Part A-Uranium-Supporting Statement-2009

Supporting Statement
for the
Uranium Data Program
OMB Number 1905-0160

Introduction:
A three-year clearance is requested for the Energy Information Administration (EIA) to modify
and continue the use of Form EIA-851A “Domestic Uranium Production Report – Annual,”
Form EIA-851Q “Domestic Uranium Production Report – Quarterly,” and the Form EIA-858
“Uranium Marketing Annual Survey” to conduct its Uranium Data Program (UDP) through
2012. These forms were previously cleared under the Uranium Data Program, OMB number
1905-0160, through 12/31/2009.
EIA proposed changes to the Form EIA-851A and Form EIA-858, which were published on
April 29, 2009 in Federal Register Notice Vol. 74, No. 81. Public comments to the proposed
changes and other items are summarized in Section 8 of this supporting statement.
Proposed Change to the EIA-851A “Domestic Uranium Production Report – Annual”
Form EIA-851A proposes the additional collection of uranium resource information. This data is
collected by a new question, Item 8 which gathers data on properties that contain uranium
resources. This question was previously included on the EIA-858 from 1984 through 2002 as
part of EIA uranium resource data collection and publication effort. This data collection was
performed to update data that was collected by a large research effort known as the National
Uranium Resource Evaluation (NURE). Although the NURE program was completed by the US
Department of Energy in 1984, EIA attempted to maintain estimates of reserve data through
2003 by decrementing reserves based on production data and by seeking updated reserves data
from EIA-858 respondents. The reserves data collection effort was suspended in 2003 when the
disconnection to the original baseline data was judged to be too significant.
Now, in response to the expected increase in demand for uranium due to expanding nuclear plant
capacity, EIA is attempting to improve the current understanding of domestic uranium resource
data. To meet this need, EIA is proposing to restore the uranium resource data component to the
EIA-851A. Specifically, the uranium resource data question which was previously cleared by
Office of Management and Budget (OMB) was pulled into EIA-851A as Item 8, with a minor
simplification.
The annual burden associated with the collection of this additional detail would be increased by
2 hours for an estimated average 5 hours per response.
Proposed Change to the EIA-858 “Uranium Marketing Annual Survey”
In the Federal Register Notice Vol. 74, No. 81, EIA proposed two significant changes to the
EIA-858. These were the addition of a new data field to an existing question and a new question.
The field that was added to an existing question was the physical location of each uranium

Supporting Statement for Uranium Data Program 1905-0160

material type. Previously, this question requested the respondent to provide the amount of
uranium, by material type, that it owned, which is essentially an inventory question. EIA
initially proposed adding another field to this inventory that requested the respondent to provide
the location of each material type in its inventory.
Additionally, a new question was proposed which requested each respondent to indicate how
much material it imported and exported. This new proposed question was to collect imports and
exports by material type and by domestic or foreign origin.
Both proposed changes were made to collect data in order to provide a better understanding of
the physical location and movement of materials along the nuclear fuel cycle.
To supplement the effectiveness of the Federal Register Notice in determining the feasibility of
collecting this data, EIA performed tests on these changes. These tests consisted of respondent
interviews that sought specific feedback about the proposed changes to the EIA-858. The results
of the tests indicated that respondents would not be able to provide sufficiently complete and
accurate responses to those questions. Commercial transactions in the uranium fuel supply
market are typically transfers of ownership rather than physical deliveries of material. This
market structure tends to minimize the amount of physical shipments of uranium materials. As a
result, the physical location of the total amount of material owned is difficult for a respondent to
determine.
The testing indicated that incorporating the proposed changes into the EIA-858 would not collect
sufficiently complete and accurate data. EIA proposes to submit the version of the EIA-858 as it
was cleared in 2006. The burden of completing the EIA-858 remains unchanged at 15 hours per
response.
There are no proposed changes to EIA-851Q, “Domestic Uranium Production Report –
Quarterly”
The information collection proposed in this supporting statement has been reviewed in light of
applicable information quality guidelines. It has been determined that the information will be
collected, maintained, and used in a manner consistent with the Office of Management and
Budget (OMB), Department of Energy (DOE), and EIA information quality guidelines.

Justification:
1.

