ML20247H298

Request for OMB Review & Supporting Statement Re Doe/Nrc Form 740M, Concise Note. Estimated Respondent Burden Is Minus 1,440 H

ML20247H298
Person / Time
Issue date:	07/18/1989
From:	Amenta J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
OMB-3150-0057, OMB-3150-57, NUDOCS 8907280347
Download: ML20247H298 (6)

Text

1 M

i MSIGNATI:D ORIGIRT; mn w o""85 Request for DMB Review w

tr<er seseeer 19sn Certified By /<

/> h In port:nt Reid indructions before completing f orm. Do not use the same SF 83 Send three copies of this form, the material to be reviewed, and for to request both an Executive Order 12291 review and approvat under paperwork-three copies of the supporting statement, to:

i the Paperwork Reducten Act Answer all questions in Part 1. If this request h 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 requist is for approval under the Paperwork Reduction Act and 5 CFR Attention; Docket Library, Room 3201 1320, ship Part II. complete Part I?, nd sign the pcperwork certification.

Washington, DC 20503 FART 1.-Complete This Part for All Requests.

I

1. Capartr;ierit/cgency and BureaCoffice originating request

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

l.Mc of person who can'bett answer %estm iegarding this request Telephor 1 number Richad Gramann (301 ) 492-0456

4. Titie of inforrnation collection or rulemaking l

DOE /NRC Form 740M - Concise Note

b. Legsl author ty for inf ormation coliection or rule (cste United States Code, Pubtoc Law. or becutwe Order) 42 2201(o) usC

. or 6 Affected pubbc(check allthat apply) b O federalagencies or Ernployees 1 C Indmdaalsof households 3 C Farms 6 O Non prof. institutions 2 O State or local governtnents 4 IXl Businesses or other for. profit 7 @ small businesses or organ;zations PART ll.-Complete Tnis Part Only if the Request is for OMB Review Under Executive Order 12291 t

7. Regulation Identcher Number (RIN;

_ _ _ ___ ~~~ _ _ _ _, or. None assigned O

6. Type of subm+ss en (check one on each category)

Type of review requested CI: ossification Stage of development Standard 1 O Major 1 0 Proposed or draft 2

Pending 2 O wma ct 2 O rinaiorrterimf;na:.witnpnorproposai 3 0 cmergency 3 C far;al or intenm final, w:thout prior proposal 4 0 statutoryorjudiciaideadan.

9. Cf R section affected CFR 4

~

10. Does this regulatio, cNtain reporting or recordkeepirq requirements that require OMB approval under the Paperwork Reduction Act

. O Yes No and $ CFR 1320?

r O Yes 2 No

11. If a major rule, is there a regulatory impact analyse attached?

3 0 Yes 4 0 No if"No." did OMB waive the anajysis?

Certification for Regulatory Submissions in subrn4tting this rec.uest f or OMB renew, the authorized regulatory ccntact and the program official certify that the requirements of E.O.12291 and any apphcable polwy d.rectives have been complaed with.

Date S gnature of program official Egnature of authonzed regulatory contact Date t'

12. 40% use only)

R g: !

Standard rorm 83 (Rev. 9 83)

Prwious editionprisowete 83 108 Prescribed by OMB NSN 7Mo or%63 4034 mR m end m 12291 8907280347 890718 i

PDR ORO EUSOMB FDC

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,1 y

' PART lli.-Compl

te This P:rt Only if tha R:quist is f tr Appr: val cf a C:llicti:n s of Inf:rmatirn Under the Pcperwirk R: duction Act arnd 5 CFR 1320.

-~ P ig.'At:: tract-Describe needs uses and affected pubric 16 50 words or less -Nuclear Facilitiest Radioactive Mater L( Licznsies affected by.10 CFR Part~75 and related sections of Parts 40,. 50, 70, and 150 are rsquired to submit DOE /NRC' Form 740M, " Concise Note," to inform the U.S. or the IAEA of any

qualifying statement or exception to any of the data contained in any of the other reporting

3. forms required under the US/IAEA Safeguards Agreement.

f.14. Type of snformatson collectson(check onlyone)

! hformation collections not contairmediniules s

.1@ Regularsubmission 2 O Emergencysubmission(certiftcationattached) information collections containedin rules 3 O Eustmg reguistion (no charige proposed) e rinai or interim finai witnout prior NeRu

7. Enter d.te of expected or xtuai rederai -

4 O Notice of proposed rulemaking(NPRM)

A O Regularsubmission Register publication at this stage of rulemaking 5 0 rinai. NPRM was previousty pubiished B O Emergency submission (certincet,on attached)

(moath cer rear >:

15. Type of review requested (check only one) 10 New collection 4 0 reinstatement of a previousiv approved coriection for which approvai 2 O Revision of a currently approved collection has expired -

3 $] Extension of the expiration date of a currently approved collection 5 O Exist;ng collection in use without an OMB control number without any change in the substance or in the rnethod of collection 16, Agency report form numbet(s)(include standard / optional form number (s))

22. P pose of information collection (check as many as apply) 1 O Application for benefits DOE /NRC Form 740M 2 O Program evaivation

' 17. Annual reporting or disclosure burrien 3 0 cen raipurpose statistics 0

1 Number of respondents.

4 @ Regulatoryorcomphance 30 2 Number of responses per respondent, 5 O Program plannir'g or menagement 1,140 g g p,,,,,cn 3 Tota! annual responses (line 1 times ime 2) 1 7 O Audit 4 Hours per response 5 Totat hours (hne 3 fimes line 4)

S*140

18. Annual recordkeeping burden

23. Frequency of recordteepmg or reporting (check all that apply) 1 Humberof recordkeepeS 1 O Recordkeeping 2 Annual hours per recordkeeper.

Key vung 3 Total recordkeepmg hourt. (hne J fimes line l' 2 b 9noccasion

' 4 Recordkeeping rete ion period years 3 g w,,gy d

19 Totalannualburden 4.O. Montniy 1 Requested (line 27 5plusline 1B 3),

1.140 5 0 Quarteriy 2 in current OMB inventory 2.580 6 O semi-annualiy 3 Difference (line1lessline2),

._LA40.

7 O Annually Explanation of difference 8 0 Bnenniatty 9 0 other(describe >:

4 Program change 5 Adiustment.

- 1,440 to. Current (most recent) 0MB controi number or comment number

24. Respor a# ct4;ntion to comply (check the strongestabligation thatapphes) 3150-0057 1 O vow <

21. Requesteo expiration date 2 O Required to obtain or retain a benefit 3 years from approval date 3 K) Mandatory

25. Are the respondents primarQ educational agencies or institutions or is the primary purpose of the collection related to federal education programs?

i

26. oes t agen use sampling to select respondents or does the agency recommend or prescribe the use of sampling or stat si cal analysis h7. Regulatoy authorrty for the ardurmation collection r

IU 75.34, 75.35 CFR

or FR

or, Other(specify)

i

'Peparwork Certification In submittiryg this request for OMO approval, the agency head, the senior official or an autheraed representative, certifies that the requirements of 5 CFR 1320, the l

Pnvacy Act. statistical standards or directives, and any other apphcable mformation policy directives have been comphed with Date

~

Signature of program official A

Date ignature of agency head, the senior official or an authorced representative f '

Joyce A. Amenta, Designated Senior Official efor Information Resources Management

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l SUPPORTING STATEMENT FOR DOE /NRC FORM 740M CONCISE NOTE Justification Need for the Information Collection.

In order for the United States to i

fulfill its responsibilities as a participant in the US/IAEA Safeguards Agreement and satisfy its domestic safeguards responsibilities, it is necessary for NRC to require that DOE /NRC Form 740M, " Concise Note," be submitted by licensees affected by 10 CFR Part 75 and related sections of Parts 40, 50, 70 and 150 to inform the U.S or the IAEA of any qualifying j

statement or exception to any of the data contained in any of the other i

reporting forms required under the US/IAEA Safeguards Agreement.

l Agency use of Information.

