ML20245B670
| ML20245B670 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1989 |
| From: | Amenta J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | |
| References | |
| OMB-3150-0135, OMB-3150-135, NUDOCS 8906260010 | |
| Download: ML20245B670 (12) | |
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" "" 8 Request for OMB ReviefS"" "T" e 5"
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_Q,m-( 4_., (.mb Important Read instructions before completing form Do not use the same SF 83 Send three copies of this form, the material to be reviewed, and for to request both an Executive Order 12291 review and soproval under paperwork-three copies of the supportng statement, to:
the Paperwork Reduction Act Answer all questions in Part 1. If this request is for review under E.O. Office of information and Regulatory Affairs 12291, complete Part 11 and sign the regulatory certificate if this Office of Management and Budget recuest is for approval under the Paperwork Reduction Act and S CFR Attention: Docket Library, Room 3201 1320, skip Part 11 complete Part 111 and segn the paperwork certification. Washington, DC 20503 PART L-Complete This Part for All Requests.
- 1. Departme nt/ agency and Bureau /otfice orErst1ng request 2.A Eenc'rcode U. S. Nuclear Regulatory Commission 3 1 5 0 Dame of pen,on wno can best ar suer questions regarding this request Telepnone numbi r Kitty Dragonette (301 ) 4920437
- 4. htie of information conection or r lemaeung u
10 CFR Part 61 - Licensing Requirements for Land Disposal of Radioactive Waste
- b. t egan authont, tor mtormat an couect,on or ruse (ote L5 tea States Code. Pubhc Las. or Enecutive Order)
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- 6. Affected pu%c (checA as turapp > > $ ] federat agenc,es or emplaces U ine vidsa s or housenous 3 0 f arn,s 6 O Non prof 4t institut.ons 2 C State or 'oca'f.ovements 4 1 Duvesses or other fo* profit 7 %) Smallbu:,inesses or orp+ eat ons PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291 7 Regulation IdentAer N Jreer (R6N)
- _ ___ _ ~ __ _ _._ , or. None ass gned C
- 5. Type of sut+m ssion (cnecso ' % m ex n c3tegn > Type of revsew requested Classification Stage of development 10 Stancard
] U Magor 1 C Proposed or dratt 2 C Pend,ng 2 U Nanr u;nr 2 0 rrs , venm f u ~tn poc.pmpo,ai 3 0 trnercency 3 C hr a or intenm final. w t$out poor prope,al a C Statutory or not.a; deadsne 9 Cf 4 section attected
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10 D:es this reruutien cute wpu tr g o' recuenpm;; requeements that requee CMD approval uncer the Paperwork Reduction 4t and 5 CF R 1220' O v es [ No
- 11. I's rnajo' rute, is there a regu?ato3 noact anaWs attached' 1 C Yes 2 C No if Naf did OMB na4e the a".a%is' 3 0 ves a O rac Certification for Regulatory Submissions in subm:ttmg this request for OVB rev'ew. the autnoolea r" date3 contact and the pme'am official certif y that the requirements of E O 12291 and ar$y apphcable ponty drectm %e been comphed w th hgrature o* propam o$c;at DMe Sr;ature of ajnoofec rq ia*.yy wtact f~ ~~
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. . j SUPPORTING STATEMENT FOR 10 CFR PART 61 !
LICENSING REQUIREMENTS FOR LAND DISPOSAL 0F RADI0 ACTIVE WASTE i
Justification Need for and Practical Utility of the Information Collection NRC regulations in '10 CFR Part 61 establish, for land disposal of radioactive l waste, the procedures, criteria, and terms and conditions upon which the !
Commission issues licenses for the disposal of low-level radioactive wastes j containing byproduct, source, and special nuclear material received from other <
persons. The regulations are issued pursuant to the Atomic Energy Act of 1954, as amended, and litle II of the Energy Reorganization Act of 1974, as amended.
In order to obtain a license under Part 61, an applicant must submit general, -
technical, institutional, and financial information. Such information is l needed to permit the Commission to determine that the proposed activities can be conducted safely and that they will not be inimical to the common tiefense and security and will not constitute an unreasonable risk to the public health and safety or the environment.
