ML24086A009

3150-XXXX Final Supporting Statement for Form 833 Generic Issue

ML24086A009
Person / Time
Issue date:	07/11/2024
From:	NRC/OCIO/DIME/FLICB
To:
Shared Package
ML24086A005	List: ML24086A009 ML24121A178
References
Download: ML24086A009 (4)

Text

FINAL OMB SUPPORTING STATEMENT FOR NRC Form 833, Form To Propose A Generic Issue 3150-XXXX NEW Abstract NRC Form 833 is used for submission of a proposed generic safety issue that has potential for affecting two or more nuclear facilities. The form calls for information on the nature of the postulated issue and why it represents a potential generic unresolved safety issue. The issue may affect public health, safety, common defense and security, or environment; and it is not being addressed by other regulatory processes.

A. JUSTIFICATION

1. Need For the Collection of Information The regulatory basis for NRCs generic issues program is based on the Energy Reorganization Act of 1974 as amended by Congress through Public Law 95-209 to include, among other things, a new Section 210, Unresolved Safety Issues. To meet both Commission and Congressional directives, the staff developed a program to address Section 210 of the Energy Reorganization Act of 1974 as described in 43 FR 1565; January 10, 1978, Program for Resolution of Generic Issues Related to Nuclear Power.

NRC Form 833, Form to Propose a Generic Issue, is a voluntary method for stakeholders to submit a proposed generic safety issue to NRC. The information is needed for describing the situation, condition, cause and significance of occurrence or adverse consequence affecting nuclear safety at multiple nuclear facilities. The proposed issue would potentially affect public health, safety, common defense and security, or environment and it is not addressed by existing regulations and guidance.

2. Agency Use and Practical Utility of Information The information called for in Form 833 is needed to assess the assertion that there is a potential generic safety issue affecting multiple nuclear facilities. This is done through screening against seven screening factors that are specified in NRC Management Directive 6.4, Generic Issues Program. The information must be complete enough to do the screening and Form 833 provides such a structure.

3. Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. Electronic submission of Form 833 offers a vehicle to use modern information technology. This does not preclude the public from

submitting a potential generic unresolved safety issue via regular mail to the NRC although 100% of submissions are estimated to be electronic.

4. Effort to Identify Duplication and Use Similar Information There is no duplication of requirements for submission of proposed generic issues related to NRCs responsibilities under the Atomic Energy Act as Amended in 1977.

5. Effort to Reduce Small Business Burden Not applicable

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently If stakeholders do not provide the information, it will be impossible for the NRC to assess whether there is a potential generic safety issues affecting nuclear facilities.

Since the submission of an NRC Form 833 regarding a specific potential generic issue is a one-time event, the information cannot be collected less frequently.

7. Circumstances Which Justify Variation from OMB Guidelines Not applicable

8. Consultations Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package was published In the Federal Register on December 21, 2023 (88 FR 88422). Comments were solicited from Brett Titus of EPRI, Emma Wong of OECD, Lesa Hill of Southern State Nuclear and Harold Scott, a retired NRC employee via email. One comment was received that was out of scope and none were received from the Federal Register Notice.

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).

11. Justification for Sensitive Questions Not Applicable

12. Estimated Burden and Burden Hour Cost It is estimated that it takes about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to complete a form and 1 form will be submitted annually. The total estimated burden for the approximately 1 form received annually is 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> x 1 form). The estimated annual cost is $300 (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> x

$300/hour).

The $300 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 Revision of Fee Schedules, Fee Recovery for Fiscal Year 2023 (88 FR 39120, June 15, 2023).

13. Estimate of Other Additional Costs There are no additional costs.

14. Estimated Annualized Cost to the Federal Government The burden to the federal government to review and disposition a submitted Form 833 is estimated to be 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. It is estimated that one proposed generic issue will be submitted annually with a cost to the Federal Government of

$12,000 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> x $300/hour).

15. Reasons for Change in Burden or Cost This is a new collection

16. Publication for Statistical Use Not applicable

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

18. Exceptions to the Certification Statement None requested.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable