ML20248E058

Request for OMB Review & Supporting Statement Re 10CFR50 Domestic Licensing of Production & Utilization Facilities. Estimated Respondent Will Be 5,626,912 H

ML20248E058
Person / Time
Issue date:	05/01/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20248E046	List: ML20248E041 ML20248E058 ML20248E107 ML20248E128
References
RTR-REGGD-01.174, RTR-REGGD-01.175, RTR-REGGD-01.176, RTR-REGGD-01.177, RTR-REGGD-01.178, RTR-REGGD-1.174, RTR-REGGD-1.175, RTR-REGGD-1.176, RTR-REGGD-1.177, RTR-REGGD-1.178 OMB-3150-0011, OMB-3150-11, NUDOCS 9806030171
Download: ML20248E058 (18)

Text

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I PAPERWORK REDUCTION ACT SUBMISSION s

Pl:ase read the instructic is before completing this torm. For additional forms or assistance in completing this form, contact gour ag:nc s Papsrwork Cie:ratice Officer. Ser.d two copies of this form, the collection instrument to be reviewed, the eupporting tatement, and any additional documentation to: Office of information and Regulatory Aff airs, Offico cf Management and Budget, Docket Library, Room 10102,72517th Street NW, Washingtort DC 20503.

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1. Agency / Subagency originating request 3 OMB control number

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U.S. Nuclear Regulatory Commission y

a.

3150-9011 b None l

1 g Type of information codedson (check one)

4. Type of review requested (ChecA 000)

a. New collectron g

a Regular

c. Delegated

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g

b. Revision of a cuntrntty approved collection

b. Emergency - Approval requested by (date)

c. Extension of a currendy approved collection

5. W'll this infonnation collection have a a.Yes bigni icant eeunomic smi.act on a

d. Reinstatement, without change, of a previously apptraed substantial number of small entites?

collection for whicn appr? val has expired Y

b~ N0

~

e. Reinstatement, with chang of a previously approvtsd l

a Three years yrom appruva; date l

collection for which approva has expired Requested j

f. Existing collection in use without an OMB control number

b. Other(Specifyp 9/30/2000 i

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1. we p:

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

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

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N/A b ;-

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9. Keywords 5/

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Nuclear Power Plants and Reactors, Reporting and Recordkeeping Requirements t' $

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10. Absttact A new series of regulatory vides will allow licensers voluntarily to use a new risk-informed method for making changes to their licensing b sis in the areas ofinsemce inspection and testing procedures, quality assurance, and technical specificadons.

11 Affected pub >c owk onman utn v aM en others that appy wth n

12. Obhgabon to respond (Mark pnmary win y aw as attes that appy win ~x-)

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d. Farms T

a. Voluntary

a. Individuals or hvuseholds l T

b. Business or other for-profd

e. Federal Govemment

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b. Requireo to obtain or reiein benefits

c. Not-for-profit inshtutions

f. State, Local or Tnbal Govemment

c. Mandatory

13. Annual reporting and recordkeeping hour burden

14. Annual reporting and recordkeeping cost burden im enousanos eremars!

a. Nu ober of respondeVs 178

a. Total anr ualized capital /sta tup costs 0_

b. Total annual responses 7,978

b. Total annual costs (O&M) 0

1. Percentage of these responses

c. T(Aal annuattrrd cost requested 0

j collected electronically 0.0 d current OMB invertory o

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c. Total annual hours requested 5,626,912

e. Difference 0

d. Current OMB inventory 5.573,39s

f. Explanation of difference

e. Difference 53,515 gram change

f. Explanation of di"erence 53,515

2. Adjustment

1. Program change

2. Adjustment

15. Purpose of information conection 141. Frequency of recordkeeping or reporting (checA allthat 7.pp'y) 1 (Mark pamary wtth "P" and aH others that apply with 'X')

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a Recordkeeping

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b. Third-party disclosure 9 \\

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c. Reporting j

l a Application for benefits

e. Program planning or management

~l1. On occasion

2. Weekly y

3. Monthly I

b. Program evaluation

f. Research

c. General purpose statistics T

g. Regulatory or compliance

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4. Quarterly

,f S. Semi-annually J

6. Annually

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d. Audit

7. Biennially

8. Other (desenbe)

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17. Statistical methods

18. Agency contact (person who can best answer questoons regaroing the Corknl Of this SUbm 5$60n) i Does this information collection employ statistical methods?

l Name:

Rov Woods 4 '#

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I Yes No 301-415-6622 Phone.

OMB 83-1 ms ** *a o****5 wS+nf o'ms 10/95 9006030171 980420 PDR ORG EUSOMB PDR W1cM *>O/ 7/

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19.Ctrtificntian for Papirwork Reouction Act Submlationa y

On behalf of this federal a6ency, I certify that the collection ofinformation encompassed by this request complies with 5 CFR 1320.9.

