ML20207H647

Request for OMB Review & Supporting Statement Re 10CFR72, Licensing Requirements for Independent Storage of Spent Nuclear Fuel & High-Level Radioactive Waste. Estimated Reporting Burden Is 22,978 H

ML20207H647
Person / Time
Issue date:	05/25/1999
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
OMB-3150-0132, OMB-3150-132, NUDOCS 9907140137
Download: ML20207H647 (13)

Text

PAPERWORK REDUCTION ACT SUBMISSION PleIs3 riad the instructions befora completing this form. For tdditionil forms or assist nes in completing this form, contact your cgincy's Paperwork Clurtnce Officer. Sind two copias of this form, the collection instrument to be reviswed, the Supporting Statiment stnd atny atdditionil documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget Docket Library, Room 10102,72517th Street NW, Washington, DC 20503.

1, Age l1cy/ Subagency onginating request 2. OMB control number U.S. Nuclear Regulatory Commission g a. 3150-0132 b.None

'J 3. Type of information collection (check one) 4. Type of review regaested (check one)

a. New collection g a Regular c. Delegated

b. Revision of a currently approved collection b. Emergency - Approval requested by (date):

c. Extension of a currently approved collection 5. Will this information collection have a a.Yes significant economic impact on a

d. Reinstatement, without change, of a previously approved substantial number of small entities?

collection for which approval has expired g b.No or 'h ch a pro"ga h s eh r"e " '

a. Wee years kom apwaWe I 10 Requested

f. Existing collection in use without an C 48 control number expwabon date

b. Other (Specify): 3/31/2000

7. Title 10 CFR 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and IIigh-Level Radioactive Waste

8. Agency form number (s) (if epphcable) l l

N/A 1

9. Keywords Nuclear Materials, Recordkeeping and Reporting Requirements, Spent Nuclear Fuel

10. Abstract

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Final rule,10 CFR 50 and 72, " Changes, Tests, and Experiments" revises requirements pertaining to changes, j tests, and experiments, and for updating final safety analysis reports. The purpose of the rulemaking is to clarify requirements and to allow more flexibility for certain changes that a licensee could make without receiving prior NRC approval. l l

11. Affected pubinc (Mark onmary men *P* and ale ctners tnat apply w!n W3 12. Obhgation to respond (Mark onmary mm *P* aM ale ctners thnt apply wth Ki

a. Individuals or households d. Farms a Voluntary T b. Business or other for-profit T e. Federal Government b Required to obtain or retain benefits

c. Not-for-profit Isistitutions f[ State. Local or Tnbal GovemmentT c. Mandatory

13. Annual reporting and recordkeeping hour burden 14 Annual reporting and recordkeeping cost burden (,n thousaws c/dollarsi a Numberof respondents 8 a Total annuah2ed capital /startup costs

b. Totalannualresponses 102 b Total annual costs (O&M) .

1. Percentage of these responses c. Total annuah2ed cost requested collected electronically  % d Current OMB inventory

c. Total annual hours requested 22,978 e Difference

d. Current OMB inventory 21.529

' f Explanation of difference

e. Difference 1,449

f. Explanation of difference 1, Program change

1. Program change 1,449 2. Adjustment

2. Adjustment

15. Purpose of information collection 16. Frequency of recordxeeping or reporting (check att that apply!

(Mark parnary with "P'and allothers that apply with *x*)

7 a. Recordkeeping , b. Third-party disclosure

a. Apphcation for benefits

~

e. Program planning or management 7

~

c. Reporting

b. Program evaluation f Research 1. On occasion 2. Weekly 3. Monthly

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c. General purpose statistics T g. Regulatory or comphance 4 Quarterly 5 Semi-annually 6. Annually

d. Audit 7. Biennially 8. Other (desenbe)

17. Statistxcal methods 18 Agency contact (person who can best answer questions regarding the Does this information collection employ statistical methods?

