ML20215H953

Request for OMB Review & Supporting Statement Re 10CFR74, Matl Control & Accounting of Snm. Estimated Respondent Burden Is 5,649 H

ML20215H953
Person / Time
Issue date:	06/17/1987
From:	Mcdonald W NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:
References
OMB-3150-0123, OMB-3150-123, NUDOCS 8706240272
Download: ML20215H953 (16)

Text

I og Request for OMB Review = tomo er y rm seenr>~ tun pg ~

C6FMM W-important v Read instructions before completing form Do not use the same SF 83 Send three copies of this form, the matenal to be reviewed, and for to request both an ExecutWe Order 12291 review and approval under paperwork-three copies of the supporting statement, to:

the Paperwork Reduction Att Answer aH questions in Part 1. If this request is for review under E.O. Office of information and Regulatory Affairs 12291, complete Part 11 and sign the regulatory certification If this Office of Management and Budget request is for approval ur. der the Paperwork Reauction Act and 5 CFR Attention. Docket bbrary, Room 3201 1320, shp Part li complete Part ill and sign the paperwork certsficahon Washington, DC 20503 PART l.-Complete This Part for All Requests.

1. Department;atenc y and Bureauf of fice orgmatmg request 2. Agency code U.S. Nuclear Regulatory Commission 3 45-.0_

Dame of person who can best answer Questions regard ng this request Telephone number Charles U. Emeigh (301 )42Z-4769

4. Title Of information conection or ruiemasics 10 CFR 74, Material Control and Accounting of Special Nuclear flaterial

b. tctai autncnty *ce mto mat,on costect an ce ru!e ccite Umted States coce. P :n c Las. or becstwe Orcer) 42_usc 2201(c) +

6. Affected pubhc (check ah that arply) 5 C Federa! agencies or employees 1 O ina+duais or nousenoics 3 0 ratrns c 0 Non prof.t institutions

? O state or ioci coar-meats 4 3 Bus nesses or other for prost 7 Q small busmesses or orranizations PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulation Icent4 e N smber(RIN)

_ _ . ~ _._ _ _ _, _ , or, None assigned O ETfoe of suomnssson (checs one m ecch catesoo) Type of review requested Classification Stage of development

_ 10 Stancard 1 C Maior  ! U Proposed or ora't 2 U Pending 2 C Nonmajor 2 O rmainontenmf nai w ino"ororcposal 3 Emergency 3 U Fmai or inteom final without poor propo.,a! 4 C Statutc ry or Judicial deadiene

9. CF R section af fectec CFR

10. Does this rerviatroa contain report ng or recordkeeping recu:rements that recurre OMB approva' under the Poperwork Reduction Act and E CFR 1320' . C Yes C No

11. If a major rute 6 rina, or intenm finai witnout pno, NeRu 7. Ente, eate o, e,pected o, actuai redeiai 4 O Notice of proposed rutemaking(NPRM) A O Reguiar s bmission Reg! ster publication at this stage of rulemaking 5 QC Tinal. NPRM was previously pubbshed e O Emergency subm ssion (cert:ficationattached) (month, day, year).

15. Type of review reavested (check only one) 1 O New conection 4 C Reinstatement of a previously approved couectron for which approval 2 QC Revision of a currently approveo coliection has expired 3 Extension of the e>piration date of a currently approved co!iection 5 O Existing cocection in use without an CMB control number without any change m the substarice or in the method of collection

16. Agency report form number (s)(mclude standard /optoonal form number (s)) 22. Purpose cf information conection (check as many as apply)

Not Applicable  ! U ^P * * * * ' ' ' ' '* **

• 2 O Program evaluation

17. Annual report,rg or disclosure burden 3 O Generalpurposestatrstics t 1 Numbe' of respondents . J 4 QC F<egulatory or compt.ance 2 Number of responses per respondent . 07; 3 o p,og,,n pgnn,ngo,m ,n,g, ment 3 Total annua! responses (hne 1 times l'ne 2) 6 O Research 4 Hours per response 1

- 7 O Audit 5 Total hours (6rie 3 times tene 4; 5 649~

j 8. Annuai record >eep,ng torcen 23. f requency of recordxceping or reporting (Check all that apply) 1 Number cf recordxcepers 658 1 g peco70,,ep,ng 2 Annual hours por recorckeeper Reportmg 3 Total recordkeepmg hours (hne 1 trmes hne 21 ks404 2 b onoccasion 4 Recordkeep.ng retention penod 3 years 3 0 wmir

