ML20198G645

Request for OMB Review & Supporting Statement Re 10CFR61, Licensing Reguirements for Land Disposal of Radwaste. Estimated Respondent Burden 4,887 H

ML20198G645
Person / Time
Issue date:	12/14/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20198F006	List: ML20198F000 ML20198G645
References
OMB-3150-0135, OMB-3150-135, NUDOCS 9812290129
Download: ML20198G645 (15)

Text

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PAPERWORK REDUCTION ACT SUBMISSION g , c,, m T b R

Flerse read the instructions before completing this form. Fcr cdditional forms or rssist nce in completing this form, contict r cg:ncy's PIperw:;rk CIIarance Offic r. Sind two coplIs cf this form ths colliction instrumint to be rsvi wid, tha pportihg Statement, and any additional documentation to: Office of information and Regulatory Affairs, Office of nagemorrt and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503.

1. Agency / Subagency ongmatmg request 2. OMB control number j- U.S. Nuclear Regulatory Commission a. 3150-0135 b.None

3. Type of informaten collechon (check one) gType of revow requested (check one) l _

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a. New collecten g a. Regular c. Delegated

y b. Revision of a currently approved couection b. Emergency . Approval requested by (date)

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l c. Extensson of a currently approved conschon 5. Will this information collection have a a.Yes

- significant economic impact on a -

d. Reinstatement, without change, of a previously approved su'bstantial number of smau entities?

collection for which approval lies expired g b.No

e. Re ly appt ed whgapprov s's skd 4 a. Three years from approval date i f. Existing conect6on in use without an OMB control number **E b. Other (Specify):

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7. Title j 10 CFR 61, Licensing Requirements for Land Dispuel of Radioactive Wastes

8. Agency form number (s) (if app 4cande)

. N/A l g. Keywords N: clear materials, Low-level waste, Reporting and recordkeeping requirements

10. Abstract 10 CFR 61 establishes procedures, criteria, and license terms and conditions for land disposal oflow-level rrdioactive waste. Records and informatian reported is evaluated by NRC to ensure that the licensee's plant,

equipment, organization, training, experience, and procedures provide adequate public protection.

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11. Affected put*c (une anme y me 7ena er omer mer sawy me m

12. Obligaton to respond (us

• pnmery me w one er omm mer sawy wm M

s. Individuals or households d. Farms s. Voluntary

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b. Business or other for-pront

e. Federal Govemment b. Required to obtain or retain benefits

c. Not-for-pront institutions f. State. Local or Tribal GovemmentT c. Mandatory l 13. Annual reportmg and recordkeeping hour burden 14. Annual reporting and recordkeeping cost burden on mousands orsome;

s. Number of respondents 7 s. Total annualized capitaVstartup costs 0 j

b. Totalannualresponses 111 b. Total annual costs (O&M) 0 j

1. Pwcentage of these responses c. Total annualized cost requested 0 cou cted electronicany 20.0  % d. current OMB inventory 0

c. Total annual hours requested 4,887 e. Diftwence 0

d. Current OMB inventory 7,547

f. Explanation of difference

e. Diffwence (2,660) I

1. Program change

f. Explanation of difference

2. Adjustnent

1. Program change

2. Adjustment O'O '

15. Purpose of informaten conecten 16. Frequency of recordkeepeng or reporting (cnock en merapply) fndert prinary e *r and e# omers mer apper wW a. Recordkeeping b. Third-party disclosure

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e. Appilcaten for benefits e. Program planning or management c. Reporting

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T b. Program evaluaten f. Research ] 1. On occasion

2. Wookly

3. Monthly

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c. General purpose statistics T

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g. Regulatory or compien= 4. Quarterty s. SemLannuaisy e. Annually T d. Audit 7. BienniaNy 8. Other (describe) who con best answer owsrons repensnp me

17. 3tatisteal methods 18. Ay nta Does this informaton conection employ statistical methods?

Frank Cardile i Name:

Yes N No Phone. 301-415-6185 .

1 oess as.t = in. mes,.a e w me 10/95 9812290129 981214 PDR ORG EUSOMB 1 PDR j

19,C:rtifl sti:n for. P:perwork Reducti:n Act Submissi:ns .

On behalf of this Federal agency, I certify that the collection ofinformation encompassed by this request complies with *

. 5 CFR 1320.9.

