ML18166A123
| ML18166A123 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/2018 |
| From: | Division of Inspection and Regional Support |
| To: | |
| Shared Package | |
| ML18166A095 | List: |
| References | |
| NRC-2018-0119, OMB 3150-0090 | |
| Download: ML18166A123 (7) | |
Text
DRAFT SUPPORTING STATEMENT FOR NRC FORM 398, PERSONAL QUALIFICATION STATEMENT - LICENSE, 10 CFR PART 55, SECTIONS 55.31, 55.35, 55.47 AND 55.57 (3150-0090)
EXTENSION Description of the Information Collection The regulations in 10 CFR Part 55, requires facility licensees to certify the qualifications and training. NRC Form 398 is the mechanism by which NRC is advised of the applicant/operator qualifications.
NRC Form 398 Personal Qualification Statement-License is used to transmit detailed information required to be submitted to the NRC by a facility licensee on each applicant applying for new and upgraded licenses or license renewals to operate the controls at a nuclear reactor facility.
The information requested includes the applicant/operator identifying information, type of application and license applying for, license held, position at the facility, education, power reactor operator training program, significant control manipulations, nuclear experience details, applicant/operator signature and signature of certifying facility.
A.
JUSTIFICATION
- 1.
Need for the Collection of Information The information is needed in order to determine facility licensees compliance with the regulations in 10 CFR Part 55. Details of these regulations can be found at the end of this supporting statement in Description of Information Collection Requirements.
- 2.
Agency Use and Practical Utility of Information NRC Form 398 is the mechanism by which NRC is advised of the information that the applicants or operator licensees has met the qualification requirements to become, or continue to be licensed reactor operators or senior reactor operators. The information assists the Commission in basing its finding upon the certification by facility licensees as detailed on NRC Form 398.
- 3.
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 has issued Guidance for Electronic Submissions to the NRC which provides direction for the electronic transmission and submittal of documents to the NRC. Electronic transmission and submittal of documents can be accomplished via the following avenues: the Electronic Information Exchange (EIE) process, which is available from the NRC's Electronic Submittals Web page, by Optical Storage Media (OSM) (e.g.
CD-ROM, DVD), by facsimile or by e-mail. It is estimated that approximately 40% of the potential responses are filed electronically.
- 4.
Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.
- 5.
Effort to Reduce Small Business Burden Not applicable.
- 6.
Consequences to Federal Program or Policy Activities if the Collection is not Conducted or is Conducted Less Frequency Frequency of reporting cannot be discontinued or reduced without violating the NRC licensing requirements as described in 10 CFR 55.31, 10 CFR 55.35, 10 CFR 55.47 and 10 CFR 55.57 which would increase the potential for endangering public health and safety.
- 7.
Circumstances Which Justify Variation from OMB Guidelines Not applicable.
- 8.
Consultations Outside of the NRC Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register.
- 9.
Payment or Gift to Respondents Not applicable.
- 10.
Confidentiality of the Information Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
- 11.
Justification for Sensitive Questions The information is required to determine the applicants has successfully completed the facility licensee's requirements to be licensed as an operator or senior operator and of the facility licensee's need for an operator or a senior operator to perform assigned duties. Without the information the Commission would have no bases for its findings upon the certification by facility licensees.
- 12.
Estimated Burden and Burden Hour Cost The NRC estimates that 1,074 NRC Form 398s are expected to be submitted annually (291 applicants (initial & upgrade), 266 applicants with waivers, 494 license renewals, and 23 re-applications). At the hourly cost of $275, the total industry reporting requirements burden cost is $1,570,525. (See Reporting Burden Table).
Note, there are no recordkeeping requirements imposed with this clearance.
Total Burden and Cost Total Annual Burden (1,891.5 + 2,527 + 1,235 + 57.5) = 5,711 hours0.00823 days <br />0.198 hours <br />0.00118 weeks <br />2.705355e-4 months <br /> Total Burden Hour Cost =1,570,525 (5,711 hours0.00823 days <br />0.198 hours <br />0.00118 weeks <br />2.705355e-4 months <br /> x $275/hour)
The $275 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20 Average cost per professional staff-hour. For more information on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2018 (83 FR 29622, June 25, 2018).
- 13.
Estimate of Other Additional Costs There are no additional costs.
- 14.
Estimated Annualized Cost to the Federal Government The staff has developed estimates of annualized costs to the Federal Government related to the conduct of this collection of information. These estimates are based on staff experience and subject matter expertise and include the burden needed to review, analyze, and process the collected information and any relevant operational expenses. It is estimated that 1,074 NRC Forms 398 will be submitted annually during the clearance period (291 applicants without waivers (initial & upgrade), 266 applicants with waivers, 494 license renewals, and 23 re-applications).
