ML20245C104

Request for OMB Review & Supporting Statement Re 10CFR50, Domestic Licensing of Production & Utilization Facilities. Estimated Respondent Burden Is 2,594,433 H

ML20245C104
Person / Time
Issue date:	06/25/1987
From:	Mcdonald W NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:
References
OMB-3150-0011, OMB-3150-11, NUDOCS 8707010627
Download: ML20245C104 (11)

Text

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l S"ea,u,m 8 3 Request for OMB Review rfew secte%e,1953:

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Import:nt Read instructons before completmg form Do not use the same SF 83 Send three copies of this form, the material to be reviewed, and for l

to request both an Esecutive Order 12291 review and approval under paperwork-three copies of the supporting statement, to:

the Paperwork Reductiori 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 certification. If this Office of Management and Budget request is for aDproval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 3201 1320, sep Part II, complete Part lli and s:gri the paperwork certification.

Washington, DC 20503 F ART !.-Complete This Part for All Requests.

1. Depa'tmentragency and bureau ottice orpnatig, request

2. Agency coce U.S. Nuclear Regulatory Commission 3 1 5

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3. Name of person who Can best answer q.>estions repromg trns request Telephont umber Gilbert C. Millman (301 )443-7713

4. Title of intorrnawn countion or ruiema6 m,

e 10 CFR 50, Domestic Licensing of Production and Utilization Facilities

5. Lega achorq iv Mormation cow:tice, or ne tme u Jea Hees Coce. fw c Las. or becutne Orcer) l 42 2201(o) usc

6. A"&ted pute, ic hec

• ah MM apply) 5 C Federa' agencies or empmyees 1 U Ind vides or householas 3 C Farms 6 C Nor. prof <t institut.ons 2 U State orla s pon e me"<

4 1 Eus resses or other forf rof t 7 0 5"el bosmesses y ovanizatrom PART li.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291 I

7. Pego:atron idenM er N prte-(DIN)

-~ _ _ _. or. NYe ass.gr;ed

~8 Type of suon tss nn rc~ec+ c~e m eam crepn i Type of review requested Classification Stage of dewopmeert

O Stancard 1 L Major

! L.J Proposed or dra't 2 C Pend;ng 2 [ Nor:ma.or 2 C Fu W or intenm f.ra,. witn p'ar proposa:

3 Emergency 3 U Fma or m?enm f na'. w;thou' poor proposa!

4 Statutory or judicial deadhne ECIR section af f ected CTR

10. Dou tm re W e mia r MM>'tme rn recem rea v,ents tre rNJJre OtJB opproval under the Paperwork Reduction Act e

end E CTP ;'20' U Yes C No

11. If a rra,or rye ts t' Tere a regalato*y impact ana'ys s atta2 ed 1

Yes 2 C No 11 'No " de DVD wewe the ena'ys's' 3 0 Yes 4 C No Certification for Regulatory Submissions m Lbm!ttmg tNs it quest f or Of/B review. tne aJt"o'Oed regmatorrcontact a,e the p ngram offoal certN that the recu-ements of E O 12291 and any apptcab*

pohcy caettives ha,e bet n C tmp'!ed etn Epatu e of p'oi"am cffca' Date

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r QaNee c' a;t'oravec rqu;sta cortam.

i Date l

l 12 toMf.' use only)

P., won ea w sa m es 83 106 standard Form 83 thw 9 63:

mw ma m m.:;34 ereuruc t, ores 87070.10627 B70625 5 " 132U *""

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PDR ORG EUSOMB l

PDR

l l PART lil.-Ccmplete This Part Only if the Requist is for Approval of a Celizction of Information Under the Paperwork Reduction Act and 5 Ci'R 13,20.

13. A~ teact-Desende needs, uses and affected pubiic in 50 words or less "Nucl ea r facil i ty safe ty" Yhe proposed rule updates existing references to specific sections of the ASME Boiler and Pressure Code that set forth requirements by which nuclear power plant components are constructed and inspected.

These requirements provide that plant owners maintain records of certain safety related activities.

