ML20070U239
| ML20070U239 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1983 |
| From: | NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| NUREG-BR-0058, NUREG-BR-58, NUDOCS 8302100271 | |
| Download: ML20070U239 (30) | |
Text
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ureted states Nuclear Regulatory Onmission Regulatory Analysis Guidelines
@f the U.S. Nuclear Regulatory Commission Office of the Executive Director for Operations January FJ83 i 830131 BR--OO58 R PDR
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December 13, 1982 f
MEMORANDUM FOR: Office Directors and Regional Administrators FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
ADOPTION OF REGULATORY ANALYSIS GUIDELINES TO REPLACE VALUE IMPACT GUIDELINES On December 7,1981, I appointed an interoffice task group to review the Comission's guidelines for performing value impact analyses and to
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recomend changes that would improve their use and quality. The revised guidelines, Regulatory Analysis Guidelines, are enclosed. A regulatory analysis, prepared pursuant to these guidelines, must accompany all proposed rules and final rules to which the guidelines apply which are submitted for review by the Comittee to Review Generic Requirements and the Deputy Executive Director for Regional Operations and Generic Requirements and for decision by the Executive Director for Operations and the Comissioners.
l The guidelines provide for a structured, but general' framework for analyzing alternative regulatory actions. They provide instructions for completing i
tasks necessary for a sound regulatory analysis. They also provide the flexibility to tailor the depth and length of an analysis to the significance of the regulatory action being considered. The procedures also provide for the incorporation of analyses of information collections required by the Paperwork Reduction Act and analyses of impacts on small entities required by the Regulatory Flexibility Act. A checklist approach is recommended for the use by the staff in identifying effects of alternative regulatory actions on other NRC programs, licensee operations, and other activities. A sample checklist is enclosed with the guidelines as well as a list of effects that illustrate consequences that could result in a cost or benefit.
To arsure that other rulemaking actions and non-rulemaking generic require-ments are also supported by a sufficient analysis, an evaluation of the action being proposed that addresses the topics set forth in Section III.B of the
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guidelines must be prepared. The evaluation at a minimum must include an assessment of the costs and benefits of the proposed action compared to the i
existing situation, but need not be as extensive or detailed as required for i
rules which fall within the coverage of the guidelines. The evaluation d
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-c shall accompany all rulemaking actions which do not meet the threshold criteria for performing a regulatory analysis and other generic requirements that are submitted for review to the Comittee to Review Generic Requirements or to the Deputy Executive Director for Regional Operations and Generic Requirements, or for decision by the Executive Director for Operations or the Comission.
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William J. Dircks Executive Director for Operations
Enclosures:
As Stated cc: Chairman Palladino Comissioner Gilinsky Comissioner Ahearne Comissioner Roberts Comissioner Asselstine SECY OGC l
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O REGULATORY ANALYSIS GUIDELINES OF THE UNITED STATES NUCLEAR REGULATORY C0!91ISSION l
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TABLE OF CONTENTS Page I.
Purpose........................................................
1
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II.
Coverage.......................................................
1 III. Instructions for Prcparing a Regulatory Analysis...............
2 A.
Instructions for Preparing a Regulatory Analysis..........
2 1.
Introduction.........................................
2 2.
Scope of the Analysis................................
2 3.
Consideration of Alternatives........................
3 4.
Analyses Required by Statute.........................
3 5.
Relationship to the Generic Environmental-Impact Statement...........................,................
3 B.
Contents and Format for the Regulatory Analysis...........
3 1.
Statement of the Problem.............................
3 2.
Objectives........................................... 4 3.
Alternatives......................................... 4 l
4.
Consequences.........................................
4 a.
Costs and Benefits of Al terr.atives..............
4 b.
Impact on Other Requirements....................
5 c.
Constraints.....................................
5 5.
Decision Rationale...................................
5 6.
Implementation.......................................
5 a.
Schedule for Implementing the Proposed Action...
5 b.
Relationship to Other Existing or Proposed Requirements....................................