NOTE: The text of 5 CFR 1320.9, and ine related provisions of 5 CFR 1320.8 (b)(3), appear at the end of the instructions The certification is to be made with reference to those regulatoryprovisions a:, setforth in the instructions.

The following is a summary of the topics, regarding the proposed col!ection of information, 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, cohesent, and unambiguous t:rminology that is understandable to respondents; (e) Its implementation will be consistent and compatible with cuent reporting and recordkeeping practices; (f) It indicates the aetention periods for recordkeeping requirements; (g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3):

(i)

Why the infuimation is luing collected; (ii) Use ofinfonnation; (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 etTective manage-e ns ms);

(i) IYu"seseb50Nhe"hSc#"enhf0ttYstkafS rk$ iso"No'g> fan *d i

(j) It makes appropriate use ofinfortnation technology.

If you are unable % ac tify ;ompliance with any of these provisions, identify the item below and explain the reason in item 18 of the Sn. %g Staic. eat.

l Date Sgnature of Authonzed Agency Official Date

$sgnature af sensor Official or d,esign

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t!iiIChief information Ofr

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OMB 83-1

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10/95 L

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OMB SUFPORTING STATEMENT FOR AN APPROACH FOR USING PROBABILlSTIC RISK ASSESSMENT IN RISK-INFORMED DECISIONS ON PLANT-SPECIFIC CHANGES j

TO THE CURRENT LICENSING BASIS i

(Regulatory Guides RG-1.174 thru RG-1.178)

(3150-0011)

REVISION Dmfripjion of In[Qrmation CollevJon l

l In the specific areas of in-Service inspection (ISI, RG-1.178), in-Sennce Testing (IST, RG

)

4 1.175), Graded Quality Assurance (GQA, RG-1.176), Technical Specifications (TS, RG-1.177),

and in an overall guide generically applicable to ali four of these areas (RG-1.174), this new series of Regulatnry Guides provides a risk-informed method for licensees to use in requesting I

changes to their current licensing bases (CLB), the requirements for which are stated or referenced in numerous sections of 10 CFR Part 50 as detailed below in Section A.1. No changes or additions have been made to those sections of Part 50 (nor to any other rules or regulations)in conjunction with the issuance of this series of guides. The new method will be an altemative to the deterministically-based CLB change method previously used (which will remain acceptable as an attemative to the new risk-informed method).

The new risk-informed attemative method will allow licensees to concentrate on plant equipment and operations that are most critically important to plant safety. For example, exiMing regulations require certain quality assurance activities to be applied to a wide variety of a plant's j

systems, structures, and components (SSCs). Although the regulations allow these quality ossurance activities to be applied in a way that is commensurate with the safety importance of each SSC, historical precedent has resulted in the same quality assurance activities being j

applied to SSCs that have a wide range of safety significar.ce. This new risk-informed j

attemative encourages quality assurance activ.ies that are compatible with safety significance, i

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thus aHowing more effort to be expenried on the more impc rtant equipment, and correspondingly less effort on the less important equipment in this way, a navings in total effort can be achieved l

with an insignificant change in overall safety. This savingr, together with the greater operating flexibility that WHI become possible utilizing t'te new meth'ad, are among the principal incentives for licensees tc voluntarily assurne the recudkeeping e,1d reporting burdens that come with the new risk-informed method.

Tho guides specify the records. analyses, and documents that licenseea are expected to prepare in support of risk-informed changes to their CLB in the specified areas. Within each of l

the four areas, the applicable Regulatory Guide (supplemented by additional generic guidance from the overall guide. RG-1.174) specifies that the licensee should consider the following four items. The licensee should:

1) identify those aspects of the plant's licensing bases that may be affected by the propor,ed change, including, but not limited to, rules and regulations, final safety analysis report (FSAR), technical specifications, licensing conditions, and licensing commitments; identify all SSCs, procedures, and activities that are covered by the CLB change under evaluation and consider the original reasons for inclusion of each program requirement; and identify available en0 neering Studies, methods, codes, applicable plant-specific and l

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industry data and operational experience, PRA findings, and research and analysis results relevant to the proposed CLB change;

2) evaluate the prc, posed CLB change with regard to the principles that adequate i

defense-in-depth is maintained, that sufficient safety margins are maintained, and that l

proposed increases in core damage frequency and risk are small and are consistent with the intent of the Commission's Safety Goal Policy Statement;

3) develop an implementation and monitoring plan to ensure that the engineering evaluation conducted to examine the impact of the proposed changes continues to reflect the actual reliability and availability of SSCs that have been evaluated, and to ensure that the conclusions which have been drawn frora the evaluation remain valid; and

4) review the proposed CLB change in order to determine the appropriate form of the change request; assure that information required by the relevant regulations (s) in support of the request is developed; and prepare and submit the request in accordance I

with relevant procedural requirements (for those applications where submittal is required, as specified later in this document).