14. Type of information co4ection (che CA only one)

Information collections not contained in rules 1

Regular submission 2 C Emergency submission (certifecation attached)

Informstlon cohections contained in rules 3 0 bisting regulation (no change proposed) 6 Final or intenm final wrthout pnor NPRM

7. Enter date of expected or actual Federal 4 b Notice of proposed rulemakmg(NPRM)

A C Regular Submission Regirter publication at this stage of rulemaking 5

Final. N?RM was previously pubhshed B

Emergency :ubmission (ce tt6 cation attached)

(month. day. year): 6/26/87

15. Type of review requested (check only one) i C New col lection 4 O Reinstatement of a previousiv approved coii ction for wnien cpp,ovai 2 b Revision of a currently approved collection has expired 3 C btenson of the expiration date of a currently approved co3ection 5 O Existing coiiection in use without an oMB controi number without agchange in the substance or in the method of collection

16. Agency report form numberts)(incIvae standard /opticna! form number (s))

22. Purpose of intormation collection (check as many as apply)

NRC 366 1

Ap@ cation for benehts 2 C Program evaluaticn

17. Annuct report ng or 0 sclosure turden 3 C General p/rpose stattstics n

1 Nurnber of respondents.

41 Regu:atory or comphance 2 Number of re:.po"ses pe* respondent.

5 C Program planningor management E'

6 C Researen 3 Tcta! annual responso (hne 1 times ime 2) 1*

7 C Audi 4 Hours per respnnse 5 Total hours (lme 3 times ime 4) d*M[N

18. Annual recordheemng burden

23. Frequency of recordkeeping or reporting (checA allthat apply) i 202 1 Numbo' of recorbeepers 1 % FecoWeeping I

Reporting 2 Annuu! bc rs pe' retc@eeper.

' Ib 2 b onoccasion 3 Total recorskeepng hours (hnc J f rmes ime 2) 4 Recordkeeprg retention pened L'Ife years 3 0 weeki,

19. Tota! annual burde..

4 O Monthly 3*928*649 5 0 Quarterly 1 R3 quested (kne 17 5 plus lune 18 3)

KbbO'b49 6 0 wro -annuany 2 in cur ent OMB mventory U

3 Difference (!me 1/ css /Ine 2) 7 C Annuany Explanation of dofference 6 D BienniaUy 4 Wogram charge 9 0 otnercdesenbe):

5 Adiustment.

24. Respondents' obhgebon to uGmpl (check the strongest obhgttlon that applies)

20. Current (most recent) oMB rontro! numbe or corrment number e

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3150-0011 1 C voiuntary 2L Requested e

2 U Reauced to obtain or retain a benefit 3 0 Mandatory

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25. Are the respondents onman!y educt 9anat agencies or institutiss o is the pnma y purpose of tt.e conection related to Federaleducation prcgrams? O Yes $ No

26. Doesit;e agency use srrphng to setect responcents or does the agency rectmmend or prescrie tne use of samphng or statistical analysis by f esponcents?

. O ves @ No 2 7. Regulatory thonty f or the information cohection 60.55a CFR rR

.o,,other(spec,rg _

Paperwcrk Certihcation in sut/nitting t*ns recuest for oMB app

• oval, the agency head. the sentor official or an aut*ionzed represertative, certifes that the requirements of 5 CFR 1320. the Prray Act. statistica: Standards o' directtves. and any other appbcable iriformation poScy d: rect:ves have been ton phed with.

bgnature of prugram of ticial i Date s

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Date

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5.g,ne of at,eng neac the sentor c%at or en authona y&

William G. Mcdonald, Director I

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Office of Administration and Resources Manaaement j L 6/7 flM i

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i Supporting Statement for Information Collection Requirements in 10 CFR 950.55a A.

JUSTIFICATION 1.

Need for the Collection of Information NRC Regulations in 10 CFR 950.55a incorporate by reference Division 1 rules of Section III, " Rules for Construction of Nuclear Power Plant Components," and Division I rules of Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Ccmponents," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). These sections of the ASME Code set forth the requirements to which nuclear power plant ccmponents are designed, constructed, tested and inspec-ted.