19. T otal annual burden 4 O Monthi y 1 Requested (hne 171 p!as Ime 18 3) . 00*100 5 O quartersy 2 h current OMS inventor, 1419b4 6 b semhannua0y 3 Difference (tr:e f less lne 2)

+15,169 7 g AnnuaUy bplanation of difference B C Ehenmany a rregram enange +15,169 9 RJ other(descnde) One-time olan submission 5 Adjustment

20. current (most recent> OMB control number or comment number i 24. Responcents' obtgat;on to comply (ChecA ff e strongest obhgatron thatapphes) 3150-0123 i 3 g y ,gn,,,,

21. Requested expiration date 2 [ Required to obta;n or retam a benefit 3 years from approval date 3 g] Ma%,to,y

25. Are the respondents pnrnardy educat<onal agences or mst tuttons or is the prima'y po' pose of the co!1ert on related to Federal education prog'ams? O Yes @ No 26 Does tne agency use samping to select respondents of does the agency recomrt end or prescribe the L5e ci samphng or statistical ana!ysts by retponcents' . C Yes @ No

27. Regulatery autnorit, for tne ctormation conection 10 crR 74 ,, rR ;or,ot.,e (spe g ,)

Paperwork Certibcation In submrtting t'us recaest it' oVB approvai the agenev head. tre semer of tcf o' an authomed representattve cert,f tes that the requirements of 5 CrR 1320. the pnvacy Act, statist cat stancards or dvectives. and any otner scoi cze mf orrnation pocry detect.ves have been cornphed wfth Sirnature ct pog am offic.a; ' Date

/ MM he ni etenev neae tne semor efu.a: er an a twenemsentam

. 4 A /fo l' Date / /"/

pWilliamG. Mcdonald, Director

.)OfficeofAdministrationandResourcesManagement a - J b I C CPO t 1984 C - 453-7',6

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l SUPPORTING STATEMENT l FOR 10 CFR PART 74 MATERIAL CONTROL AND ACCOUNTING l OF SPECIAL NUCLEAR MATERIAL NUREG 1065, ACCEPTANCE CRITERIA FOR THE LOW ENRICHED URANIUM REFORM AMENDMENTS AND NUREG 1280, STANDARD FORMAT AND CONTENT ACCEPTANCE CRITERIA FOR THE MATERIAL CONTROL AND ACCOUNTING (MC&A) REFORM AMENDMENT Need for and Aaency Use of the Information Collection NRC regulations in 10 CFR Part 70 establish procedures and criteria for the issuance of licenses to receive title to, own, acquire, deliver, receive, possess, use, or transfer special nuclear material (SNM). NRC regulations in 10 CFR Part 74 establish requirements for material control and accounting (MC&A) of special nuclear material of low strategic significance licensed pursuant to Part 70. The regulations are issued pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the Energy Reorganization Act of 1974, as amended.

Part 74 was created to separate MC&A requirements in Part 70 from health and l safety requirements in that part and to place all MC&A requirements in a  !

specific part of the regulations, much as Part 73 contains only physical security requirements. Initially, Part 74 included only general recordkeeping  !

and reporting requirements applicable to all licensees that possess SNM and  !

specific MC&A recordkeeping and reporting requirements for licensees that possess and use SNM of low strategic significance. Part 74 is now being amended to incorporate recordkeeping and reporting requirements for licensees that possess and use formula quantities of strategic special nuclear

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material. These information collection requirements were previously submitted to 0MB at the proposed rule stage and were approved by OMB on February 27, .

I 1984. At that time, they were proposed as amendments to 10 CFR Part 70 and  !

were approved under 0MB No. 3150-0009. The information collection requirements in the final amendments that appear in Part 74 have not changed j substantially from those that were approved at the proposed rule stage.

The records required to be maintained pursuant to Section 74.31 are those deemed necessary for the timely discovery of inadvertent losses of low f enriched uranium to the environment, or the theft or diversion of low enriched uranium by potentially hostile groups. Either of these events could endanger the public health and safety. The reporting requirements I imposed on the licensee are intended to point up record anomalies which might indicate loss of material control, to provide necessary information to resolve identified anomalies, to alert the commission to the condition, and to supply information that would assist in the recovery of SNM in the event of a confirmed loss.

