ML20198M418

OMB 3150-0228 Draft 2021 Collection Renewal Voluntary Reporting of Planned New Reactor Applications - Supporting Statement

ML20198M418
Person / Time
Issue date:	11/19/2020
From:	NRC/NRR/DANU, NRC/OCIO
To:
Shared Package
ML20198M188	List: ML20198M418 ML20198M495 ML20337A440 ML20337A443
References
NRC-2020-0162, OMB 3150-0228
Download: ML20198M418 (6)

Text

DRAFT SUPPORTING STATEMENT FOR VOLUNTARY REPORTING OF PLANNED NEW REACTOR APPLICATIONS (3150-0228)

EXTENSION Description of the Information Collection This voluntary information collection assists the NRC in determining resource and budget needs as well as aligning the proper allocation and utilization of resources to support applicant submittals, future construction-related activities, and other anticipated 10 CFR Part 50 and/or Part 52 licensing and design certification rulemaking actions. In addition, information provided to NRC staff is intended to promote early communications between the NRC and the respective addressees about potential 10 CFR Part 50 and/or Part 52 licensing actions and related activities, submission dates, and plans for construction and inspection activities. This information collection facilitates more effective and efficient planning, scheduling, and allocation of NRC resources so that activities and reviews for both applicants and licensees are implemented and conducted in a manner that is altogether timely, consistent, and respective of scope, schedule, and budget constraints.

Annually, the NRC issues a Regulatory Issue Summary (RIS) requesting potential respondents voluntary submit the needed information. The information requested includes design, licensing, construction, and preapplication plans and schedules. The RIS provides guidance on how potential respondents can provide the requested information.

A. JUSTIFICATION

1. Need For and Practical Utility of the Collection of Information1 The NRC is developing pre-application, licensing, and project plans for all new reactor licensing and design certification applications, to include those applications and activities relating to the advanced reactor program. The status of a variety of design-related activities for both large light water reactors and small modular reactors are factored into this justification. To support this resource and budget planning effort, the NRC is seeking voluntary responses from all holders of, and applicants or potential applicants for, an early site permit (ESP), limited work authorization (LWA), standard design certification (DC), construction permit (CP),

operating license (OL) or combined license (COL) for construction and operation of a nuclear power plant requests (under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants), as well as all holders of, and applicants or potential applicants for, a 1

AEA sec. 161c., which authorizes the Commission to make such studies and investigations, obtain such information, and hold such meetings or hearings as the Commission may deem necessary or proper to assist it in exercising any authority provided in this Act, or in the administration or enforcement of this Act, or any regulations or orders issued thereunder.

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power reactor construction permit (CP) referencing a Small Modular Reactor (SMR)2 design under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

This voluntary collection applies to new and/or updated information on schedules for submitting a CP, ESP, an amendment to, or transfer of, an ESP, an OL, a COL, a DC, amendments to a DC, a DC renewal, LWA, standard design approval (SDA),

and manufacturing license (ML) applications. In addition, NRC staff is seeking notification on the number and the degree of complexity of ESP, LWA, DC, OL, and COL applications, and any other licensing requests that applicants or potential applicants expect to submit in fiscal years (FYs) 2021 through 2023. The information collected helps facilitate more effective and efficient planning, scheduling, and allocation of NRC resources so that activities and reviews for both applicants and licensees are implemented and conducted in a manner that is altogether timely, consistent, and respective of scope, schedule, and budget constraints.

2. Agency Use of Information This information assists the NRC in determining resource requirements, aids in optimizing resource allocations, as well as informing future budget needs with respect to the aforementioned submittals, future construction-related activities, and other anticipated 10 CFR Part 50 and/or Part 52 licensing and design certification rulemaking actions. As well, this information is intended to promote early communications between the NRC and addressees about potential 10 CFR Part 50 and/or Part 52 licensing actions and related activities, submission dates, and plans for construction and inspection activities. It is also the intended goal of these communications to assist NRC staff more effectively and efficiently plan, schedule, coordinate, and implement, activities and complete reviews in a timely manner.

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. The NRC has issued Guidance for Electronic Submissions to the NRC which provides direction for the electronic transmission and submittal of documents to the NRC. Electronic transmission and submittal of documents can be accomplished via the following avenues: the Electronic Information Exchange (EIE) process, which is available from the NRC's Electronic Submittals Web page, by Optical Storage Media (OSM) (e.g. CD-ROM, DVD), by facsimile or by e-mail. It is estimated that approximately 80% of the potential responses are filed electronically.