Changes in NRC expectations regarding licensee recordkeeping and reporting in the technical areas covered by this supporting statement, due to a licensee's voluntary use of the new alternative risk-informed method for requesting CLB changes, are the subject of this clearance support document. The present supportirg staternents describing the current bases for OMB's recordkeeping and seporting approvalin these technical areas are as follows:

Part 17 of the current 10 CFR Part 50 OMB clearance covers the recordkeeping and 4

reporting burdens for inservice inspection and inservice testing programs. Not included in Part 17 are the recordkeeping and reporting needed to convert the bases of ISI and/or IST programs to the new risk informed CLB change methodology (a one-time-only effort, as described in items #1, #2, and #4 above), and the recordkeeping and reporting associated with the implementation and monitoring plan that is expected to be an integral part of these RI programs (an ongoing effort, as described in item 3 above, to ensure that no unexpected adverse safety degaoat on occum after the reques%d changes have been made). However, toe burden for CLB changes, including but not limited to CLB changes related to ISI and IST, is covered in Part 1 of the OMB clearance for 10 CFR Par 150 (!icense amendments).

Part 16 of the current 10 CFR Part 50 OMB ciecrance covers 10 CFR Fan 50, Appendix B, which contains NRC's requirements regarding the features of the quality esauranco i

(OA) programs that each license must establish, update, and follow through the life of its l

plant. Ap;endix B to 10 CFR Part 50 allows QA activities to be applied in a graded manner, and because there is variety in the exact commitment made by individual l

licensees in their CLB regarding QA programs, certain licensees can adopt certain aspects of graded QA programs without prior NRC approval. The last paragraph of Section A.1 of Part 16 states:

2 J

"Any changes to this {OA} plan must be reported to the NRC like other license conditions of a similar nature. It is estimateo that each licensee /apphant will l

initiate one such change per year. Such changes are included in the totallicense l

amendment requests reflected in the Part 1 Supporting Statement."

1 Thus the burden for CLB changes, including but not limited to CLB changes related to QA, is covered in Part 1 of the OMB clearance for 10 CFR Part 50 (ficense amendments).

Part 1 of the current 10 CFR Part 50 OMB clearance covers the recordkeeping and reporting required for technical specifications (TS). Technical specifications are required to be part of a licensee's operat;ng licence, and license amendments are issued in response to requests for changes to technical speci'ications. When the current Part 50 clearance was submitted, license amendments for technical specifications changes were anticipated for the clearance period, and the anticipated recordkeeping and reporting requirements burden was included within Pmt 1. Over the past several years, applications for license amendments for technical specification changes have made increasing use of quantitative risk era!uations (i.e., the requests have become more

" risk-informed"). Thus, issuance of the subject RG-1.177 serves more to codify and standardize existing practice than it does to significantly change that practice. Thus, many of the recordkeeping and reporting expectations associated with conversion to, and later rnaintenance of, risk-informed technical specification changes are already included within Part 1, and have already been approved by OMB in the Part 50 clearance approval. This includes the implementation and monitoring plan, since technical specifications are required only for significant, safety-related equipment for which implementation and monitoring activities are currently required by 10 CFR 50.65.

A.

JtJSTIFICATIQN 1.

Need for and Practical Utility of the Collec' ion of Information in cases where the licensee chooses to convert from the present deterministical!y oriented CLB to the new attemative risk-informed CLB in any one of (or combination of) the subject technical areas, then the licensee and the NP,C must have sufficient information to determine that the plant continues to be operated in a manner that ensures the health and safety of the public once the changes have been implemented.

The infom1ation expected to be collected for the above-stated purpose in each of the technical areas considered by the subject Regulatory Guides is specified in various sections of 10 CFR Pad 50, as described below. These regulations remain unchsnged by issuance of the subject Regulatory Guides. Only the method for compliance has been changed. The current regulations are:

In-Service Inscection (ISI. RG-1.178and the generically aoolical2 gEG-1.174):

1 10 CFR 50.55a(g) " Inservice inspection requirements," specifies in detail, according to the date of issuance of the plant's construction permit, the editions of Section XI of the 3

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ASME Boiler and Pressure Vessel Code and Addenda to which the inservice inspection l

of the plant's piping and pressure boundary equipment must comply, including the reporting and recordkeeping that is expected as part of the licensee's ISI program.