The MC&A requirements applicable to licensees that possess and use formula quantities of strategic special nuclear material (SSNM) will be contained in 66 74.51, .53, .55, .57, and .59, which will revise or replace the majority of the requirements in 66 70.51, .53, .57, and .58. The recordkeeping and reporting requirements in the indicated sections of Part 74 will provide timely detection and enhanced localization of anomalies that could be potentially indicative of a theft or diversion of SSNM. The information will significantly improve the ability to resolve alarms by identifying the cause as innocent or malevolent. In the latter case, the probability of material recovery will be significently enhanced.

Fundamental nuclear material control plans (FNMCs) that describe how licensees intend to comply with the requirements of the regulations are required to be submitted for review and approval. Approved plans will be the basis for l inspections by regional inspectors who must verify that the licensee is in compliance with the performance objectives specified in the rule. Plan reviews

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will be initiated within 30 days after submittal. The availability of supporting acceptance criteria will contribute to expeditious plan reviews. Reports of unresolved inventory differences and abnormalities identified through material i control tests and item monitoring will be reviewed by NRC Regional Offices as  !

soon as possible after receipt. Records of material control tests and anomaly investigation will be maintained by the licensees in order that inspectors may determine that performance objectives and consnitments have been met.

Section 74.11 requires that each licensee who possesses 1 gram or more of contained uranium-235, uranium-233, or plutonium shall report immediately to the appropriate NRC Regional Office listed in Appendix A of 10 CFR Part 73, by telephone and telegraph, mailgram, or facsimile, any loss, other than normal operating loss, or theft or other unlawful diversion of special nuclear material, or any incident in which an attempt has been made or is believed to have been made to commit a theft or unlawful diversion of such material. The information is used by the NRC Regional Office to determine whether there has been a diversion or loss of material and to initiate prompt action for recovery of material. The NRC Regional Office will respond according to the significance of the event. Response to a significant event is usually made by the regional staff within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Section 74.13(a) requires each licensee authorized to possess at any one time and location SNM in a quantity totaling more than 350 grams of contained uranium-235, uranium-233, or plutonium, to submit DOE /NRC Fonn 742 on a semi-annual basis. Tnese reports summarize the quantities of SNM received, produced, possessed, transferred, consumed, disposed of, or lost by the licensee.

DOE /NRC Form 742C, which reflects the composition of the ending inventory, is also submitted. These forms have been previously cleared under the following OMB clearances:

DOE /NRC Form 742 OMB No. 3150-0004 00E/NRC Form 742C OMB No. 3150-0058 The licensee reports are sent to a DOE contractor facility for recording in i an SNM tracking system. NRC staff reviews these reports. Discrepancies between the reports and licensees' records are investigated and reconciled.

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4 Section 74.13(b) requires each licensee subject to the requirements of 670.51(e) to submit a report to the appropriate NRC Regional Office, with a copy to the Director of Inspection and Enforcement, within 30 calendar days after the start of each annual physical inventory if the inventory difference exceeded both (i) its associated limit of error and (ii) 200 grams of plutonium l or U-233, 300 grams of high enriched uranium or U-235 contained in high enriched uranium or 9,000 grams of U-235 contained in low enriched uranium; a j statement of possible causes for the inventory differences, and action taken or j planned to be taken to correct the inventory difference. This section also l requires that, if for any material the limit of error of the inventory l difference exceeds any applicable limits specified in 10 CFR 970.51(e)(5) or approved pursuant to 10 CFR 670.51(e)(6), a statement of the probable reasons i

for the limit of error and actions taken or planned to be taken with respect to

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the limit of error must be submitted.

The report is used to alert the NRC Regional Office to a potential "out of j control situation" at a licensee site. If the size of the inventory difference is significant, an inspector from the NRC Regional Office usually visits the ]

site within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to observe the resolution of the inventory difference and the corrective action to be taken.  !

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Section 74.15(a) requires each licensee who transfers and each licensee who f receives special nuclear material to complete and distribute a Nuclear Material Transaction Report on DOE /NRC Form 741. This should be done in accordance with the printed instructions for completing the form whenever the licensee l i

transfers or receives a quantity of special nuclear material of 1 gram or more of contained uranium-235, uranium-233, or plutonium. DOE /NRC Form 741 has previously been approved under 0MB clearance number 3150-0003, which should be referred to for further supporting information and burden data.

