ML20217J399

Notice of OMB Review of Info Collection Entitled GL 91-02 Reporting Mishaps Involving LLW Forms Prepared for Disposal & Solicitation of Public Comment

ML20217J399
Person / Time
Issue date:	10/20/1999
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20217J404	List: ML20217J399 ML20217J424
References
GL-91-02, OMB-3150-0156, NUDOCS 9910250078
Download: ML20217J399 (10)

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[7590-01-P]

U. S NUCLEAR REGULATORY COMMISSION Agency Information Collection Activities: Submission for OMB Review; Comment request t

AGENCY; U. S. Nuclear Regulatory Commission (NRC).

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ACTION: Notice of the OMB review of information collection and solicitation of public l

comment.

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SUMMARY

The NRC has recently submitted to OMB for review the following proposal for the collection of information under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35). The NRC hereby' informs potential respondents I that an agency may not conduct or sponsor, and that a person is not required to respond to, a collection of information unless it displays a currently valid OMB control r'"mb"r.

1. Type of submission, new, revision, or extension: Extension

2. The title of the information collection: Generic Letter 91-02, " Reporting Mishaps' involving I.LW Forms Prepared for Disposal"

3. The form number, if applicable: N/A.

9910250078 991020 E B PDR ORG

4. How often the collection is required: Reports are made only when the licensee or waste processor experiences a mishap that is reportable under the guidelines described in the Generic Letter.

5. Who will be required or asked to report: Nuclear power reactor licensees and Agreement State and non-Agreement State waste processors and disposal site operators.

6. An estimate of the number of responses: 34 I

7. The estimated number of annual respondents: 34 i l

8. An estimate of the number of hours needed annually to complete the l requirement or request: 272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> (an average of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per response).

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9. An indication of whether Section 3507(d), Pub. L.104-13 applies: Not applicable.

10. Abstract: Generic Letter 91-02 encourages voluntary reporting (by both waste form generators and processors) of informatnon concerning mishaps to low-level radioacuve waste (LLW) forms prepared for disposal. l The information is used by NRC to determine whether follow-up action is necessary to assure protection of public health and safety.

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A copy of the final supporting statement may be viewed free of charge at the NRC Public ,

Document Room,2120 L Street, NW (lower level), Washington, DC. OMB clearance requests are available at the NRC worldwide web site (http://www.nrc. gov /NRC/PUBLIC/OMB/index.html).

The document will be available on the NRC home page site for 60 days after the signature date of this notice.

Comments and questions should be directed to the OMB reviewer by (insert date 30 days after publication in the Federal Reaister):

Erik Godwin Office of Information and Regulatory Affairs (3150-0156)

NEOB-10202

- Office of Management and Budget Washington, DC 20503 Comments can also be submitted by telephone at (202) 395-3067.

The NRC Clearance Officer is Brenda Jo. Shelton,301-415-7233.

Dated at Rockville, Maryland, this I/ day of [h4 Av 1999.

For the Nuclear Regulatory Commission.

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~., jy .k ,VN Brendhlo. Shelton, NRC Ofearance Officer Office of th'e Chief Information Officer.

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t A copy of the final supporting statement may be viewed free of charge at the NRC Public j l

Document Room,2120 L Street, NW (lower level), Washington, DC. OMB clearance requests are available at the NRC worldwide web site (http://www.nrc. gov /NRC/PUBLIC/OMB/index.html).

1 The document will be available on the NRC home page site for 60 days after the signature date of this notice' .

Comments and questions should be directed to the OMB reviewer by (insert date 30 days after publication in the Federal Reaister): -

Erik Godwin ,

Office 'of Information and Regulatory Affairs (3150-0156) l NEOB-10202

. Office of Management and Budget Washington, DC 20503  !

Comments can also be submitted by telephone at (202) 395-3087.

l The NRC Clearance Officer is Brenda Jo. Shelton,301-415-7233. i Dated at Rockville, Maryland, this day of 1999.