Processing the NRC Form 398 takes approximately 1.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> per application without a waiver, 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per application with a waiver, 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per renewal and 0.50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> per re-application. The NRC Form 398 processing includes data input, file maintenance, and form review regarding eligibility criteria. Data input takes longer for applications because all data must be entered to initially activate an operators docket. Alternatively, re-applications and renewals only require data updates to the existing docket file. At the hourly cost of $275, the total cost to the NRC is $260,838.
- 15.
Reasons for Changes in Burden or Cost Improvements have been made to the NRC Form 398 to aid the applicant.
Instructions have been clarified, and improved formatting changes have been applied to support a future electronic submission option. These changes are not expected to increase the burden associated with completing and submitting an NRC Form 398.
Historical numbers for total responses associated with the NRC Form 398 have remained relatively constant over the past five fiscal years. The previous cycle estimated a response rate of 1,500 responses per year. The number of estimated annual responses has been reduce to 1,074 due, in part, to improved data on the actual number of submitted responses in the past three years. The revised estimate takes into account potential plant decommissionings, the need for the remaining industry re-staff a rapidly retiring licensed operator workforce, and the expected licensing of new plants at Watts Bar Unit 2 and Vogtle Units 3 and 4.
The overall annual industry and Federal Government costs decreased by
$678,566 from $2,249,091 to $1,570,525 as a result of a decrease in the annual fee from $279/hour to $275/hour and due to re-baselining the cycle response estimates based on improved historical data.
- 16.
Publications for Statistical Use None.
- 17.
Reason for Not Displaying the Expiration Date The expiration date is displayed.
- 18.
Exceptions to the Certification Statement Not applicable.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in this collection of information.
DESCRIPTION OF INFORMATION COLLECTION REQUIREMENTS CONTAINED IN NRC FORM 398, PERSONAL QUALIFICATION STATEMENT - LICENSE, 10 CFR PART 55, SECTIONS 55.31, 55.35, 55.47 AND 55.57 (3150-0090) 10 CFR 55.31 requires that the facility licensee certify that an applicant for an NRC operator or senior operator license has successfully completed the facility licensees requirements; the facility has a need for an operator or senior operator to perform assigned licensed duties; and the applicant, as a trainee, has successfully manipulated the either the controls of the facility for which a license is sought or a plant-referenced simulator that meets the requirements of 55.46(c).
10 CFR 55.35 requires the facility licensee to resubmit an application for an applicant whose application was denied because of failure to pass the written examination or operating test, or both, certifying the applicants readiness for re-examination and or to request to be excused from taking the portion previously passed.
10 CFR 55.47 requires that the facility licensee, on application, certify all applicable information in support of a requested waiver of examination, operator experience or medical issue.
10 CFR 55.57 requires that the facility licensee, upon renewal of a license, certify the applicants experience under the existing license; that the operator licensee is capable of continuing to competently and safely assume licensed duties, has successfully completed a requalification program, has passed the requalification examinations and annual operating tests, and there is a continuing need for the operator licensee to operate, or senior operator to direct operators at the facility.
GUIDANCE DOCUMENTS FOR INFORMATION COLLECTION REQUIREMENTS CONTAINED IN NRC FORM 398, PERSONAL QUALIFICATION STATEMENT - LICENSE, 10 CFR PART 55, SECTIONS 55.31, 55.35, 55.47 AND 55.57 (3150-0090)
Title Accession number NUREG-1021 Operator Licensing Examination Standards for Power Reactors ML17038A432 NUREG-1478 Operator Licensing Examiner Standards for Research and Test Reactors ML072000059
ANNUAL REPORTING REQUIREMENTS (3150-0090)
Requirement Description Number of Respondents Responses per Respondent Total Number of Responses Burden per
Response
Total Annual Burden Hours Cost @ $275/Hour Applicants (Initial & Upgrade)
NRC Form 398 291.0 1.0 291.0 6.5 1,891.5
$ 520,163 Applicants with waiver or excusal requests NRC Form 398 266.0 1.0 266.0 9.5 2,527.0
$ 694,925 Applicants - Renewals NRC Form 398 494.0 1.0 494.0 2.5 1,235.0
$ 339,625 Applicants - re-applied NRC Form 398 23.0 1.0 23.0 2.5 57.5
$ 15,813 TOTAL 1,074.0 5,711.0
$ 1,570,525