ML22209A052

OMB Supporting Statement for Proposed Rule: Harmonization of Transportation Safety Requirements with International Atomic Energy Agency Standards

ML22209A052
Person / Time
Issue date:	10/11/2022
From:	James Firth NRC/NMSS/DREFS
To:
Firth, James
References
NRC-2016-0179, OMB 3150-0008, RIN 3150-AJ85
Download: ML22209A052 (11)

Text

DRAFT SUPPORTING STATEMENT FOR PROPOSED RULE AMENDING 10 CFR PART 71 FISSILE MATERIAL EXEMPTIONS, QUALITY ASSURANCE PROGRAMS; HARMONIZATION WITH IAEA TRANSPORTATION REQUIREMENTS, AND OTHER TRANSPORTATION SAFETY AMENDMENTS

(3150-0008)

REVISION

Description of the Information Collection

The U.S. Nuclear Regulatory Commission (NRC), in consultation w ith the U.S. Department of Transportation (DOT), is proposing to amend its regulations for the packaging and transportation of radioactive material. The NRC has historical ly been consistent in its support of harmonizing its transportation safety regulations with the Inte rnational Atomic Energy Agency (IAEA) standards. These amendments would make the NRC regulati ons conform to the recent revisions to the IAEA standards for the international transport ation of radioactive material, maintain consistency with the DOT regulations, and include NRC-initiated changes. These changes are necessary to maintain a consistent regulatory frame work for the domestic packaging and transportation of radioactive material.

Regulation changes that affect the burden for reporting include changes to § 71.22(f) and

§ 71.23(f) (via reference to § 71.17(c)(3)) to add a new requir ement for a licensee to, prior to first use of a package, submit to the NRC the licensee's name, license number, and the package identification number specified in the package approval ; § 71.31(a)(3) and § 71.35(d) to add a new requirement for an applicant to include an evaluat ion of the maintenance program as part of an application for a package approval; deletion of a duplicative requirement in

§ 71.95(a)(3); a revision to the compatibility designation of § § 71.95, 71.101(c), and 71.106(a) and (b) for Agreement States; and adding a new requirement in § 71.106(b) to notify the NRC every 24 months even if there are no changes to the approval ho lders quality assurance program. The regulation change in § 71.106(b) also affects the burden for recordkeeping.

A. JUSTIFICATION

1. Need for the Collection of Information

The NRC collects information pertinent to 10 CFR Part 71 for th ree reasons: to issue a package approval; to ensure that any incidents or package deg radation are appropriately captured, evaluated and if necessary, corrected t o minimize future potential occurrences; and to ensure that all activities are co mpleted using an NRC-approved quality assurance (QA) program.

The changes to the information collection requirements in the p roposed rule reflect changes to the NRCs transportation regulations under 10 CFR Pa rt 71 to harmonize with the international standards of IAEA SSR-6. In addition, s ome of the proposed rule changes have been coordinated with changes DOT is making t o their corresponding transportation requirements under 49 CFR, so that the NRCs and

DOTs regulations are similarly harmonized. The proposed rule would not change the need for the NRC to collect this information.

In § 71.22(f) and § 71.23(f), the NRC is proposing to add a new requirement for licensees shipping a Type B package to also comply with § 71.17 (c). In

§ 71.17(c)(3), the regulation currently requires a licensee to, prior to first use of a package, submit to the NRC the licensee's name, license number, and the package identification number specified in the package approval. This represents an increase to the reporting burden. This information is needed by the NRC to identify the licensees who are using these packages and the NRC can notify users of changes to the package designs. Knowledge of the identity of users is als o essential to the inspection program. This is a one-time requirement. Licensees need only report if they plan to make use of a particular package design.

In § 71.31(a)(3), the NRC is proposing to add a new requirement for an applicant to include a maintenance program description as part of an applica tion for a package approval. This represents an increase to the reporting burden. This information is needed by the NRC to ensure that the applicant has a maintenanc e program for the subject transportation package.