NOTE: De text of 5 CFR 1320,9, and the related provisions of 5 CFR 1320,8 (b)(3), appear at the end of the instructions. The certl/lcation is to be made with reference to thase regulatoryprovisionr ar setforth in the instructions.

De following is a summary of the topics, regarding the proposed collection ofinformation, that the certification covers:

c (a) It is necessary for the proper performance of agency functions; (b) It avoids unnecessary duplication; (c) It reduces burden on small entities; (d) It uses plain, coherent, and unambiguous terminology that is understandable to respondents; (e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; (f) It indicates the retention periods for recordkeeping requirements; (g) It informs respondents of the information called far under 5 CFR 1320.8 (b)(3):

(i) ' .Why the information is being collected; (ii) Use ofinformation; (iii) Burden estimate; (iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature of extent of confidentiality; and (vi) Need to display currently valid Ohm control number, (h) It was developed by an office that has planned and allocated resources for the efficient and effective marvement and use of the information to be collected (see note in Item 19 of the instructions);

(i) It 4ses effective and efficient statistical survey methodology; and

(i) !t makes appropriate use ofinformation technology.

If you are unable to certify compliance with any of these prov'aions, identify the item below and explain the reason in item 18 of the Supporting Statement, l

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Signature of Authonrad Agency Othcel Date Sgnature of Senor i or Date l

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. Shen Off.cor, Office of the Chiefinformaten Officer /

SMSSN

• 10/95 V

i SUPPORTING STATEMENT l FOR l 10 CFR PART 61 l LICENSING REQUIREMENTS FOR LAND DISPOSAL l OF RADIOACTIVE WASTE (3150-0135) i CLEARANCE EXTENSION REVISION Descriotion of the Information Collection NRC regulations in 10 CFR Part 61 establish, for land disposal of radioactive waste, the procedures, criteria, and terms and conditions upon which the Commission issues licenses for the disposal of low-level radioactive wastes containing byproduct, source, and special nuclear material received from other persons. The regulatiora are issued pursuant to the Atomic Energy Act of 1954, as amended, and Title ll of the Energy Reorganization Act of 1974, as amended.

This clearance extension incorporates the information collection requirements for the final rule,

" Termination or Transfer of Licensed Activities: Recordkeeping Requirements," which were approved by OMB on May 21,1996.

A. Justification

1. Need for and Practical Utility of the Information Collection l

The information included in the applications, reports and records is reviewed by the NRC staff

! to ensure the provision of an adequate level of protection of public health and safety, common defense and security, and the environment. Information concerning the requirements imposed by specific sections is provided below.

Section 61.3(b) requires that an application be filed and license be obtained before commencement of construction of a land disposal facility.

The information submitted in the application pursuant to this section and other sections

. described below is reviewed by various NRC organizational units to assess the adequacy of the

( applicant's physical plant, equipment, organization, training, experience, procedures and plans l for protection of the public health and safety, common defense and security, and the environment. The NRC review and the findings derived therefrom form the basis for NRC l decisions conceming the issuance, modification, or revocation of licenses for land disposal of l radioactive waste. 1 l

l Section 61.6 provides that the Commission may grant exemptions from the requirements of Part 61 under specified conditions, upon the application of any interested person or on its own initiative.

L Applications under this section are examined by the NRC staff to determine whether the requested exemption is authorized by law and whether it will not endanger life or property or the common defense and security, and to determine if it is otherwise in the public interest.

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Section 61.9 afb) requires that an applicant or licensee notify the Commission of information which the licensee recognizes as having significant implications for the public health and safety or the common defense and security. This requirement applies only to information which is not covered by other reporting or updating requirements. The information must be provided within two working days.

This requirement is necessary because there may be some circumstances in which a licensee possesses some information which could be important to the protection of public health and safety or the common defense and security but which is not otherwise required to be reported.

The codification of this full disclosure requirement should not result in significant additional burdens on applicants or licensees. No formal program is required. What is expected is that

, licensees will maintain a professional attitude toward safety and that if some potential safety l information is identified by the licensee, the information will be provided freely and promptly to the NRC so that the agency can evaluate it and act on it if necessary.