Name. Roberta ingram Yes

% No Phone. 301-415-1219 OMB 83-1 in.s iorm .ar

• yed uwa irearm. 10/95 9907140137 990525 PDR ORG EUSOMB PDR

p OMB SUPPORTING STATEMENT FOR FINAL RULE 10 CFR PARTS 50 and 72 CHANGES, TESTS, AND EXPERIMENTS AND UPDATING OF FINAL SAFETY ANALYSIS REPORTS 3150-0011 and 3150-0132 REVISION Description of the information Collection The exisw regulations under 10 CFR 50.59 (OMB Clearance No. 3150-0011) specify record-keepie! c w reporting requirements of changes, tests and experiments performed by licensees of production and utilization facilities. Section 72.48 (OMB Clearance No. 3150-0132) specifies requirements similar to those in section 50.59, but applicable to independent spent fuel storage installations (ISFSI). In particular, these sections require licensees to maintain records of evaluations of changes, tests and experiments e~i to ceriodically submit a report with a brief description of the change, test or experiment and a summary of the evaluation. In the subject rulemaking, the NRC is revising certain provisions of these regulations as they pertain to the j conduct of evaluations of such changes, tests, and experiments. The purpose of the rulemaking J is to clarify the requirements through definitions, and to provide some flexibility for licensees to make changes without NRC approval that have only minimal impact on safety. These revisions impact upon the recordkeeping and reporting burden of the existing rules. The authority presently provided for in section 72.48 is being extended to Part 72 certificate holders, allowing them to make certain changes to a certified spent fuel cask design without prior approval. Use of this authority necessitates accompanying record and reporting requirements for the certificate {

holders. The revised rule requires that Part 72 licensees and certificate holders provide copies I of the records of changes made to each other (when the same certified cask is involved) to keep all parties informed. Further, the rule standardizes the filing frequency at 24 months for all the facilities for the summary reports required by sections 50.59 and 72.48.  !

l Existing requirements in section 50.71(e)(OMB Clearance No. 3150-0011) and section 72.70  !

(OMB Clearance No. 3150-0132) require power reactor licensees and ISFSI licensees, l respectively, to periodically submit updates to their Final Safety Analysis Reports (FSAR). The rule modifies in certain respects the form of the information to be included in these updates to the FSAR. In addition, the rule adds a section pertaining to update requirements for FSARs for l certificate holders under new section 72.248. i

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A. JUSTIFICATION j

1. Need for the Collection of Information.

Section 50.59M throuah (d) 1 The revised rule adds definitions to clarify which changes require evaluation to determine j if prior NRC approval is needed. The definitions explicitly include additions to the facility, and changes to performance requirements and methods of evaluation presented in the FSAR as changes requiring review. The rule also defines a " change" that requires evaluation as meaning one in which design functions or performance requirements may j be affected; otherwise, a change can be made without further evaluation. The rule also l I

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explicitly relieves licensees of the need to perform evaluations under section 50.59 for '

changes to the facility as described in the FSAR when there are other regulatory processes that govern such changes. There may be a slight increase in burden for licensees who have not previously interpreteo the rule requirements as requiring evaluations of these aspects. There may be a slight unquantifiable decrease in burden from the clarification that changes to procedures do not require evaluation pursuant to section 50.59 if other provisions (such as in section 50.54) apply. Some reduction in burden is expected as a result of the definition of change as being a change that affects a design function or requirement, thus allowing licensees to screen certain changes as l not needing a detailed evaluation against the criteria in section 50.59(c)(2). A screening )

review requires less documentation and thus less recordkeeping. Records and reports l' of changes that meet the specified definitions and criteria are needed to enable the NRC to assure that the licensee has properly exercised the authority granted by this section.

The rule also specif;es more clearly that reference to %Wty analysis report" should be read to mean the FSAR, as updated. Further, explicit language was added to require  ;

that the evaluation of changes consider other changes already implemented, but not yet j reflected b the submitted FSAR. These rule changes are not viewed as adding i additional reporting or recordkeeping burden; rather, these changes would align the j stated rule requirements with standard implementation practice. Were a licensee to j conduct its evaluations against a version of the safety analysis report that did not include j consideration of other changes made, such as those that were to be reflected in the required updates, those evaluations would not provide needed assurance that the  !

licensee-planned change (to be made without prior NRC review and approval) would not j impact the licensing basis of the facility. l l

As part of this rulemaking, the NRC is revising tne frequency for submitting summary l reports of changes made pursuant to section 50.59, from the existing frequency, that is either annual, or along with the FSAR update submittan (which can be up to two years),

to a uniform requirement of no more than 24 months between submittals.

