ML20210Q549

Request for OMB Review & Supporting Statement Re, Voluntary Reporting of Performance Indicators. Estimated Respondent Burden Is 13,860 H

ML20210Q549
Person / Time
Issue date:	08/05/1999
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20210Q553	List: ML20210Q549 ML20210Q664
References
NUDOCS 9908160059
Download: ML20210Q549 (9)

Text

e ESt rb eG b mk PAPERWORK REDUCTION ACT SUBMISSION Pleise rxd thiinstructions beform compl: tin your agency's Paperwork Clearance Officer.g Send two this form.

copies of For additional this form, forms or the crWeeton assstance instrument to beinreviewed, compitting thethis form, coq Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of I Management and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503. j

1. Agency / Subagency onginating request 2. OMB controi nurrter l l U.S. Nuclear Regulatory Commission a. 3150- O g b.None

3. Type of information collection (check one) 4 1ype of revew requested (check one) g a. New collection g a Regular c. Delegated

b. Revision of a currently approved collection b. Emergency- Apptwal requested by (date):

c. Extension of a currently approved collection 5 Will this information co3ection have a a.Yes significant ecorwTwc arroact on a i substantial number of small entities? (

d. Reinstatement. without change, of a previously approved collection for which approval has expired g b.No

e. Reinstatement, with change of a previously approved -

J a' Three years from approval date collection for which approval has expired Requested 6 * " * *

f. Existing collection in use without an OMB control number b. Other (Specify):

7. Title Voluntary Reporting of Performance Indicators

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

Not applicable

9. Keywords R: porting and recordkeeping requirements, Nuclear power plants and reactors

10. Abstract As part of a joint industry-NRC initiative, NRC will request voluntary performance indicators (PI's) from power reactor licensees, which provide objective measures of heensee performance. NRC will use the PI's, along with  !

nudits and inspections, as part ofits revised performance-based reactor oversight process.

9908160059 990805 PDR ORG EUSOMB PDR

11. Affacted pUbliC (Mark pnmary eth *P' and an others that apply wth 'X3 12. Obligation to respond (Man pntney wth "P' and all others that apply wth *)G

a. Individuals or households d. Farms P a. Voluntary T b. Business or other for-profit e. Federal Government b. Required to obtain or retain benefits

c. Not for-profit institutions f. State. Local or Tnbal Government c. Mandatory

13. Annual reporting and recordkeeping hour burden 14. Annual reporting and recordkee,:ing cost burden on thousands orooltars; 66 a. Total annualized capital /startup costs 0

a. Numberof respondents 264 b. Total annual costs (O&M) O s

b. Total annual responses

c. Total annualized cost requested 0

1. Percentage of these responses collected electronically 100.0 % d. Current OMB inventory 0

c. Total annual hours requested 13,860 e. Difference O

d. Current OMB inventory 0

f. Explanation of difference

e. Difference 13.860 9 '* * ""9'

f. Exp!anation of difference 13360 2. Adjustment

1. Program change

2. Adjustment

15. Purpose of information collection 16. Frequency of recordkeeping or reporting (Check allthat apply' (Man pamary with 'P"and allothers that apply with 'X")

] a. Recordkeeping b. Third-party disclosure

a. Application for benefits Y e. Program planning or management 7 c. Reporting -

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2. Weekly 3. Monthfy T b. Program evaluation f. Research gef,"ston

6. Annually

c. General purpose statistics T g Regulatory or compliance 7 4. Quarterly 5, Semi-annually

d. Audit 7. Biennially 8. Other (desenbe)

17. Statistical methods 18. Agency contact tverson who can best answer questions regarding the

" "' ~

Does this information collection employ statistical methods? < - %

Name: Debra McCain Yes No dt 1 Pnone: 301-415-1219 ,/ $ vy 16M08 TF,es form was designed using inf orms 10/95 OMB 83-1 Y(4b~gO

19.C:rtificnti:n far Pcperw:rk Reductisn Act Submingion3 On behalf of this Federal agency, I certify that the collection ofinformation encompassed by this request complies with 5 CFR 1320.9.

