Supporting_Statement_for_Final_NRC_Form_629_Fed_Reg_Notice_20141

FINAL OMB SUPPORTING STATEMENT

FOR

NUREG/BR-0254, PAYMENT METHODS;

NRC FORM 628, “FINANCIAL EDI AUTHORIZATION” AND NRC FORM 629, “AUTHORIZATION FOR PAYMENT BY CREDIT CARD”

(OMB Clearance No. 3150-0190)

EXTENSION

Description of the Information Collection

The Office of the Chief Financial Officer is responsible for billing licensees, applicants, and individuals for payment of civil penalties, full cost licensing fees, and inspection fees. The four methods used to pay bills owed the Nuclear Regulatory Commission (NRC) are: (1) Payment by Automated Clearinghouse Network (ACH); (2) Payment by Credit Card; (3) Payment by Electronic Funds Transfer; and (4) Payment by Check. NUREG/BR-0254, “Payment Methods” is used in the billing cycle to instruct licensees how to transfer monies owed the NRC. Payment Methods (NUREG/BR-0254) which has an accompanying NRC Form 629, “Authorization for Payment by Credit Card,” is the payment method that impose information collection burdens on licensees and is described in this Supporting Statement.

A. JUSTIFICATION

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

NRC Form 629, “Authorization for Payment by Credit Card,” is another option used to authorize payment. The credit card authorization form is used by licensees to authorize payment by credit card for license fees and for payment of fees for fingerprint cards. The form solicits information that identifies the cardholder’s name, address, account number, card expiration date, cards accepted, cardholder’s signature, invoice number or license number.

NRC Form 628, “Financial EDI Authorization,” provides necessary information that will allow respondents to transfer fund electronically.  The Financial EDI authorization form is used by licensees to authorize payment by electronic funds transfer through the ACH Network for license fees and payment of fees for fingerprint cards.  The form solicits information that identifies the company name, company EFT contact, and telephone number(s).

There are no recordkeeping requirements associated with this collection.

2. Agency Use of Information.

The agency properly credits monies received through the ACH and credit card companies when these two methods are utilized by the licensees to pay their indebtedness to the NRC.

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 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. It is estimated that approximately 90 percent of the potential responses are filed electronically for NRC Form 629.

4. Effort to Identify Duplication and Use Similar Information.

No sources of similar information are available. There is no duplication of requirements. NRC has in place an ongoing 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

Approximately 28 percent of the invoices issued in FY2013 were issued to small businesses. Efforts have been made to keep the method of collecting fees as simple as possible and requirements for information have been kept to a minimum.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently.

The impact to the NRC fee program if the collection is not conducted or is conducted less frequently will be minimal. Licensees, applicants and individuals will continue to have two options open to them to pay future bills and invoices mailed to them. They may send a check or use an electronic funds transfer through FedWire. However, NRC Form 629 benefits respondents by providing the additional option for paying invoices by Credit Card.

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 was published in the Federal Register on February 19, 2014 (79 FR 9488).  No comments were received.

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.

Not applicable.

12. Estimate of Annualized Burden and Burden Hour Cost.

For NRC Form 629, “Authorization for Payment by Credit Card,” and NUREG/BR-0254, it is estimated that it takes approximately 5 minutes to read the instructions and complete the form. It is estimated that approximately 545 forms will be completed annually with an estimated burden of 45.4 hours (545 forms x 0.083 = 45.4 hours). The estimated annual cost is $12,348.80 (45.4 hours x $272). The current estimate includes burden for the NRC Form 628 and the NRC Form 629 forms.

13. Estimate of Other Additional Costs.

There are no additional costs.

14. Estimated Annualized Cost to the Federal Government.

Credit Card Forms (NRC Form 629) are processed by third party entities for the NRC annually. There is no cost to the NRC because the cost for this service, by the third party, is assumed by the Department of the Treasury.

15. Reasons for Changes in Burden or Cost.

The overall burden estimate for NRC Form 629, authorization for Payment by Credit Card and NUREG/BR-0254 has decreased by 1.6 hours from 47 to 45.4 hours and the estimated number of responses decreased by 38 from 583 to 545 responses. The estimated number of forms submitted is based on the actual number of forms received by the NRC in FY2013. NRC has seen a decrease in the number of payments by credit card since the last renewal due to a decreased in the number of respondents who want to pay their invoices by credit card. The current estimate includes burden for the NRC Form 628 and the NRC Form 629 forms.

In addition, the fee rate has increased from $259/hr to $272/hr.

16. Publication for Statistical Use

None.

17. Reason for Not Displaying the Expiration Date.

Not applicable.

18. Exceptions to the Certification Statement.

Not applicable.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

Statistical methods are not used in this information collection.