The information included in the applications, reports and records is reviewed by the NRC staff to ensure the provision cf an adequate level of protection of public health and safety, common defense and security, and the environmer.t. ,
Information concerning the requirements im)osed by specific sections is !
provided below. 1 Section 61.3(b) requires that an application be filed and license be obtained before commencement of construction of a land disposal facility. )
The information submitted in the application pursuant to this section and other sections described below is reviewed by various NRC organizational units to assess the adequacy of the applicant's physical plant, equipment, organization, training, experience, procedures and plans for protection of the public health ,
and safety, common defense and security, and the environment. The NRC review and the findings derived therefrom form the basis for NRC decisions concerning the issuance, modification, or revocation of licenser for land disoosal of radioactive waste.
Section 61.6 provides that the Commission may grant exemptions from the requirements of Part 61 under specified conditions, upon the application of any interested person or on its own initiative.
Applications under this section are examined by the NRC staff to determine whether the requested exemption is authorized by law and whether it will not 1
2 endanger life or property or the common defense and security, and to determine )
j if it is otherwise in the public interest.
i Section 61.9a(b) requires that an applicant or licensee notify the Commission of information which the licensee recognizes as having significant implications for the public health and safety or the common defense and security. This requirement applies only to information which is not covered by other reporting or updating requirements. The information must be provided within two working i days.
This requirement is necessary because there may be some circumstances in which a licensee possesses some information which could be important to the protection of p9blic health and safety or the common defense and security but which is not otherwise required to be reported. The codification of this full disclosure requirement should not result in significant additional burdens on '
applicants or licensees. No formal program is required. What is expected is that licensees will maintain a professional attitude toward safety and that if some potential safety information is identified by the licensee, the infor-mation will be provided freely and promptly to the NRC so that the agency can evaluate it and act on it if necessary.
Section 61.10 requires that an application contain information as set forth in Sections 61.11 through 61.16 and indicates that an environmental report in I l
accordance with 10 CFR Part 51 must also accompany the application.
Section 61.11 outlines general information needed to clearly identify the applicant, to describe the applicant's r, qualifications, and to provide an overview of the 'ooject. This information is used to determine who is the legally appropriate licensee, that thr. applicant can safely conduct the proposed activities, and to understard the scope of the proposed activities.
Section 61.12 specifies the information required to be submitted concerning the disposal site, including: (a) natural and demographic site characteristics; (b) design features of the land disposal facility and the disposal units; (c) principal design criteria and their relationship to the performance objectives; (d) design basis natural events or phenomena and their relationship to the principal design criteria; (e) codes and standards applied to the design and which will apply to construction of the facilities; (f) construction and operation of the facility; (9) site closure plan, (h) natural resources at the site that could attract exploitation; (i) radioactive material to be disposed ;
of; (j) quslity control program for design, construction, uperation and 1 closure; (k) radiation safety program for contrci and monitoring of radioactive effluents; (1) environmental monitoring program and plan for corrective measures; and (m) administrative procedures to be applied to control activities at the land disposal f acility. This information is needed to permit NRC to determine that the performance objectives of Subpart C of Part 61 and the technical requirements of Subpart D will be met.
Section 61.13 specifies additional technical analyses that must be submitted, including: (a) protection of the general public from releases of radio &ctive material by various pathways; (b) protection of individuals from inadvertent intrusion; (c) protection of individuals during operations; and (d) natural processes, such as erosion, settlement of wastes, and drainage, that affect the
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need for ongoing active maintenance after closure, This'information is also required to permit a determination that the performance objectives of Subpart C will be met.
Section 61.14 specifies the inform 6 tion required to be provided by the site land owner or potential land owner to enable the Commission to determine that
' adequate institutional ' arrangements have been made for long-term care of the disposal site.
Section 61.15 requires the submission of financial information sufficient to demonstrate that the~ financial qualifications of the applicant are adequate to carry out the activities for which the license is sought and meet other financial assurance requirements at specified in Subpart E. This information is needed for NRC to determine that there will be sufficient funds to safely carry out disposal and long-term care.
Section 61.16 specifies information concerning safeguards and safety, including criticality, that may be required with regard to special nuclear material.