For the Nuclear Regulatory Commission. ,

Brenda Jo. Shelton, NRC Clearance Officer Office of the Chief Information Officer.

• Sn previous concurrences -

DOCUMENT NAME: P3OM' \FRN_GL91.02 To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with ettachment/ enclosure "N" = No copy l Tm recalve a copu of this documerit, indicate in the bour "C* = Copy without attachment! enclosure "E' = Copy with attachment / enclosure "N" - No copy 1 0FFICE NMSS/IMNS NMSS/IMNS OCIO/RMB l l NAME JMMcCausland FACardile BShetMa DATE 09/*/99 09/*/99 107::9 /99 <

OFFICIAL RECORD COPY

1 A copy of the final supporting statement may be viewed fr of charge at the NRC Public Document Room,2120 L Street, NW (lower level), W shington, DC. OMB clearance requests are available at the NRC worldwide web site (htt //www.ntc. gov /NRC/PUBLIC/OMB/index.html).

The document will be available on the NRC me page site for 60 days after the signature date of this notice. )

l Comments and questions should e directed to the OMB reviewer by (insert date 30 days after publication in the Federal Re ster):

I Erik Godwin Office of Informa ' n and Regulatory Affairs (3150- )

NEOB-10202 Office of Manadenien; and Budget Washington, C 20503 Comments can al o be submi'ted by telephone at (202) 395-3087.

The NRC Clear nce Officer is Brenda Jo. Shelton,301-415-7233.

Dated at Rockville, Maryland, this , day of 1999.

For the Nuclear Regulatory Commission.

Brenda Jo. Shelton, NRC Clearance Officer

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Office of the Chief information Officer.

DOCUMENT NAME: P:\OMB\FRN_GL91.02 To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N' = No copy OFFICE NMSS/IMNS NMSS/IMNS ,

NAME JMMcCausland inuF FACardile -fC '

DATE 09/29/99 '

09/ 4/99 OFFICIAL RECORD COPY 1

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• I FINAL SUPPORTING STATEMENT FOR

! GENERIC LETTER 91-02 i " REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR DISPOSAL" (3150-0156)

EXTENSION REQUEST Description of the Information Collection NRC is requesting the extension of a previously approved information cotectiori.

The Nuclear Regulatory Commission (NRC) issued Generic Letter 91-02 to encourage voluntary submittal (by both waste form generators and processors) of inforrnation concerning mishaps to low-level radioactive waste (LLW) forms prepared for disposal. This Generic Letter also reminds licensees of their obligation to report defects and deviations in accordance with NRC requirements in 10 CFR Part 21.

A. Justification

1. Need for and Practical Utility of the Collection of information Prior to the issuance of Generic Letter 91-02, NRC collection of information concerning reported mishaps to LLW forms prepared for ultimate disposal in a licensed LLW disposal facility was conducteo through indirect and informal means. Examples of mishaps that were reported included: (1) chemical reactions which occurred in low-level waste shipping containers storing dewatered synthetic organic materials (such as resins), (2) a chemical reaction between a chemical detergent and a waste solidification agent resulting in a boiling of the mixture, and (3) i multiple incidents where cement-solidified bead resin wastes have either not solidified properly or disintegrated over a period of time following solidification. The purpose of Generic Letter 91- l 02 was to ensure that all such events are voluntarily reported to the NRC with adequate  ;

information to determine if follow-up action is necessary, i

2. Agency Use of Information A waste form mishap experienced by one reactor licensee or waste processor may raise the possibility of a generic problem. In that case, an NRC Information Notice or Bulletin would be issued to advise all power reactor licensees, low-level waste processors, and the sited-disposal States of the potential hazard (s) and to encourage (or, in the case of a Bulletin, to request)  ;

licensees to take the appropriate precautions to ensure the protection of public health and safety.

3. Reduction of Burden throuah Information Technoloav There are no legal obstacles to reducing the burden associated with this information collection l by the u3e ofinformation technology. NRC encourages the use of such technologies. The sporadic nature of the mishaps to be reported, however, does not lend itself to the use of such j f information technologies. Consequently, the current percentage of electronic submissions is zero.