6 l
Appendices:
Appendix A - Analyses Required to Justify the Imposition of an Information Collection Requirement....................
A-1 l
1 Appendix B - Analyses Required When a Substantial Number of Smal1 Entities will be Impacted.............................
B-1 Appendix C - Checklist for Identifying Potential Impacts on NRC Programs, Licensee Operations and Other Activities....
C-1 Appendix D - Examples of Effects that Could Result in a Cost or Benefit................................................ D-1 li i
1
'i REGULATORY ANALYSIS GUIDELINES i
I PURPOSE The principal purpose of these Regulatory Analysis Guidelines is to ensure that the NRC regulatory decisions are based on adequate information concerning the need for and consequences of a proposed regulatory action and to ensure that cost effective regulatory actions, consistent with providing the necessary pro-tection of the public health and safety and common defense and security, are l
identified.
High quality regulatory analyses should serve as the basis for NRC decisions.
Therefore, a regulatory analysis must be included in all decision packages on matters covered by these guidelines.
II COVERAGE A.
A Regulatory Analysis, which includes a discussion of any reasonable alternatives to the proposed action, shall be prepared for each proposed i
rule and final rule that, in the determination of the responsible office director or the' Executive Director for Operations, will likely result in the following:
a.
An annual effect on the economy of $100,000,000 or more in direct and indirect costs, or b.
A significant impact on health, safety or the environment, or c.
A substantial increase in the cost to NRC licensees, permit holders l-or applicants, to Federal, state or local governments, and geographical regions, or
- B.
A Regulatory Analysis shall also be prepared for other rules and generic requirements not covered above when directed by the Commission or the Executive Director for Operations.
AThe EDO has directed that other rulemaking actions not covered by the manda-tory, review categories above and non-rulemaking generic requirements submitted for review or approval by the Committee to Review Generic Requirements, the
,. Deputy Executive Director for Regional Operations and Generic Requirements, the EDO or the Commission should also be supported by an analysis based on the guidance provided in Part III.B of the Guidelines but much less detail is l
required.
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III GUIDELINES FOR PREPARING A REGULATORY ANALYSIS A.
Instructions for Preparing a Regulatory Analysis l
1.
Introduction The following guidelines are designed to provide a framework for structuring the analysis required to support proposed and final generic regulatory require-ments. The analysis is intended to aid the staff and the Commission in deter-mining whether to initiate a regulatory action, in selecting the preferred regulatory alternative, and in providing a coherent, understandable, and well-documented explanation of why a particular action was recommended.
Making the performance of a regulatory analysis an integral part of developing a staff position on a proposed regulatory action, not as an afterthought simply.
to meet a procedural requirement, a better and more efficiently prepared analysis should result. Also use of the procedures to outline the scope of the analysis could significantly aid in determining the level of effort and associated resources required to perform a regulatory analysis as well as contributing to the early identification of potential alternatives, possible consequences and information that may be needed to perform the analysis.
A regulatory analysis should accompany all proposed rules and final rules which are covered by these guidelines which are forwarded for review by the Committee j
to Review Generic Requirements or the Deputy Executive Director for Regional Operations and Generic Requirements, or submitted for decision by the Executive Director for Operations or the Commissioners.
2.
Scope of the Analysis The scope of the regulatory analysis should primarily be in proportion to the safety significance of the regulatory action being addressed.
However a rule or generic requirement of small safety significance and large potential costs should be rigorously analyzed.
The emphasis in implementation of the procedures should be on simplicity, flexibility, and common sense, both in terms of the type of information supplied and in the level of detail provided.
Since the l
principal purpose of the procedures is to assure that the proposed action has L
been sufficiently analyzed and the rationale for its selection well documented, staff efforts should be primarily dedicated to achieving this purpose rather th_an spending great effort rigorously analyzing an alternative when it has become apparent that the alternative will not be acceptable. However, the written narrative should indicate the rationale for rejecting any alternative that was seriously considered even though the effort required to reach the decision was limited.
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3.
