NRO RIS FINAL Supporting Statement 15DEC

FINAL SUPPORTING STATEMENT

FOR

VOLUNTARY REPORTING OF PLANNED

NEW REACTOR APPLICATIONS

(3150-XXXX)

NEW

Description of the Information Collection

This voluntary information collection assists the NRC in determining resource and budget needs as well as aligning the proper allocation and utilization of resources to support applicant submittals, future construction-related activities, and other anticipated 10 CFR Part 50 and/or Part 52 licensing and design certification rulemaking actions. In addition, information provided to NRC staff is intended to promote early communications between the NRC and the respective addressees about potential 10 CFR Part 50 and/or Part 52 licensing actions and related activities, submission dates, and plans for construction and inspection activities. This information collection is an attempt to facilitate the opportunity for more effective and efficient planning, scheduling, and allocation of NRC resources so that activities and reviews for both applicants and licensees are implemented and conducted in a manner that is altogether timely, consistent, and respective of scope, schedule, and budget constraints.

1. JUSTIFICATION

1. Need For and Practical Utility of the Collection of Information¹

The NRC is developing pre-application, licensing, and project plans for all new reactor licensing and design certification applications, to include those applications and activities relating to the advanced reactor program. The status of a variety of design-related activities for both large light water reactors and small modular reactors are factored into this justification. To support this resource and budget planning effort, the NRC is seeking voluntary responses from all holders of, and applicants for, an early site permit (ESP), limited work authorization (LWA), standard design certification (DC), or combined license (COL) for construction and operation of a nuclear power plant requests (under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants),” as well as all holders of, and applicants for, a power reactor construction permit (CP) referencing an SMR² design under 10 CFR Part 50, “Domestic Licensing of Production and Utilization Facilities.”

This voluntary collection applies to new or updated information on schedules for submitting a CP, ESP, an amendment to, or transfer of, an ESP, a COL, a DC, amendments to a DC, a DC renewal, LWA, standard design approval (DA), and manufacturing license (ML) applications. In addition, NRC staff is seeking notification on the number and the degree of complexity of ESP, LWA, DC, and COL applications, and any other licensing requests that applicants expect to submit in fiscal years (FYs) 2015 through 2017. The information collected helps facilitate more effective and efficient planning, scheduling, and allocation of NRC resources so that activities and reviews for both applicants and licensees are implemented and conducted in a manner that is altogether timely, consistent, and respective of scope, schedule, and budget constraints.

2. Agency Use of Information

This information assists the NRC in determining resource requirements, aids in optimizing resource allocations, as well as informing future budget needs with respect to the aforementioned submittals, future construction-related activities, and other anticipated 10 CFR Part 50 and/or Part 52 licensing and design certification rulemaking actions. As well, this information is intended to promote early communications between the NRC and addressees about potential 10 CFR Part 50 and/or Part 52 licensing actions and related activities, submission dates, and plans for construction and inspection activities. It is also the intended goal of these communications to assist NRC staff more effectively and efficiently plan, schedule, coordinate, and implement, activities and reviews in a timely manner.

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 0% of the potential responses are filed electronically.

4. Effort to Identify Duplication and Use Similar Information

The NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections. This supporting statement is in keeping with this goal as it combines similar information requests from both RIS 2013-08 “Process for scheduling acceptance reviews of new reactor licensing and design certification applications and process for determining budget needs for fiscal year 2016,” and RIS 2013-18 “Licensing submittal information and design development activities for small modular reactors.” By targeting communications to much of the same audiences and stakeholders, this statement seeking OMB clearance for a new combined RIS consolidates information requests in one voluntary information collection request versus two. In addition, a single and more encompassing stakeholder-centric RIS, as proposed in this supporting statement, would be useful in reducing duplication of efforts while collecting the same pertinent data that is highly advantageous to NRC staff and staff planning and budgeting efforts.

5. Effort to Reduce Small Business Burden

Not Applicable.

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

Applicants, licensees, and potential applicants report this information on a strictly voluntary basis. This information, in turn, aids NRC staff in determining resource and budget needs to support various activities and reviews so that NRC staff is able to maximize and best utilize existing budget and staff resources as well as plan effectively for future resource and budget needs, coordinate activities, and facilitate more efficient reviews.

If such information is not collected, the potential to assess the need for various resources and support capabilities, as well as enable NRC staff to efficiently and effectively plan and prepare budgets, align resources, remedy potential skill gaps, and prepare for incoming review and inspection activities, can be significantly impeded. This has the potential to result in significant program and project scope creep, schedule slip, and budget overruns that adversely affect the mission readiness of NRC staff as well as the objectives of potential new applicants, current applicants, and current licensees.