In § 71.35(d), the NRC is proposing to add a new requirement to describe the specific information to be included in the maintenance program as part of an application for a package approval. There is no increase to th e reporting burden because this is covered in § 71.31(a)(3). This information is needed by the NRC to ensure that the applicant has performed an evaluation of the ma intenance program described in § 71.31(a)(3) for the subject transportation packa ge.

In § 71.95(a)(3), the NRC is proposing to remove a duplicative requirement to submit a written report of instances where conditions in the certifica te of compliance (CoC) were not followed during shipment. This is an administrative c hange to these regulations because this requirement is duplicative to the requ irement in § 71.95(b).

As a result, there is no change to the reporting requirement an d hence, no change in reporting burden.

In § 71.95, the NRC is proposing to revise the compatibility ca tegory designation for the reporting requirements in this regulation from a D to a C. This represents a small increase in the reporting burden as Agreement State licensees w ill now be subject to these reporting requirements.

In § 71.97, the NRC is proposing to remove the duplicative burden for advance notification for shipments of spent fuel. This requirement is duplicative to §§ 73.37 and 73.35. This represents a decrease in the reporting burden.

In §§ 71.101(c), and 71.106(a) and (b), the NRC is proposing to revise the compatibility category designation for the reporting requiremen ts in this regulation from a C to a B for applicable Agreement States. This represen ts an increase in the third party reporting burden for applicable Agreement States.

In § 71.106(b), the NRC is proposing to add a new requirement t o notify the NRC every 24 months even if there are no changes to the approval ho lders quality assurance program. This represents an increase in reporting an d recordkeeping burden. This information is needed by the NRC to ensure it is informed periodically that there have been no changes to the program, and to align wi th the requirements for reactor licensees under § 50.71(e)(2).

2. Agency Use and Practical Utility of Information

The NRC reviews the information submitted with the applications to determine if the applicant's package design, description, evaluation, QA program, and other procedures are adequate to meet all the applicable requirements in 10 CFR Part 71 and the DOT regulations and to protect the public health and sa fety and the common defense and security.

Additional information provided by the certificate holders and licensees is also used as part of the basis for NRC decisions on the issuance, modific ation, or revocation of licenses, CoCs, or other approvals.

The NRC reviews the reports and records submitted pursuant to 1 0 CFR Part 71 to determine whether the licensee's shipping activities are conduc ted in accordance with the authorization in the license and applicable requiremen ts.

The agency reviews the licensees' QA programs to ensure that pa ckages are designed, fabricated, tested, procured, used, maintained, repai red, and modified in accordance with the CoC issued for the packaging.

The changes to the information collection requirements in the p roposed rule reflect changes to the NRCs transportation regulations under 10 CFR Pa rt 71 to harmonize with the international standards of IAEA SSR-6. In addition, s ome of the proposed rule changes have been coordinated with changes DOT is making t o their corresponding transportation requirements under 49 CFR, so that the NRCs and DOTs regulations are similarly harmonized. The proposed rule would not change the NRCs use of or practical utility of this information.

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 submitta l of documents to the NRC. Electronic transmission and s ubmittal of documents can be accomplished via the following avenues: The Electronic Information Exchange pro cess, which is available from the NRC's Electronic Submittals Web page, by O ptical Storage Media (e.g. CD-ROM, DVD), by facsimile or by e-mail. It is est imated that approximately 70 percent of the responses are filed electronically.

4. Effort to Identify Duplication and Use Similar Information

No sources of similar information are available. There is no d uplication of requirements.

5. Effort to Reduce Small Business Burden

Most businesses which either transport Type B 1 or fissile packages or deliver them to a carrier for transport are not small businesses as this term i s defined in the Regulatory Flexibility Act. Moreover, since the health and saf ety consequences of improper handling or transport of radioactive material are the same for large and small entities, it is for the most part not possible to reduce the burden on small businesses by less frequent or less complete reporting or recor dkeeping procedures.

However, the effort required to consolidate renewal application s is proportional to the size and extent of a licensee's program, making the required ef fort naturally less for a small business. Approximately 25 percent of respondents are small businesses.

