Section 28
FINAL SUPPORTING STATEMENT
FOR
REACTOR EVENT REPORTING REQUIREMENTS
10 CFR 50.54(z), 10 CFR 50.72(a)(1), 10 CFR 50.72(a)(2), 10 CFR 50.72(a)(3),
10 CFR 50.72(a)(4), 10 CFR 50.72(b)(1), 10 CFR 50.72(b)(2), 50.72(b)(3), 50.72(c),
and 10 CFR 50 Appendix E
DESCRIPTION OF INFORMATION COLLECTION
The U.S. Nuclear Regulatory Commission (NRC) Emergency Response Data System (ERDS) is the Information Technology that collects plant performance and environmental data for NRC and State emergency personnel to analyze during emergencies or drills.
10 Code of Federal Regulation (CFR) 50.54(z) makes it a license condition that each licensee licensed under Sections 103 or 104b of the Atomic Energy Act shall make the notifications specified in 10 CFR 50.72.
10 CFR 50.72(a)(1) and 10 CFR 50.72(a)(2) require that each power reactor licensee notify the NRC of specified events via the Emergency Notification System (ENS). If the ENS is inoperable, the licensee shall make the notifications via commercial telephone or other means. Many of these events are also subject to follow-up written reports as required by 10 CFR 50.73. These written follow-up reports are covered by a separate Office of Management and Budget clearance, 3150-0104.
10 CFR 50.72(a)(3) specifies notification immediately after notification of State and local authorities and not later than one hour after the licensee declares one of the Emergency Classes. Activation of the ERDS, as required by 10 CFR 50.72(a)(4), is covered in Section 29 of this clearance.
10 CFR 50.72(b)(1) requires notification as soon as practical and in all cases within one hour of the occurrence of any deviation from the plant’s Technical Specifications (TS) authorized pursuant to 10 CFR 50.54(x).
10 CFR 50.72(b)(2) requires notification as soon as practical and in all cases within 4 hours of events such as plant shutdown required by TS, an event that results or should have resulted in an emergency core cooling system discharge into the reactor coolant, an event that results in actuation of the reactor protection system, or any event or situation related to the health and safety of the public or protection of the environment for which a news release is planned.
10 CFR 50.72(b)(3) requires notification as soon as practical and in all cases within 8 hours of events such as (1) an event or condition that results in the nuclear power plant or any of its principal barriers being seriously degraded or the nuclear plant being in an unanalyzed condition that degrades plant safety; (2) events or conditions that result in valid actuation of specified safety systems; (3) events or conditions that could have prevented fulfillment of the safety condition of structures and systems needed to shut down and maintain the reactor in a safe condition, remove residual heat, control the release of radioactive material, and mitigate the consequences of an accident; (4) hospitalization of contaminated personnel; and (5) any event that results in a major loss of communications or emergency assessment capability.
10 CFR 50.72(c) requires that during the course of the event, the licensee shall: (1) immediately report any further degradation, any change of Emergency Class, (2) the results of ensuing evaluations, the effectiveness of response or protective measures, or plant behavior that is not understood; and (3) maintain an open, continuous communication channel with the NRC Operations Center upon request by the NRC.
10 CFR Part 50, Appendix E, Paragraph E.9.d., requires each licensee to perform monthly testing from the control room, the technical support center and the emergency operations facility. Additionally, the ENS system is exercised each morning, usually between the hours of 0400 and 0800 Eastern Time, by the Headquarters Operations Officer's (HOOs) placement of a call to each licensed facility to collect voluntary reactor status and grid information.
These reporting requirements affect 104 currently licensed to operate nuclear power plants.
JUSTIFICATION
Need for and Practical Utility of the Collection of Information
The NRC staff evaluates the information transmitted to the Commission in response to these reporting requirements and makes timely decisions required to provide adequate assurances regarding actual or potential threats to public safety. In addition, operational experience feedback is required to meet the NRC's statutory requirements for regulating the nuclear industry.
Agency Use of Information
The events reported under 10 CFR 50.72 are assessed immediately to determine the adequacy of emergency response actions, if needed. They are also assessed both individually and collectively to determine their safety significance and their generic implications and to identify any safety concerns with the potential to seriously impact public health and safety. The evaluation of these events provides valuable insights on improving reactor safety. Additionally, the reports are provided to the public in order to increase public confidence by demonstrating the NRC operates in a transparent manner.
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 issued a regulation on October 10, 2003 (68 Federal Register (FR) 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e-mail, special Web-based interface or other means. However, 10 CFR 50.72 requires that all information be communicated via an ENS or via a commercial telephone service if the ENS is inoperative. Therefore it is estimated that no information will be filed electronically.
4. Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no duplication of requirements. The NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.
5. Effort to Reduce Small Business Burden
These information collection requirements do not affect small businesses.
