ML20210G876

Notice of Pending NRC Action to Submit Info Collection Request to OMB & Solicitation of Public Comment Re NRC Form 592, NRC Handling of Your Concerns

ML20210G876
Person / Time
Issue date:	07/22/1999
From:	Shelton B NRC
To:
References
NUDOCS 9908030222
Download: ML20210G876 (12)

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U. S. NUCLEAR REGULATORY COMMISSION Agency Information Collection Activities: Proposed Collection; Comment Request

- AGENCY: U. S. Nuclear Regulatory Commission (NRC)

ACTION: Notice of pending NRC action to submit an information collection request to e

OM and solicitation of public comment.

SUMMARY

The NRC is preparing a submittal to OMB for review and approval of information collections under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapsr 35).

Information pertaining to the requirement to be submitted:

1. .The title of the information collection: NRC Form 592, "NRC's Handling of Your Concerns"

- 2. Current OMB approval number: None

3. How often the collection is required: One time, as allegations are closed.

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2 4.' .Who is. required or asked to report: Individuals who have submitted an allegation to the NRC.

5. The number of annual respondents: 240

6. 1The number of hours needed annually to complete the requirement or request: 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> (one hour per response) l l

7. Abstract: NRC Form 592 is used to conduct a voluntary survey of allegers who bring health and safety concerns to the NRC. The survey is ,

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- used to determine the level of satisfaction or dissatisfaction with NRC's 1

handling of their allegation. The survey will be sent to allegers in various 1 categories (allegers whose allegations were resolved but not substantiated, resolved and substantiated, or resolved and partially l substantiated) whose allegations were filed in each of the four NRC i regional offices and the two major program offices, the Office of Nuclear l

Reactor Regulation and the Office of Nuclear Material Safety and Safeguards. The results of this survey will be used by NRC management to gauge the effectiveness of its existing program and to i

develop programmatic revisions, as needed, to improve its handling of allegations.

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Submit, by (insert date 60 days after publication in the Federal Reoister), comments that address the following questions:

1. Is the proposed collection of information necessary for the NRC to properly perform its functions? Does the information have practical utility?

2. - Is the burden estimate accurate?

3. Is there a way to enhance the quality, utility, and clarity of the information to be collected?

4. How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms of information technology?

A' copy of the draft supporting statement may be viewed free of charge at the NRC Public Document Room,2120 L Street, NW (lower level), Washington, DC. OMB clearance requests 4 are available at the NRC worldwide web site (http://www.nrc. gov /NRC/PUBLIC/OMB/index.html).

The document will be available on the NRC home page site for 60 days after the signature date of this notice.

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Comments and questions about the information collection requirements may be directed to the NRC' Clearance Officer, E 9nda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 E6,

' Washington, DC 20555-0001, by telephone at 301-415-7233, or by Internet electronic mail at BJSi@NRC. GOV.

. Dated at Rockville, Maryland, this.11 day t/h; 1999.

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- For the Nuclear Regulatory Commission, w/n ' c --.

'briiida JoK. elgn, NRCDearance Officer Office of the Chisf Information Officer

4 Comments and questions about the information collection requirements may be directed to the f

NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 E6, Washington, DC 20555-0001, by telephone at 301-415-7233, or by Internet electronic mail at BJS1@NRC. GOV.

Dated at Rockville, Maryland, this day of ( J- 1999.

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, For the Nuclear Regulatory Commission.

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Brenda Jo. Shelton, NRC Clearance Officer Office of the Chief Information Officer i

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• SEE PREVIOUS CONCURRENCE DOCUMENT NAME: P:\0018 Rulemaking.wpd (McCain P:\ drive) l

• E* = Copy with attachment' enclosure *N" = No copy )

Tu receive e copp of this document, indicate in the boa: "C" = Copy without attachment! enclosure 0FFICE AAA:NRR E PIMB:PMAS:NRR E AAA:NRR N OCIO ,, lE NAME *CMohrwinkel DMcCain" M *EBaker BShelt M DATE 07/15/99 07/ 8 l /99 07/15/99 07/pg/99 0FFICIAL RECORD COPY i

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Comments and questions about the information collection requirements may be directed to the NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 E6,

- Washington, DC 20555-0001, by telephone at 301-415-7233, or by Internet electronic mail at BJS1@NRC. GOV.

Dated at Rockville, Maryland, this day of 1999.

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- For the Nuclear Regulatory Commission.