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,' 4. Effort to identify Duplication and Use Similar Information l The Information Requirements Control Automated System (IRCAS) was searched to identify

! duplication. None was found. There is no known information available to the Government that is similar to the information identified in the Generic Letter. Information is only provided if a mishap occurs.

5. Effort to Reduce Small Business Burden  ;

A majority of the reports from waste processors are from commercial nuclear power reactor licensees, which are not small entities. Some responses may be received from waste processors that are small businesses. However, since the consequences to public health and safety from waate form mishaps are the same whether reported by a large or a small entity, it is not possible to reduce the burden on small businesses by less frequent or less complete reporting.-

6. Consecuences to Federal Proaram or Policy Activities if the Collection is not Conducted or is Conducted Less Freaue+/f l This is a one-time voluntary submittal when a mishap occurs. It is not possible to permit reporting less frequently. If the information were not collected, NRC would not be able to identify and evaluate a waste form mishap that might raise the possibility of a generic concern, and would be unable to notify other power reactor licensees, waste processors, and sited-disposal States of the potential hazards so that they could take appropriate precautions to protect public health and safety.

7. Circumstances Which Justify Variation from OMB Guidelines Mishaps to LLW forms prepared for disposal should be reported to the NRC within 30 days so that NRC can determine whether (1) waste form requirements of 10 CFR @ 61.56 are met prior to disposal, (2) other waste processors need to be notified of processing problems, and (3) changes to the processing methods are needed.

8. Consultation Outside the NRC An opportunity to comment on the information collection requirements was provided in a Federal Register notice published on June 21,1999 (at 64 FR 33119). No comments were received.

9. Payment or Gift to Resoondents Not applicable

10. Confidentiality of the Information None, except for proprietary information.

11. Sensitive Questions 1

None.

12. Estimated Burden and Burden Hour Cost The actual burden on the licensee or processor is difficult to estimate because only a few of these mishaps have been reported An average mishap report would be about one to three pages in length. The average time to prepare such a repwt is estimated to be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This request includes burden estimates for Agreement State licensees. The burden estimate is provided in the following table.

Number of Surden Hours Respondent Total Annual Respondent Responses /Yr Per Response Burden (Hrs) Burden (Hrs)

NRC Agreement NRC Agreement States States Waste 7 14 8 56 112 168 Processors Disposal Site 3 10 8 24 80 104 Operators Total 10 24 80 192 272 Experience to date has shown the number of responses to be less than 10 per year. Therefore, as a conservctive upper bound, the number of responses is estimated to be no more than 10 per year. This is assumed to be distributed so that three fourths would come frem waste processors and one fourth would come from disposal site operators. The estimate of the number of Agreement State waste processor responses is based on the assumption that the number of such waste processors is approximately double the number of NRC waste processors, hence the number of responses will also be double (2 x 7).

At a rate of $140 per hour, the cost to respondents would be $38,080 (272 hours0.00315 days <br />0.0756 hours <br />4.497354e-4 weeks <br />1.03496e-4 months <br /> x $140/houi).

13. Estimate of Other Additional Costs None.

14. Estimated Annualized Cost to the Federal Government The collection and processing of the information requires approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of NRC staff time per l report (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for headquarters staff and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the regional offices). It is estimated that up to 10 ;

reports will be received per year from non-Agreement-State respondents. It is estimated that up to 24 '

reports will be received per year from Agreement State respondents. At $140 per hour, the annual cost I

to the Federal government would be 576,160 (34 reports x 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> / report x $140). This cost is fully recovered by fee assessments to NRC licensees pursuant to 10 CFR Part 171.

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15 Reasons for Chanoe in Burden or Cost There is no change in burden. The cost estimate has increased because of an increase in NRC's cost

- recovery fee rate from $120 to $140 per hour.-

16. Publication for Statistical Use None.

17. Reason f6/ Not Disolavina Exoiration Date

-' This information collection is contained in a Generic Letter which was distributed to potential

- respondents ni 1991 and still remains in effect. Revising and redistributing Generic Letter 91-02 merely to update the expiration date unnecessarily expends scarce agency resources.