Section 61.10 requires that an application contain information as set forth in Sections 61.11 through 61,16 and indicates that an environmental report in accordance with 10 CFR Part 51 must also accorepany the application, j Section 61.11 outlines general information needed to clearly identify the applicant, to describe l the applicant's qualifications, and to provide an overview of the project. This information is used to determine who is the legally appropriate licensee, that the applicant can safely conduct the proposed activities, and to understand the scope of the proposed activities.

( Section 61.12 specifies the information required to be submitted concerning the disposal site, including: (a) natural and demographic site characteristics; (b) design features of the land disposal facility and the disposal units; (c) principal design criteria and their relationship to the l performance objectives; (d) design basis natural events or phenomena and their relationship to the principal design criteria; (e) codes and standards applied to the design and which will apply to construction of the facilities; (f) construction and operation of the facility; (g) site closure plan, (h) natural resources at the site that could attract exploitation; (l) radioactive material to be disposed of; (j) quality control program for design, construction, operation and closure; (k) radiation safety program for control and monitoring of radioactive effluents; (1) environmental I monitoring program and plan for corrective measures; (m) administrative procedures to be applied to control activities at the land disposal facility, and (n) a description of the land disposal facility electronic recordkeeping system. This information is needed to permit NRC to determine that the performance objectives of Subpart C of Part 61 and the technical requirements of Subpart D will be met.

Section 61.13 specifies additional technical analyses that must be submitted, including: (a) protection of the general public from releases of radioactive material by various pathways; (b) protection of individuals from inadvertent intrusion; (c) protection of individuals during operations; and (d) natural processes, such as erosion, settlement of wastes, and drainage, I that affect the need for ongoing active maintenance after closure. This information is also required to permit a determination that the performance objectives of Subpart C will be met.

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l' l Section 61.14 specifies the information required to be provided by the site land owner or potential land owner to enable the Commission to determine that adequate institutional arrangements have been made for long-term care of the disposal site.

Section 61'15 requires the submission of financialinformation sufficient to demonstrate that the financ'al qualifications of the applicant are adequate to carry out the activities for which the license is sought and meet other financial assurance requirements as specified in Subpart E.

This information is needed for NRC to determine that there will be sufficient funds to safely carry out disposal and long term care.

Section 61.16 specifies information concerning safeguards and safety, including criticality, that may be required with regard to special nuclear material. This section primarily reflects existing requirements in other parts of the Commission's regulations concerning special nuclear material, and is needed since Part 70 licenses are no longer issued to waste disposal licensees.

The information is reviewed by the NRC licensing staff to assure safety, security, and accountability of special nuclear material.

l Section 61.20 requires applicants to file three copies of the application and retain 85 copies for distribution in accordance with instructions from NRC. The additional copies are required to be provided for review by affected State and local governments, Indian tribes, other Federal agencies, and other p ;rsons or entities affected by or involved in the determination on the application.

Section 61.22(b) requires that the applicant supplement or update the application as necessary prior to issuance of a license. This requirement is needed to ensure that the Commission receives information concerning any changes in the activities proposed to be carried out or new information regarding the proposed activities.

L Section 61.24(b) provides that NRC may require further statements after the filing of the application and before expiration of the license to enable NRC to determine whether the application should be granted or denied or whether a license should be modified or revoked.

Such additional information is sometimes needed to clarify Information submitted in the application, or to rectify deficiencies in proposed or existing programs for protection of the l~ public health and safety, the common defense and security, or the environment.

l The additional information submitted is reviewed by various NRC organ!zational units to assess the adequacy of the applicant's physical plant, procedures and plans for protection of the public health and safety, common defense and security, and the environment. The NRC review and the findings therefrom form the basis for NRC decisions concerning the issuance, modification, or revocation of licenses.

Section 61.24(k) requires that a licensee immediately notify the appropriate NRC Regional Administrator in writing following the filing of a bankruptcy petition by or against the licensee or

a controlling or affiliate entity. No action is required of a licensee unless, and until, a petition for bankruptcy is filed.

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l This information is needed because a licensee who is experiencing severe economic hardship may not be capable of carrying out licensed activities in a manner which protects public health and safety. In particular, a licensee involved in bankruptcy proceedings can have problems l affecting payment for proper handling of radioactive material and for decontamination and I decommissioning of the licensed facility in a safe manner. Improper materials handling or l

decontamination activities can lead to spread of contamination throughout a licensee's facility l and the potential for dispersion of contaminated material offsite. Financial difficulties can also j result in probtems affecting the licensee's waste disposal activities.