i in order for the licensee to insure, and the NRC to verify, that the requirements of this l

regulation (and the referenced codes and addenda) continue to be met following i

changes to the licensee's ISI program, in those cases where the licensee chooses to use the risk-informed a!ternative method for requesting such changes, the NRC expects the licenaec to document and submit its consideration of the four items described in the above " Description of the infntmation Collection" soction. This docurnentation is used by the NRC as indicated in Section A.2 below.

l The NRC expects licensees to maintain sufficient infor: nation regarding how the plant rneets its CLB to support NRC audit of these bases at any time such audit should l

become necessary. However, the details regaroing tha related documentation that must be maintained, and for how long, are not explicitly provided in the regula'Ms (other than that provided by the records-retention aspects of 10 CFR 50.71(c), which are discussed i

in the next-to-last paragraph under " Technical Specifications" below).

l I

L;censee requests for CLB changes to various portions of their inservice inspection programa are voluntary. The availability of the new risk-informed alternative for requesting such changes in no way makes the licensee's present inservice inspection program unacceptable. Each licensee will therefors request such a change if and when i

the licensee decides it is to its advantage (by virtue of concentrating its inspection efforts l

on the naore risk-significant portions of its piping and pressure boundaries, and by the i

resultbg increased coerating flexibility) to request such a change. Therefore, the frequency of inservice inspection program change submittals using the risk-infotmed altern&tive method is not known with any certainty, although the staff's best estimates are used in item 12 below (" Estimate of Burden").

iteService Tutino (IST. RG-1hrld.lba. 9AncriCRHX_apolicable RG-1.174k 10 CFR 50.55a(f), " Inservice testing requirements," specifies in detail, according to the date of issuanca of the pbnt's construction g,errrJt, the editions of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda to which the inservice testing of l

the plant's pumps and valves must comply, including the reporting and recordkeeping i

that is expected as part of tna licensue's IST program.

j in order for the licensee to insure, and the NRC to verify, that the requiremen's of this regulation (and the referenced codes and addenda) continue to be met following l

chartges to the licenses's IST program, in those cases where the !icensee chooses to use the risk-informed alternative metnod for requesting such ci anges, the NRC expects the licensee to document and submit its consideration of the four items described in the j

above " Description of the information Collection" section. This documentation is used by the NRC as indicated in Section A.2 below.

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l The NRC expects licensees to maintain sufficient information regarding how the plant meets its CLB to support NRC audit of these bases at any time such audit should become necessary. However, the details regarding the related documentation that must be maintained, and for how long, are not explicitly provided in the regulations (other than Inat provided by the records-retention aspects of 10 CFR 50.71(c), which are discussed in the next-to-last paragraph under " Technical Specifications" below).

Licensee requests for CLB changes to various portions of their inservice testing programs are voluntary. The availability of tha new risk-informed attemative for requesting such changes in no way makes the licensee's present inservice testing program unacceptable. Each licensee will therefore request such a change if and when the licensee decides it is to its advantage (by virtue of concentrating its testing efforts on the more risk-significant pumps and valves, and by the resulting increased operating flexibility) to request such a change. Therefore, the frequency of inservice testing program change submittals using the risk-informed attemative method is not known with any certainty, although the staff's best estimates are used in item 12 below (" Estimate of Burden").

Onality Assurance (GOA. RG-1.176. and the generically aoolicable RG-1.174):

Appendix B to 10 CFR Part 50, " Quality Assurance Criteria," describes the requirements of the quality assurance (QA) program that must be documented and applied to all activities affecting the safety-related functions of the plant's equipment, including the reporting and recordkeeping that is expected as part of the licensee's QA program. The overall purpose of the QA program is to establish a set of systematic and planned actions that are necessary tc provide adequate confidence tha,t safety-related plant equipment will perform satisfactorily in service.

The requirements delineated in Appendix B to 10 CFR Part 50 allow QA program controls to be applied in a " graded" manner, that is, with greater efforts applied to QA programs related to more safety significant equipment and activities, and lesser efforts applied to QA programs related to less safety significant equipment and activities. In tne past, engineering judgement provided the general mechanism for evaluating the relative importance to safety of plant equipment and activities, resulting in little advantage being taken of the regulation's provision that graded QA programs could be applied. The new risk-informed altemative for making QA program changes (described in the subject RG-1.176) encourages graded QA (GQA) programs by providing a more systematic methodology for categorizing safety-related equipment &nd activities according to their safety importance, and for applying commensurate QA activities to each category.

In order for licensees to insure that the requirernents of Appendix B to 10 CFR Part 50 continue to be met following changes to the licensee's QA program, in those cases where the licensee chooses to use the risk-informed alternative method for requesting such changes, the NRC expects licensees to document their consideration of the four items described in the above " Description of the Information Collection" section.