Another change in this n* making is the requirement in section 50.59(d) that records be  !

retained until the termination of a license granted pursuant to Part 54. Part 54 contains the provisions for renewal of a power reactor license originally issued under Part 50. i The records to be retained contain vital information about reactor facility changes, tests l and experiments made without prior NRC approval. Without these records, NRC's ability  !

to protect the health and safety of the public would be reduced. There is no increased  !

burden unless a licensee applies for and receives a renewed license. Further, the burden associated with the additional record retention would likely be incurred by licensees in the course of doing business.

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As a result of the public comments, revisions were made to the definition of change to facilitate screening, to the filing frequency for the summary ieports. These revisions reduce the information collection burdsn as discussed above.

Section 50.71(e) l i

3 Existing requirements in this section specify that the FSAR update reflect the effects of changes made pursuant to section 50.59, among other ways. In the Statement of Considerations for promulgation of 10 CFR 50.71(e) (45 FR 30615), the NRC l commented on the relationship between changes made under 10 CFR 50.59 and FSAR updating, stating: "The 50.59(b) reporting may not be detailed sufficiently to be considered adequate to fulfill the FSAR updating requirement. The degree of detail required for upda'hg the FSAR will be generally greater than a 'brief description' and a l

' summary of the safety evaluation'." Further, it said: "New analyses...which were required during consideration of unreviewed safety questions, technical specifications or other licensing questions may be incorporated as appendices or otherwise inserted within the FSAR." Thus, the Commission clearly expected the update submittal to include sufficient information to appropriately reflect the changes that were made. In the proposed rule, the Commission had contemplated changes to update requirements to more explicitly discuss the effects of changes that might be made. In the final rule, only editorial changes to section 50.71(e) were made, which do not impact upon the update requirements.

The NRC dropped the proposal to explicitly discuss the cumulative effect of changes in response to public comments that the burden associated with this requirement was not justified in light of the specific evaluation criteria as revised. The NRC agreed with the commenters that the existing reporting requirernents are sufficient to document the effects of such changes. Thus, there was a reduction in estimated burden from the proposed rule to the final rule for this section.

Section 72.48 The rule adds to section 72.48(a) definitions to clarify which changes require evaluation to determine if pr.or NRC approvalis needed. As noted under the earlier discussion, there may be a slight increase in burden for licensees who have not previously interpreted the rule requirements as requiring evaluations of additions, or of changes to evaluation methods cnd analyses. There may be a slight unquantifiable decrease in burden from the clarification that changes io procedures do not require evaluation pursuant to section 72.48 if other provisions apply. There is also expected to be a decrease in burden associated with the revised language on " change" that allows a licensee or certificate holder to determine that the change to the FSAR doer act affect any function, and thus, does not require a detailed evaluation. On balance, the NRC estimates a net reduction in burden. Records and reports of changes that meet the specified definitions and criteria are needed to enable the NRC to assure that the licensee has properly exercised the authority granted by this section. .

The revision to section 72.48(b) grants authority to holders of Certificates of Compliance for a spent fuel storage cask to make changes to the cask design without prior NRC approvalif specified conditions are satisfied. Recordkeeping and reporting as specified in section 72.48(c)(renumbered from (b)) will be required by the certificate holders.

Records and reports of changes are needed to enable the NRC to assure that the licensee has properly exercised the authority granted by this section.

4 The frequency for submit +al of summary reports of changes was revised from annual to once per 24 months. Certificate holders would now be required to submit reports concerning changes they made pursuant to section 72.48 on the 24 month frequency.

The rule also specifies retention periods for records of changes made. The existing requirements were revised by shortening the retention time for records of changes to procedures, and for tests or experiments to 5 years; records for facility changes must be maintained until the license is terminated.

