF cps FOR NPPs 88-20 COMPLETION OF CONTAINMENT 07/06/90 ALL LICENSEES HOLD-SUPP. 3 PERFORMANCE IMPROVEMENT ING OLs AND cps PROGRAM AND FORWARDING OF FOR NPP FACILITIES INSIGHTS FOR USE IN THE EXCEPT LICENSEES

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INDIVIDUAL PLANT EXAMINA-FOR BWRs WITH MARK I i

TION FOR SEVERE ACCIDENT CONTAINMENTS VULNERABILITIES 90-06 RESOLUTION OF GI 70, " POWER- 06/28/90 ALL PRESSURIZED OPERATED RELIEF VALVE AND WATER REACTOR 1

BLOCK VALVE RELIABILITY,"

LICENSEES AND AND GI 94, " ADDITIONAL LOW-CONSTRUCTIGN TEMPERATURE OVERPRESSURE PERMIT HOLDERS PROTECTION FOR LIGHT-WATER REACTORS," PURSUANT TO 10CFR50.54(f)