2 SMRs are defined using the International Atomic Energy Agency definition of small- and medium-sized reactors with an electrical output of less than 700 megawatts.

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4. Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.

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 Applicants, licensees, and potential applicants report this information on a strictly voluntary basis. This information, in turn, aids NRC staff in determining resource and budget needs to support various activities and reviews so that NRC staff is able to maximize and best utilize existing budget and staff resources as well as plan effectively for future resource and budget needs, coordinate activities, and facilitate more efficient reviews.

If such information is not collected, the potential to assess the need for various resources and support capabilities, as well as enable NRC staff to efficiently and effectively plan and prepare budgets, align resources, remedy potential skill gaps, and prepare for incoming review and inspection activities, can be significantly impeded. This has the potential to result in significant program and project scope creep, schedule slip, and budget overruns that adversely affect the mission readiness of NRC staff as well as the objectives of potential new applicants, current applicants, and current licensees.

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 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 accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).

11. Justification for Sensitive Questions No sensitive information is requested.

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12. Estimated Burden and Burden Hour Cost The NRC staff estimates that both applicants and licensees will submit approximately 20 responses (7 new + 3 updated + 10 declaration letters = 20 responses) to this annual voluntary information collection, and that each new or updated submittal will require approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> on average to prepare and submit. Declaration letters will require an estimated one hour on average to prepare and submit.

To ensure that the NRC can effectively schedule resources and facilitate the achievement of an acceptance review of an application in 60 calendar days, the NRC staff requests that, 90 days before the expected submission date, an applicant, licensee, or potential applicant (as applicable) declare the expected submission date (month, day, and year) and estimate the degree of complexity of each of its submittals to the NRC, to the extent practicable. The NRC staff estimates the burden to prepare and submit these declarations would be approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per response for a total of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for this clearance cycle (7 new declarations x 1 hr +

3 updated declarations x 1 hr. = 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />).

The total licensee and applicant burden for this voluntary information collection is (7 new responses x 60 hrs. = 420 hrs. + 3 updated responses x 60 hrs. = 180 hrs. + 10 declaration letters x 1 hr. = 10) = 610 hours0.00706 days <br />0.169 hours <br />0.00101 weeks <br />2.32105e-4 months <br />, see Table 1, at a cost of $170,190 (610 hours0.00706 days <br />0.169 hours <br />0.00101 weeks <br />2.32105e-4 months <br /> x $279/hr.).

There are no recordkeeping requirements imposed on these submissions, any/all recordkeeping associated with these responses are included in 10 CFR Part 52 approved by OMB under Clearance 3150-0151.

The $279 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 2020 (85 FR 37250, June 19, 2020).

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

14. Estimated Annualized Cost to the Federal Government The annual cost to the NRC including staff hours and contractual support:

Staff hours = 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year @ $279/hr. = $16,740 Contractual Support = $0 per year TOTAL COST = $16,740 4

15. Reasons for Change in Burden or Cost There has been an increase in the cost of the hourly rate from $263/hr. to $279/hr.

for this cycle. The projected increase in the expected number of respondents is due to the significant interest from industry in the new and advanced reactor programs.

Additionally, this cycle includes submissions for updating previously submitted information as well as the burden and responses for 90-day declarations.

16. Publication for Statistical Use This information is not published for statistical use.

17. Reason for Not Displaying the Expiration Date The requirement will be contained in a regulation. Amending the Code of Federal Regulations to display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.

18. Exceptions to the Certification Statement None.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in this collection of information.

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TABLE 1 ANNUALIZED REPORTING BURDEN (Voluntary)

Total Responses Burden Annual No. Of Total No. of Section per Hours per Reporting Respondents Responses Respondent Response Burden (Hrs)

Voluntary 7 1 7 60 420 Response to Annual Regulatory Issue Summary request for information -

New Submissions Voluntary 3 1 3 60 180 Response to Annual Regulatory Issue Summary request for information -

Updated Submissions 90-Day 10 1 10 1 10 Declaration Letter Submissions 20 20 610 TOTAL BURDEN HOURS: 610 hours0.00706 days <br />0.169 hours <br />0.00101 weeks <br />2.32105e-4 months <br /> (610 hours0.00706 days <br />0.169 hours <br />0.00101 weeks <br />2.32105e-4 months <br /> reporting + 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> third party notification + 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> recordkeeping)

TOTAL BURDEN HOUR COST: $170,190 (610 hrs x $279/hr)

ANNUAL RESPONDENTS: 20 respondents RESPONSES: 20 responses (10 RIS responses + 10 declaration letters + 0 third party responses

+ 0 record keepers) 6