The rule requires that copies of records of changes made under section 72.48 be provided by licensees to the certificate holder for the spent fuel storage cask design, and for certificate holders to provide copies of records of their changes to licensees who use that cask. There is no burden if no changes are made; however, should a i;censee make changes, reports are needed to enable the NRC to maintain cognizance of the licensed facility, and thus assure public health and safety. Submittal by a licensee of a copy of the report to the certificate holder (and vice versa) is a small burden that provides useful information that the certificate holder or licensee might need to exercise its responsibilities under the certificate or I; cense so that the licensees can maintain cognizance of the design and operational features of that cask type. i The report filing frequency was revised to conform with those in section 50.59 in response to public comments. As for section 50.59, the revised definition of change that will facilitate screening, and thus reduce expect, 2 ourden, was also a result of the comments. j i

Section 72.70 h

The rule provides more specificity on filing or updates to the FSAR, such as by use of replacement pages. The rule also explicitly states that the FSAR update is to include description of changes to procedures made pursuant to section 72.48. On balance, l

} these requirements are considered to not increase the burden; there may be a slight l increase for descriptions of procedures, and there may be burden reduction by limiting  !

the number of pages that need to be submitted in accordance with existing requirements for submittal of updates to the FSAR. The frequency for filing updates (after initial submittal)is every 24 months. The existing requirement to submit the FSAR 90 days prior to the planned receipt of spent fuel or high-level waste was revised to instead require submittal 90 days after issuance of the license. This provides sufficient time for a ,

licensee to finalize its FSAR to reflect changes made during the licensing process, but l removes an unnecessary linkage of the submittal to use of the facility. ,

The report filing frequency was revised, resulting in reduced burden, because of the l public comments.

Section 72.80 l

Section 72.80(g) was added to state that each specific licensee shall notify the Commission of its readiness to begin operation at least 90 days prior to first storage of

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. spent fuel or high level waste in the ISFSI or MRS (Monitored Retrievable Storage l Installation). This notification is needed in view of the change discussed under section l 72.70, and is a small, one-time reporting requirement that allows NRC to maintain cognizance of the licensee's plans to use the facility for storage.

Section 72.216(d) l l

Not included as part of the final rule. The deletion of the proposed requirement for updating by a generallicensee of the FSAR was prompted by resolution of comments received.

Section 72.244 This section adds a requirement for a certificate holder to file an amendment application with the Commission whenever the certificate holder desires to amend the Certificate of l Compliance (CoC). The application shall describe the changes desired and the reasons l for such changes. This information is needed so that NRC can determine whether the amendment can be issued without endangering public health and safety. The burden is expected to be 120 houts per change that a certificate holder wishes; the NRC estimates that there may be one such application every two years per CoC holder.

Section 72.248 This section adds requirements for filing of updates to FSARs by holders of CoCs for a spent fuel storage cask. In particular, CoC hulders are to submit an FSAR 90 days after Commission approval of the cask design (per paragraph (a)), with updates filed every 24 months thereafter to reflect changes to facility and procedures made by the CoC holder (per paragraph (b)). The updates are to be provided to the NRC. If no changes are made, a letter so indicating is sufficient to satisfy the reporting requirement. Other rule provisions proposed to be added in this rulemaking would grant authority to CoC holders to make changes to the certified cask design without prior NRC approval, under specified conditions. Updates to the FSAR that include descriptions of the changes made under this authority are needed for NRC to maintain cognizance of the certified cask design as it is used at licensed facilities, and thus to assure public health and safety.

The frequency for filing of the updated FSARs was made 24 months, as are the other reporting frequencies, in response to the public comments.

2. Aaency Use of Information The records are used by licensees to interrelate subsequent changes and to prepare reports concerning changes, tests, and experiments as required by this section of the regulatiore. These records are also frequently used by NRC inspectors. The records provide the background information needed by the NRC inspector during his or her visit to a licensed facility. The inspector uses these records to confirm the appropriateness of changes, tests or experiments, or during evaluations of abnormal occurrences. Also, the inspector uses these records to ensure that changes and modifications to the facility do

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not compromise its licensing basis.