Inherent in these requirements are certain recordkeeping functions. The information is generally not collected, but is retained by the licensee to be made available to the NRC in the event of an NRC audit.

i Incorporation of the Winter 1984 Addenda, Sunner 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Section III, Division 1, of the ASME Code adds the following recordkeeping requirements.

Section III

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o Winter 1984 Addenda 1

NCA-8213(c); Attachment of Nameplates - Nameplates attached with pressure sensitive acrylic adhesive system must meet requirements of mandatory Appendix XXI, " Adhesive Attachment of Nameplates," which states that Certificate Holders QA manuals contain written procedures for the application of nameplates.

NB/NC/ND-7141; Installation of Pressure Relief Devices -

Technfcal justification for the adequacy of the installation of such devices must be provided in the Over-pressure Protection Report.

o Summer 1985 Addenda NE-4622.11; Temper Bead Weld Repair to Dissimilar Metal E lds or Buttering - Requires preparation 0 W elding i

procedure specification.

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Winter 1985 Addenda j

l NCA-8440; Data Reports, Component Sup3 orts - New provisions require the use of NF-1 and N-5 Data Report Forms.

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NC-3812/NC-3912; Design keport - Certificate Holder must provide Design Rep 9rt as paifof his responsibility for i

achieving structural integrity of atmosoheric storage tanks l

(NC-3812) and 0 - 15 psi storage tanks (NC-3912).

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o Winter 1984 Addenda No additional recordkeeping.

NC/ND-775C; Capacity Certification of Vacuum Relief Valves-Requirement that drawings and test results are to be submitted to the ASME designee for review and acceptance.

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1986 Edition The Sunber IS83 Addenda, Winter 1983 Addenda, Sumer 1984 Addenaa, ano 1983 Edition have been incorporated by reference intt; 10 CFR 550.55a Ly a previous amandment.

Information coliaction requirements for the Winter 1984 Addenda, Sumer 1965 Addenda, and Winter 1985 Addenda are discussed above.

Incorporation of the Winter 1983 Addenda, Sumer 1984 Addenda, Winter 1904 Addenda, Summer 1985 Addenda, Winter 1985 l

Addenda, and 1996 Edition for Section XI, Division 1, of the

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ASME Code adds the following recordkeeping requirements.

Section XI o

Winter 1983 A6denda IWA-2420; Inspection Plans and Schedules - Requires i

preparation of preservice and inservice inspection plans i

and schedules.

IWA-4210; Storage and Handling of Welding Material -

l Requires written procedure for storage, handling, and control of welding material.

IWA-6210(a)/(c); Owner's Responsibility - Requires i

preparation of preservice inspection plans and schedules,

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records, and summary report for Class 1 and 2 pressure retaining components and their suppcrts.

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IWA-6340(b)/(c); Inservice Inspection Records and Reports -

Requires maintenance of preservice inspe:: tion plans, schedules, and reports.

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Appendix VI (Mandatory); Ultrason!c Examination of Bolts and Studs - Requires records of the personnel performance qualification tests, written procedures for ultrasonic o

examination, documentation of the procedure qualification,

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calibration records, and examination records.

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Summer 1984 Addenda

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No additional recordkeeping.

IThe 1986 Edition of Section III, Division 1, is equivalent to the 1983 Edition, as modified by the Sumer 1983 Addenda, Winter 1983 Addenda, i

Summer 1984 Addenda, Winter 1984-Addenda, Sumer 1985 Addenda, and the Winter 1985 Addenda.

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o Summer 1985 Addende No additional recordkeeping.

o Winter 1985 Addenda IWA-2232(f); Ultrasonic Examination - Indications that can be identified as originating from surface configurations or variations in metallurgical structure of materials may be classified as geometric indications. The maximum amplitude, location, and extent of a geometric indication shall be recorded, 2

o 1986 Edition 1

The Summer 1983 Addenda and 1983 Edition have been incorporated by reference into 10 CFR 950.55a by a previous 1

amendment.