18. Exceptions to the Certification Statement There are no exceptions.

B.. Collection of information Emolovina Statistical Methods Statistical methods are not used in this collection of information. ,

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,, <n,Io, UNITED STATES y ).,,g g NUCLEAR REGULATORY COMMISSION

wAsmNo ros. o. c. 20sss t

%, ..... f 7 ' 2 1 1990 TO: ALL OPERATORS OF LOW-LEVEL RADI0 ACTIVE WASTE (LLW) DISPOSAL SITES, WASTE' PROCESSORS,~ AND ALL !!0LDERS OF LICENSES FOR NUCLEAR FUELS, NUCLEAR MATERIALS AND NUCLEAR POWER REACTORS

SUBJECT:

' REPORTING MISHAPS INVOLVING LLW FORMS PREPARED FOR DISPOSAL (GENERICLZTTER91-02)

Purpose:

For the reasons presented below, the Nuclear Regulatory :ossif ssion (NRC) has decided to rely on voluntary submittal of informational reports by both waste form generators and processors regarding mishaps to'LLW forms prepared for disposal. This Generic Letter is intended to encourage this action on such mishaps. Licensees are also reminded of their obligation to report defects and deviations in accordance with NRC requirements in 10 CFR Part 21.

Discussion:

Background -

NRC has incomplete information on mishaps to LLW forms prepared for disposal.

Four incidents have been reported in which pressurization resulted from chemical reactions in LLW shipping containers storing dewatered synthetic

, organic materials, such as resins (NRC Information Notices 83-14. "Dewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical Reaction," March 21,1983; 84-72, " Clarification-of Conditions for Waste Shipments Subject to Hydrogen Gas Generation," September 10, 198a; 90-50, " Minimization of Methane Gas in Plant Systems and Radwaste Shippir.g Containers," August 8,1990). '

l Another incident was reported in which, during solidification of the waste, a violent reaction occurred between a chemical detergent and a vendor's waste solidification agent (NRC Information Notice 88-08, " Chemical Reactions with Radioactive Weste Solidification Agents," March 14,1988). This reaction j resulted in boiling of the mixture so that it overflowed th. liner, then hardened, and had to be chipped away. Other problems have been encountered in the use of cement to solidify and stabilize bead resin wastes. Thus, there have been multiple incidents in which cement-solidified bead resin wastes have either not solidified properly or have disintegrated over a period of time after solidification.- Although mishaps such as these generally have been made known- to regulatory authorities, mainly through indirect and informal means, there is presently no established method to encourage the reporting of such events and'the providing of adequate information on them.

91-01300223-Ql]CJ2 "S

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. Current Practice -

All three currently-sited Agreement States '1evada, South Carolira, and Washington)'have established requirements in the State licenses for the reporting of waste form and container deficiencies identified by the site operatorsLin wastes shipped to the sites for disposal. In addition, all three facilities have on-site State inspectors who inspect the condition of shipments ,

received by. the disposal-facility operators. This information is provided to j NRC as part of the NRC/ Agreement State exchange of information program. The j staff further notes, however, that neither the Agreement States nor NRC have specific regulatory requirements that apply to all licensees.for reporting of i waste form or_ container deficiencies. Therefore, the States do report what they find,.but they may 'not find some of these problems, because they have no requirement to look for all such events at their disposal facilitier., and they do not presently have the means to be informed routinely of mishaps t!. t occur at NRC-licensed facilities. l 1

Existing reporting requi m :ents contained in 10 CFR 20.403, 50.72, 50.73 and j

'61.80 do not require reporting of waste form mishap information. The j reporting requirement in 10 CFR Part 21 is associated with safety-significant j defects or noncompliances, and may not be interpreted by some to cover mishap l information. 1

' Classes of Needed Information - i l

The staff has identified three classes of useful information that interest NRC and could be reported. These three include:

1. The failure of high-integrity containers used to ensure a stable waste l form. Container failure can be evidenced by changed container dimensions, i I

cracking, or damage resulting from mishandling (e.g., dropping or impacting against another object).