I Prior to a site visit, the NRC inspection staff obtains a computer printout of l nuclear material transactions from the DOE /NRC database. The inspectors review f licensee records with the printout data to assure agreement between the record and the report and to assure that shipper-receiver differences have been reconciled, f

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Section 74.31(a) establishes general performance objectives for a

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Coninission-approved material control and accounting plan for licensees authorized to possess and use more than one effective kilogram of special nuclear material of low strategic significance. The objectives are to confirm the presence of special nuclear materials at the licensee facility, resolve indications of potentially missing material, and aid in investigation and recovery of material that is determined to be actually missing.

Section 74.31(b) established a time requirement for the submission and j implementation of plans required by 974.31(a). This was a one-tinie submittal.

All currently affected licensees have submitted the required plans.

Section 74.31(c) describes the system capabilities that must be addressed in ,

the plan in order to meet the general performance objectives of $74.31(a). l Guidance for preparing the plan is provided in the Acceptance Criteria  !

document (NUREG 1065). The plan is reviewed by the NRC staff to determine ,

whether the performance criteria have been satisfied. Initial NRC response to the plan is usually sent to the licensee within 60 days of receipt and docketing.

The approved plan will be used by the appropriate NRC Regional Office staff to monitor actual licensee performance in reaching .he performance objectives.

Section74.31(dlrequireseachlicenseetoestablishrecordsthatwill l demonstrate that the requirements of 74.31(c) have been met and to maintain those records for three years. The records to be maintained are selected by l the licensee. The 3-year retention period is the shortest time span which -

assures the NRC that all data is available which might affect the audit period.

Section 74.51(c)(1) requires licensees authorized to possess and use five or more formula kilograms of SSNM to submit a fundamental nuclear material control plan that describes how the licensee intends to comply with paragraph (b) of 1 6 74.51. Guidance for preparing the plan is provided in the Standard Format and Content Acceptance Criteria document (NUREG 1280). Review of the FNMC plans j enables the NRC to make a judgment on each licensee's capabilities to meet ]

regulatory requirements. After approval, the plans will be used by NRC l inspectors to monitor licensee performance.

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Section 74.57 contains recordkeeping and reporting requirements associated with alann resolution. A key factor in the resolution of alarms is the avail-ability of auditable records that provide a history of the processing and >

storage of SSNM in bulk and item form. The majority of innocent causes of alarms are expected to be identifiable from a review of pertinent records. The involved records will have been generated in the process of complying with the requirements of El 74.53, .55 or .59. Once an anomaly has been resolved, records must be updated and corrected to enable the licensee to maintain continuing compliance with detection and response requirements and permit NRC inspectors to evaluate the adequacy of the licensee's resolution procedures.

Regarding reports required by this section, anytime a licensee is unable to resolve a loss detection alarm within the time limit specified in its FNMC plan, the licensee must notify the appropriate NRC Region Office immediately.

In the case of a five formula kilogram loss, the maximum time for resolution is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The early notification puts the NRC on alert to a potential loss of SSNM and thus allows for contingency planning in the event a diversion or theft is indicated. NRC and possibly other federal agency involvement at an early stage will enhance the likelihood of material recovery. '

The retention time for the records required by this section is three years.

This time period is necessary to permit NRC to perform its inspection function.

Section 74.59 Contains the quality assurance and accounting requirements of the rule. Section 74.59(g) stipulates that licensees shall establish auditable records sufficient to demonstrate that the requirements of 66 74.53, .55, .57 and .59 have been met and retain those records for at least three years.

Appropriate records to satisfy this requirement would include:

- Internal transfer, storage, and processing of SSNM [74.53(c)].

- Material Control tests for abrupt losses, quality control tests, and trend analyses [74.53(b)]. l I

- Item loss tests and tamper-sealing [74.55(a) and (b)].

- Alarm investigation and resolution [74.57(b), (c), (d), (e), (f) and (g)].

- Management structure, policies and procedures [74.59(b)].  !

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- Personnel training and qualification [74.59(c)]. l Measurements for MC&A [74.59(d)]. l

- Measurement system calibrations.