Information collection requirements for the Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, and Winter 1985 Addenda are discussed above.

2.

Ajency Use of Information These records are used by the licensees, National Board j

inspectors, insurance companies, and the NRC in the review of a variety of activities, many of which affect safety. The records are generally historical in nature and provide data on which future activities can be bated. hRC inspection and enforcement personnel can spot check the records required by the ASME Code to determine, for exaaple, if proper inservice examination test methods were utilized.

3.

Reduction of Burden Though Information Technology The information being collectec' represents the docuinentation for the various plant specific inservice inspection programs. The i

NRC has no objection to the use of new information technologies i

and generally encourages their use.

4.

Effort to Identify Duplication f

ASME requirements are incorporated to avoid the need for writing equivalent NRC requirements. This amendment will not duplicate 1

the information collection requirements contained in any other

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generic regulatory requirement.

j 2The 1986 Edition of Section XI, Division 1, is equivalent to the 1983 Edition, as modified by the Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, and the Winter 1985 Addenda.

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Effort to Use Similar Information The NRC is using the information reporting requirements specified in the ASME Code in lieu of developing its own equivalent requirements.

6.

Effort to Reduce Small Business Burden v

This amendment to 550.55a affects only the licensing and

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operation of nuclear power plants. The companies that own these plants do not fall wihtin the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act in the Small Business Size Standards set out in regulations d

issued by the Small Business Administration at 13 CFR Part 121. Since these companies are dominant in tneir service areas, the proposed a:nendment does not fall in the province of this Att.

The proposed rule will have no sionificant effect on a substantial number of small companies.

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Consequences of Less Frequent Collection y

d The information is generally not collected, but is retained by j

the licensee to be made available to the NRC in the event of ll an NRC audit.

8.

Circumstances Which Justify Variation from OMB Guidelines 1

There is no variance from OMB guidelines.

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Consultations Outside the NRC q

There are no consultations outside the NRC.

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10.

Confidentiality of Information hj NRC provides no pledge of confidentiality for this collection of information.

11.

Justification for Sensitive Questions No sensitive questinns are involved.

Information collected is simply a documentstion of inservice inspection examinations.

12.

Estimated Annualized Cost to the Federal Government NRC inspection personnel who audit plant quality assurance records would include in their audit verification that the c

above records are wing properly prepared and maintained. The f

time associated with WPC inspectors verifying these records L

would be extremely small when the activity is performed as part

";i of a normal quality assurance audit.

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Estimate of' Burden a.

Number and Type of Respondents In general, the infcrmation collection requirements incurred by 650.55a through endorsement of the ASME Code apply to the owners of the 18 nuclear power plants under construction and to the owners' of the 107 nuclear power plants.in operation. _The a::tual number of plants that would implement the edition and addenda-addressed by thc proposed reviision, and thereby be affecteo by the information collection requiraments, is. dependent on a.

variety of' factors. These factors' include whether the applica-tion is for Section III or Section XI, the class and type i

of components involved, the date.of the construction permit application, the schedule of the inservice inspection program, and whether the plant voluntarily elects to implement updated editions and addenda of the.ASME Code, b.

Estimated Hours 1

The information collection requirements inherent in incorporat-1 I

ing by reference the latest edition and addenda of Section' III, Division 1, and Section XI, Division 1, of the ASME Code-are identified in Item 1.a above. These requirements may-be categorized in terms of Section III requirements that document component design, and Section XI requirements that address ultrasonic examinations and preservice inspection-l programs.

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The additional Section III requirements incur a one-time buroen on plants under construction.

