In accordance
with 5 CFR 1320, the information collection is approved for three
years.
Inventory as of this Action
Requested
Previously Approved
09/30/2014
36 Months From Approved
09/30/2011
21
0
24
1,705
0
1,825
0
0
0
The NRC's Enforcement Policy addresses
circumstances in which the NRC may exercise enforcement discretion.
A specific type of enforcement discretion is designated as a NOED
and relates to circumstances which may arise where a nuclear power
plant licensee's compliance with a Technical Specification Limiting
Condition for Operation or other license conditions would involve:
(1) an unnecessary plant shutdown; (2) performance of testing,
inspection, or system realignment that is inappropriate for the
specific plant conditions; or (3) unnecessary delays in plant
startup without a corresponding health and safety benefit.
Similarly, for a gaseous diffusion plant, circumstances may arise
where compliance with a Technical Safety Requirement or other
condition would unnecessarily require a total plant shutdown, or,
compliance would unnecessarily place the plant in a condition where
safety, safeguards, or security features were degraded or
inoperable. A licensee or certificate holder seeking the issuance
of a NOED, must document the safety basis for the request,
including: an evaluation of the safety significance and potential
consequences of the proposed request, a description of proposed
compensatory measures, a justification for the duration of the
request, the basis for the licensee's or certificate holder=s
conclusion that the request does not have a potential adverse
impact on the public health and safety, that there will be no
adverse consequences to the environment, and any other information
the NRC staff deems necessary before the NRC staff makes a decision
whether to exercise discretion. In addition, the NRC's Enforcement
Policy includes a provision allowing licensees to voluntarily adopt
fire protection requirements contained in the National Fire
Protection Association Standard 805, "Performance Based Standard
for Fire Protection for Light Water Reactor Electric Generating
Plants, 2001 Edition" (NFPA 805). Licensees who wish to implement
the risk-informed process in NFPA 805 must submit a letter of
intent (LOI) to the NRC. Licensees who wish to withdraw from the
NFPA 805 risk-informed process must submit a letter of
retraction.
The overall estimated burden
decreased by 120 hours from 1,825 to 1,705 hours because of a
reduction in the number of expected LOIs from 4 to 1 (3 x 40 hrs =
120 hrs) submittals for this clearance period. This resulted in a
reduction of 120 hours from 1,660 to 1,540 reporting hours. Since
2005, 15 licensees have submitted LOIs, which averages to three
submittals per year. However, at the present time, we have no
indication that any new licensees will be submitting a letter of
intent to transition to 10 CFR 50.48(c). The remaining licensees
that have not elected to file a letter of intent may at any time
decide that the performance-based program may be desirable. There
is reason to believe that once the process has been successfully
demonstrated through the completion of the first group of non-pilot
applications, more licensees may decide to file a letter of intent.
Given this and the number of remaining licensees that could submit
an LOI, it is estimated that 1 LOI annually could be submitted
during this clearance period. The NRC does not expect to receive
any letters of retraction. Although there has been an increase in
the fee rate from $258 to $259, the reduction in LOI submittals
resulted in a decrease in overall burden cost from $470,850 to
$441,595.
$113,960
No
No
No
No
No
Uncollected
Sheldon Stuchell 301
415-1847
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Final NOEDs Supporting Statement.doc
Notices of Enforcement Discretion (NOEDs) for Operating Power Reactors and Gaseous Diffusion Plants (GDP)