NOTE: The te'xt of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8 (b)(3), appear at the end of the instructions. The certspcation is to be made with reference to those regulatoryprovisions as setforth in the instructions.

The following is a summary of the topics, regarding the proposed collection ofinfonnation, that the certification covers:

(a) It is necessary for the proper performance of agency functions; (b) It avoids unnecessary duplication; (c) It reduces burden on small entities; (d) It uses plain, coherent, and unambiguous terminology that is understandable to respondents; (e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; (f) It indicates the retention periods for recordkeeping requirements; (g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3):

(i) Why the information is being collected; (ii) Use ofinformation; (iii) Burden estimate; (iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature of extent of confidentiality; and (vi) Need to display currently valid OMB control number; (h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected (see note in item 19 of the instructions);

(i) It uses efTective and efficient statistical survey methodology; and (j) It makes appropriate use ofinformation technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

l Sgnature of Autnonzed Agency Official Date Sgnature nior Official or Date Bren Shelton, NRC Clearance Offi f the Chief information Officer f5 ~

OM8 83-1 V 10/95

FINAL SUPPORTING STATEMENT FOR VOLUNTARY REPORTING OF PERFORMANCE INDICATORS (New Collection)

Description of the Information Collection.

In mid-1998, the nuclear industry offered to voluntarily send selected performance attributes known as performance indicators (PIs) to the NRC as part of a larger effort to improve the NRC's oversight process. Pls provide objective measures of the performance of licensees' systems or programs. The NRC is revising its reactor oversight process to use PI information, along with the results of selected audits and inspections, to provide the basis for NRC conclusions regarding plant performance and necessary regulatory response. Pts will be transmitted electronically to reduce burden on licensees and the NRC as part of the NRC's revised oversight process which is scheduled for implementation beginning in April 2000.

Improvements to the oversight process are being developed through a joint effort with public stakeholders, industry representatives, and the Nuclear Energy Institute (NEI)' NEl issued a guidance document for reporting PI information (Regulatory Assessment Performance Indicator Guideline), which is expected to be endorsed by the NRC for use. Under the revised oversight process, licensees will need to conduct a one-time review of past records to identify information needed to calculate Pls for the initial reporting in January 2000; and there will be a one-time burden to develop and implement procedures for collecting and reporting PI data. Licensees already collect most of the Pls and report some of them to various industry groups. There is widespread industry support for the revised oversight process (see attached letter from NEI) and NEl has determined that all reactor licensees plan to voluntarily submit Pls.

A. JUSTIFICATION

1. Need For and Practical Utility of the Collection of Information.

In response to concerns expressed by congressional committees, the nuclear indust ~ry, public interest groups, as well as the NRC's own internal reviews, the NRC is revising its inspection and oversight process for commercial nuclear power plants. The new process uses Pls as a means of measuring the performance of key attributes. The use of Pts allows the new process to be more objective and allows for a reduction in the amount of NRC inspections. For those attributes for which Pls could not be identified or were not sufficiently comprehensive, the NRC developed baseline inspection activities to obtain necessary information. The NRC also developed additional inspection activities to verify the accuracy and completeness of the reported PI data. The use of PI information is a basic tenet of the revised oversight program and is expected to result in significant reduction of overall NRC burden on reactor licensees.

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' NEl is a utility group whose mission is to " foster and encourage the continued safe utilization and development of nuclear energy in order to meet the nation's energy, environmental, and economic goals."

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2 The revised oversight process was issued for public comment several times during its development. Comments received indicate that industry supports the approach, and in an effort to advance the development and implementation of the new program, nine reactor sites have voluntarily submitted Pls as part of a pilot process that began in June 1999. Lessons learned from the pilot effort may result in incremental adjustments to the identified Pts. The NRC and NEl are continuing to develop an additional PI in each of the following areas: shutdown operations, fire protection, and the unreliability of systems listed in paragraph "b" below.