Brenda Jo. Shelton, NRC Clearance Officer Office of the Chief Informatioi Officer e

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DOCUMENT NAME: P:\0018 Rulemaking.wpd (McCain P:\ drive) l

• N 7ge.iv. . copy .i thi. nocum.ni. indic.i. in in. box: c - cooy without ttachmentienclosure 'E = Cop f with attachment / enclosure - No copy 0FFICE AAA:NRR M l E PIMB:PMAS:NRR IE AAA:NRR N OC10 lE EBaker T-O NAME CMohrwinkel DMcCain DYYl B$helton DATE 07/la'/99 07/ I S /99 07/ ' i /99 07/ /99 0FFICIAL RECORD COPY J

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DRAFT SUPPORTING STATEMENT l

FOR NRC FORM 592,"NRC'S HANDLING OF YOUR CONCERNS" (New Collection)

DESCRIPTION OF INFORMATION COLLECTION The NRC plans to institute a voluntary survey cf allindividuals who have submitted allegations to the Agency to determine the level of satisfaction, or dissatisfaction, with the Agency's handling of their allegations. The survey will be sent to all allegers in various categories (allegers whose allegations were resolved but not substantiated; resolved and substantiated; or resolved and partially substantiated); whose allegations were filed in each of the four NRC Regional offices and the two major program offices, the Office of Nuclear Reactor Regulation (NRR) and the Office of Nuclear Material Safety and Safeguards (NMSS). The responses to the survey will be completely voluntary. Survey participants will be asked to give their views, attitudes, and beliefs about the courtesy, timeliness, helpfulness, and responsiveness of the NRC in resolvinggeir allegations. The results of this survey will be used by Agency management to gauge the effectiveness of its existing program and to develop programmatic revisions, as needed, to improve the Agency's handling of allegations. The earlier random surveys in 1995 and 1997 were one of the recommendations of an NRC Review Team in June 1994, which performed a reassessment of the NRC's program for protecting allegers against retaliation. A comprehensive, all-alleger, programmatic assessment form to be included in a':

case close-out correspondence was a recommendation of the Genaral Accounting Office (GAO) when it issued a comprehensive report in March 1997, on nuclear safety concerns.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information As a result of the NRC " reassessment" review completed in June 1.994, and referenced above, the NRC determined that a random " customer satisfaction" survey was needed to determine how well the agency was meeting the' expectations of allegers who filed concerns with the Commission. Two random I surveys were conducted in December 1995, and December 1997. The results of these surveys were used to identify program deficiencies and develop training to assist the staff in becoming more responsive to allegers' concerns.

2. Aaency Use of Information The information obtained from the survey will be used to evaluate the effectiveness of the current method of handling and processing allegations. The information collected will be used to judge the credibility of the allegation program and identify areas for improvement.

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3. Reduction of Burden Throuah Information Technoloav There are no legal obstacles to the use of information technology; however, the information provided by the alleger is sensitive in nature. The only way to submit the information electronically, would be to put the form on the NRC's external web-site. If this were done, there would be no assurance that the person submitting the NRC Form 592 is the person who submitted the allegation. This will create a potential for receiving inaccurate data. The form gives the opportunity for the alleger to express their opinion on how they felt the NRC handled their allegation. This could include mentioning NRC employees by name in a negative sense and could potentially damage their reputation. Having i the ability to electronically submit this form would put the information in a vulnerable position. Therefore this process is not conducive to the use of modern information technologies. Additionally, the recipients may not have access to equipment to submit the information electronically.

4. EffMt to identify Duolication and Use of Similar Information No similar information is svailable to the NRC staff. Furthermore, this information does not duplicate or overlap information collections made by the NRC or other government agencies.

5. Effort to Reduce Small Business Burden This information collection does not significantly affect any small businesses; most of the allegers will be private individuals.

6. Conseauences to Federal Proaram or Policy Activities if the Collection is Not Conducted or is Conducted Less Freauently By not offering all allegers the opportunity to provide their views, the NRC would be losing a potentially valuable source of information. The previously conducted partial surveys resulted in a reassessment of NRC's allegation program. It is anticipated that a survey of all allegers will provide a broader response and more valuable insight.

7. C_ircumstances Which Justify Variation from OMB Guidelines This information collection does not vary from OMB guidelines.

8. Consultations Outside the NRC Opportunity for public comment will be published in the Federal Reaister.

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9. Payment or Gift to Respondents Not applicable.

10. Confidentiality of information The results of this survey will be used to assist the NRC in evaluating the effectiveness of its handling of allegations. The surveys will be mailed to allegers by Office Allegation Coordinators (OACs). The recipients will voluntarily return the forms to the Agency's Allegation Advisor (AAA)/ Assistant AAA who will analyze the surveys. Allinformation received will be treated as confidential and will be shared with the OACs to reconsider specific allegations or to make programmatic improvements.

11. Justification for Sensitive Questions i NoTensitive questions will be used in the survey instruments.

12. Estimated industry Burden and Costs .

l (a) Reportina Reauirements The number of allegations received each year varies. However, the NRC {

projects that approximately 800 allegations will be received annually. The I survey form is completed on a voluntary basis. The NRC estimates that approximately 240 individuals will respond to the survey annually. This estimate is based upon the previous two surveys where the response rate was 30%. The estimated annual reporting burden per allegation response is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. I Total annual burden is 240 X 1 = 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> (b) Recordkeepina Reauirements The AAA shall retain the survey forms from each respondent. Therefore, there are no requirements for industry to retain the survey forms.