The information provided by the notification would be used by the staff to initiate a determination of the need for prompt NRC response or regulatory action in the event of a potential hazard to public health and safety posed by a licensee that does not have the resources to properly secure licensed material or clean up possible contamination. In addition, prompt notification would allow the Commission to take timely and appropriate action in a bankruptcy proceeding to seek to have available assets of the licensee applied to cover costs of cleanup before funds are disbursed and become unavailable for cleanup.

Section 61.26 requires that an application for an amendment of a license must be filed in accordance with Section 61.20 and must fully describe the changes desired. This information is reviewed by the NRC licensing staff to ensure that the desired amendments will afford an adequate level of protection of the public health and safety, the common defense and security, and the environment.

Section 61.27 requires that an application for renewal or site closure must be filed in accordance with Sections 61.10 through 61.16,61.20, and 61.28.

Section 61.28 specifies the information required in an application for site closure following disposal operations. The information will be reviewed by the NRC staff to determine whether, in the case of a renewal, the requirements for a new license are met, and for site closure, whether there is reasonable assurance that the long-term performance objectives of Subpart C of Part 61 will be met.

Section 61.3Q. specifies that the licensee may apply for an amendment to transfer the license to the site owner. The af plication will be reviewed by the NRC staff in order to make necessary findings to ensure that the license for the site can be safely transferred from the site operator to the site owner. The site owner provides licensed institutional control and care of the site for up to 100 years. Section 61.30(a)(3) requires the licensee to transfer any funds for care and l records required by Sections 61.80(e) and (f) to the disposal site owner upon transfer of the license to the disposal site owner. This transfer of funds and records is necessary to ensure that adequate funding and information will be available to maintain the disposal site.

Section 61.31 specifies that, following the period of institutional control, the licensee may apply for an amendment to terminate the license. The application will be reviewed by the NRC licensing staff in order to make necessary findings that institutional control requirements have been met, that any additional requirements resulting from new information developed during the institutional control period have been met, and that permanent monuments or markers warning against intrusion have been installed. Section 61.31(c)(3) requires the licensee to send the i

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records required by Sections 61.80(e) and (f) to the party responsible for institutional control of the disposal site and to send a copy to the NRC Regional Office immediately prior to license termination. Forwarding site records is necessary to ensure that adequate information will be available to maintain the disposal site after it has been closed.

Section 61.53 requires the licensee to maintain an environmental monitoring system, requires plans for taking corrective measures if migration of radionuclides would indicate that the performance objectives of subpart C may not be met, and requires that the licensee must, during site construction and operation, maintain a monitoring program and keep records of l

measurements and observations to provide data for evaluation of potential health and

. environmental impacts.

l Section 61.55(a)(2)(iv) specifies that a licensee may submit a proposal for disposal, pursuant to l l Section 61.58, of waste greater than Class C. This requirement is needed to allow licensees

! the flexibility of safely disposing of waste that does not fit into existing categories. The l information submitted will be reviewed by the licensing staff to determine whether the proposal

! as to waste form and disposal method will provide an adequate level of protection of the public i health and safety and the environment. i Responsibility for disposal of greater than Class C waste was transferred to the Federal government under the Low Level Radioactive Waste Policy Amendments Act of 1985.

l Therefore, no burden is expected to be incurred under this section.

l Section 61.57 requires that each package of waste accepted by the licensee must be clearly labeled by the shipper to identify whether it is Class A waste, Class B wacte, or Class C waste

in order to help insure proper disposal.

Section 61.58 provides that the Commission may, upon request or on its own initiative,  ;

authorize other provisions for the classification and characteristics of waste. Requests under  ;

this section are examined by the staff to determine whether, after evaluation of the specific t characteristics of the waste, disposal site, and method of disposal, there is reasonable j assurance of compliance with the performance objectives of Subpart C.

Section 61.61 requires each applicant to show that its financial position is such that the estimated costs of conducting alllicensed activities can be met. This is needed to help ensure

that the facility will be constructed, operated, and closed according to the license.

Section 61.62 requires the applicant to provide assurance that sufficient funds, including sureties, will be available to carry out orderly disposal site closure and stabilization. This l information will be reviewed by the NRC staff to ensure that sufficient funds are available for l completion of the closure plan, including contingencies to assure adequate closure in the event l of licensee financial problems or early closure.

