The NRC regulations in 10 CFR Part 71 establish requirements for packaging, preparation for shipment, and transportation of licensed material, and prescribe procedures, standards, and requirements for approval by NRC of packaging and shipping procedures for fissile material and for quantities of licensed material in excess of Type A quantities. The NRC collects information pertinent to 10 CFR Part 71 for three reasons: to issue a package approval; to ensure that any incidents or package degradation or defect are appropriately captured, evaluated and if necessary, corrected to minimize future potential occurrences; and to ensure that all activities are completed using an NRC-approval quality assurance program.
There was a 4,995 hour increase in the overall burden, from 25,594 hours to 30,589 hours. The NRC reviewed data from the past 3 years and adjusted estimates for Part 71, based on the current number of licensees and staff knowledge of the industry. Due to variation in casework from year to year, 3 yearsâ worth of data was reviewed to assist in estimating this renewal periodâs annual reporting burden. A summary of the changes is below. Please see the supplemental burden change spreadsheet for details on burden changes for each reporting, recordkeeping, and third-party disclosure requirement under 10 CFR Part 71.
COMPARISON OF CURRENT VS. PREVIOUS ESTIMATES
2016 Submission Current Submission
Responses (estimated) 660 634
Total Burden (estimated hrs) 25,594 30,589
Fee Rate $268 /hr $275/hr
Total Burden (estimated cost) $6,859,165 $8,411,948
Most of the increase in burden can be attributed to a change in the estimated number of responses to 71.31, âApplication for package approval.â Under 71.31, licensees submit applications for new certificates or amendments to certificates under Part 71. An application must include a package description, evaluation, and a QA program description or a reference to a previously approved QA program. Previously, the NRC staff estimated that 25 respondents would each send one application annually (25 x 1 = 25 responses). Upon reviewing recent data, NRC noted that more responses were being received than previously estimated. As a result, staff adjusted this estimate to more accurately reflect that 25 respondents would each send two applications annually (25 x 2 = 50 responses). At 300 hours per application, this increase of 50 applications (25 + 25 = 50) resulted in an increase of 15,000 hours (50 x 300 = 15,000).
Another change that decreased burden totals was a change to the estimated number of responses to 71.39, âRequirement for additional information.â Under this requirement, the Commission may ask a licensee for more information to enable it to determine whether a license, CoC, or other approval should be granted, denied, modified, suspended, or revoked. The additional information submitted is reviewed by the NRC staff to assess the adequacy of the applicant's design, procedures, and other measures for protection of the public health and safety and the common defense and security and to meet all specified requirements. Previously, the NRC staff estimated that 36 respondents would each be asked to provide additional information two times per year (36 x 2 = 72 responses). After reviewing recent data, the NRC staff reduced the estimate to better reflect the actual number of requests for additional information being issued. The current request estimates that 25 respondents will be asked to provide additional information twice per year (25 x 2 = 50 responses). At 110 hours per request, this reduction of 22 responses (72 â 50 = 22) results in a decrease of 2,420 hours (22 x 110 = 2,420).
In addition, the changes in burden cost reflect an overall decrease in NRCâs hourly fee rate from $268/hr to $275/hr.
$5,383,125
No
No
No
No
No
No
Uncollected
Tomeka Terry 301 415-1488
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.