Legal Authority
Authorization for collection of data on the three UDP surveys is set forth in the Federal
Energy Administration Act of 1974, as amended, (FEA Act, Public Law 93-275).
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Supporting Statement for Uranium Data Program 1905-0160

Mandatory collection of these data is authorized by Section 13(b) of the FEA Act of
1974, 15 U.S.C. 772(b), as follows:
All persons owning or operating facilities or business premises who are
engaged in any phase of energy supply or major energy consumption shall
make available to the (Secretary) such information and periodic reports,
records, documents, and other data, relating to the purposes of this Act,
including full identifications of all data and projections as to source, time,
and methodology of development, as the (Secretary) may prescribe by
regulation or order as necessary and appropriate for the proper exercise of
functions under this Act.
The data submitted assist the Secretary in carrying out the functions and duties presented
in Section 5(b) of the FEA Act, 15 U.S.C. Section 764(b), which states that the
Administrator of the FEA (now the Secretary of the U.S. Department of Energy) shall:
(2) assess the adequacy of energy resources to meet demands in the
immediate and longer range future for all sectors of the economy and for
the general public;...
(9) collect, evaluate, assemble, and analyze energy information on
reserves, production, demand, and related economic data;...
(12) perform such other functions as may be prescribed by law.
As the authority for invoking Section 5(b) above, Section 5(a) of the FEA Act of 1974,
15 U.S.C. Section 764(a) states:
Subject to the provisions and procedures set forth in this Act, the
(Secretary) shall be responsible for such actions as are taken to assure that
adequate provision is made to meet the energy needs of the Nation. To
that end, he shall make such plans and direct and conduct such programs
related to the production, conservation, use, control, distribution,
rationing, and allocation of all forms of energy as are appropriate in
connection with only those authorities or functions:
(1) specifically transferred to or vested in him by or pursuant to this Act;...
(3) otherwise specifically vested in the (Secretary) by Congress.
Authority for invoking Section 5(a) of the FEA Act is provided, in turn, by Section 52 of
the Federal Energy Administration Act, 15 U.S.C. 790a, which states:
(a) It shall be the duty of the Director to establish a National Energy
Information System (hereinafter referred to in this Act as the "System") ...
(which) shall contain such information as is required to provide a
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Supporting Statement for Uranium Data Program 1905-0160

description of and facilitate analysis of energy supply and consumption
within and affecting the United States on the basis of such geographic
areas and economic sectors as may be appropriate to meet the needs of
(1) the (Department of Energy) in carrying out its lawful functions; ...
(b) At a minimum, the System shall contain such energy information as is
necessary to carry out the Administration's statistical and forecasting
activities, and shall include, at the earliest date and to the maximum extent
practical subject to the resources available ... , such energy information as
is required to define and permit analysis of:
(1) the institutional structure of the energy supply system including
patterns of ownership and control of mineral fuel and non mineral fuel
resources and the production, distribution, and marketing of mineral fuels
and electricity; ...
(3) the sensitivity of energy resource reserves, exploration, development,
production, transportation, and consumption to economic factors,
environmental constraints, technological improvements, and
substitutability of alternate energy sources: ...
Additional authority for collection of uranium information on Form EIA-858 "Uranium
Marketing Annual Survey," is provided through the Energy Policy Act of 1992 (EPACT
1992), Public Law 102-486. This law provides under Subtitle B, 42 U.S.C. § 2296b-4,
Sec. 1015, that:
“. . . the owner or operator of any civilian nuclear power reactor shall report to the
Secretary (of Energy), acting through the Administrator of the Energy
Information Administration, for activities of the previous fiscal year—
(1) the country of origin and the seller of any uranium or enriched uranium
purchased or imported into the United States either directly or indirectly by
such owner or operator; and
(2) the country of origin and the seller of any enrichment services purchased by
such owner or operator.”

2.