Because the goveming regulation (Appendix B to 10 CFR Part 50) allows QA activities to be applied in a graded manner, and because there is variety in the exact commitment l

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1 made by individual licensees in their CLB regarding QA programs, certain licensees can adupt certain aspects of graded QA programs withou+ prior NRC approvel. However, in these cases, the NRC expects licensees to document their consideration of the above-described four items for NRC's use during later audits of their QA program. This documentation may be used by NRC as indicated in Section A.2 below.

The NRC expects licensees to maintain sufficient information regarding how the plant meets its CLB to support NRC audit of these bases at any time such audit should become necessary. However, the details regarding the related documentation that must be maintained, and for how long, are not erplicitly provided in the regulations (other than that provided by the records-retention aspects of 10 CFR 50.71(c), which are discussed in the next-to-last paragraph under " Technical Specifications" below).

Licensee requests for CLB changes to various portjens of their quality assurance programs are voluntary. The availability of the new risk-informed alternative for requesting such changes in no way makes the licensee's present quality assurance program unacceptable. Each licensee will therefore request QA program changes if and when the licensee decides it is to its advantage (by virtue of concentrating its QA efforts on the more risk significant SSCs and activities in its plant, and by the resuiting increased operating flexibility) to request such a change. Therefore, the frequency of QA program change submittals using the risk-informed alternative method is not known, although the staff's best estimates are used in item 12 below (" Estimate of Burden").

Technical Soecications (TS. RG-1.177. and the generically apolicable RG-1.174k 10 CFR 50 36. " Technical Specifications," requires that technical specifications be included as pi,rt of the plant's license specifying certain safety and controllimits and settings, limiting conditions for operations, surveillance requirements, design features, administrative controls, and required notifications and reports, and it includes specification of the reporting and recordkeeping that is expected as part of the licensee's TS program. Requests for changes to technical specifications are submitted as applications for ainandments to the plant's operating license.

Over the past several years, applications for license amendments for technical speciscation changes have made increasing use of quantitative risk evaluations (i.e., the requests have becomo more " risk-informed"). Thus, i?suance cf the subject RG-1.177 serves rnore to codify and standardize existing practice than it does to significantly change that practice.

In order for the !icensee to insure, and the NRC to verify, that the requirements of this regulation continue to be met following changes to the licensee's TS program, the NRC expects the licensee to document and submit its consideration of the four items described in the above " Description of the Information Collection" section. This documentation is used by the NRC cs indicated in Section A.2 below.

10 CFR 50.71(c) states, ' Records that are regt, ired by the regulations in this part, by licenso condition, or by technical specifications, must be retained for the period specified 6

by the appropriate regulation, license condition, or technical specification. If a retention period is not otherwise specified, these records must be retained until the Commission terminates the facility license." Thus, the required retention period varies according to

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the particular regulations, license conditions, or technical specifications that govern the particular aspect of the plant's CLB that is being changed.

Licensee requests fnr license amendments for technical specification changes are

)

usually voluntary, but are sometimes in response to regulatory changes or regulatory j

positions that reflect changes in risk perspectives (for example, as caused by the i

occurrence of a significant operating event). In either case, the frequency that technical specification changes will be requested using the new risk-informed method is not presently known, although the staff's best estimates are used in item 12 below (" Estimate of Burden").

2.

Agency Use of frsformation lo-Service insp.e_ction (RG-1.178. and the generically aoolicable RG-1.1~74)-

l The information expected as described in Section A.1 will be used by responsible NRC l

personnel to make the finding that the requirements of the plant's CLB in areas related to l

inservice inspection will continue to be satisfied once the requested changes are made, thus insuring the continuing validity of the plant's operating license.

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lo-Service Testing (RG-1.175. and the acogiically acolicable RG-1.174):

l The infctmation expected as described in Section A.1 will be used by responsible NRC personnel to make the finding that the requirements of the plant's CLB in areas related to inservice testing will continue to be satisfied once the requested changes are made, thus insuring the continuiN validity of the plant's operating license.

Quality Aggrance (RG-1.176. an.d the generically _appJiCable RG-1.174):

For licensees whose license requires NRC approval prior to implernentation of the specific type of QA chnge being requested (see discussion in Section A.1), the submitted information (also described in Section A.1) is used by the responsible NRC personna! to make the finding that the QA requirements will continue to be met once the requested QA changes are made. For licensees whose license does not require prior approval (see discussion in Section A.1), the same information should be used by the licensee to determine that the QA requirements will continue to be met once the requested changes are made, and also should be retained on-site for possible NRC inspection to confirm that the plant contir'ues to conform to its CLB in areas related to quality assurance.

Technical So_e_cjfic_ations (RS-1177. and the generically poolicable RG-1.174):

The mformation expected as described in Section A.1 will be used by responsible NRC personnel in the review and approval of the requested license amendment, thus insuring 7

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the continuing validity of the plant's operating license once the requested technical specification changes are made.

