ML23138A347
| ML23138A347 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/2023 |
| From: | NRC/NMSS/DFM/MCAB |
| To: | |
| Shared Package | |
| ML23138A346 | List: |
| References | |
| OMB 3150-0057 | |
| Download: ML23138A347 (5) | |
Text
DRAFT OMB SUPPORTING STATEMENT FOR DOE/NRC FORM 740M, CONCISE NOTE AND NUREG/BR-0006, REVISION 9 INSTRUCTIONS FOR COMPLETING NUCLEAR MATERIAL TRANSACTION REPORTS, (DOE/NRC FORMS 740M)
(3150-0057)
EXTENSION
Description of the Information Collection
The U.S. Nuclear Regulatory Commission (NRC) is required to collect nuclear material transaction information for domestic safeguards use and to make it available to the International Atomic Energy Agency (IAEA). One of the forms tha t NRC uses to collect this information is U.S. Department of Energy (DOE)/NRC Form 740M, Concise Note. Form 740M is used to provide additional information such as qualifyi ng statements or exceptions to data on any of the other data forms required under the U.S.-IAE A Safeguards Agreements (including DOE/NRC Forms 741, 742, and 742C).
The licensees who are primarily affected are (1) facilities tha t have been notified by letter from NRC that they are subject to Title 10 of the Code of Federal Regulations (10 CFR) Part 75 (sections 75.12, 75.34 and 75.35), (2) licensees that may need to provide additional information to document inventory changes for special nuclear material and source material, and (3) licensees who import or export nuc lear materials. However, any facility may use the DOE/NRC Form 740M to provide explanatory information concerning nuclear material transaction if they choose. The NRC provides the form and instructions to all affec ted licensees who must submit reports electronically.
Licensees submit reports on a continuing basis when specified e vents occur, such as the receipt, transfer, or inventory adjustment of licensed material. The instructions for completing DOE/NRC Form 740M are in NUREG/BR-0006, Revision 9 Instructions for Completing Nuclear Material Transaction Reports (DOE/NRC Forms 741 and 740M).
A. JUSTIFICATION
- 1. Need for and Practical Utility of the Information Collection
In order for the United States to fulfill its responsibilities as a participant in the U.S.-IAEA Safeguards Agreements and satisfy its domestic safegu ards responsibilities, it is necessa ry for licensees affected by 10 CFR Part 75 and licensees who import or export nuc lear material to submit DOE/NRC Form 740M, "Concise Note. This submittal informs the U.S. or the IA EA of any qualifying statement or exception to any of the data contained in any of the other reporting forms required under the U.S.-IAEA Safeguards A greements.
- 2. Agency Use of Information
The NRC is required to collect nuclear material transaction inf ormation for domestic safeguards use and to make it available to the IAEA. T he NRC uses 1
DOE/NRC Form 740M, together with NUREG/BR-0006, Revision 9 (the instructions for completing the forms), to collect, retrieve, a nalyze, and submit required data to IAEA. Without the report form, NRC's ability t o collect and provide these data would be severely limited.
- 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 submittal of documents can be accomplished via the following avenues: the Electronic Submitta ls application, which is available from the NRC's Electronic Submittals Web p age, by Optical Storage Media (OSM) (e.g. CD-ROM, DVD), by facsimile or by e-mail. The Electronic Submittals application allows electronic transmissio n of information to the NRC pertaining to licensing actions, associated hearings, a nd other regulatory matters. The application ensures that information se nt to the NRC via the Internet is secure and unaltered during transmission. It op erates 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, except when it is taken down for scheduled maintenance. Th e application serves as a secure portal that respondents may use to transmit documents to the NRC. It is estimated that 79% of the responses are filed electr onically.
Form 740M is a common form hosted by the NRC that is also used by the DOE.
The NRC provides the form and instructions to all affected NRC licensees who must submit reports electronically. Once submitted by licensees, information from these forms is saved in t he Nuclear Materials Management a nd Safeguards System (NMMSS). The use of common reporting forms mi nimizes the reporting burden on industry members required to provide re gulatory or contractual obligations. The licensee is thus able to file one report to meet the requirements of both agencies. Compliance with specific reporti ng requirements is monitored by the agency for which the specific data are requ ired. Currently DOE has no burden hours associated with the use of this form.
- 4. Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no du plication of requirements. In addition, the use of common reporting forms by DOE and NRC minimizes the reporting burden on industry members required to provide nuclear material data to one or both agencies.