Needs and Uses
The EIA's UDP collects basic data, which are required to meet the needs of DOE
legislative mandates and those of the States, the industry, and the user community. Data
obtained include, but are not limited to: selected annual data relating to aspects of
uranium exploration, mining of mineral materials from the ground, uranium concentrate
production and employment, inventories, actual and future uranium deliveries and
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Supporting Statement for Uranium Data Program 1905-0160

requirements, actual and future enrichment-feed shipments, uranium used in fuel
assemblies loaded into U.S. civilian nuclear power reactors, different uranium and
contract types, contract transactions and prices of uranium, purchases of enrichment
services (the standard measure is SWU), and data required by Congress that describes
the sellers and quantities of uranium and enrichment services including country origin of
the material. The data collected on these surveys are unique. Although limited amounts
of related or somewhat similar data might be available from other Federal agencies,
sources in the industry, and private sources, those data collections are not reasonable
alternatives for the data sets obtained through the Uranium Data Program surveys.
EIA-851Q (Quarterly)/EIA-851A (Annual), Domestic Uranium Production Report
The data collected on the EIA-851Q quarterly survey are used by the EIA to publish
quarterly uranium concentrate production and facility operating status in EIA report
Domestic Uranium Production Report - Quarterly.
The data collected on the EIA-851A annual survey will be used by the EIA to publish
annual data in EIA reports Domestic Uranium Production Report and Annual Energy
Review. Both surveys are used to answer inquiries and requests about these data from the
Congress, Federal Government, States, the industry, and public data users.
Among the specific uses for the EIA-851A annual data are the following:
o

To continue historical trends of uranium exploration and development activities
in the U.S. uranium industry including data on drilling and expenditures in the
domestic industry;

o

To publish annual U.S. production of uranium concentrate from ore and/or
solutions from different methods of mining, including underground, open pit, insitu leaching, and other production sources;

o

To publish uranium production including quantities of U.S. mine production,
uranium concentrate, processing facility capacities, uranium concentrate
inventories and shipments, and status of production facilities;

o

To continue historical trends on employment in the raw materials sector of the
U.S. uranium industry by State and category of work performed in exploration,
mining, milling, processing and reclamation operations.

Form EIA-858, Uranium Marketing Annual Survey
The data collected on Form EIA-858 are used by the EIA to publish annual reports, to
fulfill Congressional mandates under the Energy Policy Act of 1992 (Public Law 102486), and to answer inquiries and requests about these data from the Congress, Federal
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Supporting Statement for Uranium Data Program 1905-0160

Government, States, the domestic industry, and public data users. Form EIA-858 data are
not collected for any other organization within the DOE.
Form EIA-858 data are published in aggregate form for general statistical uses and are
the primary source of data on the U.S. uranium market. The EIA reports Uranium
Marketing Annual Report and Annual Energy Review carry forward several important
time series of data.
Among the specific uses of the EIA-858 data are the following:
o

To provide to Congress the origin countries and sellers of any uranium and
enrichment services purchased or imported into the United States by
owners or operators of any U.S. civilian nuclear power reactors;

o

To provide current and historical data trends on uranium marketing
activities in the United States, including amounts and prices of uranium
transactions, contract and material type, purchases of enrichment services
(the standard measure is SWU), domestic or foreign purchase and sale,
origins and destinations of enrichment feed deliveries, uranium loaded into
U.S. civilian nuclear power reactors, and uranium inventories;

o

To provide future data trends on U.S. uranium market requirements,
including contracted deliveries (filled requirements), unfilled market
requirements, and projected enrichment feed deliveries.

The uses described above for the data collected on Forms EIA-851A/Q and Form EIA858 assist the EIA and the DOE in fulfilling their legislative mandates and supplying upto-date information about the U.S. uranium industry to policymakers and all data users.

3.

Technical Considerations
The UDP survey instruments are designed to minimize respondent burden insofar as
possible and still meet requirements for data from the DOE and the user community. In
addition to the standard respondent identification information preprinted on Form EIA851A, Form EIA-851Q, and Form EIA-858, information for selected data elements from
each respondent’s survey form for the prior year are also preprinted on each form to
assist respondents in completing the surveys for the current year.
EIA developed and began a new Form EIA-858 Internet Data Collection (IDC) system in
2006. EIA developed and began a new Form EIA-851A&Q Internet Data Collection
(IDC) system for 2007 data. The IDC system offers greater data collection and
management efficiency, which reduces the overall reporting burden. EIA plans to
continue use of these data collection systems for Form EIA-851A, Form EIA-851Q and
Form EIA-858 respondents.
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Supporting Statement for Uranium Data Program 1905-0160

4.