3.

Reduction of Burden Through Information Technology Because each submittal is unique, is made only once, and is unlikely to be developed from other compiled information sources, the reports do not tend themselves readily to the use of technological collection techniques for submission. Thus, no reports are submitted electronically, and the NRC foresees no opportunity to reduce the burden of information submittal through the use of information technology.

4.

Effort to identifv Duplication and Use Similar Information These are licensing submittals describing the CLB of the plant. Each submittalis a unique combination of information which is assembled by the licensee for a specific purpose for its specific plant. No similar information exists. The informat:-a Requirements Control Automated System (IRCAS) was searched and no duplication was found.

5.

Effort to Reduce Small Business Burden Not applicable. These submittals are prepared by licensees of nuclear power plants, which are not smal! businesses.

6.

Consequences to Federal Procram or Poliev Activities if the Collection is Not Conducted or is Conducted Less Frecuentiv These voluntary cohections are not required on a specified frequency (or at all). The only effect on Federal Programs of not receiving information, or receiving it less frequently, would be that of not allowing licensees the possible savings in resources and the increased operating flexibility that would otherwise result from such submittals.

7.

Circumstances which Just;fv Variation from OMB Guidelines These records and reports become part of the licensing basis of the plant (or the license itself, as noted in the sections that discuss technical specifications). The NRC expects licensees to maintain sufficient information reg"-fng how the plant meets its CLB to support NRC audit of these bases at any time such audit should become necessary.

However, the details regarding how much related documentation must be maintained, and for how long, are not explicitly provided in the regulations (other than that provided by the records-retention aspects of 10 CFR 50.71(c), which are discussed in the next-to-l last paragraph under " Technical Specifications" above).

8.

Consultations Outside NRC l

Opportunity for public comment was published in the Federal Reaister on 2/28/98 (63FR8222). The only comments received were two sets of identical comments, one 8

from the Westinghouse Electric Company (a nuclear steam supply systems (NSSS) vendor) and the other from the Westinghouse Owner's Group (an organization of utiJties that operate nuclear power stations that use the Westinghouse NSSS). There were four

{

comments.

]

First, they commented that, ". the information required to be submitted to the NRC for these applications is viewed to be excessive and the actua! value of some of the information in relation to the application is questionable." Similar cornments were received by the staff during the earlier public comment period to solicit specific comment on the risk-informed draft regulatory guides. The proposed final guides were changed to take those earlier comments into account, and the reporting and recordkeeping requirements were reduced in the many cases where the staff concluded thht it was possible to do so. Thus, no further reductions have been made in the actual reporting and recordkeeping requirements as a result of this comment.

Second, they commented that, given the reporting and recordkeeping requirements as stated, the staffs estimates of the time required for the licensees to perform (and the staff to review) that reporting and recordkeeping were too high Specific estimates were given in the comment regarding those burden estimates for ISI, IST, and GQA applications, which typically represented 30% to 40% reductions from the staffs earlier estimates. The commentors' specific estimates regarding the licensees' burden estimates have been adopted in this (final) version of the OMB supporting document, on the basis that the licensees who will make the applications (as represented by the owner's group) are in a better position than the NRC staff to estimate the time required to perform the required reporting and recordkeeping. However, on the same basis, the commentors' estimates regarding the NRC staffs time needed to review those reports and records were not adopted, on the basis that the staff is in the best position to make those particular estimates regarding its own time requirements to perform specific reviews.

Third, they commented that the staffs burden estimates were too high because they appeared to be based on " full scope' applications (i.e., where the licensee makes application to change many or all of the ISI, !ST, or QA programs in the plant), instead of making application to change a more limited number of such programs. The staff made no change as a result of this comment, because the original estimates were based on the assumption that some of the applications would be limited in scope, and the staff prefers to stay with the present conservative assumption until experience shows that the resulting burden estimates were too high because more of the applications were of

" limited scope" than anticipated.

Fourth, they commented that the staffs burden estimates were too high because the NRC took no credit for NSSS vendors' development of generic topical reports which they believe will reduce the reporting and recordkeeping time requirernents associated with these applications. The staff made no change as a result of this comment, preferring instead to await future review, acceptance, and trial use of the topical reports before taking credit for the resulting possible, but as yet unproven, burden savings.

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9.

Eay1nent of Gift to Respondents Not applicable.

10.

Confidentiality of the InformajioD No information normally considered confidential is required.

11.

Justification for Sensitive Questions No sensitive information is requested.

12.

Estimete of Burden and Burden Hour Cost ISI and IST burdens are included in Part 17 of the OMB clearance for 10 CFR Part 50.