- 5. Effort to Reduce Small Business Burden
The burden on licensees will vary with the size and type of lic ensed operation.
Further burden reductions for small businesses would prevent th e NRC from fulfilling its international or domestic responsibilities.
- 6. Consequences to Federal Program or Policy Activities if the Col lection is not Conducted or is Conducted Less Frequently
Collection of the subject information corresponds to the physic al movement or transmutation of special nuclear material or source material co vered by the regulation. The information is generally collected from the shi pper immediately following dispatch and from the receiver within 10 days of rece ipt. This is the 2
minimum frequency of collection required to satisfy reporting r egulations and as required by the facilitys license to possess material. A su ggestion by reactor operators regarding delay of submittal of receiver's in formation to allow batch reporting on a monthly basis was reviewed and deemed to b e inconsistent with international treaty commitments. NRC and ind ustry continue to jointly examine some industry suggestions to reduce reportin g burden at annual meetings between the U.S. Government and nuclear industr y representatives.
- 7. Circumstances which Justify Variation from the Office of Management and Budget (OMB) Guidelines
There is no variation from OMB guidelines.
- 8. Consultations outside NRC
Opportunity for public comment on the information collection re quirements for this clearance package has been published in the Federal Regist er.
- 9. Payment or Gift to Respondents
Not applicable.
- 10. Confidentiality of Information
Confidential and proprietary information is protected in accord ance with the NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
- 11. Justification for Sensitive Questions
None.
- 12. Estimated of Annualized Burden and Burden Hour Cost
Licensees submit reports on a c ontinuing basis when specified e vents occur, such as the receipt, transfer, or inventory adjustment of licen sed material. They must submit the reports in computer readable format. The data a re then entered into NMMSS. The information is not compiled or published.
The NRC expects an annual total of approximately 6 7 reports (approximately 67 reporters. The burden of preparation and submission of each rep ort is estimated to be 0.75 hour8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />. The total resulting burden for requi red submissions of the form by all licensees will be 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> (67 r eports x 0.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> per report). These reports are submitted on average by 17 unique reporters, five of whom use the reports in conjunction with rep orting requirements in 10 CFR Part 75 for facilities selected for IAEA Safeguards Reporting. These five reporters submit approximately 50 of the 67 reports with their nuclear material transactions.
The total annual cost to all respondents to comply with this re quirement is estimated to be $14,500 (50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> x $290/hour).
3 The $290 hourly rate used in the burden estimates is based on t he Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20, Average cost per professional staff-hour. For more informatio n on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2022 (87 FR 37214, Jun. 22, 2022).
- 13. Estimate of Other Additional Costs
There are no additional costs.
- 14. Estimated Annualized Cost to Federal Government
The collected information is not submitted to the NRC. Licensee s report directly to NMMSS. The data contained in NMMSS is available to various N RC staff that uses it to perform their assigned job functions; however, the i ndividual submissions are not reviewed by NRC staff. The NRC costs for NM MSS operations are approximately $1,900,000 per fiscal year. This i s the NRCs contribution for the operations of the NMMSS to support the col lection of Forms 740M, 741, 742, and 742C data, in addition to other data collec tions and operations.
The staff has developed estimates of annualized costs to the Fe deral Government related to the conduct of this collection of informa tion. These estimates are based on staff experience and subject matter expe rtise and include the burden needed to review, analyze, and process the c ollected information and any relevant operational expenses.
- 15. Reason for Change in Burden or Cost
The number of anticipated responses and associated burden has d ecreased from 175 responses and 131 hours0.00152 days <br />0.0364 hours <br />2.166005e-4 weeks <br />4.98455e-5 months <br /> to 67 responses and 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />. The F orm 740M is an optional reporting form that provides additional information not captured in the form fields for DOE/NRC Form 741 or Form 742. Consultation with NMMSS analysts prior to reporting nuclear material transaction forms (Form 741) has decreased the need for reporting the optional Form 740M form to provide additional clarifying information for the Form 741.
The cost per hour has increased from $278 to $290, based on an increase in the NRCs fee rate.
- 16. Publication for Statistical Use
None.
- 17. Reason for Not Displaying the Expiration Date
The expiration date is displayed on DOE/NRC Form 740M.
- 18. Exceptions to the Certification Statement
None.
4 B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not used in this collection of informat ion.
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