Section 50.55a specifies that the Code Edition, Addenda, and optional Code Cases to te applied to reactor coolant pressure boundary, and Quality Group i

B and Quality Group C components must be determined by the i

provisions of paragraph NCA-1140 of Subsection NCA of Section

'i III of the ASME Code. NCA-1140 specifies that the owner (or his designee) shall establish the ASME Code edition and addenda to be included in the Design Specificatfons, but that in no i

case shall the Code editinn and addenda dates established in the Design Specifica-tions be earlier than three years prior to the date that the nuclear power plant c0nstruction permit is l

docketed. NCA-1140 further states that later ASME' Code edi-t tions and addenda may be used by mutual consent of the_ Owner _

(or his designee) and Certificate Holder. The earliest Section III addenda being addressed in the proposed rule is the Winter i

1984 Addenda, Since'the last plant docketed in October 1974 (Palo Verde Units 1, 2, 3), there is no plant under construc-tion for which imolementation of the Section III edition and addenda specified'in the. proposed rule is' a requirement.

Plants may implement these improved reles on a voluntary basis, but unless they make that choice, there is no additional paperwork burden associated with incorporating the proposed Section III edition and addenda.

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The additional Section XI requirements incur an information collection burden associated with the documentation of procedures for the storage, handling, and control of welding material; the documentation of preservice inspecticn plans and i

schedules; and the implementation of the ultrasonic examination of bolts and studs.

Nuclear power plants are required to update their inservice inspection programs by incorporating into their initial 120-month inspection interval requirements of the latest edition and addenda of Section XI, Division 1, that have been incorpo-rated by reference into 550.55a as of 12 months prior to the date of issuance of the operating license; and by incorporating into successive 120-month inspection intervals re-quirements of the latest edition and addenda of Section XI that have been incorporated by reference as of 12 months prior to the start of a 120-month inspection interval.

On this basis, many plants will at one time be required to implement the l

Section XI, Division 1, edition and addenda specified in the proposed rule. The number of plants that will be implementing the specified edition and addenda will grow gradually as each plant updates its inservice inspection program at the 10-year interval. Therefore, conservatively, the total number of plants that may ultimately be required to implement the specified edition and addenda is 125 (i.e.,107 operating plants and 18 plants under construction).

Paragraph IWA-2420 was revised in the Winter 1983 Addenda to require the preparation of preservice and inservice inspection plans, to specify the content of those plans, and to require an implementation schedule for the performance of examination and tests.

Inservice inspection plans and schedules, including those for preservice inspection are routinely submitted to the NRC as part of the regulatory process. The types of items specified for inclusion in the plan (e.g., applicable Code edition and addenda, identification of components subject to examination and test, and Code requirements for each specified component) are typically included in the plans submitted to the NRC. Therefore, there is no additional recordkeeping burden associated with the revision of IWA-2420.

Paragraph IWA-4210 was added in the Winter 1983 Addenda to require a written procedure for the storage, handling, and control of welding material.

In general, this procedure would become part of the Owner's Quality Assurance Manual. The procedure would be prepared once per plant and would, like other procedures, be maintained annually thereafter.

It is estimated that the time rrequired to prepare the original procedure would he 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, and the time required to maintain the procedure would be 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / year / plant.

Assuming that all plants presently operating and under construction would at some time implement i

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this requirement, the total annual burden for all 127 plants, 1

averaged over a ten-year inspection interval, would be 1524 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79882e-4 months <br /> / year for all plants (i.e., ((100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> / plant)/10-year interval) + E hours / year / plant) x 125 plants = 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> / year j

total for all plants).

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Paragraphs IWA-6210 (a) and (c), and IWA-6340 were revised in i

the Winter 1983 Addenda to clarify that " inservice inspection" included preservice, as well as inservice programs, and that j

Owners were responsible for preparing and maintaining preservice inspection plans and schedules. Preservice inspections have been a requirement of Section XI, Division 1, since its inception. Preservice inspection plans and schedules are routinely submitted to the NRC as part of the approval process for the inservice inspection program. Therefore, there is no additional recordkeeping burden associated with the revision of IWA-6210(a)and(c),andIWA-6340.

Appendix VI, " Ultrasonic Examination Of Bolts and Studs" was added to Section XI, Division 1, as a mandatory appendix in the Winter 1983 Addenda. Appendix VI provides procedures for the ultrasonic examination of Class 1 and Class 2 bolts and studs.