The agency uses the updated FSAR information supplied by the licensees and certificate ,

holders in response to the reporting requirements (sections 50.71(e),72.70 and 72.248) l as a primary reference source to be employed during the numerous safety studies ,

undertaken 'uy licensees, certificate holders, the Commission, and other interested parties. It also provides an information basis on the intended design and operation of the ,

facility for purposes of inspection.

3. l Reduction of Burden Throuah Information Technoloav I l

There is no legal obstacle to the use of information technology. Moreover, NRC )

encourages its use and has a goal of receiving at least 70 percent of all documents in i electronic format by the year 2000. At the current time, however, no responses are )

submitted electronically. l

4. Efforts to Identify Duolication and Use Similar information The information is not required by any other Federal regulation. The Information Requirements Control Automated System (IRCAS) was searched, and no duplication was found. This information can only be obtained from licensees of power and nonpower (research/ test) reactors, or from licensees and certificate holders for independent spent fuel storage installations, monitored retrievable storage or spent fuel storage casks.

5. Effort to Reduce Small Business Burden The burden on small businesses affects 55 licensees of nonpower reactors and 7 holders of certificates of compliance for spent fuel storage casks. This burden only occurs when licensees or certificate holders choose to make changes, tests or l experiments and cannot be further reduced without endangering the health and safety of j the public. I l

6. Consecuences to Federal Proaram or Policy Activities if the Collection is not Conducted or is Conducted Less Freauentiv The NRC would not be able to ensure the public health and safety with respect to ,

changes made to the facility without prior NRC approval. l

7. Circumstances which Justifv Variation from OMB Guidelines 1

Information is required to be submitted pursuant to 10 CFR 50.59 at least once per 24 l months and, therefore, does not vary from OMB guidelines. The record retention periods  ;

specified in 50.59(d)(5 years, and until termination of the license (either under Part 50 or I under Part 54)) are required because these records provide the NRC with vital I information about reactor facility changes, tests and experiments made without prior  ;

NRC approval. Without these records, NRC's ability to protect the health and safety of 1 j

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the public would be reduced. l A similar need exists for reports and retention of records as required by section 72.48 for changes, tests or experiments performed by ISFSI or MRS licensees or CoC holders for spent fuel storage cask designs. l l

The updated FSAR must be retained until the operating license is terminated because, in order for the NRC to ensure the public health and safety at all times, the staff must be certain of the current status of a facility's design and supporting analysis requirements.

8. Consultations Outside the NRC l 1

Opportunity for public comment for the revised reporting and recordkeeping requirements associated with sections 50.59,50.71(e),72.48,72.70,72.216 (withdrawn),72.244 and 72.248 was published in the Federal Reaister on October 21,1998 (63 FR 56236). No comments were received on this notice. However, comments were received in response to the proposed rule which was published October 21,1998 (63 FR 56098). These comments were considered prior to final rulemaking as noted above.

9. Payment or Gift to Respondents l 1

Not applicable.

10. Confidentiality of information No confidential information is generally received. However, proprietary or confidential information is hsndled in accordance with 10 CFR 2.790 of the NRC regulatbas.

11. Justification for Sensitive Questions This information collection does not require sensitive information. ]

12. Estimated Industry Burden and Burden Hour Cost The burder from recordkeeping and reporting reauirements arising from the revisions to the rules is estimated as shown in the attached Tables. For purposes of this estimate, NRC has used the assumptions used in its most recent information collection request to the Office of Management and Budget concerning the existing regulations, except for j those aspects specifically impacted by the rulemaking. The burden estimste, including j an estimate of one-time costs as a result in changes to the rule requirements, is shown l in the attached table. As noted, the NRC concludes that the effect of the changes on j recordkeeping and reporting requirements will be at most a small increase over the l existing burden, mostly due to the implementation costs for the revisions. j For Part 72 facilities, the existing burden for reporting and recordkeeping is quite smallin comparison to that for Part 50 facilities. This is because the number of licensees is ,

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. smaller and the expected number and complexity of changes is less than would be expected for reactors. The NRC estimates the change in burden for Part 72 as being only a slight increase over the existing burden and the increase is associated with the rule changes related to CoC holders.

