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
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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 safety issue that has potential for affecting two or more nuclear facilities. A generic safety issue 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 certification rules); 2) affects public health and safety, the common defense and security, or the environment; 3) is not already being processed under an existing program or process; and 4) can be resolved by new or revised regulation, policy, or guidance or voluntary industry initiatives. A generic safety issue may lead to regulatory changes that either enhance safety or reduce unnecessary 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 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 requested in Form 833 is needed to enable the NRC staff to assess the potential generic safety issue against the seven screening factors specified in NRC Management Directive 6.4, Generic Issues Program. Potential 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 technology 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% of 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 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, the NRC will be unable to assess whether a potential generic safety issues affecting nuclear facilities exists.

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 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, 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 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 />. Using an hourly rate of $300 for 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 that one proposed generic issue will be submitted annually with a cost to the Federal 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