(c)- Total Industry Cost and Burden  ;

1 240 survey forms X 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> = 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> X $141 = $33,840 Total annual industry burden is 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br />. Total cost is $33,840.

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13. Estimate of Other Additional Costs None.

14. Estimatd Annualized Cost to the Federal Government Although it is difficult to determine how much time will be spent by the Agency Allegation Advisor and Assistant and the Office Allegation Coordinators reviewing the survey forms and reexamining allegations that may be identified as I problematic by the allegers in their completed survey forms, a reasonable estimate is 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per case. With an estimated survey return rate of 30%  !

based upon previous experience, for the approximately 800 allegations the NRC anticipates receiving this fiscal year, this would amount to approximately 360 l hours of review on the 240 anticipated responses by the various NRC officials.

Based upon previous experience, approximately 40% of the 240 responses will contain negative comments by the allegers, or 96 responses will require l fo!!ow-up activity, based upon experience with the two previous surveys. Such follow-up could be as simple as a case review by the inspector or resident who conducted the initial review or inspected the allegation., which could take 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, or conduct a new inspection, which could take considerably more time.

The average time to complete the follow-up of an allegation is approximately 50 liours. If 25% of the 96 negative responses needed some type of follow-up, approximately 24 cases would need follow-up. The effort to review the 24 allegations needing follow-up would take 1,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of effort (24 x 50 =1,200).

The other 72 negative responses would only require the 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of effort by the inspector or resident mentioned above, for a total time on the responses of 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br /> (72 X 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> = 108 hours0.00125 days <br />0.03 hours <br />1.785714e-4 weeks <br />4.1094e-5 months <br />).

Along with the initial 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> of review, this would total 1,668 hours0.00773 days <br />0.186 hours <br />0.0011 weeks <br />2.54174e-4 months <br /> of effort (360 + 1,200 + 108 = 1,668). At a per hour cost of $141 this would total

$235,188.

This cost is fully recoverable by fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

15. Reasons for Chanae in Burden or Cost New collection.

16. Publication for Statistical Use This information is not published for statistical use.

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17. Reasons for Not Disolavina the Exoiration Date The expiration date is displayed.

18. Exceptions to the Certification Statement None.

B. COLLECTION OF INFORMATION EMPLOYlNG STATISTICAL METHODS Statistical methods are not employed in the collection of information.

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NRc FORM 592 U.s. NUCLEAR REGULATORY COMMisslON APPROVED LY oMB: No. 3150 0000 EXPlREs: MM/DDifffY MM YYYY) Estimat;4 burdIn par response to comply with this voluntIry Collection requist.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> This information is requ;st:d by NRC to assess how effectively the NRC es handling allegations that are received from individuals. send comments regarding burden estimate to the Records Management Branch (T-6 E6). u s Nuclear Regulatory Commission.

NRC'S HANDLING OF wasnington. De 20sss.000i. or by intemet e- to bisionre gav and to the Desk officer. Office of Information and Regulatory Affairs.

YOUR CONCERNS NEOB-10202. (3150-0000). Office of Management and Budget.

Washington. DC 20503 If a means used to impose an information collection does not display a currently valid OMB control number. the ALLEGATlON NUMBER: reN["d toj$ 'n o"rn" t!on'c*o$c"t on' ""# * ** " " ' '* ""*  !

The NRC welcomes your feedback on its handling of your concern (s). Please respond to the statements listed below. J

1. I was satisfied with the NRC's allegation process STRONGLY AGREE DISAGREE

! as outlined in the NRC brochure, " Reporting Safety Concerns to the NRC... AGREE STRONGLY DISAGREE j l

j 2. The NRC understood and acknowledged STRONGLY AGREE DISAGREE my concerns.

AGREE STRONGLY DISAGREE I

The concerns NRC did not understand and/or acknowledge are specified below. I n

3. I was satisfied with the timeliness in resolving my STRONGLY AGREE DISAGREE concerns.

AGREE STRONGLY DISAGREE

4. I was satisfied with the NRC's explanation of their STRONGLY AGREE DISAGREE resolution of my concern.

AGREE STRONGLY DISAGREE

5. If you were less than satisfied with NRC's allegation process, check all areas in which the NRC's performance could have been better. Check as many as apply, but explain your dissatisfaction with each item in the space below.

INITIAL CONTACT CLOSURE LETTER IDENTITY PROTECTION ACKNOWLEDGMENT COURTEOUS AND TECHNICAL REVIEW OF LETTER PROFESSIONAL TREATMENT MY CONCERN STATUS LETTER TIMELINESS SAFETY BROCHURE Explanation of dissatisfaction in areas in which the NRC's performance could have been better.

NRC FORM 592 (MM-YYYY) PRINTED ON RECYCLED PAPER This form was cesegned using inF orrr+s l