This section primarily reflects existing requirements in other parts of the Commission's regulations concerning special nuclear material, and is needed since Part 70 licenses will no longer be issued to waste disposal licensees.
The information is reviewed by the NRC licensing staff to assure safety, security, and accountability' of special nuclear material.
Section 61.20 requires applicants to file three copies of tne appilcation and retain 85 copies for distribution in accordance with instructions from NRC.
The additional copies are required to be provided for review by affected State and local governments, indian tribes, other Federal agencies, and other persons or entities affected by or involved in the determination on _the application.
Section bl.22(b) requires that the applicant supplement or update the application as necessary prior to issuance of a license. This requirement is needed to ensure that the Commission receives information concerning any changes in the acti'tities proposed to be carried out or new information regarding the proposed activities.
Section 61.24(bj provides that NRC may require further statements af ter the filing of the application and before expiration of the license to enable NRC to determine whether the application should be granted or denied or whether a license should be modified or revoked. Such additional information is sometimes needed to clarify information submitted in the application, or to rectify deficiencies in proposed or existing programs for protection of the public health and safety, the common defense and security, or the environment.
The additional information submitted is reviewed by variour. NRC organizational units to assess the adequacy of the applicant's physical plant, procedures and plans for protection of the public health and safety, common defense and security, and the environment. The NRC review and the findings therefrom form the basis for NRC decisions concerning the issuance, modification, or revocation of licenses.
Section 61.24(k) requires that a licensee immediately notify the appropriate NRC Regional Administrator, in writing, following the filing of a bankruptcy
. 4 petition by or against.the licensee or a controlling or affiliate entity. No action is required of a licensee unless and until c petition for bankruptcy is filed.
This information is needed because a licensee who is experiencing severe I economic hardship may not be capable of carrying out licensed activities'in' a manner which protects public health and safety. In particular, a licensee l involved in bankruptcy proceedings can have problems affecting payment for I
proper handling of radioactive material and for decontamination and-decommissioning of the licensed facility in a safe manner. Improper materials handling or decontamination activities can lead to spread of contamination-throughout a licensee's facility and the potential fcr dispersion of contaminated material offsite. Financial. difficulties can also result in problems affecting the licensee's waste disposal activities.
The information provided by the notification would be used by the staff to initiate a determination of the need for prompt NRC response or regulatory-action in the event of'a potential hazard to public health and safety posed by a licensee that does not have the resources to properly secure licensed material or clean cp possible contamination. In addition, prompt notification would allow the Commission to take timely and appropriate action in a l t'ankruptcy proceeding to seek to have available assets of the licensee applied to cover costs of cleanup before funds are disbursed and become unavailable for' cleanup.
Section 61.26 requires that an application- for an amendment of a license must be filed in accordance with Section 61.20 and must fully describe the changes desired. This information is reviewed by the NRC licensing staff to ensure that the desired amendments will afford an adequate level of protection of the public health and safety, the common defense and security, and the environment.
_Section 61.27 requires that an application for renewal or site closure must be' filed in accorduce with Sections 61.10 through 61.16, 61.20,'and 61.28.
Section 61.28 specifies the inf>rmation required in an application for site closure following disposal operttions. The information will be reviewed by the NRC staff to determine whether, w the case of a renewal, the requirements for a new license are met, and for site closure, whether there is reasonable assurance that the long-term performance objectives of Subpart C of Part 61 will be met.
Section 61.30 specifies that the licensee may apply for an amendment to transfer the license to the site owner. The application will be reviewed by the NRC staff in order to make necessary findings to ensure that the license for the site can be safely transferred from the site operator to the site owner. The site owner provides licensed institutional control and care of the site for up to 100 years.
Section 01.31 specifies that, following the period of institutional control, the licensee may apply for an amendment to terminate the license. The application will be reviewed by the NRC licensing staff in order to make necessary findings that institutional control requirements have been met, that any additional requirements resulting from new information developed during the
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5 institutional control period have been met, and that permanent monuments or markers warning against intrusion have been installed.
Section 61.53 requires the licensee to provide and maintain a basic environ-mental monitoring system prior to license submittal, during construction and operation, and after the site is closed. The information is needed for the-Commission to evaluate site characteristics prior.to' licensing and then to
- provide an early warning if radioactive releases are occurring in quantities or in a. manner not anticipated in licensing the site.