Fullimplementation of the revised oversight process will begin April 2000. Licensees who report Pls, would do so quarterly and retain records as long as necessary to calculate specific indicators, but in no case longer than 3 years. ,

The specific Pi information is listed below;

a. The number of:

unplanned scrams per 7,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of critical operation scrams with loss of the normal heat removalin the preceding 36 months unplanned transients per 7,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of critical operation safety system functional failures in the preceding 12 months non-conformances with 10 CFR Part 20 requirements for high or very high radiation areas, or unintended personnel exposures in the preceding 36 months occurrences of radiological effluent releases that exceed values derived from the Radiological Effluent Technical Specifications (RETS) or provisions in the Offsite Dose Calculation Manual (ODCM),if applicable, in the preceding 36 months reportable failures of the security program to screen personnelin the preceding 12 months reportable failures of the security program for personnel reliability in the preceding 12 months

b. The unavailability (the percentage of time the system was unavailable for operation in the preceding 36 months) of the following systems:

high-pressure injection high-pressure heat removal residual heat removal emergency AC power

c. The percentage of:

reactor coolant activity (as a percent of the Technical Specification limit) reactor coolant leakage (as a percent of the Technical Specification limit) l containment leakage (as a percent of the Technical Specification limit) successful (accurate and timely) classifications, notifications, and protective action recommendations (as a percent of all such actions) by the Emergency Response Organization (ERO) during drills, exercises, and actual events in the preceding 24 1 months )

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3 key ERO members who participated in emergency drills, exercises, or actual events in the preceding 24 months sirens that operated reliably in the preceding 12 months guard duty required to compensate for the unavailability of protected area security equipment (as a percent of total time) in the preceding 12 months

d. A point of contact for Pl data, including a name, e-mail address, and phone number.

2. Aaency Use of Information.

The Office of Nuclear Reactor Regulation (NRR) will use Pls, along with the results of audits and inspections, as a basis for determining if specific performance thresholds (as

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described in the oversight program guidance) have been exceeded. The oversight process relies, in part, on performance insights gained from PI data to trigger regulatory ,

actions and to aid in the assessroent of plant performance. Pls, along with the results of inspection, will be made publically available on the Internet shortly after the end of each  ;

quarter. 1

3. Reduction of Burden Throuah Information Technoloav.

All Pl data will be transmitted electronically to reduce burden on both industry and the NRC. The NRC is in the process of selecting the best process to receive PI information and store it in the Agencywide Documents Access and Management System. One approach being considered is the use of electronic information exchange capability being developed by OClO. The NRC is continuing to work with industry while developing its capability to receive electronic information.

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4. Effort To identify Duplication and Use Similar Information. l l

The Pls were selected to maximize usefulness, and consequently, they track specific performance over predetermined periods. Although licensees report similar information for 6 of the 19 indicators, this information is not always reported in sufficient detail to properly characterize issues to meet the requirements of the revised oversight program. ,

1 The industry expressed a strong preference to report Pls separately from other reporting requirements (even if there is some overlap with required reports) to expedite the ,

development and implementation of the revised oversight process. Licensees report l similar information for three of the six Pls under the general reporting requirements in 10 CFR 50.72 and 50.73. As a separate action, both of these requirements are being reviewed to identify changes to reduce the reporting burden (reduce scope and lengthen response time) on licensees and to better align the reporting requirement with the NRC's current reporting needs.

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5. Effort to Reduce Small Business Burden.

This information co!!ection does not impact small business as all respondents are nuclear power plant licensees.

6. Conseauences to Federal Proaram or Policy Activities if the Collection is Not Conducted or is Conducted Less Freauentiv.

The NRC would not be able to implement the revised oversight process as it is currently structured if Pi information were limited or not available. The insights gained from Pls are a critical element of the new oversight program. The Pls establish an objective basis for the assessment of licensee performance and for allocating NRC inspection resources.

The NRC would be forced to rely on inspections to obtain assessment information to the extent that Pi information is not available.

7. Circumstances which Justifv Variation form OMB Guidelines.

This information collection does not vary from OMB guidelines.