However, the burden for CLB changes, including but not limited to CLC changes related to ISI ard IST, is covered in Part 1 of the OMB clearance for 10 CFR Part 50 (license amendments} The number of licensing submittals listed in the tables below for ISI and IST are the at Zonal annual submittals that are anticipated as a result of the new risk-informed attemative method. Tnese submittels were not antic.ipated under the pret.ent methodology, and thus ere not covered by Parts 17 and 1 of the present OMB clearance.

Plant licenses require that the sections of the licensees' Final Safety Analysis Reports (FSARs) that describe its ISI program be updated when the ISI programs are changed, e.g., when a risk-informed ISI program is adopted. This is a relatively minor effort since the necessary information will already have been collected in support of ths submittal that requests the change. The "FSAR update" burden is shown on a separate line in tne

" reporting burden" table below.

QA burdens are included in Part 16 of the OMB clearance for 10 CFR Part 50. However, the burden for CLB changes, including but not limRed to CLB changes related to QA, is covered in Part 1 of the OMB clearance for 10 CFR Part 50 (license amendments). The single submittal listed in the tables below for GQA ic the single additional annual subrnittal that is anticipated as a result of the new risk-informed altemative method. This submittal was not anticipated under the present methodology, and thus is not covered by Parts 16 and 1 of the present OMB clearance.

Burdens for all types of TS changes are included in Part 1 (license amendments) of the OMB clearance package for 10 CFR 50. That clearance includes, but is not limited to, the relatively small sub-set of all TSs that are related to allowed outage times (AOTs) and surveillance test intervals (STis), which are the only types of TSs that can be changed utilizing the new risk-informed attemative method presented by the subject regulatory guides.

The 20 licensing submittals listed in the tables belo*.y for TS are the ant'.cipated annual AOT-and STl-related submittals that will be based upon the new risk-informed attemative method. Ti.e tables show the estimated burdens for reporting, recordkeeping, 10

etc., that are anticipated for licensees using the new method. However, absent the new risk-informed method, the staff estimates that 15 of those submittals would have been made under presently existing methods (whosc associated burdens are already approved by Part 1 of the present OMB clearance for 10 CFR 50). Because the burden associated with those 15 submittals is not the same per submittal as that estimated for licensees using the new method, the estimated burden for the 15 submittals using the old method has been subtracted and the estimated burden for the 20 submittals using the new method has been added in the tables in its place.

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ANNUAL REPORTING REQUIREMENTS FOR SUBMITTALS REQUESTING Ri PROGRAM APPROVALS Section/

Number of Lic.

Hours per Total Annual Cost @

BE_ GRide Sdmitta's S.ubmittal Burden (Hrt)

$131/Hr.

10CFR50.55a(g) 6 530 3,180

$416,580 RG-1.178, ISI (FSAR Update) 6 20 120 15,720 10CFR50.55a(f) 3 550 1,650 216,150 RG-1.175, IST 10CFR50 App B 1

550 550 72,050 RG-1.176, GQA 10CFR50.36 20 200 4,000 524,000 RG-1.177, TS (15)

(61)

(915)

(119,865)

TOTAL FOR PART 50 REPORTING:

9,500 Hrs.

$1,244,500 (915)

($119.865)

Net Additional Burden-8,585 Hrs.

$1,124,635 ANNUAL RECORDKEEPING REQUIREMENTS TO SUPPORT SUBMITTALS REQUESTING RI PROGRAM A,oPROVALS Section/

Number of Lic.

Hours per Total Annual Cost @

(Reo Guide)

Proaram Chnot Erogam_C.tlas.

B.u.rgen (Hrs.)

$131/Hg 10CFR50.55a(g) I 6

3,750 22,500

.$2,947,500 RG-1.178, ISI 10CFR50.55a(f) 3 2,250 6,750 884,250 RG-1.175, IST 10CFR50 App B 1

2,250 2,250 294,750 RG-1.176, GQA 10CFR50.36 20 800 16,000 2,096,000 RG-1.177, T8 (15)

(498)

(7,470)

(978,570)

~

TOTAL FOR PART 50 RECORDKEEPING 47,500 Hrs.

56,222,500 TO SUPPORT SUBMITTALS:

(7,470)

($978,570) 3 Net Additional Burden: 40,030 Hrs.

55,243,930 i

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ANNUAL RECORDKEEPjNG REQUIREMENTS TO SUPPORT IMPLEMENTATION AND MONITORING PLAN Section/

Number' of Lic.

Hours per Total Annual Cost @

(Rec. Guide)

Proaram Ghragt Proaram ChDg, Surcen flirL)

$131/Hr.

10CFR50.55a(g) 12 200 2,400

$314,400 RG-1.178, ISI 10CFR50.55a(f) 6 200 1,200 157,200 RG 1.175, IST 10CFR50 App B 2

200 400 52,400 J

RO-1.176, GQA 10CFR50.36 40 60 2,400 314,400 RG-1.177, TS (30)

(50)

(1,500)

(196,500)

TOTAL FOR PART 50 RECORDKEEPING TO 6,400 Hrs.

$838,400 SUPPORT IMPLEMENTATION AND MONITORING PLAN:

(1,500)

($196,500)

Net Additional Burden:

4,900 Hrs.

$641,900 l

NET ADDITIONAL BURDEN FOR ALL PART 50 l

REPORTING AND RECORDKEEPING IN THIS PART:

53,515 Hrs.

$7,010,465

{

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'Recordkeeping for the implementation and monitoring plan is a continuing effort. After making a risk-informed change in the CLB, each licensee would be expecteo to expend this effort every year on a continuing basis. Thus, in the first year there will be (using, for examp!e, IS), for which the tables on the previous page indicate 6 submittals are expected each year) 6

(

such efforts in the first year,12 such efforts in the second year, and 18 such efforts in the third l

year, for an average per year for the three year reporting period of (6 ^ 52 + 18) / 3 = 36 / 3 =

12. This same calculation has been applied to the recordkeeping for the submittes expected each year for IST, GQA, and TS (as given in the recordkeeping table on the previous page).

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13.

Estimate of Other Additional CosfJ There are no additional known costs.

1 14.

Estimated Annualized Cost to the Government The following tables and text present this information.

ANNUAL GOVERNMENT REVIEW OF REQUESTS FOR Ri PROGRAM APPROVAL Section/

Number of Hours per Total Annual Gov. Cost @

(8.qq. Guide)

Beviews Review Review (Hrs.)

$131/Hr.

10CFR50.55a(g) 6 1,000 6,000

$786,000 RG-1.178, ISI 10CFR50.55a(f) 3 1,000 3,000 393,000 RG-1.175, IST 10CFR50 App B 1

750 750 98,250 RG-1.176, GQA 10CFR50.36 20 200 4,000 524,000 RG-1.177, TS (15)

(200)

(3,000)

(393,000)

TOTAL FOR PROGRAM SUBMITTALS:

13,750 Hrs.

$1,801,250 (3,000)

($393,000)

Net Additional Government Burden: 10,750 Hrs.

$1,408,250 14

ANNUAL GOVERNMENT REVIEWS / AUDITS OF RECORDS SUPPORTING IMPLEMENTATION AND MONITORING PLAN 2

Section/

Number of Hours per Total Annual Cost @

(Reo. Guidg)

Reviews /Auditri Review / Audit Bgv./Aud. (Hrs.)

$131/Hr.

10CFR50.55a(g) 12 50 600

$78,600 RG-1.178, ISI 10CFR50.55a(f) 6 40 240 31,440 RG-1.175, IST 10CFR50 App B 2

45 90 11,790 RG-1.176, GQA 10CFR50.36 40 0

0 0

RG-1.177, TS (30)

(0)

(0)

(0)

TOTAL FOR PART 50 RECORDKEEPING TO 930 Hrs.

$121,830 SUPPORTIMPLEMENTATION AND MONITORING PLAK (0)

(0)

Net Additional Government Burden-930 Hrs.

$121,830 TOTAL NET ADDITIONAL GOVERNMENT BURDEN:

11,680 Hrs.

$1,530,080 This cost is fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

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l See footnote #1 (under previous table related to recordkeeping for implementation and 2

monitoring plan)

I 3These records are reviewed as a normal part of the routine inspection process and, therefore, incur minimal cost to the government.

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15.

Reason for Chanae in Burden or Cost Licensees may choose to change certain safety programs from 9 predominately deterministic basis to the new methodology that makes increased use of risk-informed techniques. Such changes allow licensee resources (i.e., manpower and funds) to be concentrated on more safety significant equipment and activities, and correspondingly h

less on less safety significant equipment and activities. Such changes also allow the licensee considerable additional flexibility in the way in which the plant is operated and maintained. To make these changes, licensees are expected to perform (and in some cases submit) analyses, and develop and maintain an implementation and monitoring plan which willinclude maintaining records of equipment performance. Although this will increase their overall reporting and recordkeeping burden, it is expected to result in overall savings and in increased operating flexibility (which will more than compensate for this increase), with no significant change in overall plant safety. The burden hours for 10 CFR Part 50 are expected to increase because we anticipate that annually approximately thirty respondents may take advantage of these voluntary provisions.

16.

Publication for Statistical Use

}

This information will not be published for statistical use.

17.

Reason for Not Disolavino the Exoiration Date The information collections contained in these regulatory guides are contained in a regulation. Revising the guides merely to update the expiration date unnecessarily expends scarce agency resources.

18.

Exceotions to the Certification Statement There are no exceptions.

B.

COLLECIlONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in this collection of information.

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