Section 61.55(a)(2)(iv) specifies that a licensee may submit a proposal,for disposal, pursuant to Section 61.58, of waste greater than Class C. .This requirement is needed to allow licensees the flexibility of safely disposing.of waste that does not fit into existing categories. The information submitted will be reviewed by the licensing staff to determine whether the proposal as to.
waste form and disposal method will provide an adequate level of protection ~of the public health and safety and the environment.
Responsibility for disposal of greater than Class C waste was transferred to the Federal government under the Low Level Radioactive Waste Policy. Amendments Act of 1985. Therefore, no burden is expected to be incurred under this section.
Section 61.57 requires that each package of waste accepted by the-licensee must be clearly labeled by the shipper to identify whether it is Class A waste, Class B waste, or Class C waste in order to help insure proper disposal.
Section 61.58 provides that the Commission may, upon request or on its own initiative, authorize other-provisions for the classification and characteristics of waste. Requests under this section are examined by the staff to determine whether, after evaluation of the specific characteristics of the waste, disposal site, and method of disposal, there is reasonable assurance of compliance with the performance objectives of Subpart C.
Section 61.61 requires each applicant to show that its financial position is such that the estimated costs of conducting all licensed activities can be met.
This is needed to help ensure that the facility will be constructed, operated, and closed according to the license.
Section 61.62 requires the applicant to provide assurance that sufficient funds, including sureties, will be available to carry out orderly disposal site closure and stabilization. This information will be reviewed by the NRC staff to ensure that sufficient funds are available for completion of the closure plan, including contingencies to assure adequate closure in the event of licensee financial problems or early closure.
! Section 61.63 requires the applicant to provide a copy of a binding arrangement
! between the applicant and the disposal site owner that ensures that sufficient I funds will be available to cover the costs of monitoring and any required maintenance during the institutional control period. This is necessary to assure that sufficient funds are available for post-closure activities.
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I Section 61.72 allows a State or tribal governing body whose interest is affected by a near-surface disposal facility to submit a formal proposal for..
participation in the review of a license application. This information is j
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necessary in order to provide a State or tribal body greater input during the licensing process.
Section 61.80 specifies requirements.for maintaining records and filing reports. Subsection (a) requires licensees to maintain records and make .)
reports that may be required by the conditions of the licerse or by the rules, I regulations and orders of the Commission. Records and reports provide-a primary basis for determination that licensees receive, possess, transfer,'and dispose of material as authorized in the license and in accordance with the regulations and orders of the Commission. This requirement provides additional j regulatory support for those conditions and provisions and serves to remind ,
licensees that they must comply not only with Part 61 but with other Commission regulations and with specific license conditions. The burden associated with those other r. requirements is accounted for in the clearances for those regulations. Subsection (b) requires licensees to maintain records.that are required by the regulations or license conditions for the period specified in the regulation or license condition. If a retention period is not otherwise; specified, those records must be maintained for the duration of the license and transferred to the officials specified in Section 61.80(e) upon termination unless the Commission otherwise authorizes their disposition. Subsection (c) j authorizes the licensee to use repro'duced copies or microfilm for record-keeping. Subsection (d) provides that in the event there is a conflict between the regulations, license conditions, or other written approval or authorization pertaining to the retention period for a record, the longest retention period specified. takes precedence. Subsection (e) provides-that specified data on disposal of wastes at the site must be transferred on license termination to a ;
specified local, state, or Federal government official. 1 i
The records, record transfers, and record maintenance requirements in ;
Subsections (a)-(e) are needed to provide information to the Commission and j other responsible agencies for use in determining that activities are being I conducted safely and in accordance with license requirements and other applicable requirements such as leases or local ordinances. .The information is ;
needed to evaluate environmental monitoring data and deal with contingencies. :
Data on the wastes would be essential in planning and conductinq remedial actions at the sites should they be necessary. !