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 September 17, 2014 (79 FR 55832).  No comments were received.  

So in addition to the FRN comments (none received), the NRC solicited three potential licensees, and received one response from NuScale Power.

1.  Is the proposed collection of information necessary for the NRC to properly perform its functions?  Does the information have practical utility?

Some of the proposed collection of information is necessary for the NRC to properly perform its function and has practical utility.  However, there are questions in this RIS that require excessive burden on the responders and do not meet the definition of the purpose of the RIS.  Examples include the third and last questions under Design and Licensing, and the entire set of questions under Design, Testing, and Application Preparation.

               

2.  Is the burden estimate accurate?

No, the burden estimate is not accurate.  Response to the RIS has required an expenditure of 80 hours because of some of the details requested that do not appear to be necessary for the purpose of the RIS and for management review prior to formal submittal to the NRC.

3.  Is there a way to enhance the quality, utility, and clarity of the information to be collected?

Yes, as suggested above, some of the questions  do not appear necessary for the NRC to better plan and budget for new reactor licensing should be deleted.  For example, the questions under Design, Testing, and Application Preparation require substantial inter-departmental development, review and approval.  Other questions would benefit from re-phrasing as well.  If this is done, the burden to the respondee could be 16 hours.

4.  How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms of information technology?

Automated collection techniques or other forms of information technology can improve the venue for response, but will not significantly reduce the burden of the information collection as this is primarily driven by the nature of the questions that have been in the RIS.

9. Payment or Gift to Respondents

Not Applicable.

10. Confidentiality of 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

No sensitive information is requested.

12. Estimated Burden and Burden Hour Cost

The NRC staff estimates that both applicants and licensees will submit approximately 5 responses to this annual voluntary RIS, and that each submittal will require approximately 60 hours on average to prepare and submit. The total licensee and applicant burden for this voluntary information collection is 300 hours at a cost of $82,200 (60 hours x 5 responses = 300 hours; 300 hours x $274/hr.).

13. Estimate of Other Additional Costs

There are no additional costs.

14. Estimated Annualized Cost to the Federal Government

The annual cost to the NRC including staff hours and contractual support:

Staff hours = 60 hours per year @ $274/hr. = $16,440

Contractual Support = $0 per year

TOTAL COST = $16,440

15. Reasons for Change in Burden or Cost

This Regulatory Information Summary is a new collection. This voluntary information collection assists the NRC in determining resource and budget needs as well as aligning the proper allocation and utilization of resources to support applicant submittals, future construction-related activities, and other anticipated 10 CFR Part 50 and/or Part 52 licensing and design certification rulemaking actions. In addition, information provided to NRC staff is intended to promote early communications between the NRC and the respective addressees about potential 10 CFR Part 50 and/or Part 52 licensing actions and related activities, submission dates, and plans for construction and inspection activities. The current burden rate is $274/hr.

16. Publication for Statistical Use

Not Applicable.

17. Reason for Not Displaying the Expiration Date

18. Exceptions to the Certification Statement

None.

2. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Not Applicable.

TABLE 1

ANNUALIZED REPORTING BURDEN (Voluntary)

Section	No. Of Respondents	Responses per Respondent	Total No. of Responses	Burden Hours per Response	Total Annual Reporting Burden (Hrs)
Voluntary Response to: NRC REGULATORY ISSUE SUMMARY 2014-xx “SCHEDULING AND ALLOCATING RESOURCES IN FY 2017 FOR THE REVIEW OF NEW LICENSING APPLICATIONS FOR LARGE LIGHT-WATER REACTORS AND SMALL MODULAR REACTORS”	5	1	5	60	300
	5		5		300

TOTAL BURDEN HOURS: 300 hours (300 hours reporting + 0 hours third party notification + 0 hours recordkeeping)

TOTAL BURDEN HOUR COST: $82,200 (300 hrs x $274/hr)

ANNUAL RESPONDENTS: 5 respondents (none required)

RESPONSES: 5 responses (5 RIS responses + 0 third party responses + 0 recordkeepers)

1 AEA sec. 161c., which authorizes the Commission to “make such studies and investigations, obtain such information, and hold such meetings or hearings as the Commission may deem necessary or proper to assist it in exercising any authority provided in this Act, or in the administration or enforcement of this Act, or any regulations or orders issued thereunder.”

2 SMRs are defined using the International Atomic Energy Agency definition of small- and medium-sized reactors with an electrical output of less than 700 megawatts.

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