SUPPORTING STATEMENT farmer survey

SUPPORTING STATEMENT FOR REQUESTS FOR APPROVAL UNDER
THE PAPERWORK REDUCTION ACT AND 5 CFR 1320
Survey of Farms in the Vicinity of Nuclear Power Plants
OMB Approval # 3316-0016
Summary:
• This is a request for approval for an information collection for which approval has
expired.
• The information collection is planned to be conducted in mid-Spring 2012.
• The information collection is basically unchanged from previous approvals.
• This information collection does not employ statistical methods.

A. Justification.
1. Explain the circumstances that make the collection of information necessary. Identify any
legal or administrative requirements that necessitate the collection. Attach a copy of the
appropriate section of each statute and regulation mandating or authorizing the collection of
information.
The Nuclear Regulatory Commission (NRC) requires that all nuclear plants that are
operating, or are about to operate, conduct a survey of residents within five (5) miles of
the plant. The purpose of the survey is to locate in each of the sixteen compass sectors,
for monitoring and modeling purposes, the nearest residents, home gardens and animals
producing milk for human consumption. The license conditions also require the
consideration of the impacts of the use of irrigation water from streams receiving
effluents from the nuclear plants.
This monitoring is a mandated requirement of the NRC and is specified in the plant
technical specifications or other supporting documents. TVA currently has three (3)
nuclear power plants that are licensed for operation by the NRC. The appropriate section
of the supporting documentation outlining the requirements for the surveys for the
Browns Ferry, Sequoyah and Watts Bar Nuclear Plants is attached to this information
collection request.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a
new collection, indicate the actual use the agency has made of the information received from
the current collection.
In accordance with the licensing requirements, TVA’s Environmental Radiological
Monitoring and Instrumentation Department monitors milk and food products on a
regular basis. The results of these surveys identify the locations of the nearest residents,
gardens, and milk animals to aid in the selection of the sampling locations.
The plant licensing documents prescribe a radiological environmental monitoring
program to sample, among other things, soil, milk, vegetation, food crops and water
supplies. The primary purpose of this monitoring program is to determine if the
operation of the plants has an adverse impact on the environment or on people living
near the plants. The data obtained in the land use survey provides guidance regarding
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the selection of locations that should be sampled and is used to estimate radiological
exposures to people who live or work in the vicinity of the plants.
The survey (see TVA form 9476, Farmer Questionnaire), is required by Control 1.2.3 of
the respective ODCMs for Browns Ferry (Appendix A), Sequoyah (Appendix B), and
Watts Bar (Appendix C) Nuclear Plants. The questions in the survey are designed to
collect the information called for in the radiological environmental monitoring
specifications. A summary of the primary purposes of the questions included in the
survey is outlined below:
Top of the form: For identification purposes.
Section 1: To determine water sources that could be influenced by plant operations and
to identify potential locations for taking samples produced in home gardens.
Section 2: To identify locations producing milk for human consumption and to aid in the
identification of milk sampling locations.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological collection techniques or other forms of
information technology, e.g. permitting electronic submission of responses, and the basis for the
decision for adopting this means of collection. Also, describe any consideration of using
information technology to reduce burden.
The licensing conditions require an annual survey of residents within a 5-mile radius of
each plant. Because the respondents are typically farmers and rural residents, the use of
computers and other electronic information collection and transmission measures and
methods is precluded. Additionally, TVA does not believe it is feasible to conduct the
survey by mail or telephone. The person conducting the survey is required to be in the
survey area weekly to read radiation monitors. Once each year he incorporates
conducting the survey into his monitor reading activities.
For survey purposes, the 5-mile area around each of TVA’s nuclear plants is divided into
16 sectors. The residents who were surveyed the year before may not qualify for the
current survey because they may not have a home garden, milk animal, etc., that they
had the previous year. When a resident cannot be resurveyed, the surveyor must then
visually locate a new resident to survey who has one or more of the survey requirements
(home garden, milk animal, etc.).
4. Describe efforts to identify duplication. Show specifically why any similar information already
available cannot be used or modified for use for the purposes described in Item 2 above.