Consideration of Alternatives A Regulatory Analysis prepared for a proposed rule or final rule covered by
- Sectten II.A of these guioelines should include a discussion of any reasonable alternatives to the proposed action. Alternatives considered should be confined to major alternative regulatory approaches rather than to relatively minor vari-ations of the proposed action.
Among alternatives that could be considered are taking no action at all, making more effective use of existing enforcement mechanisms, establishing performance standards and deregulation when appropriate.
The extent to which costs and benefits should be assessed for alternatives is l
to be determined by the responsible office director.
l 4.
Analyses Required by Statute Information collection requirements (application, reporting and recordkeeping) affecting ten or more persons or organizations must be approved by the Office of Management and Budget (OMB) pursuant to the Paperwork Reduction Act.
Instruc-tions.for addressing factors needed to obtain the OMB's approval are contained in Appendix A.
These factors must be addressed in the regulatory analysis when the alternative regulatory actions involve information collections.
Where a rulemaking action is likely to have a significant impact on a substantial number of small entities, the Regulatory Flexibility Act requires that the impact be addressed specifically. Appendix B provides guidance on the factors that must be addressed when evaluating economic impacts on small entities.
5.
Relationship to the Generic Environmental Impact Statement In those circumstances where a Generic Environmental Impact Statement (GEIS) has been prepared and forms the basis for the proposed action, a brief summary of the GEIS will be an acceptable substitute for Sections III.B.1,2,3,4 of the regulatory analysis guidelines which address the problem. objectives, alterna-tives, and consequences, respectively.
Staff will have to provide an explanation of the rationale for selecting the proposed action and rejecting other alterna-tives considered in the GEIS (Section III.B.5), and &iscribe the implementation.
schedule and relationship of the proposed action to other requirements and programs (Section III.B.6).
B.
Contents and Format of the Regulatory Analysis
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1.
Statement of the Problem Explain the nature of the problem that will be addressed by the proposed regula-tory requirement and why any action is necessary at this time.
Identify the class or classes of licensees, reactors or other facilities affected by the problem.
Discuss any applicable existing or proposed NRC regulatory actions that currently address the problem, their achievements and costs, and sig-nificance of taking no action to address the problem.
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Objectives Within the general objectives of protecting the public health and safety and the common oefense and security and of identifying cost-effective alternatives, precisely state the specific objectives that the proposed regulatory action is designed to achieve.
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Alternatives Identify any reasonable alternatives considered for achieving the specific regulatory objectives.
4.
Consequences Provide an analysis of each alternative considered that discusses the following factors:
a.
Costs and Benefits of Alternatives For proposed rules and final rules above the thresholds set forth in Section II the regulatory analysis should describe the benefits and the costs, including any cumulative effects, that may result from the imple-mentation of the proposed requirement or any reasonable alternative that was considered.
Examples of the types of effects that could result in a cost or benefit are listed in Appendix D.
The analysis should also iden-tify the classes of persons or organizations who will receive the benefits, or incur the costs from the proposed alternatives.
These could include licensees, vendors, licensee suppliers or contractors, the NRC staff, Federal, State or local governments or small business establishments and other small entities. Any effects on geographical regions should also be identified.
The sources of cost data and methodolog: s for deriving costs and benefits i
should be identified and referenced.
Every attempt should be made to quantify the costs and benefits that may result from a particular alterna-tive, even if uncertainties in the data prevent a precisely accurate numerical estimate. Where it is not possible to quantify costs and ben-efits, the reason should be indicated; and the analyst should describe l
the nature and extent of the costs or benefits in as precise and succinct a manner as possible. All assumptions and uncertainties underlying the data and methodologies should be stated.
Where possible, costs and benefits should be expressed in safety, occupa-1
'tional exposure or monetary terms. Monetary costs and benefits should be expressed in present value through the use of an annual discount rate of ten percent (10%).
However, other discount rates may be used to test the sensitivity of the analysis. All benefits and costs which are expressed in monetary terms should be converted to constant dollars (i.e., dollars j
should not be adjusted to reflect anticipated inflation).
