ML20236R113
| ML20236R113 | |
| Person / Time | |
|---|---|
| Issue date: | 07/10/1998 |
| From: | Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | |
| Shared Package | |
| ML20236Q346 | List: |
| References | |
| OMB-3150-0139, OMB-3150-139, NUDOCS 9807210249 | |
| Download: ML20236R113 (6) | |
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PAPERWORK REDUCTION ACT SUBMISSION PbIsa raed tha instructions before completing this form. For additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503 l
- 1. Agency / Subagency originating request J OMB control number !
U.S. Nuclear Regulatory Commission X a. 3150-0139 b.None
- 3. Type of information collection (check one/ 4. Type of review requested (check one)
- a. New collection X a. Regular submission c. Delegated X b. Revision of a currently approved collection b. Emergency - Approval requested by (date):
- c. Extension of a currently approved collection 5. Will this information collection have a ,, y,,
- * * " E'" "'
- d. Reinstatement, without change, of a praviously approved collection for which approval has expired substantial number of small entities? X b.No 4
- e. Reinstatement, with change, of a previously arproved collection for which approval has expired Requested X a. Three years from approval date
- f. Existing collection in use v,ithout an OMB control number 6' expiration date
- 7. Title NRC Form 327, Special Nuclear Material (SNM) and Source Material (SM) Physical Inventory Summary Report, and NUREG/BR-0096, Instructions and Guidance for Completing Physical Inventory Summary
- 8. Agency form number (s) /// sop // cable)
- 9. Keywords Nuclear Materials, Special Nuclear Material, Source Material, Material Control and Accounting
- 10. Abstract NRC Form 327 is submitted by fuel facility licensees to account for special nuclear material. The data is used by NRC to assess licensee material control and accounting programs and to confirm the absence of (or detect the occurrence of) SNM through theft or diversion. NUREG/BR-0096 prevides specific guidance and instructions for completing the form.
- 11. Affected public IMark primary with *PZnd an others mar appy with *X*) 12. obhgation to respond IMark pohnery with "P' and en others that aup4 with X*)
- a. Individuals of households d. Farms a. Voluntary
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P b. Business or other for-profa e. Federal Government b. Required to obtain or retain benefits
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- c. Not-for-profi* institutions f. state, Local, or Tribal Government X c. Mandatory i I
- 13. Annual reporting and recordkeeping hour butden 14. Annual reporting and recordkeeping cost burden //n thousands of vo#ars/ '
- a. Number of respondents 10 a. Total annualized capital /startup costs O @ i
- b. Total annual responses 23 b. Total annual costs (o&M) o ,
- 1. Percentage of these responses c. Total annvahzed cost requested 0 ,,
collec+e) Jactronically o % d. Current Of/B Inventory o ,,U>l
- c. Total annual hours requested 98 e. oifference o d current oMB inventory 89 f. Explanation of difference
- e. olfference 9 1. Program change
- f. Explanation of difference 2. Adjustment
- 1. Program change
- 2. Adjustment 9
- 16. Purpose of informatier .- %on 16. Frequency of recordkeeping or reporting ICheck s// ther apply /
(Mark primary with 'P'so . "nhors that app /y with *X')
f a. Recordkeepnng b. Thord-party desciosure Q- e. Application for FMts Y
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- e. Program planning or management T c. Reporting l
O X b. Prograrh evaluation f. Research 1. on occasion 2. Weekly 3. Monthly
- c. General purpose statistics y g. Regulatory or compliance 4. ouarterly X 6. semi-annually x 6. AnnuaPy P X 7. Biennially X 8. Other toescribei e every 2 months NO 11. statistical methods 18. Agency contact (person who can best answer questions regarding the O ry g content of this subinossbn}
N ooes this information Collection employ statistical methods?
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s Nami frank P. Cardile (Do '
yes /'
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- Pnone: 301-415-6185 6
OMB 83-1 e 1 , 1o/95 511 I l-
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- 19. Certification for Paperwork Reduction Act Submissions On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.
NOTE: The 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 certification is to be made with reference to those regulatoryprovisions as setforth in the instructions.
The following is a summary of the topics, regarding the proposed collection ofinformation, that the certification covers:
(a) It is necessary for the proper performan A 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 for under 5 CFR 1320.8(b)(3):
(i) Why the information is being collected; i (ii) Use ofinformation; (iii) Burden estimate; (iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and (vi) Need to display currently valid OMB control number; (h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected (see note in Item 19 of the instructions).
(i) It uses effective and efficient statistical swvey methodology; and (j) It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.
l l I i i 1 Signature Senior Official or desig e Date l
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so m xm ' t o,o
FINAL SUPPORTING STATEMENT FOR NRC FORM 327 "SPECIAL NUCLEAR MATERIAL (SNM) AND SOURCE MATERIAL (SM)
PHYSICAL INVENTORY
SUMMARY
REPORT" AND NUREG!BR-0096
" INSTRUCTIONS AND GUIDANCE FOR COMPLETING PHYSICAL INVENTORY
SUMMARY
REPORTS" (3150-0139)
REVISION TO AN EXTENSION Dascriction of the Information Collection Special nuclear material (SNM) is required to be controlled and accounted for because of the government's national security obligation to prevent or detect loss, diversion or theft, or the appearance thereof, of quantities cf SNM that could be used for clandestine nuclear devices.
To meet this obligation, NRC's safeguards Material Control and Accounting (MC&A) regulations for fuel facilities require the conduct of physical inventories of SNM on a periodic basis by licensees. Section 74.17 requires the reporting of physical inventory results on NRC Form 327 each time that a physical inventory is conducted by any fuel facility authorized to possess and use more than one effective kilogram of SNM.
A. JUSTIFICATION
- 1. Need for and Practical Utility of the Information NRC Form 327 requires that licensees submit information concerning inventory difference (ID),
standard error of the ID (SEID), SEID limit, and ID limit. The information is needed to permit NRC to evaluate licensee performance and ability to provide accurate accounting for SNM and to confirm the absence of (or detect the occurrence of) SNM theft or diversion. The information prcvided by NRC Form 327 is used for:
- 2) Assessing the material control and accounting performance and compliance of SNM licensees;
- 3) Caking safeguards regulatory decisions; and
- 4) Fulfilling the Commission's commitcnent to report to the public (in NUREG-0430) differences between licensees' book and physical inventories.
(
NUREG/BR-0096 provides specific guidance and instructions for completing the form in accordance with the requirements of the particular regulation a licensee is subject to.
- 2. Aaencv Use of Information The NRC uses the information to ensure that licensees are complying with 10 CFR 74.17 in a manner adequate to properly account for SNM and protect public health and safety and the common defense and security. The information is also used by the NRC to evaluate licensees' operations to ensure that they are meeting the requirements of their licenses.
- 3. Reduction of Burden Throuah Informz"on Technoloav There are no legal obstacles to reducing the burden by the use of improved information technology. Certain information is maintained by some licensees using automated information technology. Licensees are encouraged to use automated information technology whenever it will reduce the burden on them. However, respondents report classified information and thus must adhere to security regulations. Because of the type and relatively small amount of information, the reports do not lend themselves readily to the use of automated information technology.
- 4. Effort to identifv Duplication and Use Similar Information The Information Requirements Control Automated System (IRCAS) was searched to identify
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duplication. None was found. The physicalinventory data requested on NRC Form 327 is not s available in any other NRC data collection system. NRC requires periodic SNM material status reports from all SNM licensees (DOE /NRC Forms 742 and 742C), but that information is based on licensee book records and is not necessarily the immediate result of a physicalinventory, l nor do such forms provide measurement uncertainty and related information needed to assess the reliability of licensees' accounting programs.
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- 5. Effort to Reduce Small Business Burden i NRC has determined that the licensees requiled to submit NRC Form 327 are not smCi entities as that term is defined in the Regulatory Flexibility Act.
- 6. Consequences to Federal Procrams or Polier Activities if the Collection is not Conducted or is Conducted Less Freauentiv The reporting corresponds to the physicalinventory frequencies required by NRC regulations.
The frequenc~y depends on which regulation (regarding physical inventories) a licensee is subject to, which in turn depends on the category of SNM possessed by the licensee and the level of control and monitoring requirements imposed. Less frequent reporting would result in (1) unacceptable delays in determining whether a safeguards significant quantity of SNM had l been lost, diverted, or stolen; (2) inadequate N'RC knowledge of a keensee's current processing throughput; and (3) inadequate NRC knowledge of a licensee's current measurement capabilities.
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- 7. Circumstances Which Justifv Variation from OMB Guidelines There is no variation from OMB guidelines.
- 8. Consultations Outside the NRC An invitation to comment on the information collection requirements for NRC Form 327 was published in the Federal Reaister on May 7,1998 (63 FR 25238). There were no comments.
- 9. Pavment or Gift to Respondents Not applicable.
- 10. Confidentiality of information The respondent's data for high enriched uranium is classified and low enriched uranium is usually treated as proprietary. Thus, the information is confidential. The only exception is the periodic publication of inventory difference data (after a minimum of 1 year waiting period) in NUREG-0430, which requires the Commission's approval before the information is released.
- 11. Justification for Sensitive Questions None.
- 12. Estimated Burden and Burden Hour Cost As noted above, the reporting frequency depends on which regulation (regarding physical inventories) a licensee is subject to, which in turn depends on the category of SNM possessed by the licensee and the level of control and monitoring requirements imposed. There are currently two uranium enrichment facilities that are required to conduct physicalinventories every 2 months. Two facilities that process strategic SNM and one th# processes SNM of moderate strategic significance are required to conduct physical invenaries at least every 6 months. Additionally, there are five fabricators of commercial power ruactor fuel (SNM of low strategic significance) that are required to perform physical inventories at least every 12 months. Overall, there will be an estimated 23 inventory summary reports required each year.