The United States Department of Agriculture offices have indicated that they do not
collect this type of information nor are they aware of any other organizations or agencies
which may collect this type of information.
5. If the collection of information impacts small business or other small entities (Item 5 of OMB
Form 83-I), describe any methods used to minimize burden.
This collection of information does not involve small businesses or other small entities.
The respondents are farmers and rural and/or residential residents.
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6. Describe the consequence to Federal program or policy activities if the collection is not
conducted or is conducted less frequently, as well as any technical or legal obstacles to
reducing burden.
If the collection were not conducted or were conducted less frequently, the licenses for
the operation of the nuclear power plants could be revoked by the U.S. Nuclear
Regulatory Commission (NRC).
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
- requiring respondents to report information to the agency more often than quarterly;
- requiring respondents to prepare a written response to a collection of information in fewer than
30 days after receipt of it;
- requiring respondents to submit more than an original and two copies of any document;
- requiring respondents to retain records, other than health, medical, government contract,
grant-in-aid, or tax records for more than three years;
- in connection with a statistical survey, that is not designed to produce valid and reliable results
that can be generalized to the universe of study;
- requiring the use of statistical data classification that has not been reviewed and approved by
OMB;
- that includes a pledge of confidentiality that is not supported by authority established in statue
or regulation, that is not supported by disclosure and data security policies that are consistent
with the pledge, or which unnecessarily impedes sharing of data with other agencies for
compatible confidential use; or
- requiring respondents to submit proprietary trade secret, or other confidential information
unless the agency can demonstrate that it has instituted procedures to protect the information’s
confidentiality to the extent permitted by law.
There are no special circumstances that require the collection of information to be
conducted in a manner inconsistent with the guidelines of 5 CFR 1320.6.
8. If applicable, provide a copy and identify the date and page number of publication in the
Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on
the information collection prior to submission to OMB. Summarize public comments received in
response to that notice and describe actions taken by the agency in response to these
comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the
availability of data, frequency of collection, the clarity of instructions and recordkeeping,
disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or
reported.
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Consultation with representatives of those from whom information is to be obtained or those
who must compile records should occur at least once every 3 years—even if the collection of
information activity is the same as in prior periods. There may be circumstances that may
preclude consultation in a specific situation. These circumstances should be explained.
A copy of the Federal Register Notices are attached. There were no public comments
received by TVA.
Since its inception, at the request of the Office of Management and Budget, the
questionnaire was reduced from six (6) pages to four (4) pages. In addition, the maximum
possible data elements to be completed from information received from the respondents
was reduced from 373 to 197. The survey was further reduced to its current two (2)
pages. These reductions have reduced the burden on each respondent to approximately
15 minutes.
The respondents are not required to keep any records; and since the information is
collected by personal interview, their prior understanding of the questionnaire is not
necessary. In addition, the majority of the respondents do not change from one survey to
the next. In these cases, the survey only involves updating the information for the
location.
9. Explain any decision to provide any payment or gift to respondents, other than
reenumeration of contractors or grantees.
None.
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
Respondents are assured that the information provided will not be used in making
decisions about them individually. Information that is furnished and which is personally
identifiable will be considered confidential and will not be disclosed, as guaranteed
under the Privacy Act of 1974, unless TVA is required to do so by law.
The information provided is covered by a Privacy Act System of Records Notice. A copy
of the notice is attached to this information request.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private. This justification should include the reasons why the agency considers the questions
necessary, the specific uses to be made of the information, the explanation to be given to
persons from whom the information is requested, and any steps to be taken to obtain their
consent.
Not applicable. Questions of a sensitive nature are not included in this collection of
information.
12. Provide estimates of the hour burden of the collection of information. The statement should:
- Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Unless directed to do so, agencies should not
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conduct special surveys to obtain information on which to base hour burden estimates.
Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour
burden on respondents is expected to vary widely because of differences in activity, size, or
complexity, show the range of estimated hour burden, and explain the reasons for the variance.
Generally, estimates should not include burden hours for customary and usual business
practices.
- If this request for approval covers more than one form, provide separate hour burden
estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
- Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories. The cost of contracting out
or paying outside parties for information collection activities should not be included here. Instead
this cost should be included in Item 14.
Approximately 150 respondents are personally interviewed annually. This number is
obtained by actual count. The annual burden per respondent is approximately 15
minutes. Consequently, the annual burden is estimated to be 38 hours.
The estimated hourly wage (including benefits) for the TVA service area is $19.00;
therefore, the estimated respondent cost is $722 ($19 x 38 hours = $722 total estimated
annualized cost to respondents). The hourly wage information was obtained from the
PEW Center on the States, a research organization administered by the University of
Richmond. A sixty percent load for benefits was added to the $12.00 from the PEW
Center to reach the estimated hourly wage of $19.00.
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers
resulting from the collection of information. (Do not include the cost of any hour burden shown in
Items 12 and 14).
- The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life); and (b) a total operation and maintenance
and purchase of services component. The estimates should take into account costs associated
with generating, maintaining, and disclosing or providing the information. Include descriptions of
methods used to estimate major cost factors including system and technology acquisition,
expected useful life of capital equipment, the discount rate(s), and the time period over which
costs will be incurred. Capital and start-up costs include, among other items, preparations for
collecting information such as purchasing computers and software; monitoring, sampling, drilling
and testing equipment; and record storage facilities.
- If cost estimates are expected to vary widely, agencies should present rates of cost burdens
and explain the reasons for the variance. The cost of purchasing or contracting out information
collection services should be a part of this cost burden estimate. In developing cost burden
estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60day pre-OMB submission public comment process and use existing economic or regulatory
impact analysis associated with the rulemaking containing the information collection, as
appropriate.
- Generally, estimates should not include purchases of equipment or services, or portions
thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with
requirements not associated with the information collection, (3) for reasons other than to provide
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information or keep records for the government, or (4) as part of customary and usual business
or private practices.
Because this data is obtained by personal interview, there is no cost to the respondents
except for their time. As noted in question 12, the estimated hourly wage (including
benefits) for the TVA service area is $19.00; therefore, the estimated respondent cost is
$722 ($19 x 38 hours = $722 total estimated annualized cost to respondents). The hourly
wage information was obtained from the PEW Center on the States, a research
organization administered by the University of Richmond. A sixty percent load for
benefits was added to the $12.00 from the PEW Center to reach the estimated hourly
wage of $19.00.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description
of the method used to estimate cost, which should include quantification of hours, operational
expenses (such as equipment, overhead, printing, and support staff), and any other expense
that would not have been incurred without this collection of information. Agencies also may
aggregate cost estimates from Items 12, 13, and 14 in a single table.
TVA receives no appropriated funds; therefore, the cost of this information collection is
paid from power-generated revenue. TVA estimates that 50 hours is spent annually to
conduct the survey at each of the three nuclear power plants, for a total of 150 annual
hours. Another 150 hours is spent annually by TVA employees to enter information into
GELIC, the dose calculation computer program, and to run the required reports for each
of the three nuclear plants, the estimated cost for gathering this information is:
Salaries (300 hours) $12,000
Overhead
3,000
Travel
2,000
Support Staff
500
Printing and supplies 500
Total
$18,000
The total cost to TVA is estimated to be $18,000.
15. Explain the reasons for any program changes or adjustment reported in Items 13 or 14 of
the OMB Form 83-I.
Not applicable.
16. For collections of information whose results will be published, outline plans for tabulation,
and publication. Address any complex analytical techniques that will be used. Provide the time
schedule for the entire project, including beginning and ending dates of the collection of
information, completion of report, publication dates, and other actions.
This information will not be published for statistical use.
17. If seeking approval to not display the expiration date for OMB approval of the information
collection, explain the reasons that display would be inappropriate.
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Not applicable.
18. Explain each exception to the certification statement identified in Item 19, “Certification for
Paperwork Reduction Act Submissions,” of OMB Form 83-I.
Not applicable.

B. Collections of Information Employing Statistical Methods
Not applicable. This survey does not employ statistical methods.

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