ML23340A138
| ML23340A138 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/2024 |
| From: | Division of Operating Reactor Licensing |
| To: | NRC/OCIO |
| Shared Package | |
| ML23340A124 | List: |
| References | |
| OMB-3150-XXXX, NRC-2023-0141 | |
| Download: ML23340A138 (7) | |
Text
FINAL SUPPORTING STATEMENT FOR PRE-APPLICATION COMMUNICATION AND SCHEDULING FOR LICENSING ACTIONS RELATED TO DIGITAL INSTRUMENTATION AND CONTROLS (3150-XXXX)
NEW Description of the Information Collection The Instrumentation and Controls (I&C) systems of a nuclear power plant (NPP) function as the "nervous system" of the plant. They provide operators with critical safety information on plant operation, allow operators to control various plant safety systems during routine operations, and automatically protect the reactor core during potential accidents. In current operating nuclear facilities, I&C equipment obsolescence is creating a challenging environment for licensees.
Consequently, operating nuclear facilities are starting to replace analog I&C safety systems with digital technology. The implementation of digital technology in safety and security systems can be useful for resolving obsolescence issues, reducing uncertainties in the maintenance of plant safety, reducing opportunities for human error, reducing maintenance costs, and potentially improving safety. Many industry stakeholders (i.e., licensees, applicants, and vendors) desire to take advantage of these potential safety and reliability benefits introduced by digital I&C.
As licensees continue to submit licensing amendment requests for analog to digital or digital-to-digital I&C upgrades, the U.S. Nuclear Regulatory Commission (NRC) staff seeks opportunities to innovate, to be risk-informed, and to increase the efficiency and effectiveness of reviewing digital I&C licensing amendments. In order to support the timely processing of future reviews related to analog to digital or digital-to-digital I&C upgrades and better inform the NRCs budget and resource planning, the NRC seeks scheduling information for preapplication activities, and the submittal of applications related to digital I&C from all holders of Part 50 operating licenses or Part 52 combined licenses for nuclear power reactors.
This information will enable the NRC to effectively allocate its resources to support digital I&C technology licensing activities while also increasing the ability to meet the industrys desired timelines. The NRC is asking for voluntary responses from holders of Part 50 operating licenses or Part 52 combined licenses for nuclear power reactors and voluntary updates to the initial responses as significant scheduling changes occur.
A. JUSTIFICATION
- 1. Need for the Collection of Information A significant portion of the level-of-effort for a digital I&C review will require specialized digital I&C and human factors engineering skills. Given the industry stakeholders desire to take advantage of the potential safety and reliability benefits introduced by the use of digital I&C, analog to digital or digital-to-digital I&C upgrades are expected to be widely seeing throughout NPPs in the United States. Providing the NRC with advance notice of planned scheduling information for preapplication activities and application submittals related to digital I&C activities will allow the
agency to better align its resources (including, availability of sufficient digital I&C and human factors engineering skills) consistent with the anticipated future amendment requests.
Given the expected volume of amendment requests and the potential complexity associated with reviewing the requests, the NRC needs additional information on industry plans for deploying these technologies to facilitate the allocation of resources to support the industrys efforts.
NRC has the authority to request this information under Section 161c of the Atomic Energy Act of 1954, which states, In the performance of its functions the Commission is authorized tomake such studies and investigations, obtain such information, and hold such meetings or hearings as the Commission may deem necessary or proper to assist it in exercising any authority provided in this Act, or in the administration or enforcement of this Act, or any regulations or orders issued thereunder.
- 2. Agency Use and Practical Utility of Information The information gathered by this request will allow the NRC to effectively allocate its resources to support the activities leading up to and including the review of digital I&C license amendment requests. Additionally, this information collection seeks to promote early and frequent communication between the NRC and stakeholders on topics such as analog to digital or digital-to-digital I&C upgrades, and industry schedules. Communication between both parties promotes the submission of high quality and complete applications. Incomplete or insufficient applications increase the risk of schedule delays and unnecessary resource expenditure.
- 3. Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them.
The NRC has issued Guidance for Electronic Submissions to the NRC which provides direction for the electronic transmission and submittal of documents to the NRC. Electronic transmission and submittal of documents can be accomplished via the following avenues: the Electronic Information Exchange (EIE) process, which is available from the NRC's Electronic Submittals Web page, by Optical Storage Media (OSM) (e.g. CD-ROM, DVD), or by e-mail. It is estimated that approximately 100% of the potential responses are filed electronically.
- 4. Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.
- 5. Effort to Reduce Small Business Burden None of the potential applicants responding to this collection are small businesses.
- 6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently If the information is not collected, the NRC will be unable to inform its budget and resource planning for the review of digital I&C license amendment request applications. This could cause the NRC to have a mismatch between the resources needed to complete the reviews in a timely manner and the resources available and may result in the reviews not being completed by the requested date of the licensees. This schedule is the minimum frequency necessary for the NRC to update its budget and resource planning as submittal schedules change.