2. The misuse of high-integrity containers, evidenced by a quantity of free liquid greater than 1 percent of container volume, or by an excessive void space within the container. Such risuse is prohibited by 10 CFR 61.56. l l

3. The production of a solidified Class B or C waste form that has any of l the following characteristics: j

- Conta, ins free liquid in quantities exceeding 0.5 percent of the j volume of 'the waste. 1

- Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of waste class.

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- Contains a significantly different waste loading than that used in qualification testing accepteo by the regulatory agency.

- Contains' chemical ingredients no' present in qualification testing accepted by the regulatory agency, and those quantities are sufficient to unacceptably degrade the waste product.

- Shows-instability evidenced by crumbling, cracking, spalling, voids, sof tening, disintegration, nonhomogeneity, or dimensional changas.

- Evidence r' processing phenomena that exceed the. limiting processing conditions identified in applicable topical reports on process control plans, e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material.

Bases for Needed Information -

The voluntary reporting of the three classes of information outlined above would allow the staff access to information o. field experiences with LLW forms and to determine when modifications to test criteria are necessary. 10 CFR Nr: 61 establishes certain " minimum"(61.56(a)) and " stability" (61.56(b))

requircaents for LLW, whereas Part 20-(Section 20.311) requires waste

- generators and processors to certify that the waste satisfied the requirements

. of.Part 61. The Nuclear Material Safety and Safeguards (NMSS) staff reviews

- topical reports and other documents provided by vendors and licensees to ensure that the waste-form requirements of Part 61 will be met and to provide a vehicle with which the certification requirements of Part 20 can be satisfied (by reference). In a parallel effort, the Office of Nuclear Reactor Regulation (NRR) staff reviews information on waste-processing equipment and procedures to ensure that 10 CFR Part -50, App. A " General Design Criteria for Nuclear Power Plants," is satisfied. The NRC staff findings of acceptability and. adequacy of process-control provisions affecting the characteristics of the waste-form produced may require modification, if subsequent experience in the field reveals that the bases for the approvals are being exceeded or are no longer relevant. . Therefore, to make informed decisions on regulatory action, to inform licensees of events that may have generic implications, and to make uinspectors a~ ware of the reported information, the staff needs to have quantitative information on the nature and frequency of occurrence of mishaps ,

regarding waste form and packaging fc disposal.

It is suggested that the voluntary submittal of information regarding waste-form mishaps be reported within.30 days of the incident to NRC's Director l

of the' Division of Low-Level Waste Management and Oe:onissioning and to the designated State disposal-site regulatory authority. .

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,4 This request s coverea c, '#-':a - ":ra:er - tec 2,::4: '. art ce 'luncer:

315C-0156, wnicn'e43 i res Novem:er .:. '. ?!. 'ai ei;' ated aver.3ge ourden is approximately 5 person-hours per 'icersee *esconse, teciuding visual observation.of the waste form misnao, draf ting a description of the observation, and prepariry:a final nishap report for submittal to.NRC.

Comments on the accuracy of this. estimate and sugges: ions tc-rouuce the burden cuy be directed to the Office.of the fianagement anc Budget, Room 3208, tiew Executive Office Building, Washington, D.C. 20503, and the U.S. Nuclear Regulatory Commission, Information and Records Itanagement Branch, Office of Information Resources !!anagement, Washington, D.C. 20555.

- If you have any questions a Jut this . letter, please direct them

- to the technical cont.ct listed below or to the appropriate regional office.

Sincercly, n

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,(ftI,,,,,I L / ar c.o

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- Richard L. Bangart, Directer Division of Low-Level Waste fianagement ar.d Decommissioning, flMSS Technical

Contact:

Michael Tokar, flMSS l (301) 492-0590 l l

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Enclosure:

List of~Recently Issued Generic Letters )

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