ML23102A009

3150-XXXX, Draft Supporting Statement for NRC Form 833

ML23102A009
Person / Time
Issue date:	12/13/2023
From:	O'Donnell E NRC/RES/DE/RGDB
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ML23110A003	List: ML23102A009
References
Download: ML23102A009 (3)

Text

SUPPORTING STATEMENT FOR

NRC Form 833, Form to Propose a Generic Issue (GI)

(3150-XXXX)

NEW

Abstract

NRC Form 833 is used for submission of a proposed generic safet y issue that has potential for affecting two or more nuclear facilities. A generic safety issu e is a well-defined, discrete, technical or security issue, the risk/or safety significance of which can be adequately determined, and which: 1) applies to two or more facilities and /or licensees/certificate holders, or holders of other regulatory approvals (including design cert ification rules); 2) affects public health and safety, the common defense and security, or the envi ronment; 3) is not already being processed under an existing program or process; and 4) can be r esolved by new or revised regulation, policy, or guidance or voluntary industry initiativ es. A generic safety issue may lead to regulatory changes that either enhance safety or reduce unne cessary regulatory burden. The form requests information on the nature of the postulated issue, why it represents a potential generic unresolved safety issue, and any supporting information sources or references. The issue may affect public health, safety, common defense and secu rity, 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 Publi c Law 95-209 to include, among other things, a new Section 210, Unresolved Saf ety Issues. To meet both Commission and Congressional directives, the staff de veloped 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 I ssues 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 signi ficance of occurrence or adverse consequence affecting nuclear safety at multiple nuc lear facilities. The proposed issue would potentially affect public health, safety, common defense and security, or environment and it is not addressed by existing re gulations and guidance.

2. Agency Use and Practical Utility of Information

The information requested in Form 833 is needed to enable the N RC staff to assess the potential generic safety issue against the seven screening factors specified in NRC Management Directive 6.4, Generic Issues Program. Potent ial generic issues that are not screened out are evaluated to determine if further regulatory action is needed.

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 t echnology when it would be beneficial to them. NRC Form 833 can be submitted via email to GIP.Resource@nrc.gov. It is estimated that approximately 100% o f the potential responses will be filed electronically.

4. Effort to Identify Duplication and Use Similar Information

There is no duplication of requirements for submission of propo sed generic issues related to NRCs responsibilities under the Atomic Energy Act a s 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, the NRC will be unable to assess whether a potential generic safety issues affecting nuclear fac ilities exists.

7. Circumstances Which Justify Variation from OMB Guidelines

Not applicable

8. Consultations Outside the NRC

Opportunity for public comment on the information collection re quirements for this clearance package has been published in the Federal Register.

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 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 a nd, on average, 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 an nual 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 t he 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 202 3 (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 />. Using an hourly rate of $300 f or 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> comes to

$12,000 for a single proposed generic issue. It is estimated th at one proposed generic issue will be submitted annually with a cost to the Fed eral Government of

$12,000.

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

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable