NRC Form 171 Revision Request SS 2009 (2)

NRC Form 171 Revision Request SS 2009 (2).doc

NRC Form 171, Duplication Request

OMB: 3150-0066

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DRAFT SUPPORTING STATEMENT

FOR

NRC FORM 171, “DUPLICATION REQUEST”

(3150-0066)


REVISION REQUEST



Description of the Information Collection


As indicated in 10 CFR 9.21(b), various Nuclear Regulatory Commission (NRC) documents are made available to the public through the NRC Public Document Room (PDR). In addition to ensuring accessibility to reading the documents, the NRC has a contractor provide reproduction services to the public. Although individuals may utilize the NRC microfiche reader-printers, as well as the public computers with access to ADAMS, to print and pay for full text documents, they often request the contractor to perform this reproduction service.


  1. JUSTIFICATION


1. Need for and Practical Utility of the Collection of Information


Only one form is required to capture the different electro-mechanical processes necessary to complete the different reproduction services requested by the public.


2. Agency Use of Information


Reproduction form is completed by the individual member of the public making a request, or by the Technical Information Center Section / PDR personnel in response to requests from the public, for which the contractor’s reproduction services are to be utilized. The specific data on this form permits the contractor to reproduce the correct items, to contact the requester when problems arise, and to provide a bill for services rendered. The requester, if onsite, maintains a copy for his records. Otherwise, the PDR staff retains this copy, the contractor returns a copy of the completed request to the requester, and a third copy is maintained by the contractor in request order number sequence in case a question arises concerning a past service performed. No Personally Identifiable Information is retained beyond 90 days, after which the forms are securely destroyed. The contractor provides the Public Document Room/Technical Information Center Section each month with a statistical summary report related to the number of users in the past month and to the number of pages, microfiche, aperture cards, computer diskettes, audio and video cassettes reproduced the previous month for requesters. This data is utilized by the NRC in its annual report to Congress.



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 new automated information technology when it would be beneficial to them. NRC issued a regulation on October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e-mail, special Web-based interface, or other means. Requests which are not for personal records that require verification of identity of the requester are being accepted by e-mail, fax, mail, phone, and in-person written requests. It is anticipated that one-half of all requests will be submitted electronically.


Requests for NRC documents can be made by e-mail. However, there is no mechanism currently in place to submit orders directly to the contractor. Due to the documents being physically available only in the Public Document Room, the contractor cannot directly take orders from the public.


4. Effort to Identify Duplication and Use Similar Information


The collection of the information required is not a duplication of other information and no sources of similar information are available. NRC has in place an on-going program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.



5. Effort to Reduce Small Business Burden


The information required is needed for all individuals regardless of the size of the entity, if any, by which they are employed. The information requested is basic to the information search and retrieval, and cannot be reduced.


6. Consequences to Federal Program or Policy Activities if the Collection is not

Conducted or is Conducted Less Frequently


The respondent determines the frequency of completing the form. A form is completed only at the time the document is requested for reproduction at the PDR.


7. Circumstances Which Justify Variation from OMB Guidelines


This information collection does not vary from OMB guidelines.



8. Consultation 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 the 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


This form includes questions about address, phone number, e-mail address, and credit card information necessary for billing the customer correctly. The PDR staff does not maintain credit card information on the copy of the form kept for our records.


12. Estimate of Annualized Burden and Burden Hour Cost


Documents for duplication are requested by the public. The PDR staff submits an individual NRC Form 171 per each request for duplication. The estimated burden for submission of requests is based on the number of requests received during the current clearance period, observation, and sampling and is as follows:


Total Requests 1,200 respondents


Total Burden: 100 hours = 1,200 respondents X 5 minutes = 6,000 minutes/60


Cost $25,700 (100 hours x $257)


Based on the number of requests received during the current clearance period, we estimate an 85% decrease in the number of requests during this 3-year renewal period.


13. Estimate of Other Additional Costs


Not applicable.









14. Estimated Annualized Cost to the Federal Government


Estimated burden for NRC staff to record telephone requests and verify all requests for NRC documents is as follows:


It is estimated that it takes the NRC staff 5 minutes each to fill out the Form 171 for a total cost for 100 hours of $25,700 (1,200 requests @ 5 minutes each of 6,000 minutes/60 minutes = 100 hours X $257)

This cost is fully recoverable by fee assessments to NRC licensees pursuant to 10 CFR Part 171.


15. Reasons for Change in Burden


The burden hours decreased by 890 hours from 990 hours to 100 hours as a result of the introduction of the agency’s Web-based Agencywide Documents Access and Management System (ADAMS) in 2004, and due to more microfiche documents being retrofitted or scanned into ADAMS. This has made more of the agency’s public documents accessible to all Internet access users. Since the deployment of Web-based ADAMS to the public, there has been a decrease in the number of requests from the public to duplicate documents primarily resulting in telephonic request. Based on the number of requests received during the current clearance period, we estimate an 85% decrease in the number of responses from 7,940 to 1,200 during this 3-year renewal period.


The changes in burden cost reflect an increase in NRC’s recoverable fee rate, which increased from $216/hr to $257/hr.


16. Publication for Statistical Use


The reproduction contractor provides the Public Document Room /Technical Information Center Section each month with a statistical summary report related to the number of users in the past month and to the number of pages, microfiche, and aperture cards reproduced the previous month for the users. This data is utilized by the NRC in its annual report to Congress.


17. Reason for not Displaying the Expiration Date


Not applicable.


18. Exceptions to the Certification Statement


There are no exceptions.


  1. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS


Statistical methods are not used in the collection of information.


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