The proposed rule and its associated changes to 10 CFR Part 71 would not reduce the burden on small businesses.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently

Applications for new package certifications are submitted only once. A consolidated application is required only at renewal time every 5 years. Th e serial number information required by §§ 71.19 and 71.85 is only collected on e time. Other information is collected as dictated by specified events. Writ ten instructions for exclusive use shipments are needed each time one of these shipm ents is made, so no less frequent collection is pos sible. Recording shipment da ta, including package serial number, at the time of each shipment is necessary to ens ure compliance.

Less frequent collection would impair the ability of the NRC to evaluate the adequacy of the safety of package designs for transport and would not pe rmit the NRC to carry out its obligation to ensure that adequate measures are taken t o protect the public health and safety.

The proposed rule and its associated changes to 10 CFR Part 71 would not justify the NRC reducing the frequency of information collections, nor would it justify the NRC not collecting the information.

7. Circumstances Which Justify Variation from The Office of Man agement and Budget Guidelines

There are variations from the Office of Management and Budget Guidelines (OMB) guidelines. The proposed rule contains requirements, consisten t with current transportation requirements, to retain certain recordkeeping do cuments throughout the life of a license. By maintaining these records throughout the life of the license, the NRC can maintain proper oversight and enforcement, includin g inspections.

Based on its authority under the Atomic Energy Act, the NRC has determined that these requirements are necessary to provide for the public heal th and safety.

8. Consultations Outside the NRC

On April 12, 2019, the NRC issued a draft regulatory basis in t he Federal Register and requested public comments (84 FR 14898). The NRC also held a public

1 Types A and B quantities of radioactive material are defined in § 71.4.

meeting on April 30, 2019, to discuss the draft regulatory basi s with interested stakeholders. The results of this public meeting are detailed in the meeting summary (Agencywide Documents Access and Management System (ADAMS) Acce ssion No.

ML19136A167).

The NRC received seven comment submissions on the draft regulat ory basis. The NRC considered those comment submissions in preparing the propo sed rule.

Because the public comments would only require minor changes to the regulatory basis document, the NRC decided against issuing a final regulat ory basis, and instead moving ahead with developing the proposed rule. None o f these comments involved reporting or recordkeeping requirements.

The NRC will provide another opportunity for public comment whe n the proposed rule is published under RIN # 3150-AJ85. The NRC staff will is sue the draft implementing guidance with the proposed rule and draft regulato ry analysis to support more informed external stakeholder feedback. Further, the NRC staff will continue to hold public meetings throughout the rulemaking proc ess. Any comments related to information collection requirements in the proposed rule will be addressed at the final rule stage.

9. Payment or Gift to Respondents

Not applicable.

10. Confidentiality of Information

Confidential and proprietary information is protected in accord ance with NRC regulations at §§ 9.17(a) and 2.390(b). However, no informatio n normally considered confidential is requested, except for proprietary in formation. Some proprietary information may be included when necessary to provi de an adequate response. An application to withhold such information from pub lic disclosure may be made in accordance with the provisions of § 2.390.

The proposed rule and its associated changes to 10 CFR Part 71 would not change the manner in which the NRC protects confidential, proprietary, or other types of sensitive information.

11. Justification for Sensitive Questions

Neither this information collection nor the proposed rule and i ts associated changes to this collection involves sensitive questions.

12. Estimated Burden and Burden Hour Cost

The proposed rule would harmonize the NRCs transportation safe ty requirements with that of IAEA and DOT, as described in the Abstract. This harmonization would make insignificant changes to the process for an applicant to r eceive an approval for transport, and consequently insignificant changes to the burden on those applicants under 10 CFR Part 71.

In § 71.22(f) and § 71.23(f), the NRC is proposing to add a new requirement for licensees shipping a Type B package to also comply with § 71.17 (c). In

§ 71.17(c)(3), the regulation currently requires a licensee to, prior to first use of a package, submit to the NRC the licensee's name, license number, and the package identification number specified in the package approval. This would represent an increase in reporting burden. The requirements in § 71.22(f) a nd § 71.23(f) do not involve recordkeeping.

