ML20199J845

Request for OMB Review & Supporting Statement Re Doe/Nrc Forms 741 & 741A, Nuclear Matl Transaction Rept & NUREG/BR-0006.Estimated Respondent Burden Is 24,000 H

ML20199J845
Person / Time
Issue date:	07/01/1986
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
RTR-NUREG-BR-0006, RTR-NUREG-BR-6 OMB-3150-0003, OMB-3150-3, NUDOCS 8607080449
Download: ML20199J845 (8)

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"" *'"'"" 8 3 Request for OMB Review nameom m y

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Read instructions before completing form. Do not use the same SF 83 Send three copies of this form the material to be reviewed, and for to request both an Enecutive Order 12291 review and approval under paperwork-three copies of the supporting statement. to-the Paperwork Reduction Act Answer all questions in Part 1. If this request is for review under E.0, Of fice of Information and Regulatory Af fairs 12291, complete Part il and sign the regulatory certification if this Office of Management and Budget rIquest is for approvat under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 32ol 1320, skip Part II, complete Part til and sign the paperwork certification.

Washington, DC 20503 PART I,-Complete This Part for All Requests.

1. Dep2rtment/ agency anc Bureau / office onginatirig request

2. Agency code U.S. Nuclear Regulatory Commission 3 1 5 0

3. Name of person who can best answer Questions regardmg this request Telephone number June Robertson (301 ) 427-4233

4. Title of information collection or rulemaking 00E/NRC Form 741 and 741 A - Nuclear Material Transaction Report and NUREG/BR-0006

5. Legat authority for enformation coiiect'on or rule tcote Umted States Coae. Pubhc Law. or Enecutsve Order) 42 usc 2201(o)

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6. Affected pubhc(checkallthatapply) s O rederaiagenciesorempioyees 1 O ind viduais or nousehoids 3 0 rarms 6 0 non prof,t institutions 2 O state oriocairo,ernments 4 0 eusinesses or other for-profit 7 El smaiibusinessesororganizations PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulation identifier N ;rnber (RIN)

_., or, None ass.gned O

8. Type of submissron (check one in each category)

Type of review requested Classificatforr Stage of development 1 O standard 1 O uajo, 1 O proposedordraft 2 O Pending 2 O Nonmajor 2 O rinatorinterimfinai.w,tnpriorproposai 3 0 Emergency 3 0 renai or intenm finai. witnout pnor proposai 4 0 statutory or rudiciai deadiine

9. CFR section affected CFR

10. Does this regulation cor tain reporting or recordpeeping requirements that recuire OMB approval under the Paperwork Reduction Act and 5 CFR 1320'

. O ves O no

11. If a mijor rule. is there a regulatory ernpact analysis attached' i O yes 2 O no if"No." did OM8 wan,e the analysis' 3 0 ves 4 0 no CertificStion for Regulatory Submissions i

in submittmg this request for oMB rev ew, the authorized regulatory contact and the program official certify that the requirements of E O 12291 and any appl cable l

i potecy directives have been compleed with s-gnature of program offcal Date s:gnature of authon/ed regu'atory cor' tact Date 8607080449 860701 PDR ORG EUSOMB

12. (OMB use only)

PDR Prewous ed tens ubsolete

8) log standard Form 8)(New 9 B U PEN 754o 00 634-4034 p, gr, bed by (W8 5 CFR I120 andI o iml

PART lil.-Camplzt2 This P rt Only if ths Rgquest is f ar Appr:vilcf a C lltcti:n of Information Under the P perwirk RIducti;n Act tnd 5 CFR 1320.

13. Abstract--Descnba needs, uses and af fected putWe in 50 words or less

" Nuclear facilities, Radioactive materials, Nuclear facility safeguards" NRC and Agreement State licensees are required to make inventory and accounting reports for certain source or special nuclear material inventory changes, for transfers or receipts of

- special nuclear material, or 1 kilogram or more of source material.

14. Type of information collection (ct'ect only one)

Information collections not containedin rules 1 @ Regular submission 2 O Emergency submission (certificatenattaused)

Information collections contained in rules 3 O Esisting regulation (no change proposed) 6 Final or intenm final without pnor NPRM

7. E nter date of expected or actual Federal 4 0 Notice of proposed rulemaking(NPRM)

A O Regular submission Register pubhcation at this stage of rulemaking 5 0 rinai. NeRM was previousty pubbsned B O Emergency submission (certifrcation attached)

(month, day, year):

15. Type of review requested (check only one) 10 Newcollection 4 0 Reinstatement of a previously approved collection for which approval h*5'"S

• 2 O Revision of a currentry approved co+iection 31 Extension of the expiraten date of a currently approved collection 5 O Existing collection in use without an oMB control number without any chanEe in the substance or in the method of collection