While one-time costs will be incurred for procedure revisions and training, NRC expects savings to result from the added flexibility being provided for licensees to implement certain changes without the need to submit a license (or certificate) amendment request for NRC approval before implementation. The potential burden reduction from this part of the rule change is not included in the estimates of burden presented below. l

13. Estimate of Other Additional Costs l None.

14. Estimated Annualized Cost to the Government The estimated annual .J cost to the government is not expected to change as a result ,

of the rule except for a one-time burden to revise existing procedures and to train staff. l The estimated burden is 6,100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> at a cost of $756,400 ($124 an hour). I The cost is fully recovered through fee assessments to NRC licensees pursuant to l 10 CFR Parts 170 and 171.

15. Reasons for Chance in Burden or Cost i The rule is estimated to increase the information collection burden by an estimated 37,295 hours0.00341 days <br />0.0819 hours <br />4.877645e-4 weeks <br />1.122475e-4 months <br />. This burden increase is as follows and is shown on the attached Tables. 1 Under Part 50, the reporting burden per response for section 50.59(d) will increase because of the larger volume of changes in a two year period, but the frequency of  ;

reporting is less; also, the number of changes to be reported may be slightly smaller as a result of screening, thus, on an annualized basis, there is a slight reduction in burden.

The total Part 50 reporting burden as a result of the rule is expected to decrease by 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />.

The recordkeeping burden under Part 50 decreases per recordkeeper, for those changes that can be screened rather than receive a full evaluation, for a total estimated reduction of 15,664 hours0.00769 days <br />0.184 hours <br />0.0011 weeks <br />2.52652e-4 months <br />. The estimate in the tables also includes a one-time annualized burden of 52,115 hours0.00133 days <br />0.0319 hours <br />1.901455e-4 weeks <br />4.37575e-5 months <br /> to revise existing procedures. The total Part 50 burden increase for the rule is thus 35,851 hours0.00985 days <br />0.236 hours <br />0.00141 weeks <br />3.238055e-4 months <br />.

For Part 72, the revised rule adds 7 respondents under sections 72.48 and 72.248. The reporting frequency under sections 72.48 and 72.70 was revised from 12 monthe to 24 months. The burden increase for (new) section 72.248 is from 0 to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. In ,

addition, the estimated reporting burden per response under section 72.48 increases l from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> because the reporting frequency has increased. A decrease 1

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9 of 210 burden hours per year is expected under section 72.70. The repnrting burden added for section 72.244 is estimated as 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per respondent per year. Thus, the '

total Part 72 reporting increase is 420 hours0.00486 days <br />0.117 hours <br />6.944444e-4 weeks <br />1.5981e-4 months <br />.

The recordkeeping burden under Part 72 adds 7 recordkeepers for an increase of 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />. As in Part 50, Part 72 also includes a one-time annualized burden of 954 hours0.011 days <br />0.265 hours <br />0.00158 weeks <br />3.62997e-4 months <br /> to revise existing procedures. The total Part 72 burden increase for the rule is thus 1,444 ,

hours. l l

Chanaes from the Proposed Rule in the estimates for the proposed rule, the NRC had included estimated changes in burden for FSAR updating for Part 50 facilities. With the revisions included in the final rule, no change in burden under $50.71(e) is expected and therefore this section is not included in the tables.

In the proposed rule, NRC had estimated an increase in reporting burden because of the proposed addition in section 72.216(d) of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per respondent for general licensee updating of FSARs. In the final rule, this section was removed.

The net effect of the changes from the proposed rule to the final rule is a reduction in informauon collection burden of 102,629 hours0.00728 days <br />0.175 hours <br />0.00104 weeks <br />2.393345e-4 months <br />.

16. Publication for Statistical Use 1

The collected information is not published for stctistical use.

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17. Reason for not Disolavino the Exoiration Date l

The requirements are contained in regulations. Amending the Code of Federal l Regulations to display information that, in an annual publication, could become obsolete I would be unduly burdensome and too difficult to keep current.

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18. Exceptions to the Certification Statement None.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.

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