In § 71.19(a)(3), the NRC is proposing to phase out the use of packages approved to NRC regulations that were harmonized with the IAEAs SS No. 6, 1973 edition, and SS No. 6, 1973 (as amended) edition (i.e., package that do not have either a -85 or a -96 in the package identification number on the certificate ), 8 years after the effective date of this rulemaking. These packages would be req uired to be re-certified, removed from service, or used via exemption. Most c ertificate holders will likely choose to recertify packages. This would represent an i ncrease in reporting burden § 71.31(a). The requirements in § 71.19(a)(3) do not in volve recordkeeping.

In § 71.31(a)(3), the NRC is proposing to add a new requirement for an applicant to include a maintenance program description as part of an applica tion for a package approval. This represents an increase to the reporting burden. The requirements in

§ 71.31(a)(3) do not involve recordkeeping.

In § 71.35(d), the NRC is proposing to add a new requirement fo r an applicant to include an evaluation of the maintenance program as part of an application for a package approval. This represents an increase to the reporting burden. The requirements in § 71.35(d) do not involve recordkeeping.

In § 71.95(a)(3), the NRC is proposing to remove a duplicative requirement to submit a written report of instances where conditions in the CoC were not followed during shipment. This requirement is duplicative to the requirement in § 71.95(b). Hence, there is no change in reporting burden. The requirements in § 71.95(a)(3) do not involve recordkeeping.

In §§ 71.95, 71.101(c), and 71.106(a) and (b) the NRC is propos ing to revise the compatibility category designation for these reporting requirem ents. This represents an increase in the reporting burden for Agreement States. For §§ 71.95(b),

71.101(c), and 71.106(a) and (b), these requirements are being transferred to third party burdens as they were previously shown as reporting burden s to the NRC.

In § 71.97, the NRC is proposing to remove the duplicative burden for advance notification for shipments of spent fuel. This requirement is duplicative to §§ 73.37 and 73.35. This represents a decrease in the reporting burden.

In § 71.106(b), the NRC is proposing to add a new requirement t o notify the NRC every 24 months even if there are no changes to the approval ho lders quality assurance program. This represents an increase to both reporti ng and recordkeeping burdens.

The overall estimated annual burden increase is 1376.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> at an estimated annual cost increase of $384,099 (1376.7 hrs x $279/hr). This includes an increase of 1052.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for reporting, a net increase of 322.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> fo r third party reporting, and an increase of 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for recordkeeping.

Table 1 Total Burden Summary

Annualized Number of Total Burden Total Section/Form Description Number of Responses Annual Hrs Per Annual Cost @

Respondents Per Responses Response Burden $279/Hr Respondent (Hrs) (Hrs)

REPORTING

Notify NRC when 71.17(c)(3) using a Type B 1 1 1 1 1 $279 package Notify NRC when 71.22(f) using a Type B Included in 71.17(c) package Notify NRC when 71.23(f) using a Type B Included in 71.17(c) package Expected applications due to 71.31 phasing out 2 1.5 3 300 900 $251,100 packages in 71.19(a)(3)

Include a maintenance 71.31(a)(3) program description 2 1 2 75 150 $41,850 in the contents of an application for package approval Include an evaluation of the 71.35(d) applicants Included in 71.31(a)(3) maintenance program Submit a written 71.95(a)(3) report of instances (burden covered where conditions in 25 1 25 0 0 0 under 71.95) the CoC were not followed during shipment Submit a written report of instances of a defect or 71.95(a) significant reduction 0 0 0 24 0 0 in effectiveness of an NRC-approved package Notify NRC every 24 months even if 71.106(b) no changes to 1.5 1 1.5 1 1.5 $419 quality assurance program TOTAL 6.5 7.5 1052.5 $293,648

THIRD PARTY REPORTING BURDEN

Annualized Number of Total Burden Total Section/Form Description Number of Responses Annual Hrs Per Annual Cost @

Respondents Per Responses Response Burden $279/Hr Respondent (Hrs) (Hrs)