16. Ag2ncy report form number (s)(include standard /optionalform number (s))

22. Purpose of information collectson (check as many as apply)

DOE /NRC Form 741 & 741 A, & NUREG/BR-0006 10 Apphcation for benefits 2 O Programevaiuaten

17. Annual reportir g or disclosure burden 3 0 ceneraipurposestatistics 1 Number of respondents.

IE00 4 @ Regulatory or comphance 2 Number of responses per respondent 16 5 O Program planningormanagernent 3 Total annuai responses (line J times t ne 2) 24.DD L 6 O Research 4 Hours per response 1

7 O Audit 5 Total hours (ime 3 times lene 41 24.000

18. Annualrecordkeepingburden

23. Frequency of recordkeeping or reporting (check allthatapply) l 1 Number of recordkeepers 1 O Recordbeeping 2 Annual hours per recordkeeper.

Reporting 3 Totai recordkeeping hours (kne l times tene 2) 2 0 onoccasion 4 R:cordkeepmg retention period years 3 0 weekly 19.. Total annual burden 4 O Monthiy 1 R equested (hne 175 plus kn* 18-3).

24,000 5 0 quarterty 2 in current oMB inven ory 121,000 6 0 semi.annuairy 3 Difference (hne J less hoe 2)

- 92.000 7 O Annually Esplanation of difference 8 0 Biennially 4 Program change 9 0 otner(desenbe):

5 Adjustment.

_ 1Q Q QO

20. CurrInt (most recent) oMB control number or comment number

24. Responce N obhgation to comply (check the strongest obhgation thatapplies) 3150 nnn2 1 O vo u ry

21. Requested empiration date 2 O Required to obtain or retain a benefit 3, vaa re f enm a nn enva l ria to 3 E3 Mandatory

25. Are the respondents pnmanfy educational agencies or institutens or is the pnmary purpose of the collection related to Federal education programs? O ves a No

26. Does the agencg use samphng to select respondents or does the agency recommend or prescnbe the use of samphrig or statistical analysis

. O yes G No by respondents.

27, Regulatcry authonty for the information collection I

10 CFR dn;6d; En;71; 70_Ed;;gld;lE FR

or,other (specsfy) 75.31, 75.34, 150.16, 150.17, Paperwork Certtf6 cation in submitting thrs request for oMB approvat tre agency head, the senior official or an authonred representative, certifies that the requirements of 5 CFR 1320, the Pnvacy Act, statistical standards or directives, and any other applicable mformation policy directives have been comphed with s.gnstureof program official oate s gnitura of agency head the senior officiat or an authortred representatrve oate

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i SUPPORTING STATEMENT FOR DOE /NRC FORM 741, 741A, AND NUREG/BR-0006 l

Justification Need for the Information Collection.

In order for the United States to fulfill its responsibilities as a participant in the US/IAEA Safeguards Agreement and to carry out its domestic safeguards responsibi-i lities, it is necessary for licensees affected by 10 CFR Part 75 and re-lated sections of Parts 40, 50, 70, 74 and 150 to submit accounting reports.

4 The accounting reports for each IAEA material balance area must include inventory change reports showing all changes in the inventory of nuclear material.

NRC regulations (10 CFR 40.64, 50.71, 70.54, 74.15, 75.31, 75.34,150.16 and 150.17) require NRC and Agreement State licensees to make certain inventory and accounting reports for reporting any special nuclear material j

(SNM) or source material inventory changes that meet certain criteria; for each transfer and receipt of SNM of one gram or more of contained uranium-235, uranium 233, or plutonium, or any combination thereof; or one kilogram or more of source material (depleted uranium, natural uranium, or thorium).

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DOE /NRC Form 741, " Nuclear Material Transaction Report" and its continuation sheet, Form 741A, are used for the collection of this information. PRC and the Department of Energy (D0E) jointly utilize a Nuclear Materials Management and Safeguards System (NMMSS). Common 1

reporting forms are used to minimize the reporting burden on industry i

members required to provide nuclear material data to one or both agencies 5

in accordance with prevailing regulations or contractual obligations.

The licensee is thus able to file one report to meet the requirements of both agencies. Compliance with specific reporting requirements is monitored by the agency for which the specific data is required.

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Agency Use of Information. NRC is required to collect nuclear material transaction information for domestic safeguards use and make it available

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j to the IAEA. The use of Forms 741 and 741A, together with NUREG/BR-0006, the instructions for completing the forms, enables NRC to collect, retrieve, analyze as necessary, and submit the data to IAEA to fulfill its reporting responsibilities. Without these report forms, in ADP format, NRC's ability 4

to collect and provide this data would be grely limited.

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. Reduction in Burden Through Information Technology. There are no legal l

obstacles to reducing the burden associated with this information collection.

However, licensees have the option of submitting the required information on a facsimile of the form and transmitting the information electronically.

