ML23094A063

NRC-2022-0145- NEI Official Comment Attachment on 10 CFR Part 21 Information Collection Renewal

ML23094A063
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/28/2023
From:	Tony Brown Nuclear Energy Institute
To:	David Cullison NRC/OCIO
References
NRC-2022-0145
Download: ML23094A063 (1)

Text

TONY BROWN Technical Advisor, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8087 mab@nei.org nei.org March 28, 2023 Mr. David Cullison Office of the Chief Information Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Submitted via Regulations.gov

Subject:

Industry Comments on the Information Collection for Reporting of Defects and Noncompliance (Docket ID: NRC-2022-0145)

Project Number: 689

Dear Mr. Cullison:

The Nuclear Energy Institute (NEI), 1 on behalf of its members, appreciates the opportunity to comment on the Nuclear Regulatory Commissions (NRC) renewal of Office of Management and Budget (OMB) approval for an existing collection of information entitled, Reporting of Defects and Noncompliance.

Specifically, NEI is responding to the NRCs Question #2: Is the estimate of the burden of the information collection accurate? NEI notes that the NRC staff estimates receiving 43 reports annually, which includes 16 initial notifications by facsimile or telephone, for which the NRC staff estimates 2 burden hours per response. Using the Part 21 reporting data provided on the NRCs website, NEI estimated the most recent 5-year average to be approximately 53 annual reports. While the overall trend in Part 21 reports has decreased over the past 10 years, recent data suggests the number of reports are slowly leveling off.

Additionally, we note that an estimate of 2 burden hours per initial notification by facsimile or telephone seems low. Any report to the NRC, whether written or verbal, requires significant preparation by a licensee, vendor or applicant to ensure completeness and accuracy.

Therefore, NEI recommends that the NRC staff use a higher estimate for total annual responses of approximately 50 responses and recommends the NRC staff revise the burden hours for initial notification by 1

The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

Office of the Chief Information Officer March 28 Page 2 facsimile or telephone to approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to account for the preparation and validation of information, by multiple staff, required to make the notification.

If you have any questions or require additional information, please contact me at 202.739.8087 or mab@nei.org.

Sincerely, Tony Brown cc: George Tartal, NMSS, NRC