Subsection (f) requires that the licensee keep records on the waste received 1 for disposal, including date received, location in the disposal site,- condition 1 of the waste package as received, any discrepancies between the manifest and ,
the waste actually received, and any evidence of leaking or damaged packages or !
radiation or contamination levels in excess of regulatory limits. The licensee ,
must also describe any repackaging operations and provide any other information !
that may be required by license condition. This information will be used to ,
help generate inventory data and data on the condition of the waste for -i estimating source term. and identifying problem shippers who need to improve their programs for preparing waste for shipment. The data will be used by the operators to evaluate waste handling procedures to be sure the procedures are !
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7 adequate to protect workers handling waste in the condition in which it actually arrives, not just as it is expected to arrive.
Subsections (g) and (j) provide that the licensee must comply with specified safeguards reporting requirements contained in Parts 30, 50, and 70 of the Commission's regulations. Information submitted pursr- to these requirements is needed for the NRC to carry out its statutory responsibility to protect the common defense and security and to permit NRC to take any necessary action in response to a criticality accident or loss or theft of nuclear material.
Subsection (h) requires an annual financial report. The stability and financial soundness of disposal site operators is important to prevent abandonment of the sites or inability to carry out disposal in accordance with approved procedures because of shortage of funds. The financial information will be reviewed by the NRC staff for early warning of the possible development of such problems.
Subsection (i) requires an original and two copies of an annual report on site activities. The information to be reported includes summaries of environmental releases, environmental monitoring data, waste disposed of, maintenance activities, and new data on the site, if any. Such summary data is needed to help the Commission monitor the continuing validity of the initial findings on which the license was issued.
Subsection (k) provides that the licensee must comply with specified provisions of Parts 30, 40, and 70 for any transfer by the licensee of byproduct, source, nr special nuclear material.
Reduction of Burden Through Information Technology The regulations provide flexibility for the use of improved information technology in information collection and recordkeeping. The approach throughout Part 61 was to specify the necessary information but not to specify ;
how the information must be maintained. For example, no application form is j specified and Section 61.80(c) explicitly allows the use of microfilm for l recordkeeping.
Efforts to Identify Duplication I The Information Requirements Control Automated System (IRCAS) was searched to determine duplication. No duplication was found. )
Use of Similar Information Section 61.21 specifically provides an opportunity for the applicant to avoid repetition in filing licensing submittals: ,
I "61.21 Elimination of repetition.
In its application, the applicant may incorporate by reference information contained in previous applications, statements, or reports filed with the Commission if these references are clear and specific."
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Effort to Reduce Small Business Burden Applicants for operation of a disposal site.may be small businesses. However, since'the total number of applicants is expected to be small~and the information needs are the same'for both_large and small entities, it is not possible to reduce the burden on small businesses by less frequent or less complete" reporting or recordkeeping procedures.
Consequences of Less Frequent Collection Less frequent information collection would compromise.NRC ability to make licensing decisions and monitor the continuing safety of disposal operations.
Applications are required only when a licensing action is required. Reports-are required annually on financial status and site operations. Less frequent reports would not give early warning of potential problems.
Circumstances Which Justify Variation from OMB Guidelines Section 61.20 conforms to OMB quidelines in requiring only three copies of the application, but' varies from the guidelines in requiring that 85 copies be retained by the applicant for distribution in accordance with instructions from NRC. The additional. copies are required to be provided for review by affected State and local governments, indian tribes, other Federal agencies, and other-persons or entities affected by or involved in the determination on the application.
Consultations Outside NRC Development of Part 61 involved extensive public input. Two commercial firms operate the three active disposal sites: Chem-Nuclear Systems, Inc. and US Ecology, Inc. Formal and informal comments by these companies were considered.
States were actively involved. (States are likely to be the long-term care licensee). The host states for the operating sites are South Carolina, Washington, and Nevada. Both companies and the three states submitted formal comments on Part 61 when it was proposed.
Confidentiality of Information None, except for proprietary information.
Sensitive Questions None.
9 Estimate of Compliance Burden Reporting Requirements No. of Annual Total. Licensee Total Annual No.-of Responses per Annual. Staff Hours Licensee Section Respondents Respondent __ Responses Per Submittal . Burden (Hrs)-
61.3(b)) 2 0.33 0.66 18,000 12,000 61.6 1 0 0 2 0 61.9a(b)- 1 0 0 1 0 61.10 - Included in 61.3(b) above or in 10 CFR Part 51,-0MB.No. 3150-0021.