Efforts to Reduce Duplication and Inadequacies of Similar Data
EIA is one of two statistical agencies that collect and/or maintain uranium data in the
Federal Government. The U.S. Geological Survey (USGS) collects information on
nonfuel minerals and materials, and also maintains the National Geochemical Data Base,
for hydrogeochemical and stream sediment analyses, based on the National Uranium
Resource Evaluation.
Non-statistical agencies that collect uranium data in the Federal Government include:
o U.S. Department of Commerce’s Bureau of Industry and Security (BIS), U.S.
Additional Protocol
o The Nuclear Regulatory Commission (NRC)
In the private sector, some uranium consultants, vendors, and brokerage, investing, and
trading firms collect data from the industry, and subsequently provide information on
production, prices, supply, and demand frequently through their websites and
subscription-based analytical reports. This information is similar to some of the data
collected on Form EIA-851A, Form EIA-851Q, and Form EIA-858.

5.

Burden Reduction for Small Businesses and Small Entities
Minimizing the burden to small businesses of responding to EIA surveys, which
constitute a sizeable segment of the domestic uranium industry, is of primary concern to
the EIA. Given the relatively small number of U.S. firms in the uranium industry, it is
important that each firm participating in the industry, regardless of the firm's size,
participate in the EIA's uranium industry surveys in order for the resulting statistical
information to accurately represent the entire domestic industry.
Companies engaged in the domestic industry range in size from small firms which can
participate in limited or full range of industry activities from land acquisition through
exploration, drilling, mining, milling, processing, conversion, and U.S. market
broker/traders; to large firms that own and operate U.S. nuclear power reactors, enrich
uranium, and fabricate nuclear fuel assemblies. The UDP survey forms request data for
items that are normally recorded in maintaining any business. Of the data elements
requested, little time will have to be spent by small companies in preparing their
responses.

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Supporting Statement for Uranium Data Program 1905-0160

6.

Results of Collecting Data Less Frequently
The Form EIA-851A and Form EIA-858 surveys collect U.S. uranium industry data
annually. The Form EIA-851Q survey collects three months of domestic uranium
production data each quarter of the year. Less frequent reporting would not enable EIA
to meet its mandate of providing timely, reliable information on the U.S. uranium
industry.

7.

Special Considerations
There are no special circumstances which would require the UDP surveys to be
conducted in a manner inconsistent with the guidelines in 5 C.F.R. 1320.6.

8.

Summary of Consultations Outside the EIA
Comments from the Federal Register Notice
EIA filed a notice of request for comments in the Federal Register on April 29, 2009
(Vol. 74, No. 81, pages 19449-19551.

During the 60-day comment period (April 29-June 29, 2009), EIA received two
comments directly pertaining to the notice:

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Supporting Statement for Uranium Data Program 1905-0160

Comment 1: Uranerz Energy Corporation

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Supporting Statement for Uranium Data Program 1905-0160

Comment 1: Uranerz Energy Corporation (continued)

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Supporting Statement for Uranium Data Program 1905-0160

Comment 1: Uranerz Energy Corporation (continued)

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Supporting Statement for Uranium Data Program 1905-0160

EIA Response to Comment 1:
For data collection purposes EIA considers reserves and reasonably assured resources to
be functionally equivalent. In response to Uranerz’s comment, EIA modified EIA-851A,
Item 8 and the instructions to make this functional equivalence more clear. This should
address the concern regarding Securities and Exchange Commission liability as well as
the taxation issue discussed in Item 4 of Uranerz’s comment letter. EIA will continue to
respect its confidentiality requirements as described in the Respondent Contact
Identification section of the EIA-851A.
In response to the request to clarify the definitions of the studies, EIA removed the
‘Studies’ field altogether from Item 8, avoiding the need for this clarification.
In response to the request to clarify reporting responsibilities by property, EIA would
expect that respondents would provide data for each U.S. property that they own or for
which they have development rights.