- Measurement quality control data and statistical analyses [74.59(e)].

- Inventory listings, inventory difference / standard error of inventory difference (ID/SEID) calculations, and ID/SEID investigations [74.59(f)].

- Receipts, shipments,andinventory[74.59(g)].

Shipper-receiver difference evaluations and investigations [74.59(h)]. l Assessments and audits [74.59(h)].

A requirement to report the failure to resolve an excessive inventory difference is also included in s 74.59.

l Information recorded and reported in accordance with the requirements in this section will enable NRC regional inspectors and licensing personnel to assess  !

licensees' ongoing capabilities to control and account for SSNM in their )

possession. As indicated previously, these records and reports will be invaluable to the licensees and the NRC in the event of an attempted diversion or theft since they will permit localization of losses in space and time.

The retention time for records required by this section is three years to.

permit the NRC to conduct periodic inspections of licensees' MC&A systems.

Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this I l

information collection. Applicants and licensees may use electronic '

information processing systems to prepare and submit required information.

Licensees have the option of preparing certain of the reports on a computer i generated facsimile of the report form and transmitting the information electronically.

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8 Effort to Identify Duplication In an effort, to minimize duplication and licensee burden, NRC and the Department of Energy (00E) jointly utilize a Nuclear Materials Management and Safeguards System (NMMSS). Common reporting forms are used to minimize the reporting burden on industry members required to provide nuclear materials data to one or both agencies in accordance with prevailing regulations or contractual obligations. The licensee is thus able to file one report to meet

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the requirements of both agencies. l 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 material, and the date of transfer. This transfer must also be reported on DOE /NRC Form 741. 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 as to 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 ,

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Effort to Use Similar Information l l

To the extent possible the information collection requirements have been l structured to permit licensees to use information already generated for other l purposes such as production control, quality control, product certification, etc. Where new information must be generated, there is no other source that could be used.

___-____-____.__-__________--_-___-_-_-__________--______-_______-______-_-____-___-_________-________-_---_A

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i Effort to Reduce Small Business Burden A number of licensees who use special nuclear material are small businesses.

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Since the consequences to the common defense and security or to the health and safety of the public of the' improper control or use of a given quantity of ]

special nuclear material are the same for large and small entities, it is not j possible to reduce the burden on small businesses by less frequent or less j complete accounting or. control procedures. (

f Consequences of Less Frequent Collection l Applications for new licenses and amendments may be submitted at any time. I Applications for renewal of licenses are submitted every five years. l t

Information submitted in previous applications.may be referenced without being d I

resubmitted. The Loss of Material Report required by Q74.11 is submitted on

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the average of five times per year. In four out of five occurrences, the cause  ;

is usually found in less than 1 week and is a result of measurement error, accounting error, number transposition, or failure to list all inventory items.

a Approximately once a year the quantity of material is significant, requiring >

submission of a detailed report and proposed action plan to the NRC. Less 1 frequent reporting would preclude the NRC from being notified in time to b provide rapid response and quick assistance in achieving timely resolution. ,

l Failure to collect the informati6n required by Sections 74.51 - 74.59 on the  !

indicated frequencies would negate the purposes of the new requirements which are timely detection of anomalies potentially indicative of material losses and j generation of information useful in the resolution of discrepancies when they  !

do occur. h 1

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10 I Circumstances Which Justify Variation from OMB Guidelines 4 Contrary to the OMB Guidelines in 5 CFR 1320.6(b), certain sections of Part 74 require that licensees submit reports to the NRC in less than thirty days. j

.Section 74.11 , Material Loss Report, must be made immediately. This requirement is needed to permit NRC to determine whether there has been a loss l or diversion of special nuclear material and to initiate prompt action for l recovery of such material.

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Section 74.13(b), Inventory Difference Exceeds Limit of Error, must be reported within thirty days after the start of the inventory. This requirement is  !

needed to alert the NRC Regional Office to a potential "out of control situation" at a licensee site. If the report indicates that the size of the inventory difference is significant, an NRC inspector will usually be dispatched to the site to observe the resolution and corrective action.

1 Section 74.57 specifies that a confirmed loss of an item and the failure to resolve loss detection alarms within agreed upon times must be reported to the NRC immediately. The reason for the short detection times is to permit the Commission to take appropriate response actions in a timely maaner in the event a diversion or theft is indicated.