, Section 61.63 requires the applicant to provide a copy of a binding arrangement (and any j subsequent changes) between the applicant and the disposal site owner that ensures that

sufficient funds will be available to cover the costs of monitoring and any required maintenance

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during the institutional control period. This is necessary to assure that sufficient funds are  !

available for post-closure activities.

i nection 61.72 allows a State or tribal governing body whose interest is affected by a near-surface disposal facility to submit a formal proposal for participation in the review of a license ,

application. This information is necessary in order to provide a State or tribal body greater input during the licensing process.

Section 61.80 specifies requirements for maintaining records and filing reports. Subsection (a) l requires licensees to maintain records and make reports that may be required by the conditions of the license or by the rules, regulations and orders of the Commission. Records and reports provide a primary basis for determination that licensees receive, possess, transfer, and dispose of material as authorized in the license and in accordance with the regulations and orders of the Commission. This requirement provides additional regulatory support for those conditions and provisions and serves to remind licensees that they must comply not only with Part 61 but with other Commission regulations and with specific license conditions. The burden associated with those other requirements is accounted for in the clearances for those regulations.

Subsection (b) requires licensees to maintain records that are required by the regulations or license conditions for the period specified in the regulation or license condition. If a retention l period is not otherwise specified, those records must be maintained for the duration of the license and transferred to the officials specified in Section 61.80(e) upon termination unless the Commission otherwise authorizes their disposition. Subsection (c) authorizes the licensee to use reproduced copies or microfilm for recordkeeping. Subsection (d) provides that in the event there Is a conflict between the regulations, license conditions, or other written approval or

! authorization pertaining to the retention period for a record, the longest retention period l specified takes precedence. Subsection (e) provides that specified data on disposal of wastes

, at the site must be transferred on license termination to a specified local, state, or Federal

! government official.

l The records, record transfers, and record maintenance requirements in Subsections (a)-(e) are needed to provide information to the Commission and other responsible agencies for use in determining that activities are being conducted safely and in accordance with license requirements and other applicable requirements such as leases or local ordinances. The information is needed to evaluate environmental monitoring data and deal with contingencies.

! Data on the wastes would be essential in planning and conducting remedial actions at the sites

! should they be necessary.

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. Subsection (f) requires that the licensee keep records on the waste received for disposal, including date received, a traceable shipment manifest number, a description of any engineered barrier or structural overpack, the volume of pallets or bracing disposed of with the waste, the location in the disposal site, condition of the waste package as received, any discrepancies between the manifest and the waste actually received, and any evidence of leaking or damaged packages or radiation or contamination levels in excess of regulatory limits. The licensee must

also describe any repackaging operations and provide any other information that may be

required by license condition. This information will be used to help generate inventory data and data on the condition of the waste for estimating source terms and identifying problem shippers who need to improve their programs for preparing waste for shipment. The data will be used by

7 the operators to evaluate waste handling procedures to be sure the procedures are adequate to protect workers handling waste in the condition in which it actually arrives, not just as it is expected to arrive. it also permits determination of waste handling time between waste receipt and disposal (potential worker exposures), and permits accurate tracing of the location of waste l within the disposal site.

, Subsections (a) and m provide that the licensee must comply with specified safeguards i i reporting requirements contained in Parts 30,40, and 70 of the Commission's regulations.

Information submitted pursuant to these requirements is needed for the NRC to carry out its statutory responsibility to protect the common defense and security and to permit NRC to take any necessary action in response to a criticality accident or loss or theft of nuclear material. i l

Subsection (h) requires an annual financial report. The stability and financial soundness of disposal site operators is important to prevent abandonment of the sites or inability to carry out disposalin accordance with approved procedures because of shortage of funds. The financial information will be reviewed by the NRC staff for early warning of the possible development of such problems.

Subsection (i) requires an original and two copies of an annual report on site activities. The information to be reported includes summaries of environmental releases, environmental monitoring data, waste that has been disposed of, maintenance activities, and new data on the site, if any. Such surnmary data is needed to help the Commission monitor the continuing validity of the initial findings on which the license was issued.

Subsection (k) provides that the licensee must comply with specified provisions of Parts 30,40, and 70 for any transfer by the licensee of byproduct, source, or special nuclear material.