Submit a written report of instances 71.95(b) where conditions in 78 1 78 3 234 $65,286 the CoC were not followed during shipment Submit advance notification to State 71.97 and Tribal officials -7 1 -7 0.9 -6.3 -$1,758 for shipments of spent fuel Submit a description 71.101(c) of the quality 0.5 1 0.5 120 60 $16,740 assurance plan for review Submit a description of a revision to a 71.106(a) quality assurance 1 1 1 25 25 $6,975 plan that reduces commitments Submit a biennial report of changes to quality assurance 71.106(b) plans that do not 10 1 10 1 10 $2,790 reduce commitments or if no changes were made

TOTAL 89.5 89.5 322.7 $90,033

RECORDKEEPING

Total Section/Form Description Annualized Number of Burden Hrs. Per Annual Cost @

Recordkeepers Recordkeeper (Hrs) Burden $279/Hr (Hrs)

Retain a record of the NRC notification 71.106(b) every 24 months 1.5 1 1.5 $419 even if no changes to the quality assurance program

TOTAL 1.5 1 1.5 $419

The $279 hourly rate used in the burden estimates is based on t he NRCs fee for hourly rates as noted in 10 CFR 170.20 Average cost per profes sional staff-hour.

For more information on the basis of this rate, see the Revisio n of Fee Schedules; Fee Recovery for Fiscal Year 2020 (85 FR 37250, June 19, 2020).

13. Estimate of Other Additional Costs

The NRC has determined that the quantity of records to be maint ained is roughly proportional to the recordkeeping burden and, therefore, can be used to calculate approximate records storage costs. Based on the number of page s maintained for a typical clearance, the records storage cost has been determined to be equal to 0.0004 times the recordkeeping burden. Because the recordkeepi ng burden is estimated to be 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the storage cost for this clearance is $1 (1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> x 0.0004 x $279/hour).

14. Estimated Annualized Cost to the Federal Government

The NRC has developed estimates of annualized costs to the Federal government related to the conduct of this collection of information. Thes e estimates are based on staff experience and subject matter expertise and include the b urden needed to review, analyze, and process the collected information and any relevant operational expenses.

The NRCs average annual burden associated with the information collections is given in Table 2 (Annualized NRC Cost). The annualized cost in crease to the government is estimated to be $114,809 (411.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> x $279/hour ).

Table 2 Annualized NRC Cost NRC Action Rule Text No. of Burden Total Burden Provision Actions/Year Hours/Action Hours Total Cost Notify NRC when using a Type B 71.22(f) 1 0 0 $0 package Notify NRC when using a Type B 71.23(f) 0 0 0 $0 package Expected applications due to phasing out 71.31 3 120 360 $100,080 packages in 71.19(a)(3)

Include a maintenance program 71.31(a)(3) description in the contents of an 2 25 50 $13,900 application for package approval Include an evaluation of the applicants 71.35(d) Included in 71.31(a)(3) maintenance program Submit a written report of instances 71.95(a)(3) where conditions in the CoC were not 25 0 0 $0 followed during shipment (eliminating duplicate requirement)

Notify NRC every 24 months even if no 71.106(b) 1.5 1 1.5 $417 changes to quality assurance program Total 7.5 146 411.5 $114,397

The current annualized cost to the Federal government for 10 CF R Part 71 is $5,383,125. The total annualized cost to the government for 10 CFR Part 71 prop osed rule will be $ 5,497,522 (5,383,125 +114,397).

15. Reasons for Change in Burden or Cost

The proposed rules changes to 10 CFR Part 71 would affect appl icants during the period of this clearance.

The proposed rule would increase the annualized burden for 10 C FR Part 71 from 30,589 hours0.00682 days <br />0.164 hours <br />9.738757e-4 weeks <br />2.241145e-4 months <br /> and 634 responses to 31,965.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 734 respon ses, an addition of 1,376.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and 100 responses.

In § 71.19(a)(3), the NRC is proposing to phase out the use of packages approved to NRC regulations that were harmonized with the IAEAs SS No. 6, 1973 edition, and SS No. 6, 1973 (as amended) edition (i.e., package that do not have either a -85 or a -96 in the package identification number on the certificate ), 8 years after the effective date of this rulemaking. These packages would be req uired to be re-certified, removed from service, or used via exemption. Most c ertificate holders will likely choose to recertify packages. This would represent an i ncrease in reporting burden § 71.31(a). The requirements in § 71.19(a)(3) do not in volve recordkeeping.