61.11 - Included in 61.3(b) abovec 61.12 - Included in 61.3(b) above.
61.13 - Included in 61.3(b) above.
61.14 - Included in 61.3(b) above.
61.15 - Included in 61.'3(b) above.
61.16 - Included in 61.3(b) above or in OMB Clearances 3150-0009 or 3150-0002.
61.20 - Included in 61.3(b) above.
61.22(b) 2 - Included in 61.3(b) above.
61.24(b) 2 - Included in 61.3(b) above.-
61.24(k) 2 0 0 0.5 0 61.26 No burden anticipated for period of this clearance.
61.27 2 0.33 0.66 2,500 1,650 61.28 - Included in 61.27 above.
61.30 - Included in 61.27 above.
61.31 No burden' anticipated for period of this clearance.
61.53 2 12 24 80 1,920
'10 Estimate of Compliance Burden Reporting Requirements (cont'd).
.No. of Annual. Total Licensee Total-Annual No.-of ..
Responses per Annual Staff Hours Licensee:
Section Respondents Respondent Responses Per Submittal Burden-(Hrs]-
61.55(a)(2)(iv) None 61.57 2- 36 72- 2.0 144 61.61 - Included in 61.3(b) above.
61.62. - Included in 61.3(b) above.
61.63- --Included in 61.27.above.
61.12 - Included in 61.3(b) above.
61.80(g),(j) - Included'in OMB Clearances 3150-0017,.
3150-0020,,and 3150-0009 61.80(h) 0 0 0 200 0 61.80(i) 1 1 1 400 400 Total 98.32 4-16,114..
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1 Recordkeeping Requirements Total Record No. of Annual Hrs per Recordkeeping ' Retention Recordkeepers Recordkeeper Hours Period 61.80(a)-(f) 2 2,080 .4,160 Duration of License 61.80(k) - Included in OMB Clearances 3150-0017, 3150-0020,'and 3150-0009 Total Recordkeepers.- 2 ' Total 4,160. :
Recordkeeping Hours- j d
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TOTAL LICENSEE BURDEN HOURS - 20,274
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l Estimated Annual Cost to Respondents The total estimated annual cost to respondents'to respond to the collection is j
$1,216,440 ($60/hr X 20,274 hrs). -l
'The burden and cost estimates are based on NRC staff analyses.' Costs are-estimated based on a $60 hourly rate.
Estimated Annual Cost to the Federal Government The estimated annual cost to the government for; years 1 - 10"is $443,040.-The.. 1 estimated annual cost- to the government for years :11.'- 30 is. $285,840.
Reasons for Changes in Estimated Burden The changes in estimated burden reflect several. factors, including numbers of l potential applicants, inclusion of burdens from pre-Part 61 sites, and'a better. understanding of the nature'and levels of effort required. No applications for new sites were filed in the previous clearance period, i although one was estimated. Two'are now projected for the renewal-period. 'l The level- of effort anticipated to prepare an application is n'ow believed' to {
be about double previous estimates (i.e. , six staff years or-about 18,000 '
licensee staff hours). This increase is due to better staff understanding of '
the information needed to. demonstrate compliance with the rule and reflects additional interactions with States and others involved in developing new sites. In view of the increase and level of uncertainty in this estimate for 61.3(b), several separate estimates of effort (e.g., for 61.22(b)) have been
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dropped. Pre'Part 61 sites were grandfathered under Part 61, but one renewal and one closure action for the two'NRC special nuclear material lonly licenses ,
will be done under 61.27 during the renewal period. This' burden is-now .
included. Other operational provisions have-also been imposed at one'or both' tites through license conditions and are included. The estimate for 61.57 '
reflects the level of effort at the two pre-Part 61 sites and has been significantly reduced to be more realistic and reflect incremental burden only. No change to 61.57 is involved. The current' estimate recognizes that l recording or recordkeeping concerning labeling.of packages by the waste. site !
operator is required only if there is noncompliance with other requirements by .!
the shipper. Correctly labeled packages produce no incremental burden and I merely facilitate handling. i
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