The completion of the SNM Physical Inventory Summary Report will require approximately four and one-fourth (4%) staff hours per licensee per report (including any time needed to read or ;
review the NUREG guidance document). The totalindustry burden would then be l approximately 98 hours0.00113 days <br />0.0272 hours <br />1.62037e-4 weeks <br />3.7289e-5 months <br /> (23 reports x 4% hours /repon). The total annual cost would be approximately $12,250 (GB hcurs x $125 per huur).
- 13. Estimate of Other Additional Cost Not applicable.
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- 14. Estiolated Annualized Cost to the Federal Government The collection of information will require an average of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of NRC staff time per report to ;
review and evaluate licensees' physical inventory results. Thus, the annual cost for this activity will be $5,750 per year (23 reports x 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / report x $125 per hour). In addition, the compilation, printing, and distribution of inventory difference information in NUREG-0430 is estimated to cost $1,550 per year ($750 for compilation, $360 for printing, and $440 for distribution). Therefore, the total annual cost to the Federal Government will be approximately
$7,300.
- 15. Reason for Chance in Burden or Cost The burden hours for this clearance increased from 89 to 98 hours0.00113 days <br />0.0272 hours <br />1.62037e-4 weeks <br />3.7289e-5 months <br /> because of an increase in the number of responses fm 21 to 23 as a result of an additional respondent that is required to report once every 6 montns. The overall cost therefore also increased, although not in the same ratio, because tr.3 cost per hour charge was decreased to $125 per hour.
- 16. Publication for Statistical Use None.
- 17. Reason for Not Disolavino the Exoiration D.ple $
The expiration date is displayed.
- 18. Exceotions to the Certification Statement Not applicable.
B. Collection of Information Emolovino Statistical Methods Statistical methods are not used in this collection of information.
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tuds (PGTEM3/ 00.@,CEBl@DGIEW3Sts27@5M@$52) APPROVED BY OMB: 3160 4139 l 51(c)(3). 74.31(c)(3).
74 33(c)(4), snd 74 50(r)(1)
Estimsted burdrn per response to cornply with this manda. tory irforrrdion collection request: 4.25 Hours. This information is SPECIAL NUCLEAR MATERIAL (SNM) submmad bv'u="=*ty iian- ta ==un"or spa *i nuci==
material. Forward comments regarding burden estimate to the AND SOURCE MATERIAL (SM) Records uanagement Branch (T-e r33). U.S. Nucisar Regulatory Commission, Washington, DC 20555-0001, and to PHYSICAL INVENTORY
SUMMARY
REPORT ihe Paperwork Reduction Project (3150-0139), Office of Management and Budget, Washington, DC 20503. If an (Physical inventories of SM pertain only to uranium enrichment facilities.) Information collection does not display a currentty valid oms (See NUREG/BR 0096 for instructen and guidance for completing this form) "
[n'" o nd o in o at cI on A. LICENSEE NAME B. FACILITY LOCATION 1
C, COCKET NUMBER D. SNM LICENSE NUMBER E. PLANT DESIGNATION l BEGINNING DATE ENDING DATE F. MATERIAL BALANCE PERIOD LEU U-233 Pu-238 NORMAL URANIUM G. MATERIAL HEU PLUTONIUM URAN!UM IN CASCADES DEPLETED URANIUM H. LICENSEE'S CERTIFYING OFFICIAL (Printed Name and Signature) DATE L8NE GRAMS ELEMENT GRAMS ISOTOPE NUMBER DESCR R ON (U or Pu) ISOf0pe Code
- Indicate whether the entered values si3 positive or negative by use of appropriate "+" or *
- signs.
1 BEGINNING INVENTORY (BI) ,
)
2 PLUS ADDITIONS TO INVENTORY (A) 3 MINUS SHIPMENTS (S) 4 MINUS MEASURED DISCARDS (MD)
)
5 MINUS ENDING INVENTORY (EI) I 6 EQUALS INVENTORY DIFFERENCE (ID)
PLUS BIAS CORRECTION TO ID (BC) 7 (Net sum of all bias corrections pertaining to, but not includsd in the above quantities)
- PLUS SUM OF PRIOR PERIOD ADJUSTMENTS (PPA) 8 THAT AFFECT THE CURRENT PERIOD 10 9 EOUALS ADJUSTED INVENTORY DIFFERENCE (AID) ;
10a STANDARD ERROR OF THE ID (CEID) 10b UMIT OF ERROR OF THE 10 (LEID) 11a ACTIVE INVENTORY (AI) ggg THE LARGER OF
- ADDITIONS TO PROCESS" (ATP)
- REMOVALS FROM PROCESS" (RFP) 12a SEID LIMIT 12b LEID LIMIT l 1$ ID UMIT NRC FORM 327 WYYYY) NOTE ANY sPECIAL EXPT.ANATIONs OR COMMENTS To THis COMPLETED PORM sHOuLD eE ATTACHED oN A CORPORATE LETTERHEAD,
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