8. Consultations Outside the NRC.

The NRC has worked closely with industry and public stakeholders in revising the reactor oversight program, including the collection of Pi data. NRC and industry representatives have met frequently (more than 10 times in 1998 and biweekly in 1999), and the NRC has held a number of public meetings (a 4-day public workshop on September 28-October 1, 1998, and public Commission briefings on April 2,1998, November 2,1998, January 20, 1999, and March 26,1999) to provide information and to solicit comments on the new process. l NRC and industry representatives have discussed Pls, including the availability of data, the frequency of collection, the clarity of each indicator, and the reporting format. On j January 22,1999, the NRC issued a Federa/ Register notice (64 FR 3576) soliciting public j comments on the scope and content of the revised oversight process, including Pls. 1 Comments overwhelmingly support the new oversight process, including the collection of Pls. Additional workshops on the revised oversight process, including Pls, were open to the public and conducted on April 12-15 and May 17-20,1999.

The NRC issued a FederalRegister notice (64 FR 28530) soliciting public comments on ,

the collection of Pl data on May 26,1999. No comments were received. j l

9. Payment or Gift to Respondents. '

Not applicable.

10. Confidentiality of the Information.

No information normally considered confidentialis requested. The NRC intends to place PI information on its Web site for public viewing.

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11. Justification for Sensitive Questions.

Not applicable.

12. Estimate of Industry Burden and Burden Hour Cost.

The following table reflects licensee burden to provide Pi information and is based on information from industry (see attached letter from NEI) and staff's best estimate. The estimates include only additional hours needed above those already expended by licensees to report indicators to the Institute of Nuclear Power Operations or to comply with other regulatory requirements (e.g., the maintenance rule,10 CFR 50.73 reporting, etc.). The NRC anticipates that the reporting of Pls under the revised oversight process will result in an overall reduction in the amount of time licensees must expend supporting NRC inspection activities. This information collection imposes a minimal recordkeeping burden due to efficiencies inherent with electronic storage and transmission of data.

The following table assumes there will be one response per reactor site on a quarterly basis (4 X 66 = 264 annual responses) and that licensees will occasionally need to update i the Pls and related procedures based on experience.

ANNUAL REPORTING BURDEN No. Annual Burden per Total Annual Annual Responses Response Burden Hours Cost at

$141/hr Pl Reporting 264 50 13,200 $1,861,200 ANNUAL RECORDKEEPING BURDEN No. of reactor Burden per Total Annual Annual ,

Sites reactor site Burden Hours Cost at I

$141/hr Recordkeeping 66 10 660 $93,060 ONE-TIME BURDEN Licensees will need to review historical records to collect and report eight quarters of Pl data for the initial, one time, report.

Review of Historical No. of reactor Burden per Total Burden One-time Records sites reactor site Hours Cost at 4

$141/hr l I

66 100 6,600 $930,600 1

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Licensees will need to develop and implement site-specific procedures to collect and report Pl data.

Develop and No. of reactor Burcen per Total Burden One- time Implement Pl sites reactor site Hours Cost at Procedures $141/hr 66 100 6,600 $930,600 Combining these one-time activities and converting to an annual burden spread over the threa-year period of this clearance request yields a burden of 4,400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> (13,200/3) at a cost of l

$620.400. Total burden equals 18,260 (4,400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> plus 13,200 plus 660 annual burden hours) -

for the first 3 years. After the first 3 years the estimated annual burden will be 13,860 hours0.00995 days <br />0.239 hours <br />0.00142 weeks <br />3.2723e-4 months <br />.

13. Estimate of Other Additional Costs.

None.

14. Estimated Annualized Cost to the Federal Government.

The overall cost to the Government should decrease because the reduction in costs related to NRC oversight will more than offset any increased costs associated with reviewing PI data. The review of Pi data willinvolve minimalincremental cost to the Government as most of the information contained in these indicators is reviewed as part of the routine inspection and assessment process. This cost is fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

15. Reasons for Chanae in Burden or Cost.

This will create a new burden for licensees to implement and maintain a voluntary PI program. The burden is expected to be offset by a reduction in the amount of time licensees must devote to responding to NRC inspections.

16. Publication for Statistical Use.

This information will not be published for statistical use.

17. Reason for Not Disolavina the Exoiration Date.

The expiration date will be displayed.

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18. Exceptions to the Certification Statement.

..There are no exceptions.

B.. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.

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