6. Consequences to Federal Program or Policy Activities if the Collection is Not
Conducted or is Conducted Less Frequently
Not collecting this data or less frequent data collection would, in general, substantially reduce the NRC's ability to respond promptly to emergencies and would degrade the NRC's ability to assess operating experience and act on the lessons learned in a timely manner, including corrective actions to prevent recurrences.
7. Circumstances which Justify Variation from OMB Guidelines
Notification of significant events is needed within one to eight hours to ensure that the NRC promptly responds to situations with the potential to seriously impact public health and safety. Additionally, it allows the NRC to be informed of significant events in order to respond to public inquiries.
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 May 14, 2013 (78 FR 28244). No comments were received.
9. Payment or Gift to Respondents
Not applicable.
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). However, no information normally considered confidential or proprietary is requested.
Justification for Sensitive Questions
The subject regulations do not request sensitive information.
Estimated Industry Burden and Burden Hour Cost
Based on experience in recent years, it is estimated that about 500 reports per year will be received in response to 10 CFR 50.72. The burden for each call is estimated to be 90 minutes (1.5 hours). Therefore, the total annual burden would be about 750 person hours (1.5 hours x 500 reports) = 750 hours. At $274 per person hour, the annual cost to industry would be about $205,500. Staff estimates that of this burden, 10 percent (75 hours) is attributable to recordkeeping associated with the requirement, and 90 percent (675 hours) is reporting.
During the daily testing of the ENS system by the HOO, voluntary reactor status and grid information is collected. The burden to each licensee to submit this information is estimated to be 5 minutes for a total of 3,151 hours (.083 hrs x 104 licensees x 365 days/yr) for all licensees annually at a cost of $863,374 (3,151 hrs x $274/hr).
The total industry burden is therefore 3,901 hours (75 hours recordkeeping + 3,826 hours reporting [675 hours for 10 CFR 50.72 notifications + 3,151 hours for daily status reporting) at a cost of $1,068,874 (3,901 hrs x $274/hr).
Total number of respondents = 104
Total number of responses = 38,460 (500 + 104 x 365 days/yr).
The estimated cost per burden hour is based upon NRC’s annual fee recovery rate, as published in NRC’s annual fee recovery rule.
13. Estimate of Other Additional Costs
The NRC has determined that the quantity of records to be maintained is roughly proportional to the recordkeeping burden and, therefore, can be used to calculate approximate records storage costs. Based on the number of pages maintained for a typical clearance, the records storage cost has been determined to be equal to 0.0004 times the recordkeeping burden cost. Because the recordkeeping burden is estimated to be 75 hours, the storage cost for this clearance is $8.22 (75 recordkeeping hours x 0.0004 x $274/hour).
14. Estimated Annualized Cost to the Federal Government
Event Analysis
The cost to the Federal government is estimated as follows:
a. Office of Nuclear Reactor Regulation - 4.25 person years (2,080 person hours/per year x 4.25 person years = 8,840 person hours) 8,840 x $274 = $2,422,160.
b. Four Regional offices - 1 person year each (2,080 person hours x 4 = 8,320 person hours) 8,320 x $274 = $2,279,680.
Event Report Receipt
Two operations officers on shift 7 days per week, 24 hours per day, every day
of the year (24 hours/day x 365 days/yr x 2) for a total of 17,520 hours x $274
= $4,800,480 annually.
b. The projected cost of maintaining the emergency telecommunications system
(ETS) (Direct Access Lines) is estimated at $320,000 per year during this
clearance period.
Review of Voluntary Reactor Status and Grid Information
The cost to the Federal government to analyze reactor status and grid information is estimated as follows:
NRC employee evaluation of the information is estimated at 30 minutes for all licensees any given day for a total of 183 hours annually (.5 hrs/day x 365 days/yr) at a cost of $50,142 (183 hours x $274).
Reactor Operating Experience
The Reactor Operating Experience application allows regional and Headquarters users to create reports and view Event Notifications and Power Reactor Status data. The cost of this process is $85,000 per year.
Based on the above, the annual Federal cost associated with these regulations is estimated to be ($2,422,160 + $2,279,680 + $4,800,480 + 320,000 + $50,142 + $85,000) = $9,957,462. The estimated cost per burden hour is based upon NRC’s annual fee recovery rate, as published in NRC’s annual fee recovery rule.
This cost is fully recovered through fee assessments to NRC licensees pursuant to 10 CFR 170 and/or 10 CFR 171.
15. Reasons for Changes in Burden or Cost
The number of event reports estimated to be received per year and the burden for each call remain unchanged from the previous period. The burden for the voluntary submission of reactor status and grid information also remains unchanged from the previous period. The estimated licensee cost has increased slightly based on the increase of the burden cost from $257 to $274 per hour.
16. Publication for Statistical Use
The collection information is not published for statistical purposes.
17. Reason for Not Displaying the Expiration Date
The requirement is contained in a regulation. Amending the CFR to display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.
18. Exceptions to the Certification Statement
There are no exceptions.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Section 28 |
| Author | Leslie A. Hill |
| File Modified | 0000-00-00 |
| File Created | 2021-01-26 |