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5 The cost of complying with the proposed requirement or part of the pro-posed requirement through the use of a Regulatory Guide or other means deemed acceptable by the NRC should be specifically identified.
4 b.
Impacts on Other Requirements The effect of an alternative on all other NRC programs and requirements, as well as those of other government entities and licensees, should be considered. Any associated costs or benefits should be indicated. The extent to which these effects are addressed should be in proportion to the significance of their impact on the other programs.
Common sense should be used to avoid such considerations becoming a major study effort.
To assist the staff in identifying impacts on other requirements or programs, j
use of a checklist such as the one described in Appendix C is recommended.
c.
Constraints Identify any constraints that affect the implementation of the alterna-tive, including scheduling, enforceability, policy, institutional, or legal considerations.
5.
Decision Rationale Explain why3 -in light of the analyses performed, the proposed action is recom-mended and why other alternatives considered were rejected.
Identify and reference the data or studies on which the decision is based, including ANSI or ASME standards, staff papers or other documents.
Identify any decision criteria used.
Also, it should be indicated if the proposed action represents the staff's definitive position on the subject, or if the requirement is the first or part of a series of related requirements to be issued.
6.
Implementation a.
Schedule for Implementing the Proposed Requirement Describe the steps and schedule, or alternative schedules, that will likely be required to implement the proposed requirement.
Include in the schedule any staff actions which will be needed.
Sufficient information should be provided to demonstrate that the schedule or alternative schedules are realistic. When the proposed action involves short-term and long-term requirements, those requirements should be stated.
Where one or more classes of reactors or other facilities are affected, it should be demonstrated that sufficient time is provided to make required computations, allow the licensee, permit holder or applicant to design any needed new systems or modifications to existing systems, obtain any needed NRC approval of designs or changes in technical specifications, test and evaluate designs, procure equipment and labor, install equipment, develop operating procedures and train operators.
Plant conditions which are necessary for installing equipment, conducting preoperational tests s
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and operable tests should be described.
The length of time a plant must be shut down to meet the proposed requirements should be indicated.
Also indicate whether any required new equipment is available in sufficient
- quantity to meet the needs of all affected licensees or whether it must be designed.
I b.
Relationship to Other Existing or Proposed Requirements Ind* ate the relationship of the proposed action to other existing or pro-posed requirements, its effect on priorities for implementing other requirements for related activities, and if the proposed action means that other actions or systems or prior analyses need to be reassessed.
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I APPENDIX A Analysis Required to Support the Imposition of Information Collection Requirements 4
The Paperwork Reduction Act (P.L.96-511) requires agencies to obtain a clearance from the Office of Management and Budget (OMB) for all information collection requirements (applications, reporting, recordkeeping) that affect 3'
10 or more persons.
The analysis required for DMB clearance must consider the necessity for the proposed information collection, its practical utility, the economic and time burden placed on the person subject to the requirement, lin.!
its cost to the federal government.
All regulatory actions proposed by the l
staff that involve information collections, whether mandatory or voluntary, must be accompanied by an DMB Supporting Statement that justifies and describes the requirement. The regulatory analysis may constitute the supporting state-ment. The following factors must be addressed in any regulatory analysis involving an action which imposes an information collection requirement.
1.
Justification a.
Need for The Inforeation Collection l
Explain why the information collection is needed (i.e., describe any problems that justify the need for the requirement and explain how it is the best means of achieving the regulatory objective).
b.
Practical Utility of the Infaymation Collection Explain to whom the information is to be reported and for what purpose it will be used.
Decribe the NRC's capability to use the reported information in a timely and useful fashion.
Explain the purpose for requiring respondents to maintain information not required to be submitted to NRC.
c.
Duplication With Other Collections of Information If the requirement duplicates or overlaps other information collec-tions made by the NRC or other government agencies, identify those information collections and explain why that information cannot meet
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the need being addressed.
d.
