ML20203L754

Request for OMB Review & Supporting Statement Re State Agreements Program. Estimated Burden Is 570 H

ML20203L754
Person / Time
Issue date:	02/19/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20203L758	List: ML20203L754 ML20203L763
References
OMB-3150-0029, OMB-3150-29, NUDOCS 9803060210
Download: ML20203L754 (6)

Text

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PAPERWORK REDUCTION ACT SUBMISSION Pirs3 rrd the Instructions b3 fore complIting this form. For additionil forms or assistance 'n compieting this fo.Tn, contact your agIncy's Paperwork Clearance Officer, Send two copies of this form, the collection instrument to be reviewed, tbs Supporting Statement, and ar y additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Ubrary, Room 10102,72517th Street NW, Washington, DC 20503

1. Ag:;ncy/ Subagency originating request 1 OMB control number U.S. Nuclear Regulatory Commission X

a.

3150 0029 b, None

3. Typa of information collection (check onel

4. Type of review requested (check onel

a. New collection X

a. Regular submission

c. Delegated X

b. Revision of a currently approved collection

b. Emergency - Approval requested by (dateh

c. Extension of a currently approved collection

5. Will this information collection have a

,, y,,

d. Reinstatement, without change, cf a previously approved significant economic impact on a collection for which approval has expired substantial number of small entities?

X 1b.No i

~

e. Reinstatement. with change, of a previously approved X

a. Three years frc 1 approval date collection for which approval has expired 6' Requested n

a

f. Existing collection in use without sa OM3 control number expiration date

7. Titta State Agreements Program

8. Ag:ncy form number (s) (if applic>rble/

N/A

9. Keywords Criminal penalties, hazardcus materials transportation, intergovernmental relations, nuclear materials, source materials, special nuclear material, nuclear power plants and reactors

10. Abctract There are unique instances in which Agreement States must be surveyed on a one time or as-needed basis to gather information on licensing and inspection practices and other technical and statistical information.

Such requests, which are authonzed under Sectior 274(b) of the Atomic Energy Act, are used by the Commission for preparing responses to Congressi4allnquiries and requests for information fr other sources

11. Art:cted public IMort prenary wM ?* aM et etners ther ecow wirn *x9

12. obligation to respond IMart ownery wrrn ?* ed et erners that sapN wrrh xy

a. Individuals or households

~

d. Farms

a. Voluntary

~

b. Busmoss or other for prellt

e. Federal oovernment

5. Required to obtain or retam benefits

c. Not for profit instituaans Y f. state, Local. or Tribal oovemment P

c. Mac.datory

13. Annual reporting and recorokeepmg hour burden

14. Annual reporting and recordkeepmg cost burdsn Ifn thoussMs et staaerst

e. Number of respondents 30

a. Total annuall ed capital /startuo coats o

b. Total annual responses 95

b. Total annua. cests to&M) 0

1. Percentage of these responses

c. Total annualized cost requested o

collected electrorncally So%

d. Current OMB inventory o

c. Total annual hours requested

$70 e, oifference o

d. Current oMB fnventory 1.000

f. Explanation of difference e oifference (430)

1. Program change

f. Explanation of difierence

2. Adiustment

1. Program change

2. Atustment (43o)

15. Purpose of information collection

16. Frequency of recordkeeping or recomng Icheck ett that app /v/

/Mert primary wim *P'encr e/Iothers met app 4 with *X*/

e. Recordkeepmg

b. Third-party disclosure

a. Application for benefits

e. Program planning or management T

X

b. Program evaluation

f. Research ~

c Rer'orting

~

X

1. on occasion

2. Weeitly

3. Monthly

c. oeneral purpose statistics Yg. Regulatory or compliance

4. Quarterly

5. semi-annually

8. Annually

d. Audit

8. othe- (descr5e) 7, g;,nni,igy

17. ststistical methods

18. Agency contact tverson who can best answer questions regertfing me content of tnis submission) oose this information collection employ statistical metnods?

Name:

Rosetta O. Virgilio

] Yes X No Phone:

301-415-2307 oMe e3a 9803060210 990219 10/9s PDR ORG EUSOMB PDR

OMB SUPPORTING STAMMEN T FOR OFFICE OF STATE PROGRAMS REQUESTS TO AGREEMENT STATES FOR INFORMATION (3150-0029)

REVISION TO CLEARANCE EXTENSION Descriotion of the Information Collection Section 274(g) of the Atomic Energy Act authorizes and directs the U.S. Nuclear Regulatory Commission (NRC) to cooperate with the States in the formulation of standards for protection against hazards of radiation to assure that State and NRC programs wih 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 techrilcal and statisticalinformation is exchanged. Agreement State comments are also solicited in the areas of propossd implementing prccedures relative to NRC Agreement State program policies. The information requests take the form of one-time surveys, e.g., teleohonic and electronic surveys and facsimiles (questionnaires). The information collection requests have been expanded to take into account the impact of NRC/ Agreement State working groups and the re-defining of the Agreement State Program through the " Statement of Principles and Policy for the Agreement State Program," the " Policy Statement on the Adequacy and Compatibility of Agreement State Programs," and the associated implementing procedures, including the " Integrated dlaterials Performance Evaluation Program."

A.

