ML20209B944
| ML20209B944 | |
| Person / Time | |
|---|---|
| Issue date: | 04/03/1986 |
| From: | Feld S NRC OFFICE OF RESOURCE MANAGEMENT (ORM) |
| To: | Nellis D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20209A892 | List:
|
| References | |
| FRN-49FR1205, RULE-PR-20 AA39-2-021, AA39-2-21, NUDOCS 8704280552 | |
| Download: ML20209B944 (2) | |
Text
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MEMORANDUM FOR:
Donald 0. Nellis, Jr.
Radiation Risk Assessment and Management Branch Division of Radiation Programs and Earth Science Office of Nuclear Regulatory Research FROM:
Sidney E. Feld, Senior Cost Analyst Cost Analysis Group Resource Analysis Branch Division of Budget and Analysis Office of Resource Management
SUBJECT:
COST ANALYSIS REVIEW 0F AMENDMENTS TO 10 CFR PART 20 TO REQUIRE THE USE OF ACCREDITED PERSONNEL D0SIMETRY PROCESSORS In response to your request of March 28, 1986, the Cost Analysis Group (CAG) has reviewed the subject regulatory package. Our comments focus on the cost analysis portion of the regulatory analysis (pp. 5 & 6, enclosure B).
1.
The analysis does not explicitly discuss the cost of implementing a tetting and accreditation program. The current write-up does note that this program has been in effect since January 19 M and that funds have already been committed (presumably by NBS).
It would be very useful to tie this information more directly to a staff conclusion on the implemen-tation cost of a testing and accreditation program, e.g., Proficiency testing and NVLAP accreditation of processors began in January 1984 and thus, the costs of implementing such a program have already been incurred. Since these costs are sunk, the effec-tive implemantation cost of such a program is zero.
2.
The current write-up assi;,ns various dollar values to a processor for maintaining the testing and accreditation program. The basis for these dollar values is not provided.
Presumably, these fees parallel what is currently in place, or represent NBS' judgement as to what is required to maintain and operate the program on a self-supporting basis. Explicitly identifying either one of these as the basis for these dollar values would, in our view, add significant credibility to the cost analysis.
3.
The treatment of costs and benefits in the current write-up appears to be of limited utility for decision-making purposes.
For example, costs are expressed on a per processor basis with no sense of the number of processors likely to be impacted. Thus, the total cost to industry remains unknown. On the benefit side, no quantification was attempted and the benefits are simply characterized as improvements to the health and safety of occupationally exposed workers.
In our view, additional and important insight into these costs and benefits can be attained with limited effort.
pg42g552870422 20 49FR1205 PDR pcMR0 5:2.
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Donald 0. Nellis, Jr. p3 gg On the cost side, an estimate of the number of processors likely to be impacted could be provided which when multiplied by the proposed fees would show the aggregated one-time and biennial costs to industry of the proposed requirement. The inherent variability of the fees could be accounted for by developing this estimate as a range based on the high and low ends of the fees reported in the regulatory analysis. Alterna-tively, one could attempt to develop a best estimate by stratifying the processor population based on one's knowledge of where specific processors would fit within the range of fees.
(e.g., assuming there are 100 processors, the staff estimates that 60 would incur costs at the low end, 10 at the high end, and 30 in the middle).
With respect to benefits, a useful perspective might be to provide an estimate of the number of workers whose personnel radiation exposure records would potentially be improved as a result of the proposed requirement. With this type of reformulation, one could contrast the total cost to industry with the number of workers who could potentially benefit. Such a comparison should provide a more meaningful basis for a decision on the proposed regulatory action.
Sidney E.'Feld, Senior Cost Analyst Cost Analysis Group Resource Analysis Branch Division of Budget and Analysis Office of Resource Management l
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