Consultations Outside the NRC Describe any consultations with other Federal, state or local govern-ment agencies or with other organizations or individuals regarding
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the information collection.
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Other Supportino Information Discuss any other information which may help in understanding and evaluating the need for and use of the information collection requirement.
2.
Description of the Information Collection I
a.
Number and Type of Respondents Identify the number and type of respondents to which the information collection requirement applies annually.
b.
Reasonableness of the Schedule for Collecting Information Describe the schedule for imposing the information collection require-ment and explain why it is reasonable within the context of the need for the information.
c.
Method of Collecting the Information 1
Discuss alternative methods, if any, for collecting the information.
If alternatives are available, explain why the information collection requirement selected is the least burdensome method for achieving the regulatory objective, and is consistent with sound management practices.
Examples of less burdensome methods include verification and review of a record at the licensee site rather than submission of a report, submission of reports or retention of records in micro-l form rather than in paper copy, transmission of reports through use of automated word processing or computer means rather than by paper or microform, reduction in the number of copies distributed, simpli-fication.of format, accepting a similar report containing the same information, consolidation of two or more reports into a single report, or conducting interviews or telephone surveys of a sample segment of the licensees affected.
d.
Record Retention Period Identify the record retention period and explain why it is necessary.
Provide justification where records are required to be retained for more than four years.
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Reporting Period Identify the frequency with which the report must be submitted to j
the NRC or other organizations.
If the report is required to be o
submitted more often than quarterly, the need for this more frequent L
reporting should be specifically described.
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Copies Required to be Submitted Identify the number of copies to be submitted, their distribution and usage.
Provide justification where more than three (3) copies are required to be submitted.
3.
Estimate of Burden i
a.
Estimated Hours Required to Respond to the Collection Indicate how much time (staff hours) the respondent will spend annually if it is a recurring or multi year requirement to comply with the information collection requirement.
b.
Estimated Cost Required to Respond to the Collection Indicate how much it will cost (dollars) the respondent annually to comply with the information collection requirement.
c.
Source of Burden Data and Method for Estimatina Burden Indicate the sources from which burden estimates were obtained and the method used to estimate the burden.
d.
Reasonableness of Burden Estimates Explain why the burden estimates are reasonable.
4.
Estimate of the Cost to the Federal Government Describe the annual cost of the information collection to the NRC in terms of staff time and administrative expense.
Costs include time and resources required to obtain, process and store the information, such as "the cost of information collection design development, tests, printing forms, mailing list compilation and maintenance, editing, coding, tabula-tion analyses and publication.
If contractors are involved in the informa-tion collection, then their cost should be included."
Commission procedures for implementation of the Paperwork Reduction Act require each office, through its Information Management Coordinator, to submit the Supporting Statement to the Office of Administration for review before it is submitted to OMB for approval.
Further information on procedures related to the Act will be published in NRC Manual Chapter 0230 " Federal Reports Management."
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APPENDIX B Analyses Required When a Substantial Number of Small Entities Will Be Impacted The Rehulatory Flexibility Act (P.L.96-534) requires an analysis of any pro-posed rule, or final rule that is r eceded by a proposed rule, which is likely to have a significant economic impact on a substantial number of "small entities" (small business establishments, non profit organizations, and small government jurisdictions). The analysis must indicate the criteria used to identify the small entities (annual receipts for sales or service, number of employees, etc.)
and explain how the regulatory action will affect the small entity. - The analyst must determine whether a significant number of the small entities affected are likely to experience substantial economic consequences including additional burdens associated with information collection requirements as a result of the proposed rulemaking action.
It must also include consideration of alternatives which could accomplish the objective of the proposed regulation while minimizing the economic impact on small entities.
l In cases where a proposed rule will not have a significant economic impact on a substantial number of small entities, a " regulatory flexibility certification" to this effect must be included in the Federal Register Notice.
It should be noted that the Regulatory Flexibility Act applies only to rulemaking actions.