JUSTIFICATION

1. Nged for and Practical Utility of the Collection Informatiori Prior to 1954, atomic energy activities were largely confined to the Federal government.

Only the Federal government issued licenses to users of radioactive material. In that year, the enactment of the Atomic Energy Act made it possible for private commercial firms to enter the field. Because of the hazards, Congress determined these activities should be regulated under a system of licensing to protect the health and safety of radiation workers and the public. The NRC, as a successor to the Atomic Energy Commission, is charged by Congress with this responsibility.

Protection of 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 t'.; Atomic Energy Act was enacted to spell out a State's role and to provide a statutory basis under which the Federal govemment could relinquish to tho States portions of its regulatory authority. The 1959 amendments made it possible for the States to license and regulate byproduct, source materials, and small quantities of special nuclear material. The' mechanism for the transfer of NRC's au+hority to a State is an agreement between the Govemor of the State and the NRO. Thirty States have entered into such Agreements with NRC. These States now regulate 72% of byproduct, source and special nuclear material licenses in the United States, as permitted by Section 274 of the Atomic Energy Act.

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2 Responsibility for regulating the 21,700 specifically licensed users of radioactive materials is shared between the NRC and the 30 Agreement States. Agreement States regulate a range of fewer than 100 licenses to more than 2,000 licenses. 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 voluntarily exchanged.

2. Agency Use ofInformation The periodic one-time collection of data from the individual Agreement States enables the NRC and States to identify issues and plan and evaluate options for future actions.

The data arc also utilized in prepcring responses to Congressionalinquiries and g

requests for information from other sources. There is no source for obtaicMg such necessary information other than from the Agreement States.

3. Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this infor...ation l

collection through the use of information technology. The NRC encourages the respondents to use any innovative technology which would reduce the burden. The percentage of responses collected electronically is approximately 50%.

4. Effort to identifv Duo:ication and Sirrillar Use Infom1ation l

These one-time or as-needed information collections iodress specific generic issues and events or procedures and guidance that are unique to the Agreement States and to not addressed ty use of existing data collections. The information Requirements Control Automated System (IRCAS) was searched and no duplication was found.

5. Effort to Reduce Small Gusiness Burden There is no impact or burden on small business because the reebients of the requests are State agencies.

G. Conseauences to Federal Proaram or Policy Activities if the Coitection is Not Conducted or is Conducted Less Frecuentiv The information collections are a one-time or as-needed action, which address specific issues generic to the Agreement States. The consequences of not collecting information, such as licensing and inspection practices, incidents and other technical and statisticalinformation, could potentially impact the American public health and safety and also hamper the identification and evaluation of issues and options for the development of program responses to national problems. Fudher, the opportunity for valuable Agreement State review and comment on proposed policy and program updates arid revisions would not be timely or eliminated altogether.

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7. Circumstances Which Justifv Variation From OMB Guidelines Because information would be collected in the most expedient manner possible in order to respond to an exigent or unique circumstance which could affect public health and safety, it is possible that such a request would require a response in less than 30 days, l

8. Consultation Outside the NRC An opportunity to comment on the State /.greements Program information collection requirements was published in the Federal Reaister on December 10,1997 (62 FR 65106). There were no comments.

9. Payment or Gift to Resoondents flot applicable.

10. Confidentiality of the Information l

Proprietary information would be handled with confidentielity, as required under 10 CFR 2.790(d). All otherinformation would be made part of the public record.

11. Justification for Sensitive Questions The NRC does not require the Agreement States to submit anv sensitive information.

12. Estimated Burden and Burden Hour Cost Based upon Agreement State response estimates, the 30 Agreement States expend a total of 570 staff hours annually providing about 95 responses to approximately 20 information requests from NRC at a cost of $71,250. it is estimated that an average of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is expended per response [20 requests x 4.75 responses x 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per response

= 570 staff hours; the annualize6 cost is $71,250 or $125 per professional staff hour x 570 staff nours). The States are not required to mainte:in records of their responses.

13. Estimate of Other Additional Costs None.

14. Estimated Annualized Cost to the Federal Government Based upon staff estimates, NRC spends a total of 118 professional hours annually or, the exchange ofinformation with the Agreement States. Staff experience indicates another 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of clerical time is also expended annually. Based upon current estimates, using the professional and cierical staff hourly rates of $125 and $45, respectively, the annual cost to the NRC is approximately $15,830.

u

4 Ib

15. Reasons for Chanae in Burden The overall burden to Agreement States has been reduced from 1,000 to 570 staff hours-

- because there is a need for fewer requests for information from the Agreement States

- as a result of more information being gathered from NRC/ Agreement State working groups. Based upon past history, the number of Agreement State responses is estimated to decrease from 320 to 95 responses annually. The overall burden per response incteased from 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> because of a reestimate of the amount of time

. required to respond to an inform 9 tion request. The reestimate is based on the Agreement States' estimate of the average amount of time required to respond to an--

Information request.

16. Publication for Statistical Use

- This information will not be published for statistical use.

117. Baason for Not Disolavina the Exoiration Date in the case of an exigent or unique circumstance which would trigger a telephonic NRC survey of Agreement States; the expiration date for OMB approval will be verbally transmitted,

- 18. Excsotion2 to the Certification Statement Not applicable.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS :

Not applicable.

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