Subsection (i) requires the low level waste facility operator to store manifest and other i

information pertaining to receipt and disposal of LLW in an electronic recordkeeping system. In addition, the operator must report specified manifest information to the NRC on a computer-readable medium. Because thousands of manifest documents will be used annually, submittal of necessary documentation in a medium other than electronic would be an inefficient use of licensee and NRC resources. Requiring that the data be stored electronically also ensures that the licensee is using the same database as that submitted to the NRC, thus reducing potential duplication and error. All current operators use electronic recordkeeping.

l l 2. Aaency Use of Information The general, technical, institutional, and financial information included in applications is needed to permit the Commission to determine that the proposed activities can be conducted safely and that they will not be inimical to the common defense and security and will not constitute an unreasonable risk to the public health and safety or the environment.

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. 3. Reduction of Burden Throuah Information Technoloav The regulations provide flexibility for the use of improved information technology in information collection and recordkeeping. The approach throuahout Part 61 was to specify the necessary information but not to specify how the information must be maintained. For example, no appli-cation form is specified, and Section 61.80(c) explicitly allows the use of microfilm for recordkeeping. However, Section 61.80(l) requires each low-level waste facility operator to store manifest and other information pertaining to receipt and disposal of LLW in an electronic recordkeeping system. In addition, the operator must report specified manifest information to the NRC on a computer-readable medium. Other information collections under Part 61 are generally not submitted electronically, however, because of the types of information and the infrequency of submission. The reports submitted electronically under Section 61.80(l) make the percentage of electronic submissions for Part 61 in this clearance request approximately 20 percent.

4. Effort to identifv Duolication and Use Similar Information The Inforrnation Requirements Control Automated System (IRCAS) was searched to determine duplication. No duplication was found. Section 61.21 specifically provides an opportunity for the applicant to avoid repetition in filing licensing submittals by referencing previously submitted material.

5. Effort to Reduce Small Business Burden Applicants for operation of a disposal site may be small businesses. However, since the total number of applicants is expected to be small and the information needs are the same for both large and small entities, it is not possible to reduce the burden on small businesses by less frequent or less complete reporting or recordkeeping procedures.

6. Consecuences to Federal Proaram or Poliev Activities if the Collection is Not Conducted or is Conducted Less Frecuentiv Not conducting the information collection or less frequent information collection would compromise NRC's abil!ty to make licensing decisions and monitor the continuing safety of disposal operations. Applications are required only when a licensing action is required.

Reports are required annually on financial status and site operations. Less frequent reports would not give early warning of potential problems.

7. Circumstances Which Justifv Variation from OMB Guidelines Contrary to the OMB Guidelines in S CFR 1320.6(b), Section 61.9a)(b) requires that an applicant or licensee submit a notification to NRC in less than thirty days from the date of identifying information having significant implications for the public health and safety or the common defense and security and which is not covered by other reporting requirements. The requirement to provide notification within two working days following the identification of the information is necessary to ensure that NRC is made aware of the significant safety information so as to take prompt effective action to protect tSe public health and safety.

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Section 61.20 conforms to OMB guidelines in requiring only three copies of the application, but varies from the guidelines in requiring that 85 copies be retained by the applicant for distribution in accordance with instructions from NRC. The additional copies are required to be provided for review by affected State and local governments, Indian tribes, other Federal agencies, and other persons or entities affected by or involved in the determination on the application.

Contrary to the OMB Guidelines in 5 CFR 1320.6(b), Section 61.24(k) requires that licensees submit a notification to NRC in less than thirty days from the date of filing of a petition in bankruptcy. The requirement to provide notification promptly following the filing of the petition is necessary to ensure that NRC is made aware of the bankruptcy so as to take effective action to protect the public health and safety. Allowing a period of thirty or more days to elapse might preclude NRC from becoming aware of the licensee's distressed financial circumstances in time to prevent the development or aggravation of a potential hazard to the public. Moreover, the l United States Code contains requirements regarding notification of creditors in bankruptcy.

l Notifying NRC promptly after the filing of the petition would in fact be less of a burden on the l bankrupt than a separate notification later in the proceedings.

8. Consultations Outside the NRC An opportunity to comment on the information collection requirements in 10 CFR Part 61 was published in the Federal Reaister on September 18,1998. There were no comments.

9. Pavment or Gift to Resoondents Not applicable.

i 10. Confidentiality of Information l

None, except for proprietary information.