- 7. Circumstances Which Justify Variation from OMB Guidelines Not applicable.
- 8. Consultations Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on December 5, 2023 (88 FR 84365). Additionally, NRC staff contacted nine stakeholders via email. The stakeholders were operating reactor owner/operator licensees and industry representatives from Constellation Energy, Department of Energy, Dominion Energy, Florida Power & Light Co, Framatome, Inc., Sargent & Lundy, Southern Nuclear Operating Co., Westinghouse Electric Co., LLC, and Xcel Energy.
Staff received the following comments from Constellation Energy, no additional responses were received because of the FRN or the staffs direct solicitation for comments:
Comment:
The proposed collection of information is not necessary, but it will help with planning future NRC resources to support industry efforts for digital modifications.
NRC staff response:
The proposed collection of information will inform NRCs budget and resource planning for the review of digital I&C license amendment request applications. This will result in more effective scheduling of resources for reviewing these requests and result in the timely completion of the reviews.
Comment:
200hr range for a corporation the size of Constellation is more appropriate.
NRC staff response:
The estimate should reflect the level of effort of various constituents including the licensees that operate large fleet of reactors. The original estimate only reflected the level of efforts to prepare a response but did not reflect the total effort needed to
prepare a response and submit it to the NRC. The estimate in the supporting statement have been updated to reflect the total effort provided by the commenter.
Comment:
The NRC can provide clarity on how far in future they are requesting this information for (ex: 3yrs out, 5yrs)
NRC staff response:
The NRC staff is interested in any future licensing actions that are currently being considered by the licensee whether they plan to submit in 1, 3, 5, or more years.
Comment:
We dont see the need for any forms OR automated collection techniques at this time.
NRC staff response:
Agree.
- 9. Payment or Gift to Respondents Not applicable.
- 10. Confidentiality of Information Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
- 11. Justification for Sensitive Questions No sensitive information is required.
- 12. Estimated Burden and Burden Hour Cost The RIS will be sent to holders of Part 50 operating licenses or Part 52 combined licenses for nuclear power reactors, except those that have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel or combined license holders that have not receive authorization to load nuclear fuel and begin operation. There are 94 operating reactor units at 54 sites that are expected to potentially respond to the survey. The reactor licensees that will respond to the survey are expected to provide one response for all units at sites with multiple units with an indication of whether the requested information is applicable to all units or select units, and if so, which ones. Based on interactions with industry, the NRC anticipates a modest response from reactor licensees. The burden to the public for this voluntary information collection to respond to the survey is estimated to average 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> per response. Because the NRC is also asking industry for voluntary updates the NRC estimates that it will receive responses in
the second and third years of the clearance period, (4.33 respondents, 13 responses total). The staff anticipates on average 4.33 responses per year (5 in year 1 + 4 in year 2 + 4 in year 3). The total annualized burden for the collection is 867 hours0.01 days <br />0.241 hours <br />0.00143 weeks <br />3.298935e-4 months <br /> and 4.33 responses, (see burden spreadsheet) at a cost of $260,100 (867 hours0.01 days <br />0.241 hours <br />0.00143 weeks <br />3.298935e-4 months <br /> x $300/hr.)
Burden estimates for each year in the clearance cycle are included in the supplemental burden spreadsheet.
Table 1. Total Annualized Burden and Responses Hours Responses Year 1 1000 5
Year 2 800 4
Year 3 800 4
Annual Average 867 4.33 The $300 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20 Average cost per professional staff-hour. For more information on the basis of this rate, see the Revision of Fee Schedules, Fee Recovery for Fiscal Year 2023 (88 FR 39120, June 15, 2023).
Additionally, there are no recordkeeping requirements imposed in this clearance.
- 13. Estimate of Other Additional Costs No other additional costs are anticipated.
- 14. Estimated Annualized Cost to the Federal Government The staff has developed estimates of annualized costs to the Federal Government related to the conduct of this collection of information. These estimates are based on staff experience and subject matter expertise and include the burden needed to review, analyze, and process the collected information and any relevant operational expenses.
The annualized cost to the government is estimated to be $15,000 (50 staff hours x
$300/hr).
- 15. Reasons for Change in Burden or Cost The request is a new OMB Clearance.
- 16. Publication for Statistical Use Not applicable
- 17. Reason for Not Displaying the Expiration Date The expiration date will be displayed.
- 18. Exceptions to the Certification Statement The collection of information does not employ statistical methods.
GUIDANCE DOCUMENTS FOR INFORMATION COLLECTION REQUIREMENTS RELATED TO DIGITAL INSTRUMENTATION AND CONTROLS (3150-XXXX)
NEW Title Accession No.
DI&C-ISG-06 Licensing Process Interim Staff Guidance, Revision 2 ML18269A259