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Supporting Statement for Uranium Data Program 1905-0160

Comment 2: Southern Company

From: Hagan, Don C. [mailto:[email protected]]
Sent: Friday, May 01, 2009 10:18 AM
To: Bonnar, Douglas
Subject: RE: Federal Register Notice regarding EIA Uranium Survey Forms
Doug,
What's the definition of "Location"???? Are we being required to account for every pound or equivalent
pound by location??? Looks like there can only be one input from the way the form is set up.
It should be noted that utilities and vendors don't do "physical imports and exports" of material. We
have book transfers which means the material could have been imported or exported in prior years.
Please clarify.
There certainly don't decrease the burden put on utilities and there is no benefit in the end to utilities in
my opinion.
Don

From: Bonnar, Douglas [mailto:[email protected]]
Sent: Friday, May 01, 2009 8:53 AM
To: undisclosed-recipients
Subject: Federal Register Notice regarding EIA Uranium Survey Forms
Please note the recent posting to the EIA website at:
http://tonto.eia.doe.gov/whatsnew/newwhatsnew.cfm
Federal Register notice - Uranium Surveys
2009 Draft Forms and Instructions: Uranium Survey Forms Authorization 2009-2012
Douglas Bonnar
202-586-1085
[email protected]
Survey Operations Team
Coal, Nuclear and Renewable Fuels Division
Office of Coal, Nuclear, Electric and Alternate Fuels
Energy Information Administration
202-586-8800
www.eia.doe.gov
U.S. Department of Energy
www.energy.gov

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Supporting Statement for Uranium Data Program 1905-0160

EIA Response to Comment 2
As discussed in Comment 1, EIA proposes to remove this question from the EIA-858.

9.

Payments to Respondents
Respondents to Form EIA-851A, Form EIA-851Q, and Form EIA-858 receive no
payments.

10.

Provisions Regarding Confidentiality of Information
Except for the elements listed below, the information you provide will be used for
statistical purposes only. In accordance with the Confidential Information Protection
provisions of Title V, Subtitle A of Public Law 107-347 and other applicable Federal
laws, your responses will be kept confidential and will not be disclosed in identifiable
form to anyone other than employees or agents without your consent. By law, every EIA
employee, as well as every agent, is subject to a jail term, a fine of up to $250,000, or
both if he or she discloses ANY identifiable information about you.

The following elements reported on the uranium surveys will be considered “public information”
and may be publicly released in company or individually identifiable form, and will not be
protected from disclosure in identifiable form.
The information will be considered “public information” because the information has
been released in identifiable form for many years in the Domestic Uranium Production
Report – Quarterly, annual Domestic Uranium Production Report, Uranium Marketing
Annual Report, and Uranium Industry Annual reports.
Form EIA-851A (Annual) and Form EIA-851Q (Quarterly):
Respondent and Contact Information:
- Company Name
Item 1: Facility Information
- Name
- County
- State
- Owner
- Rated Capacity
- Operating Status

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Supporting Statement for Uranium Data Program 1905-0160

Form EIA-858:
Respondent and Contact Information:
- Company Name
Item 1: Contract
- A. Other Party Name
Item 3, Enrichment Services Purchased by Owners and Operators of Civilian Nuclear
Power Reactors
- B. Seller's Name
Instructions to the forms will include the following statement for each of the items below:
The information reported on the form will be considered “public information” and may be
publicly released in company or individually identifiable form, and will not be protected from
disclosure in identifiable form.

Form EIA-851A
The items RESPONDENT IDENTIFICATION NAME and all of ITEM 1:
FACILITY INFORMATION on Form EIA-851A

Form EIA-851Q
The items RESPONDENT IDENTIFICATION NAME and all of ITEM 1:
FACILITY INFORMATION on Form EIA-851Q

Form EIA-858
The items RESPONDENT IDENTIFICATION NAME and OTHER PARTY
NAME (ITEM 1A), and SELLER’S NAME (ITEM 3B) on Form EIA-858

11.

Justification for Sensitive Questions
There are no questions of a sensitive nature included on the UDP survey forms.

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Supporting Statement for Uranium Data Program 1905-0160

12.

Estimated Reporting Burden

Number of Respondents:
Frequency of Response:
Hours per Response:
Total Burden Hours:

Form EIA-851A
101
annually
5
505

Form EIA-851Q
17
quarterly
0.75
51

Form EIA-858
65
annually
15
975

The total burden for the surveys is 1,531 hours annually.

13.