Effort to Identify Duplication. The Federal Information Locator System was searched to determine NRC and other Federal agency duplication.

There is a small amount of duplication in that, upon termination of licensed operations by a licensee, NRC requires the licensee to file NRC Form 314, reporting the transfer or other disposition of any remaining licensed radioactive material, and the date of transfer. This small duplication imposes a minimal burden on licensees, and is necessary to maintain accountability of licensed material in NMMSS and to permit NRC to make a determination whether the facility has been cleared of radioactive material and is suitable for release for unrestricted use or whether additional decontamination measures may be required.

Effort to Use Similar Information.

NRC and the Department of Energy jointly utilize the Nuclear Materials Management and Safeguards 5ystem to process and store and subsequently retrieve the information contained on the forms. The licensee is able to file one form to meet the require-ments of both agencies. This minimizes the reporting burden on industry members required to provide nuclear material data to both agencies.

Effort to Reduce Small Business Burden.

Burden on licensees will vary with the size and type of licensed operation.

The burden on small businesses will represent approximately five vaccent of the total burden.

Further reduction would not enable the NRC to fulfill its international or domestic responsibilities.

Consequences of Less Frequent Collection.

If the requested information is collected less frequently, the NRC would be unable to have current knowledge of locations of nuclear materials as is required.

Circumstances Which Justify Variation from OMB Guideline. There was no variation from OMB guidelines.

Consultations Outside NRC. There have been no consultations outside NRC since the previous clearance of these forms.

Confidentiality of Information.

Information on the form may qualify as business or financial confidential under the Code of Federal Regulation, Title 10, Part 2.790.

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. Justification for Sensitive Questions.

None.

Description of the Information Collection Number and Type of Respondents.

This reporting requirement affects approximately 1500 persons licensed by the NRC or an Agreement State to possess source or special nuclear material at certain types of facilities, or at any location in amounts greater than one effective kilogram.

Method and Schedule for the Information Collection. Forms and instruc-tions are provided 60 all affected licensees by NRC. Reports are required as occasioned by the occurrence of specified events, such as the receipt, transfer, or adjustment to inventory of licensed material. Reports are collected on a continuing basis as transactions occur. The data is entered into the NMMSS as received.

The information is not compiled and published.

However, it is available to the public for inspection and copying.

Copies Required. There is no variation from OMB guidelines.

Three copies of the form are required to be submitted.

One copy is filed with NRC and two copies are submitted to the receiver of the shipment.

The receiver completes the forms, returns one to the shipper, and sends one to NRC.

Estimate of Burden Estimated Hours Required to Respond to the Information Requirement.

The burden for preparation and submission of each report is e,timated to be one hour.

The number of reports submitted annually will vary with the size and type of licensed operation.

Large licensees with complex operations may submit 1,000 forms annually.

Small licensees may submit 50 forms annually. A total of approximately 24,000 reports are expected to be submitted annually.

Thus, the total resulting burden i

for all licensees will be 24,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. The decrease in burden from the previous clearance is attributable to a misinterpretation of the reports count for CY 1982 Estimated Cost to Respond. The average annual cost to each respondent to comply with this requirement is estimated to be $960.00. The total annual cost to all affected licensees is estimated to be $1,440,000. Cost estimates are based on a rate of $60/ hour.

Source of Burden Data and Method of Estimating Burden. This data is based on informal consultations by the staff with a small number of typical licensees and on actual reports submitted by licensees during CY 1985.

e Estimate of Cost to the Federal Government. The estimated annual cost to the government for processing this form is $395,000.

Annual Cost - NRC Staff Review (Professional effort - 5 min / form @ $60/hr)

= $120,000 Annual ADP Cost

= $275,000*

Total Annual Cost

= $395,000*

Publication for Statistical Use.

None.

Collections of Information Employing Statistical Methods.

None.

NRC and DOE share the cost of operating the Nuclear Materials Management and Safeguards System (NMMSS). Current and projected cost of the system is:

FY 86, $1.1 million; FY 87, $1.1 million; FY 88, $1.1 million. As indicated in the Supporting Statement for 10 CFR Part 73, ONB No. 3150-0002, 75% of the cost of the system is attributable to Part 73. The remaining 25%

is attributable to these nuclear materials transaction and accounting report forms. This includes the cost of ADP, record holding, and clerical processing of all forms (DOE /NRC Foms 741, 741A, 740M, 742, 742C, and IAEA Form N-71).

It is not possible to suballocate this cost to individual forms.

For simplicity, this entire cost is allocated to Form 741 (0MB No.

3150-0003) and is omitted from the cost data for the remaining foms.

Annual Cost = $1.1 + $1.1 + $1.1

= $3.3 million = $1.1 million of System 3

3 Annual ADP Cost = $1.1 million = $275,000 Attributable to Forms 4

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