I All the information. required for purposes of the Regulatory Flexibility Act should be contained in the analysis prepared pursuant to the Regulatory Analysis Procedures and a separate analysis need not be prepared.
For more information on the Act and its requirements, see " Guidance fer Implementing the Regulatory Flexibility Act and the Preparation of Regulatory Flexibility Analyses," dated j
April 1,1981 (Division of Rules and Records, Office of Administration).
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APPENDIX C i
Checklist for Identifying Potential Impacts on NRC Programs, Licensee Operations and Other' Activities Alternative:
Analyst:
Date:
Instructions:
This sample checklist is designed to aid the analyst in identifying the impacts of each alternative gula-tory action on other NRC programs, licensee operations and other activities.
It is not intended to be all inclusive.
Rather, it is intended to serve as a guide for the analyst who may develop a more comprehensive checklist that would apply to the particular program area.
The analyst should indicate whether each alter-native being considered will affect (1) NRC programs and requirements, (2) licensee programs and operations, (3) interagency or intergovernmental agreements between NRC and other agencies, (4) U.S. international agreements and commitments, and/or (5) other analyses required by law.
The staff responsible for a specific activity should be consulted if the analyst cannot independently determine if an impact on the activity would result.
Each area or program identified as being affected should be evaluated and addressed in the regula-tory analysis.
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il C-2 Checklist A.
NRC Programs and Requirements and Licensee Operations 1.
Indicate the areas or programs which may be affected by each alternative regulatory action being considered for each of the categories listed below:
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i NRC programs and requirements Licensee implementation
- U Licensing Facilities Facilities actions Inspection /
in early in late o
H NRC under enforcement Operating construction construction
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review program facilities stage stage (a) Reactors 1.
Reactor construction, for example:
a.
Seismology b.
Welding c.
Concrete d.
Fire protection e.
Other (specify) 11.
Reactor operations, for example:
a.
Control room b.
Safety checks / tests A
Licensee programs and operation.
Proposed or existing regulations or any implementing guidance such as Regulatory Guides, or NUREGs.
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C-3 NRC programs and requirements Licensee implementation Licensing Facilities Facilities actions Inspection /
in early in late NRC under enforcement Operating construction construction regulations review program facilities stage stage c.
Human factors d.
Fire protection e.
Other (specify) l iii.
Vendor reactor designs v.
Protecting workers from radiation vi.
Protecting members of public in unrestricted areas vii.
Protecting the environment viii. Safeguards physical security l
ix.
Licensee personnel l
access screening program x.
Safeguards infor-mation security program (b) Fuel Facilities and Materials 1.
Protecting workers from radiation 11.
Protecting members of public in unrestricted areas
C-4 NRC programs and requirements Licensee implementation Licensing Facilities Facilities actions Inspection /
in early in late NRC under enforcement Operating construction construction i
regulations review program facilities stage stage l
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Protecting the l
environment l
iv.
Safeguards material control and account-ability vi.
Safeguards physical security vii.
Licensee personnel access screening program viii. Safeguards informa-tion security program ix.
Transportation safety and security (c) Waste management, for example:
i.
Waste management site construction L
a.
Seismology b.
Hydrology c.
Geology d.
Other
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Licensing Facilities Facilities actions Inspection /
in early in late NRC under enforcement Operating construction construction regulations review program facilities stage stage a
11.
Site operations etc.
a.
Public health b.
Environmental considerations iii.
Closure, decommission-ing and long-term care, etc.
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iv.
Transportation 2.
Indicate whether or not the NRC staff w'ill have difficulty in inspecting or enforcing the alternative regulatory action being considered.
3.
Indicate whether the alternative regulatory action being considered will I. ave an impact on the operational status of the facility 4.
Indicate if the alternative regulatory action being considered will have an impact on the NRC:
1.
Export / Import Responsibilities 11.
Rules of Practice (e.g., 10 CFR Part 2) iii. Other (specify)
B.
Licensee Capabilities 1.
Indicate whether or not the alternative regulatory action being considered will have an impact on:
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i.
The size or quality of the licensee's staff 11.