11. Justification for Sensitive Questions None.

! e l 12. Estimated Burden and Burden Hour Cott Reoortina Reoutrements l No.of Annual Total Licensee Total Annual i No. of Responses per Annual Staff Hours Licensee l Section Resoondents Resoondent Responses Per Submittal Burden (Hrs) 61.3(b)) 2 0 0 16,000 0 61.6 2 0 0 2 0 )

61.9a(b) 2 0 0 1 0 61.10 Included in 61.3(b) above or in 10 CFR Part 51, OMB No. 3150-0021. i l

61.11 - Included in 61.3(b) above. l 1

61.12 - Included in 61.3(b) above.

61.13 - Included in 61.3(b) above.

61.14 - Included in 61.3(b) above.

61.15 - Included in 61.3(b) above.

61.16 - included in 61.3(b) above or in OMB Clearances 3150-0009 or 3150-0002.

61.20 - Included in 61.3(b) above.

61.22(b) - included in 61.3(b) above.

61.24(b) - Included in 61.3(b) above.

61.24(k) 2 0 0 0.5 0 61.26 2 0 0 500 0 61.27 2 0 0 2,500 0 61.26 - Included in 61.27 above.

61.30 - included in 61.27 above.

61.31 2 0 0 2,000 0 i

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• l 12.' Estimated Burden and Burden Hour Cost (continued) i Reoortina Raouirements (cont'd) ,

1 No. of No.of Annual Total Licensee Total Annual )

l Responses per Annual Staff Hours Licensee L Section Respondents Respondent Responses Per Submittal Burden (Hrs)

L l: 61.55(a)(2)(iv) 2 0 0 2,000 0 61.57 2' 36 72 2 144 61.58 0 0 0 1,000 0 61.61 - Included in 61.3(b) above.

i 61.62 - included in 61.3(b) above.

61.63 - included in 61.27 above.

l 61.72 - included in 61.3(b) above.

l 61.80(g), (j) - Included in OMB Clearances 3150-0017, 3150-0020, and 3150-0009 61.80(h) 2 1 2 1 ~2 61.80(i) 2 8 16 9 144 61.80(l)- 7- 3 21 4 84 Total 111 374 i

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Recordkeeolna Reauirements Total Record No. of Annual Hrs per Recordkeeping Retention Recordkeepers Recordkeeper Hours Period 61.30(a)(3) 1 4.5 4.5 -Duration of License 61.31(c)(3) 1 5.5 5.5 Duration of License 61.53 2 960 1,920 Duration of License 61.80(a)-(f) 7 369 2,583 Duration of License l

61.80(l) - Included in 61.80(f) and 10 CFR Part 20 Appendix G 61.80(k) - Included in OMB Clearances 3150-0017,3150-0020, and 3150-0009 Total 7 Recordkeepers Total 4,513 Recordkeeping Hours TOTAL LICENSEE BURDEN HOURS- 4,887 I

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Estimated Annual Cost to Resoondents The total estimated annual cost to respondents to respond to the collection is $591,327

($121/hr X 4,887 hrs).

The burden and cost estimates are based on NRC staff analyses. Costs are estimated based on a $121 hourly rate.

13. Estimate of Other Additional Costs None.

14.- Estimated Annualized Cost to Federal Govemment The estimated annual cost to the Federal government for reviewing applications and reports, responding to notifications, and inspecting applicable records is $174,482 ($121/hr X 1,442 hrs). This cost is fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.  ;

15. Reasons for Chanaes in Burder, or Cost There is a smallincrease in burden und cost based on inclusion of the recordkeeping hours for ,

Sections 61.30(a)(3) and 61.31(c)(3) made in the May 21,1996 rulemaking (and approved by I OMB). There is a small increase in burden from the May 21,1996 rulemaking to account for sending a copy of records to the NRC under 61.31(c)(3), however there is a decrease in burden and cost based on updated information regarding the number of operational or planned disposal facilities that will report under 61.80(l) and conduct recordkeeping under 61.80(a)-(f).

16. Publication for Statistical Use None.

17. Beason for Not Disolavino the Exo! ration Date The requirements are contained in a regulation. Amending the Code of Federal Regulations to display information that, in an annual publication, could become out of date, would confuse the public.

18. Exceotions to the Certification Statement None.

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

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