This would represent an increase in 900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> of reporting burd en and 3 responses.

In § 71.22(f) and § 71.23(f), the NRC is proposing to add a new requirement for licensees shipping a Type B package to also comply with § 71.17 (c). In

§ 71.17(c)(3), the regulation currently requires a licensee, pr ior to first use of a package, to submit to the NRC the licensee's name, license numb er, and the package identification number specified in the package approval. This is a one-time notification to the NRC. The requirements in § 71.17(c) do not involve recordkeeping. This would represent an increase in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of r eporting burden and 1 response.

In § 71.31(a)(3), the NRC is proposing to add a new requirement for an applicant to include a maintenance program description as part of an applica tion for a package approval. This represents an increase to the reporting burden. The requirements in

§ 71.31(a)(3) do not involve recordkeeping. This would represe nt an increase in 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of reporting burden and 2 responses.

In § 71.35(d), the NRC is proposing to add a new requirement fo r an applicant to include an evaluation of the maintenance program as part of an application for a package approval. This represents an increase to the reporting burden. The requirements in § 71.35(d) do not involve recordkeeping. There is no increase to the reporting burden because this is covered in § 71.31(a)(3).

In § 71.95(b), the NRC is proposing to revise the Agreement Sta te compatibility category to require State licensees to submit a written report of instances where conditions in the CoC were not followed during shipment to the applicable Agreement State. This represents an increase to the third part y reporting burden.

The requirements in § 71.95(b) do not involve recordkeeping. T his would represent an increase in 234 hours0.00271 days <br />0.065 hours <br />3.869048e-4 weeks <br />8.9037e-5 months <br /> of third party reporting burden and 78 responses.

In § 71.97, the NRC is proposing to delete advanced notificatio ns for shipments of spent fuel. This represents a decrease to the third party repo rting burden. The requirements in § 71.97 involve recordkeeping but are covered u nder § 71.91. This would represent a decrease in 6.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of third party reportin g burden and a decrease of 7 responses.

In § 71.101(c), the NRC is proposing to revise the Agreement St ate compatibility category to require Agreement State licensees to file a descrip tion of its QA program with the Agreement State and obtain its approval. This represe nts an increase to the third party reporting burden. The requirements in § 71.101(c) involve recordkeeping but are covered under § 71.91(d). This would represent an incr ease in 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of third party reporting burden and 0.5 responses.

In § 71.106(a), the NRC is proposing to revise the Agreement St ate compatibility category to require Agreement State licensees to submit to the Agreement States a description of changes that reduce commitments to the quality a ssurance plan and show that the changes meet the applicable requirements of Subpa rt H to 10 CFR Part 71. This represents an increase to the third party report ing burden. The requirements in § 71.106(a) inv olve recordkeeping but are covered under § 71.91(d).

This would represent an increase in 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of reporting burde n and 1 response.

In § 71.106(b), the NRC is proposing to revise the Agreement St ate compatibility category to require Agreement State licensees to submit to the Agreement States a biennial report of changes to quality assurance plans that do n ot reduce commitments or if no changes were made. This represents an inc rease to the third party reporting burden. The requirements in § 71.106(b) involv e recordkeeping but are covered under § 71.91(d). This would represent an increase in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of reporting burden and 10 responses.

In § 71.106(b), the NRC is proposing to add a new requirement t o notify the NRC every 24 months even if there are no changes to the approval ho lders quality assurance program. This represents an increase to both reporti ng and recordkeeping burdens. This would represent an increase in 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of reporting burden, 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of recordkeeping burden and 1.5 responses.

16. Publication for Statistical Use

Not applicable. The information being collected is not expecte d to be published for statistical use.

17. Reason for Not Displaying the Expiration Date

The reporting requirements for this information collection are associated with regulations and are not submitted on instruments such as forms or surveys. For this reason, there are no data instruments on which to display an OM B expiration date.

Further, amending the regulatory text of the CFR to display inf ormation that, in an annual publication, could become obsolete would be unduly burde nsome and too difficult to keep current.

18. Exceptions to the Certification Statement

There are no exceptions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable