ML21364A108

Draft Supporting Statement for NRC Forms 361 361A 361N

ML21364A108
Person / Time
Issue date:	03/14/2022
From:	Office of Nuclear Security and Incident Response, NRC/OCIO, NRC/OGC
To:
Cecere B
Shared Package
ML22005A062	List: ML21364A108 ML22027A593 ML22104A050 ML22104A051 ML22104A052
References
3150-0238
Download: ML21364A108 (7)

Text

DRAFT SUPPORTING STATEMENT FOR NRC FORM 361, "REACTOR PLANT EVENT NOTIFICATION WORKSHEET" NRC FORM 361A, FUEL CYCLE AND MATERIALS EVENT NOTIFICATION WORKSHEET NRC FORM 361N, NON-POWER REACTOR EVENT NOTIFICATION WORKSHEET (3150-0238)

Extension Description of the Information Collection NUREG -1022, Rev. 3, Event Report Guidelines, 10 CFR 50.72 and 50.73 provides guidance to licensees for meeting the requirements of 10 CFR 50.72 Immediate notification requirements for operating nuclear power reactors and 10 CFR 50.73 Licensee event report systems. Specifically, Section 4.2.4 of NUREG-1022 references the Event Notification Worksheet (NRC Form 361) as a tool to facilitate easier communication between the U.S.

Nuclear Regulatory Commission (NRC) Headquarters Operations Officers and licensees during event notifications. The use of the form is voluntary, but the form provides the usual order of questions and discussion to enable a licensee to prepare answers for a more clear and complete telephonic notification. The NRC has prepared different versions of NRC Form 361 as described below for each type of licensees with reportable events.

Additionally, the NRC launched a new non-emergency and emergency event notification (EN) module on the self-service web-based portal (MAP-X). The EN Module provides a foundation for more automation of interactions between the NRC and the licensees and has tremendous long-term benefits.

Currently, there are two live modules in MAP-X which provide the reactor licensees the ability to submit relief requests (i.e., the EN Module and the Web-based Relief Request Module). The use of these modules is not a regulatory requirement but provides licensees with alternative methods for submitting information and interacting with the NRC. Licensees must request a user account to get access to the modules in MAP-X. MAP-X can be accessed at https://mapx.nrc-gateway.gov/

Holders of operating licenses for commercial nuclear power plants are required to report specified events per 10 CFR 50.72 and other requirements (10 CFR 20, 21, 26, 73, and 74) to the NRC Operations Center via telephone. Holders of NRC Fuel Cycle Facility and Materials licenses are required to report specified events per 10 CFR 40.60, 10 CFR 70.50 or 10 CFR 72.75 and other requirements (10 CFR 20, 21, 26, 30, 35, 36, 37, 73, and 74) to the NRC Operations Center via telephone. Holders of NRC Non-Power Reactor licenses are required to report specified events per their respective Technical Specifications and other requirements (10 CFR 73 and 74) to the NRC Operations Center. While each version of NRC Form 361 contains unique information with respects to reference to different

sections of the 10 CFR above, the information requested for all three forms generally include time of event, name and location of the facility, plant conditions at the onset of the events, detailed event descriptions, effect to other or facilities on site, and status of the affected facilities.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information The NRC licenses and regulates the Nation's civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety, promote the common defense and security, and protect the environment. In order for the NRC to carry out these responsibilities, its regulations require licensees to report significant events so that the NRC can evaluate the events to determine what actions, if any, are warranted to ensure protection of public health and safety. In addition, this information is needed for the NRC to carry out its responsibility to inform Congress of those events constituting "abnormal occurrences."

10 CFR 50.72 requires commercial nuclear power plants to report certain reactor events and emergencies that have potential impact to public health and safety.

In order to efficiently process the information received through such reports for reactors, the NRC developed Form 361 as a vehicle to record the information in a templated fashion. Similarly, the NRC also created other NRC Forms (361A, 361N) to allow for efficient collection of information for Fuel Cycle licensee, Material Licensee, and Non-Power Reactor events with potential significance and impact to public health and safety. Without the templated format of the NRC Forms 361, the information exchange between licensees and NRC Headquarters Operations Officers via telephone could result in delays due to excessive follow- on questions for additional details, repeat-backs for confirmation, as well as unnecessary transposition errors.

