ML18170A136

Rroar Draft Evaluation Criteria

ML18170A136
Person / Time
Issue date:	05/31/2018
From:	Margaret Ellenson, Alexa Sieracki Office of Nuclear Material Safety and Safeguards
To:
Andy Carrera 415-1078
Shared Package
ML18170A331	List: ML18170A134 ML18170A135 ML18170A136
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Download: ML18170A136 (10)

Text

Draft Evaluation Criteria Margaret Ellenson and Alexa Sieracki Division of Rulemaking Office of Nuclear Material Safeguards and Security

• Focus the RROAR effort on administrative requirements, which are often information collections.

- Complement the existing NRC retrospective review program.

• Expedite the review of internal and external input.

• Target regulatory changes that may have an appreciable impact.

• This effort is not intended to replace or change the NRCs existing processes for establishing requirements (e.g., the rulemaking process or obligations under the Paperwork Reduction Act).

2

Routine and periodic recordkeeping and reporting requirements, such as directives to submit recurring reports, which the NRC has not consulted or referenced in programmatic operations or policy development in the last 3 years.

• Objective: identify outdated requirements.

3

Reports or records that contain information reasonably accessible to the agency from alternative resources or routine reporting requirements where less frequent reporting would meet programmatic needs.

• Objective: identify duplicative information or overused collection requirements.

4

Recordkeeping and reporting requirements that result in significant burden.

• Objective: target changes that would result in appreciable reductions in burden for the NRC, licensees, or both.

• Examples:

- >$100,000 overall per potential regulatory change;

- > 1,000 reporting hours for each affected individual or entity over a 3-year period; or

- > 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for each affected individual or entity each calendar year or per application.

5

Reports or records that contain information used by other Federal agencies, State and local governments, or Federally-recognized Tribes will be eliminated from the review.

• Objective: mitigate the potential for unintended consequences.

6

• Regulatory changes that the NRC will consider in the ROAR do not need to meet all four criteria.

- Changes will meet either Criterion #1 or #2 and will ideally meet Criterion #3.

• Criterion #4 will be used to eliminate third-party notifications from further consideration under the RROAR.

7

Final Rule: Occupational Dose Records, Labeling Containers, and the Total Effective Dose Equivalent, (12/4/2007, 72 FR 68043)

Reduced the administrative and information collection burdens on NRC and Agreement State licensees without affecting the level of protection for either the health and safety of workers and the public, or for the environment.

• Criterion 1: The information contained in 10 CFR Parts 19, 20, and 50 reports were routine.

• Criterion 2: The staff determined less routine reporting requirements would meet the programmatic needs.

• Criterion 3: The rulemaking effort averted an estimate 132,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year of burden and $135 million (7-percent real discount rate in 2007 dollars).

• Criterion 4: This report wasnt used by another governmental agency.

8

• The Federal Register notice requests public comment on specific topics:

- Do the criteria meet the purpose of the RROAR?

- Thresholds?

• Is significant burden an appropriate measure for considering a regulatory change?

• Bases for measuring significant burden

- Multiple thresholds for different licensee classes?

- Other potential evaluation criteria?

9

Questions?