The licensee's ability to:
a.
Develop new equipment or designs b.
Acquire contract services iii. The licensee's program for complying with the requirements of the license?
(e.g., QA tests, training, reporting)
C.
Interagency or Intergovernmental Agreements 1.
Indicate whether or not the alternative regulatory action being considered will have an impact on:
4 1.
The NRC State Agreements Program a.
Licensing of byproduct, source and small quantities of SNM (specifically address changes that may be required of individual s?ates' licensing programs) 11.
Any agreements (MOUs) between NRC and other U.S. Agencies (e.g., DOE, FEMA, EPA, j
111.
Other regulatory programs of Federal and State Agencies D.
U.S. International Agreements i
1.
Indicate whether or not the alternative regulatory action being considered will have an I
impact on:
1.
Bilateral or multilateral agreements between U.S. and other nations relative to t
nuclear trade, imports or exports:
1 11.
U.S. agreements with international agencies (e.g., U.S. - United Nations IAEA Safeguards agreement)
E.
Applicability of Other Analyses Required by Law 1.
Indicate whether or not the alternative being considered will impose an information collection (application, reporting, or recordkeeping) requirement? If applicable, refer to Appendix A.
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Indicate whether or not the alternative being considered is likely to have a significant impact on a substantial number of small entities including those which may be licensees, i
voadors, or suppliers? If applicable, refer to Appendix B.
F.
Indicate Impacts Not Referenced in Sections A through E 1.
Specify i
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V APPENDIX D Examples of Effects that could Result in a Cost or Benefit 1.
RADIOLOGICAL SAFETY CONSEQUENCES (a) Change in accident probabilities; specify the accidents (old, new probabilities)
(b) Change in failure probabilities; describe the equipment directly ana indirectly affected by the proposed action (old, new probabilities)
(c) Change in population at risk (percent and absolute)
(d) Change in occupational exposure; during installation, operation or maintenance (rem)
(e) Change in unplanned radioactive releases offsite (curies)
(f) Change in routine radioactive effluent releases (curies)
(g) Change i' operator response times (seconds / minutes)
(h) Change in maintenance capability (yes/no) (explain) i (i) Change in NRC's inspection and enforcement capabilities (yes/no) 2.
SAFEGUARDS IMPACTS
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(a) Change in facility security (yes/no) (explain)
(b) Change in materials control e,d accountability (yes/no) (explain)
(c) Change in transportation security (yes/no) (explain) 3.
OPERATIONAL IMPACTS (a) Change in reactor availability (hours / days)
(b) Change in facility downtime beyond that normally scheduled (hours / days)
(c) Change in allowable reactor rating (percent and absolute)
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D-2 4.
ECONOMIC TMPACTS (a) Construction cost change (dollars)
(b) Operating cost changes (dollars)
(c) Retrofit costs (dollars)
(d) Recordkeeping and reporting cost changes (staff-hour; dollars)
(e) Change in onsite personnel requirements (staff-hours)
(f) NRC costs change; include contractor technical assistance costs (staff-hours or dollars)
(g) Other increases in applicant expenditures for compliance with regulatory requirements (staff-hours or dollars)
(h) Change in expected direct cost of an accident (dollars) 5.
ENVIRONMENTAL IMPACTS (a) Change in water quality (b) Change in air quality 6.
INFORMATION COLLECTION IMPACTS (Resulting from application, reporting or recordkeeping requirements)
(a) Annual licensee / applicant staff hours (hours)
(b) Annual licensee / applicant cost (dollars)
(c) Annual cost to the NRC (hours / dollars) 7.
OTHER IMPACTS (for example)
(a) Consequences for small Dusiness (dollars / hours)
(b) Significant impacts on vendors, and equipment suppliers (yes/no)
(c) Anti-competitive consequences (impact on viability of existing firms to complete or provide equipment) er i
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D-3 (d) Availability of skilled labor / professional assistance (regional employment ligures by a relevant category)
(e) Number of licensees affected i
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