ML20128M233

From kanterella
Revision as of 18:39, 7 July 2020 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Cost Analysis Group Review of Proposed New Rule 10CFR39 on Well Logging Operations
ML20128M233
Person / Time
Issue date: 07/19/1984
From:
NRC OFFICE OF RESOURCE MANAGEMENT (ORM)
To:
Shared Package
ML20127B584 List:
References
FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310610
Download: ML20128M233 (3)


Text

- _ _ .

8 i

. 8

. p r

i

[

~

i . ,

1 -

CAG REVIEW 0F PROPOSED NEW RULE 10 CFR 39'

(

ON WELL-LOGGING OPERATIONS

__ /

l Prepared by: COST ANALYSIS GROUP DIVISION OF BUDGET AND ANALYSIS OFFICE OF RESOURCE MANAGEMENT U.S. Nuclear Regulatory Commission .

l l

.s

.g <

! . ' Ld i S

  • e 4); I

%,,' ' % . ,/

8505310610 850530 PDR PR 39 PDR ,

-s .,

=.

] -

1 CAG REVIEW 0F 10 CFR 39: RULE ON WELL-LOGGING OPERATIONS The Cost Analysis Group (CAG) has reviewed the cost analysis of the proposed new Rule 10 CFR 39 on well-logging operation. Our comments by section number are enumerated below.

, Section 4.1.1 l

With regard to NRC costs, from the data you've supplied and appropriate cost assumptions you should be able to determine the total NRC costs in dollars.

You do not state whether the one NRC staff year required is a one-time cost or an annual cost. If it is an annual cost you should calculate present value discounted cost for a time period of, say, 20 years. (Beyond this time period 1

the present value discount factor is so small it can usually be ignored.) We l also recommend a present value discount rate of 10%.

Section 4.1.2 .

Again, for the costs of the other government agencies, you should be able to l determine a total dollar cost.

l Section 4.1.3 The annual costs for licensees for each part of 10 CFR 39 as referenced in Table 1 are detailed in an excellent manner. But the section as a whole ,

leaves questions; (1) are there any initial one-time costs for licensees? (2) is the annual cost for one year expected to continue at a constant level into the future? As indicated in our comment on Section 4.1.1, a single year's annual cost is not sufficient, you should determine the present value for a sum of <

about 20 years of annual costs. In addition, although you specify the current

~

2 number of licensees affected by this new rule, do you anticipate an increase in the number of such licensees over the next 20 years? If so, you should include the present.value discounted costs for these additional licensees over the period during which they are in operation.

Section 4.2.2 This section is mis-numbered as Section 4.4.2; we assume this is merely a typo.

Also in this section, you do not specify who reimburses the Office of the Federal Register. Although you do state that NRC bears these costs in Section 4.1.1, repeating this fact in Section 4.2.2 would add clarity tio your presentation.

There is one more general coment that may require another section and/or table.

. We recommend that you provide a sumary cost / benefit section. You should be able to provide dollar costs for all cost categories (making the appropriate.

explicitassumptions). And although you may not be able to quantify all benefits, you can at least enumerate them and determine how much the total benefits associated with this new rule would cost.

The CAG remains ready to discuss our comments with you and to help you-in implementing any of our comments you shculd so desire.

NOTICE OF OFFICE OF M AN AGEMENT AND BUD 3ET ACTION TO: STEPHEN SCOTT ACTION DATE NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C., 20555 Nuclear Regulatory Commission 04/15/85 ON 04/01/8 5, YOU REQUESTED APPROV AL OF TH5 FOLLOWI NG INFORM ATION COLLECTION:

TITLE: LIC ENS ES AND EADIATION SAFETY REQUIR EM EN TS FOR WELL-LOGGING O P ER ATIONS 10 CFR PART 39 AGENCY FORM NOS.:

.IN ACCORD ANCE WITH THE PAPERRORK REDUCTION ACT, WE HAV E TA KEN THE FOLLOWIN3 ACTION ON'THIS INFORMATION COLLECTION:

A PPROVED FOR USE THROUGH 12/31/87. OMB NO. 3150-0129.

THE OFFICE OF MANAGEMENT AND BUDGET CONTROL NUMBER MUST EE DISPLAYED IN ACCORDANCE WITH 5 CPR 1320. UNLESS OTHERRISE PROVIDED IN " REMARKS,"

EXPIR ATION DATES MUST ALSO BE DISPLAY ED AS REQUIRED BY 5 CFR 1320.

EFFECT.ON BUEDEN: RESPONSES EEPORTING HOURS PREVIOUS STATUS 0 0 NEW STATUS 180 14,539 DIFFEREN CE 180 14,539 EXPLA N ATION OF DIFFERENCE:

ADJUSTMENTS CORRECTION-EREOR 0 0 CORRECTION-REESTIMATE O O CHANGE IN USE O O ,

PROGRAM CHANGES INCREASE 180 14,539 DECREASE O O REMARKS:

NOTICE OF OFFICE OF MAN AGEMENT AN D BUDGET ACTION - PAGE 2 OMB NO. 3150-0129

-ABSTRACT:

THE NUCLEAR REGULATORY COMMISSION IS PROPOSING A NEW 10 CFR PART 39 THAT WOULD REQUIRE A SINGLE SOURCE OF APPLICATION , RECORDKEEPING, REPORTING, AND R ADI ATION SAFETY REQUIREMENT FOR THE USE OF LICENSED D ADID ACTIVE M ATERIAL IN WELL-LOGGING OPEEATIONS BY THE OIL AND GAS INDUSTRY.

ALLO ! ANCE LETTER: NO FUNCTION: EULTIPLE FUNCTIONS ON PLAN: NO EICEED BUDGET: NO 3 504 (H) : N/A

- N O. OF FORMS: 1 USE: PUBLIC- REQUEST: NEW EESPONDENTS: 1 RESPONSES: 180 HOURS: 14,539 AFFECTED PUBLIC: BUS / INST

-SMALL BUSINESS: NO ACTIVITY TYPE: 999 PURPOSE: APPLICATION FREQUENCY: OCCAS COLLECTIOu METHOD: MAIL S/A RETENTI3": COLLECTION AGENT: POSTNG DPT/AGCY CONFIDENTIALITY: NO COMPULSOhY STATUS: REQD FOR BEN FEDERAL COST: PUBLIC COST:

- P EVI EWER : JEFFERSON B. HILL

. ACTION  ! AUTHORIZING OFFICIAL  ! TITLE: DEPUTY ADMI NIST E ATO R ! D AT E APPROVED BY:  !/S/ JAMES B. MACEAE FOR ! OFFICE OF INFORMATION 104/15/05

! !AND REGULATOPY AFFAIRS  !

I MPO RT ANT : BECAUSE THIS INFORM ATION COLLECTIJN HAS BEEN APPROVED, PLEASE SEN]

_TO TH E O. M. B. AS SOON AS AVAILABLE: ONE COPY OF THE FINAL PEINTED (OR OTH E!: k'l S E

' R EPP O DU C ED) REPORT FORM, OR PEPORTING OR RECORDKEEPING R EQU I R EM ENT, TRANS3ITTAL

. LETTER, INSTRUCTIONS, AND ANY DOCU".ENT EEING SENT TO EACH RESPONDENT.

n