NRC is required to collect nuclear material l

transaction information for domestic safeguards use and make it available 1

to the IAEA.

DOE /NRC Form 740M is used to provide information concerning i

qualifying statements or exceptions to other data forms submitted.

The l

use of Form 740M, together with NUREG/BR-0006 and NUREG/BR-0007, the 1

instructions for completing the forms, enables NRC to collect, retrieve, 4

I analyze as necessary, and submit the data to IAEA to fulfill its reporting.

responsibilities.

Without these report forms, in ADP format, NRC's ability to collect and provide this data would be severely limited.

Reduction in Burden Through Information Technology.

There are no legal obstacles to reducing the burden associated with this information collec-tion.

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

Effort to Identify Duplication.

The Information Requirements Control Automated System (IRCAS) was searched to determine NRC duplication.

No duplication was found.

Effort to Use Similar Information.

NRC and the Department of Energy jointly utilize the Nuclear Materials Management and Safeguards System to process and store and subsequently retrieve the information contained on i

the forms.

The licensee is able to file one form to meet the requirements of both agencies.

This minimizes the reporting ourden on industry members reqm red to provide nuclear material data to botn agencies.

[

Effort to Reduce Small Business Burden.

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

The burden on small businesses will represent approximately five percent 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.

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Circumstances which Justify Variation from OMB Guidelines.

There is 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 Regulations, Title 10, Section 2.790.

Justification for Sensitive Questions.

There are no sensitive questions.

Description of the Information Collection Number and Type of Respondents.

Only those f acilities which have been notified by letter from NRC that they are subject to 10 CFR Part 75 and those licensees who import or export nuclear materials are affected.

Facility Attachments or Transitional Facility Attachments for such facili-ties may specify circumstances under which Concise Notes are required to be submitted to the IAEA as attachments to other reports.

In addition, submission of this form is required of licensees who import or export specified nuclear material.

Approximately 38 licensees will have to submit i

Form 740M annually.

Fewer licensees are now subject to IAEA safeguards requirements.

j Method and Schedule for the Information Collection.

Forms and instructions j

are provided to all affected licensees by NRC.

Reports are required as i

occasioned by occurrence of specified events, such as the receipt, transfer, or adjustment to inventory of licensed material.

Reports are collected on d 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 the 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 +'1 Information Requirement.

Thirty-eight respondents are affected 6 '.his requirement.

They are expec-ted to submit an average of 30 forms eaco, annually.

A total of approxi-mately 1,140 reports are expected to be submitted annually.

The burden of preparation and s iomission of each report is estimated to be one hour.

The total resulting burden for required submissions of the form by all licensees will be 1,140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br />.

The decrease in burden from the previous clearance of 2,580 hours0.00671 days <br />0.161 hours <br />9.589947e-4 weeks <br />2.2069e-4 months <br /> is due to fewer licensees being required to submit forms.

Estimated Cost to ResponG The annual cost to each respondent to comply with this requirement is estimated to be $1,800..

The total annual cost to all affected licensees is estimated to be $68,400.

Cost estimates are based on a rate of $60 per 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 1988.

Reason for Change in Burde.n g

The lower burden is due to fewer licensees being required to submit forms.

]

Estimate of Cost to the Federal Government.

The estimated annual cost to the government for processing this form is $5,700.

Annual Cost - NRC Staff Review

=$

5,700 (Professional effort -5 min / form @ $60/hr)

Annual ADP Cost *

= $ 55,000 Total Annual Cost

= $ 60,700 NRC and DOE share the cost of operating the Nuclear Materials Management i

and Safeguards System.(NMMSS).

Current and projected annual cost of the system is $1.1M.

This includes the cost of ADP, record holding, and clerical processing of all forms (DOE /NRC Forms 741, 741A, 740M, 742, 7420, and IAEA Form N-71).

The cost suballocated to Form 740M is $55,000.

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