ML20150E371

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Request for OMB Review & Supporting Statement Re State Agreement Program.Estimated Respondent Burden Is 10,000 H
ML20150E371
Person / Time
Issue date: 07/08/1988
From: Mcdonald W
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:
References
OMB-3150-0029, OMB-3150-29, NUDOCS 8807150101
Download: ML20150E371 (10)


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"Nuclear fadlities, nuclear material" Agreement States are surveyed to obtain comprehensive information on the materials regulatory program in their states.

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. William G. Mcdonald, Director

'7;6 Office of Administration and Resources Management

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SUPPORTING STATEMENT FOR GPA/SLITP REQUESTS T0 AGREEMENT STATES FOR INFORMATION Description of the Information Collection Section 274(g) of the Atomic Energy Act authorizes and directs the Commission to cooperate with the States in the formulatien of standards for protection against hazards of radiation to assure that State and

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Commission programs will be coordinated and compatible. As part of the NRC cooperative post-agreement program with the States, information on

. licensing and inspection practices, and/or incidents, and other technical and statistical.information is exchanged.

A.

JUSTIFICATION 1.

Need for the Collection of Information Section 274(j) of the Atomic Energy Act requires the Commission to periodically review agreements and actions taken by the States to ensure that they remain adequate and compatible and comply with other requirements of the Act.

Prior to 1954, atomic energy activities were largely confined to the Federal government.

In that year, the enactment of the Atomic Energy Act made it possible for private commercial

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. firms to enter the field.

Because of the hazards, Congress determined these activities should be regulated under a systen of licensing to protect the.. health and safety of radiation L

workers and the public.

The Nuclear Regulatory Commission, as a successor to the Atomic Energy Commission, is now charged by Congress with this responsibility.

Protection of the public health and safety has traditionally been a State responsibility, but the 1954 Act did not carve out any specific role for the States.

In 1959, Section 274 of the Atomic Energy Act was enacted to spell out a State role and to provide a statutory basis under which the Federal government could relinquish to the States portions of its regulatory authority. The 1959 amendments made it possible for the States to license and regulate byproduct, source material, and small quantities of special nuclear materials.

The mechanism for the transfer of NRC's authority to a State is an agreement between the Governor of the State and the Commission.

Twenty-nine States have entered into such Agreements with NRC.

These States now regulate 65% of byproduct, source, and special nuclear material licenses in the United States, as required by Section 274 of the Atomic Energy Act.

Their

programs are routinely reviewed by the Connission tu assure that they are adecuate to protect public health and safety and i.

are compatible with'NRC programs, i

l 2.

Agency l'se of Information Information received from Agreement States under this program assists NRC in obtaining a complete picture of the materials regulatory program in the United States: Numbers of licenses (including by type), numbers of inspections and inspection data, leaking sources, licensee incidents, radioactive waste collectors, and disposal sites.

These data provide a basis for assessing the effectiveness of current NRC and Agreement State regulatory programs including identification of regulatory program weaknesses.

The information received also provides a critical part of the data base used by NRC for its l

periodic determinations of adequacy and compatibility of the State programs. There is no source for obtaining the necessary information other than from the Agreement States.

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3.

Reduction of Burden Through Information Technology l

There are no legal obstacles to reducing the burden associated with this information collection through the use of ir. formation technology. The nonrecurrence of each individual collection

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nakes~ it difficult.to reduce the burden through the use of technology. However, the NRC encourages the respondents to use any innovative technology which would reduce burden.

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Effort to Identify Duplication The Federal Information Locator System (FILS) was searched to determine NRC and other Federal agency duplication. None was found.

5.

Effort to use Similar Information The one time information collections would address specific problems or events that are unique and that could not be addressed by use of existing data collections.

6.

Effort to Reduce Small Business Burden There is no major impact or burden on small business for the collection of our required information. However, when small businesses are involved, every effort is made to keep the burden to a minimum within reason, without compromising the safety and health of the American public, i

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Consequences of Less Frequent Collection Information collections are one tine or as needed action r

which address a specific generic problem.

o 8.

Circumstances Whic.h Justify Yariatien From 0MB Guidelines i

Information woulo be collected in the'most expedient manner possible in order to respond to the emergency ond the particular infonnation being requested, a

The respondence universe is 29 States who have signed Section 274b agreements with NRC. The list of Agreement State radiation control program directors prepared by NRC's State, local and Indian Tribe Programs is used as the mailing list.

Licensing statistics and similar data are collected on an as ~

needed basis, or on special matters that could impact the American public health and safety, and often to enable development of program responses to national problems.

Standardized formats are followed by the Statas for some data such as information regarding incidents and medical misadministrations.

For certain incidents, sumaries are requested for inclusion in NRC's Abnormal Occurrence Report to Congress.

Information is also solicited on a case-by-case l

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basis for limited, specific purposes.

In the latter cases, NRC provides specific, written instructions to the States or,-

the nature of the information needed.

In some cases, information.may be requested by telephone.

Pretests are not needed.

Routine information collection follows standardized formats.

Non-routine requests are limited and specific.

Non-responses are handled by written or telephonic follow-up.

9.

Consultations Outside the NRC NRC sponsors an annual meeting of Agreement State radiation control program directors at a three-day meeting, usually in October.

In addition, NRC is one of the Federal agencies which sponsors the Conference of Radiation Control Program Directors, Inc., an organization of State radiation control officials. State radiation control program directors are also consulted individually.

NRC is not aware of any significant problems in this program.

10. Confidentiality of Information Proprietary and safeguards information would be handled with confidentiality.

All other information would be made part of the public record.

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11. Justification'for Sensitive Ouestions Generally, no sensitive questions are asked. Any sensitive questions, however, would be handled with confidentiality.

12.

Estimated Annualized Cost to the Federal Government Based upon manpower system reports, NRC expends about 1,000 professional hours per year on exchange-of-information with the Agreement States.

Staff experience indicates another 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of clerical time also is expended per year.

Based upon current estimates, using loaaed labor rates of $60/ hour and $30/ hour, respectively, the annual cost to Government would be approximately $90,000.

13.

Estimation of Burden NRC contacted six Agreement States where sizes and responsibilities are a' representative cross-section of the Agreement States.

Based upon their estimates, the 29 Agreement States expend a total each year of 10,000 staff-hours providing about 1,000 responses to information requests from NRC. The States are not reqJired to maintain records of their responses.

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.. 14. Reasons for Change in Burden No change.

15.

Publication for Statistical Use Responsibility for regulating the 24,000 specifically licensed users of radioactive materials is shared between NRC and the 29 Agreement States. The latter range from States regulating as few as 59 licenses to over 2,000 licenses.

The collection of data from the individual Agreement States enables assemblage of a data base of the national pattern.

Safety problems affecting workers and the public that may not appear to be significant in small State programs (or may not appear at all) may become apparent in the assembled data base. The data enables the NRC and States to not only identify problems but to also assess the effectiv'eness of existing regulatory programs and for planning and evaluating options for future actions. The data is also utilized for preparing responses to Congressional inquiries and requests for information from other sources, such as the National Governors' Association.

l B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in this collection of information.

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