2. Agency Use of Information The NRC staff uses the information reported using these forms for responding to emergencies, monitoring ongoing events, confirming licensing bases, studying potentially generic safety problems, assessing trends and patterns of operational experience, monitoring performance, identifying precursors of more significant events, and providing operational experience to the industry.

3. Reduction of Burden Through Information Technology The NRC has issued Guidance for Electronic Submissions to the NRC which provides direction for the electronic transmission and submittal of documents to the NRC. Electronic transmission and submittal of documents can be accomplished via the following avenues: the Electronic Information Exchange (EIE) process, which is available from the NRC's Electronic Submittals Web

page, by Optical Storage Media (OSM) (e.g., CD-ROM, DVD), by facsimile or by e-mail. It is estimated that approximately 0% of the potential responses are filed electronically.

The information collections related to the requirement to make an initial event report telephonically are covered under OMB Clearance Number 3150-0011. NRC Forms 361 provide a tool that allows licensees to relay by phone specific details in a templated and sequenced fashion to minimize follow up questions for additional details and repeat-backs for confirmation. The form also provides a template for licensees follow-on event reports, if required, to be written in a manner consistent with their event reporting procedures.

It is estimated that approximately 97% of reactor licensees use the format of NRC Form 361 to prepare their event report notification, and these licensees also typically follow telephonic notifications with electronic confirmation via email or facsimile.

It is estimated that 1 Fuel Cycle Facility use the NRC Form 361 format and approximately 20% of the 31 Non-Power Reactor licensees use the format.

Approximately 3 Fuel Cycle Facilities, and Non-Power Reactors licensees follow their required telephonic notifications with electronic confirmation via email or facsimile.

4. Efforts to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.

5. Effort to Reduce Small Business Burden Efforts have been made to keep the requirements for information to a minimum.

However, since the health and safety consequences of the events being reported are likely to be the same for large and small entities, it is not possible to further reduce the burden on small businesses by less frequent or less complete recordkeeping or reporting.

6. Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently Not collecting the information, or collecting it less frequently, would degrade the NRCs ability to determine in a timely manner what actions, if any, may be needed to resolve potential threats to public health and safety or the environment and inform Congress of those events constituting abnormal occurrences.

7. Circumstances Which Justify Variation from OMB Guidelines Not applicable.

8. Consultations Outside the NRC.

Not applicable as this is a renewal to a cleared voluntary form.

9. Payment or Gift to Respondents Not Applicable

10. Confidentiality of Information Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b). However, no information normally considered confidential or proprietary is requested.

11. Justification for Sensitive Questions No sensitive information is requested.

12. Estimated Burden and Burden Hour Cost There are no record keeping or third-party disclosure burden associated with licensees telephonic reporting requirement.

Table 1 reflects the estimated annual burden to different types of licensees to provide a written event report, whereas Table 2 is total burden. The estimate includes the time to complete and submit the form since the reporting requirements have not changed. However, the estimates include only additional time needed above those already expended by licensees to comply with regulatory notification requirements, such as the requirements of 10 CFR 50.72.

Operating reactor licensees have submitted (on average) approximately 500 telephonic reactor event report notifications per year (initial event reports, updated event reports, and retractions) over the past three years. The licensees operating the 95 power reactors are expected to continue to submit a maximum of about 500 telephonic event reports per year for the foreseeable future. The hourly additional licensee burden associated with these event reports is estimated at 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per report. The burden estimate of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per each event report is valid since the reporting requirements of 10 CFR 50.72 have not changed. Therefore, the estimated annual reporting burden is 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> (500 event reports x 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report) at a cost of $72,000 (250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> x $288 per hour).

Fuel Cycle Facility licensees have submitted (on average) approximately 32 telephonic reactor event report notifications per year (initial event reports, updated event reports, and retractions) over the past three years. The licensees are expected to continue to submit a maximum of about 32 telephonic event reports per year for the foreseeable future. The hourly additional licensee burden associated with these event reports is estimated at 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per report. The

burden estimate of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report is valid since the reporting requirements for Fuel Cycle Facilities have not changed. Therefore, the estimated annual reporting burden is 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> (32 event reports x 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report) at a cost of $4,608 (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> x $288 per hour).

Non-Power Reactor licensees have submitted (on average) approximately 14 telephonic reactor event report notifications per year (initial event reports, updated event reports, and retractions) over the past three years. The licensees are expected to continue to submit a maximum of about 14 telephonic event reports per year for the foreseeable future. The hourly additional licensee burden associated with these event reports is estimated at 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per report. The burden estimate of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report is valid since the reporting requirements of Non-Power Reactor licensees have not changed. Therefore, the estimated annual reporting burden is 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> (14 event reports x 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report) at a cost of $2,016 (7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> x $288 per hour).

Materials licensees have submitted (on average) approximately 366 telephonic materials event report notifications per year (initial event reports, updated event reports, and retractions) over the past three years. The licensees are expected to continue to report a maximum of about 366 events per year for the foreseeable future. However, only a small number of the reports (approximately 10) are estimated to have NRC Form 361A follow the telephonic reports. The hourly additional licensee burden associated with these event reports is estimated at 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per report. One new reporting criterion was added since original issue of the form 361A, but the increase in reports is negligible over the past 3 years. The burden estimate of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report is valid since only one reporting requirement of Materials licensees has been added, which affects a small number of respondents. Therefore, the estimated annual reporting burden is 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (10 event reports x 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report) at a cost of $1,440 (5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> x $288 per hour).

The $288 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20 Average cost per professional staff-hour. For more information on the basis of this rate, see the Federal Register notice at: (86 FR 32170, Jun. 16, 2021).

13. Estimate of other Additional costs There are no additional costs.

14. Estimated Annualized Cost to the Federal Government The staff has developed estimates of annualized costs to the Federal Government related to the conduct of this collection of information. These estimates are based on staff experience and subject matter expertise and include the burden needed to review, analyze, and process the collected information and any relevant operational expenses.

Operating reactor licensees represent the bulk of required event reports processed by the NRC. These licensees have submitted (on average) approximately 500 telephonic reactor event report notifications per year (initial event reports, updated event reports, and retractions) over the past three years.

The licensees operating the 95 power reactors are expected to continue to submit a maximum of about 500 telephonic event reports per year for the foreseeable future. The burden associated with processing each event report by the NRC Headquarters Operations Officers is reduced by the licensee voluntary use of the NRC Forms 361 format to provide event descriptions via telephonic notification.

Without the use of the NRC Form 361 event description information, the Headquarters Operations Officers would be required to take slower notes of the event description, keeping the licensee on the phone longer, and rely on use of telephonic notification audio recordings to transcribe the detailed event description information into the HOO database for processing and distribution. It is estimated that the use of the NRC Forms 361 saves the NRC Headquarters Operations Officers approximately 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of processing time per report. The burden estimate of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per written submission of each event report is valid since the reporting requirements of 10 CFR 50.72 have not changed. Therefore, the total estimated annual reporting burden reduction is 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> (500 event reports x 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report) at a cost of $72,000 (250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> x $288 per hour).

15. Reasons for Change in Burden or Cost The previous burden for this collection was 268.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 537 responses. Based on data from the last three years, the burden is expected to slightly increase to 278 hours0.00322 days <br />0.0772 hours <br />4.596561e-4 weeks <br />1.05779e-4 months <br /> and 556 responses (an increase of 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 19 responses). One reporting criterion was added for Materials licensee, but given the few licensees this affects, and the few numbers of reports taken over three years of the criterion, this adds negligible additional burden or cost. The NRC Form 361 hourly rate has increased since the initial clearance from $263/hr to $288/hr.

16. Publication for Statistical Use Not applicable.

17. Reason for Not Displaying the Expiration Date The expiration date will be displayed

18. Exceptions to the Certification Statement Not applicable

B. Collection of Information Employing Statistical Methods The collection of information does not employ statistical methods.

Description No. of Responses Number of Burden Total Cost at Respondents per Responses Hours per Annual $288/hr Respondent Response Burden Hours Operating 95 5.3 500 0.5 250 $72,000 reactor licensees Fuel Cycle 50 0.64 32 0.5 16 $4,608 Facility licensees Non-Power 52 0.27 14 0.5 7 $2,016 Reactor licensees Materials 10 1.0 10 0.5 5 $1,440 licensees TOTAL 556 278 $80,064 TABLE 2: BURDEN TOTALS Total Annual Burden: 278 (556 event reports x 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per event report) Total Burden Hour Cost: $80,064 (278 hours0.00322 days <br />0.0772 hours <br />4.596561e-4 weeks <br />1.05779e-4 months <br /> x $288/hour)

Total Responses: 556 event reports