The recordkeeping requirenients of this appendix can be divided into those associated with documenting the examination procedures (i.e., initial examination development and updates) and those associated with personnel qualification records (i.e.,

test administration, taking tests and updating records).

It is estimated that initial development of the examination procedures would require a one time effort for each plant of approximately l

400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of a level III Examiner's time. Assuming 3 updates of these procedures during o ch 10-year inspection interval, it is estimated that an adoitional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> wo'uld be expended durin;1 each interval by Level III examination personnel for updating.

The burden associated with documenting the examihation procedures per plant per 10-year inspection interval would thec be 496 hours0.00574 days <br />0.138 hours <br />8.201058e-4 weeks <br />1.88728e-4 months <br />. Assuming the need for three qualified ultrasonic bolting examiners per plant, and four bolting configurations for each test, it is estimated that for each inspection interval, the burden associated with personnel qualification records would be a total of 304 hours0.00352 days <br />0.0844 hours <br />5.026455e-4 weeks <br />1.15672e-4 months <br /> for each inspection interval for each plant (i.e., 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of test administration,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> of updcting personnel records, and 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />'of actual testing of Level I and II technicians). The burden associatea with administering personnel qualification records per plant per 10-year inspection interval would then be 304 houts.

Conservatively assuming that all plants presently operating end under construction would at some time implement Appendix VI, the total annual burden of the associated recordkeeping is estimated to be 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year for all plants (i.e., (304 + 496 hours0.00574 days <br />0.138 hours <br />8.201058e-4 weeks <br />1.88728e-4 months <br /> / plant)/(10-yearinterval)x125 plants).

Paragraph IWA-2232(f) was added in the Winter 1985 Addenda to provide the conditions by which ultrasonic indications can be classified as geometric iridications. The revision specifies A-7

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that the maximum amplitude, location, and extent of a geometric indication shall be recorded.

Since such indications are nomally recorded in this manner, there is no additional paperwork burden associated with this requirement.

In sumary, the estimated total additional burden associated with the additional recordkeeping requirements is 11,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> /

year for all plants. The additional burden is the result of the following two items which were described above.

Estimated Burden Item Addenda Bnrden(hours / year for all plants IWA-4210 Winter 1983 1,500 Appendix VI Winter 1983 10,000 c.

Estimated Cost Raquired to Respond to the Collection Based upon the hours specified in Item 3.a. it is estimated that the cost of responding to the information collection required by the Section III, Division 1, and Section XI, Division 1, edition and addenda specified in the proposed amendraent to 650.55a is a total of $690,000/ year ((10,000 + 1500) hours. x $60/ hour) for l

125 plants, or $5520/ year for each plant.

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Record Retention Period The retenticn period for information is in accordsnce with a schedule provided in Table NCA-4134.17-I and paragraph IWA-6300 of the ASME Code. The record retention periods for information specified in Item 1.a above are:

Infomation Retention Period Procedure for attachment of nameplates.

3 yrs afjer superseded Overpressure protection report.

Lifetime Welding procedure specification.

Lifetime NF-1/N-5 Data Report Foms.

Lifetime Design Report for storage tanks.

Lifetimo Test results for vacuum relief valves Lifetime i

Proced, for control of welding material. 3 yrs after superseded Preservice Inspection Plan.

Lifetime Ultrasonic examination records.

Lifetime Lifetime retention of the above records is necessary to ewTe adequate historical infomation on the design and examination of components and systems to provide a basis for evaluating degra-j dation of these components and systems at any time during their service lifetime.

3Service lifetime of tLa componer.t or system.

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14.

Reasons for Change in Burden

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The change in burden results from a changre in ASME Code record-keeping requirements effected by the add <.nda and edition that I

are being incorporated by reference thr'.sugh this proposed a

amendment into the NRC regulation.

15.

Publication for Statistical Use i

This information will not be published for statistical use.

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COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS i!

Statistical methods are not used in the collection of the required

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inforrration.

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