Estimate of Cost to Respondents
The EIA estimates that there are no additional costs to respondents associated with these
surveys other than the costs associated with the burden hours as set forth in item 12
above. Costs of the burden hours to the respondent universe for completion of the Form
EIA-851A, Form EIA-851Q, and Form EIA-858 are estimated below. The dollar values
shown were derived using the standard formulas:
(Total burden hours)X($62.50 per hour*)=(Total respondent burden cost in
dollars)
* An average cost per hour of $62.50 is used because that is the average loaded (salary
plus benefits) cost for an EIA employee. EIA assumes that the survey respondent
workforce completing surveys for EIA is comparable to the EIA workforce.
and
(Total respondent burden, dollars)÷(Total number of respondents)=(Average cost per
responding company).
Form EIA-851A:

505 X $62.50 = $31,562.50
and
$31,562.50 ÷ 101 = $312.50/respondent

Form EIA-851Q:

51 X $62.50 = $3,187.50
and
$3,187.50 ÷ 17 = $187.50/respondent

Form EIA-858:

975 X $62.50 = $60,937.50
and
$60,937.50 ÷ 65 = $937.50/respondent
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Supporting Statement for Uranium Data Program 1905-0160

The total cost to all respondents for these 3 surveys is $95,687.50

14.

Estimate of Costs to the Federal Government
The total cost for EIA’s UDP is 1 Full-Time Equivalent (FTE) ($128,000) and contracted
IT support to develop, maintain, and enhance the internal & IDC systems for the Form
EIA-851A, Form EIA-851Q, and Form EIA-858.

15.

Changes in the Reporting Burden
Because of the increase in number of respondents and burden hours, the total for this ICR
has increased from 1,185 hours in 2006 to 1,531 hours in 2009.

Change from
2006 to 2009
Number of
Respondents
Hours per
Response
Burden increase
due to change in
respondent size
Burden increase
due to change in
form design

Form EIA-851A

Form EIA-851Q

Form EIA-858

+46

+7

-1

+2

0

0

+230

+21

-15

+110

0

0

Total Burden
Hours

+340

+21

-15

The total burden hour increase is 346 hours annually. This burden increase includes two
components. The increase that is attributable to a change in the size of the respondent
population is 236 hours. The principal causes of this change are an additional 46
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respondents in the EIA-851A frame and an additional 7 respondents in the EIA-851Q
frame.
The increase that is due to the program change at the agency discretion is 110 hours. The
principal cause of this change is the 2 hour per response burden increase on the EIA851A.

16.

Plans for Tabulation and Publication
Data tabulation and publication (EIA website posting) of Form EIA-851Q data is
scheduled 45 days after each quarter. The Forms EIA-851A and EIA-858 tabulated data
are scheduled to be posted in May of each year.

Form EIA-851A
Form EIA-851Q
Form EIA-858

17.

Month posted on EIA website
May
February; May; August; November
May

Display of Expiration Date
All three survey forms will display the expiration date.

18.

Exception to Certification
There are no exceptions to the certification.

B.

Collection of Information Employing Statistical Methods

1.

Universe of Respondents
The universe of the UDP respondents (companies) is as follows.


In 2009, seventeen respondents with existing or planned facilities report
(quarterly) on the Form EIA-851Q.

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2.



In 2009, there were 101 respondents on Form EIA-851A (those 17 quarterly
respondents plus another 84 respondents with uranium land, exploration, drilling,
mining, and/or reclamation activities in the United States).



In 2009, there were 65 respondents on the Form EIA-858. Thirty-four owners and
operators of U.S. civilian nuclear power reactors report and 31 U.S. suppliers
report on the Form EIA-858.

Collection Procedures
Both Form EIA-851A and Form EIA-851Q surveys were conducted on a new IDC
system to collect the data starting in 2007. The Form EIA-858 survey will utilize its IDC
system to collect the data. EIA will continue to maintain an alternative method to collect
the data using the Secure File Transfer (SFT) of the survey forms.

3.

Response Rates
The response rate for the surveys is expected to be 100 percent, based on the past three
years of respondent reporting patterns:

Survey Year:
EIA-851A
EIA-851Q
EIA-858

4.

Response Rate
2006 2007 2008
100% 97% 99%
100% 100% 100%
100% 100% 100%

Tests
No tests are necessary.

5.

Statistical Contacts
EIA Coal Nuclear Energy and Alternative Fuels (CNEAF) Program Office:
Glenn McGrath, (202) 586-4325, [email protected]
For other questions, EIA Statistics and Methods Group (SMG):
Grace Sutherland, (202) 287-6264 or email at [email protected]

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