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Another area of variation is in the number of copies of the FNMC plan to be '

submitted to demonstrate how compliance with rule requirements will be achieved. An original and four copies of the plan are required. The distribution will be as follows:

Safeguards Licensing Branch 2 .

- NRC Regional Office 2 NRC Docket Room 1 i Me Licensing Branch copies will be used in the review process. Two copies are necessary because of the involvement of more than one reviewer. 7he Regional I Office copies will be used in their inspection program. The Docket Room copy will be kept on file under the licensec's docket number.

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11 Consultations Outside the Agency Consultations were held with representatives from the Department of Energy, the DepartmentofState,andtheInstituteofNuclearMaterialsManagement(INMM) at various times during the development of the rulemaking concerning formula quantities of strategic special nuclear material. The INMM is a professional l

association whose members come from the nuclear industry, government agencies, l science faculties and similar groups. The INMM subcommittee members who were involved in the discussions on that rule' making were predominantly an it;dustry group. All affected licensees were represented on the subcommittee. Comments from the above groups were taken into account in the rulemaking process.

Confidentiality of Information None, except for proprietary or safeguards information.

Sensitive Questions None.

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12 Estimate of Compliance Burden Reporting Requirements Licensee Total No. of Licensee Staff Hours Annual Section Responses Annually Per Submittal Burden 74.11 5 15 75 74.13(a) - See OMB Clearance Nos. 3150-0004, 3150-0058 i

74.13(b) 5 350 1,750 74.15(a) - See OMB Clearance No. 3150-0003 )

74.31(b) 0 865 one-time cost 0 .

74.51(c)(1) 4 (one-time cost) 900 3,600 74.57(c) 24 8 192 l

74.57(g)(2) 4 4 16 74.59(e) 4 4 16 Total: 46 5,649 i

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Recordkeeping Requirements No. of Records Annually Hours / Record Total Burden 74.31(d) 7 1,012 7,084 74.53(a),74.59(g) 1,000 0.1 100 74.53(b)&(c) 7,000 1.0 7,000 74.55(a)&(b);74.59(g) 74.57(b),(c),(d), 700 1.0 700 (f),(g);74.59(g) 74.59(b) 500 1.0 500 74.59(c) 500 1.0 500 74.59(d) 8,000 0.2 1,600 74.59(e) 4,000 0.2 800 l

l 74.59(f) 600 2.0 1,200 74.59(g) 4,000 1.0 4,000

'74.59(h) 1,000 1.0 1,000 l

Total: 27,307 24,484 1 .

l l i TOTAL ANNUAL BURDEN HOURS: 30,133 l l

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Includes 8,308 hours0.00356 days <br />0.0856 hours <br />5.092593e-4 weeks <br />1.17194e-4 months <br /> transferred from Part 70 to Part 74 l

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Estimated Cost to Respond to the Collection The estimated annual cost to licensees to respond to the collection requirements is $1,807,980 (30,133 hrs X $60/hr).

Source of Burden Data and Method for Estimating Burden Consistent with the performance oriented nature of Part 74, the specific records that a licensee must keep are not explicitly defined. Licensees have the flexibility to develop a records system that is compatible with their particular programs. In so doing, each licensee will be able to satisfy ,

recordkeeping requirements in the most cost-effective manner. The burden j

estimates reflected in the table are based on a hypothetical model system 1 designed in accordance with the guidance provided in the Standard  !

Format / Acceptance Criteria document' There is a high probability that the  !

licensees will propose systems similar to the model or systems that are most s cost-effective without sacrificing essential qualifications. The baseline was taken from the burden estimates previously determined for the 10 CFR Part 70 1 clearance. The estimates for new record and reporting requirements were ,I developed by comparison to existing estimates for similar records and reports.

The burden estimate for a major license amendment was taken from prior cost data since the effort should not be significantly different.

Reason for Change in Burden Current licensees have made the required one-time submission of plans required under 574.31(b) and no new licensees are expected to file plans in the next ,

three years. Transfer of regulations for material control and accounting at j Category I fixed sites from 10 CFR Part 70 to 10 CFR Part 74, with the addition of some new information collection requirements, will result in an overall increase in the burden for Part 74. There will be a decrease in the burden for l Part 70.

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