Ml15153a004

FINAL SUPPORTING STATEMENT
FOR
NRC FORM 7, “APPLICATION FOR NRC EXPORT/IMPORT LICENSE,
AMENDMENT, RENEWAL OR CONSENT REQUEST(S)”
(3150-0027)
--EXTENSION
Description of the Information Collection
The United States (U.S.) Nuclear Regulatory Commission (NRC), under the Atomic Energy Act
of 1954, as amended, (AEA) and Title II of the Energy Reorganization Act of 1974, as amended,
has authority for exercising export and import controls over nuclear equipment and material. All
persons who wish to export or import nuclear equipment and material as specified in 10 CFR
Part 110, Sections 110.8, 110.9, and 110.9a must provide certain information to enable the
NRC and the Executive Branch to make required export and import licensing determinations to
ensure compliance with NRC regulations and to satisfy statutory requirements of the AEA.
The public has submitted the required information on NRC Form 7 (OMB Clearance Number
3150-0027) for all licensing requests, (i.e., applications for export, import, amendments,
renewals and consent requests). Final rule under 10 CFR Part 110, Export and Import of
Nuclear Equipment and Material; Updates and Clarifications (RIN 3150-Al16), became effective
August 27, 2010. Part 110, Section 110.27 was amended to authorize imports of Category 1
and Category 2 quantities of byproduct material listed in Appendix P to Part 110. Therefore,
references to combined export/import licenses, unique only to Appendix P byproduct materials,
were removed from the regulation and the NRC Form 7. Also effective August 27, 2010, NRC
removed the reporting requirement for exports of radioactive waste on NRC Form 7. Consistent
with these regulatory revisions, on August 27, 2010, the NRC Form 7 was revised by removing
references to combined export/import and the reporting requirement for exports of radioactive
waste. The changes made to NRC Form 7 do not impact the burden calculation.
A summary of the NRC Form 7 for providing the information required in 10 CFR §110.32
follows.
Part A is for the NRC internal use. Parts B and E are completed by all applicants. Part C is
completed by applicants for export licenses, amendments, renewals and consent requests.
Part D is completed by applicants for import licenses, amendments and renewals.
In Part B, to be completed by all applicants, Block 1 requires the name and complete physical
address of the corporation or other entity with direct control over distribution of proposed
exports(s) or imports(s), and where required records will be maintained and can be inspected.
Blocks 1a through 1e require name and contact information identifying the best party to answer
questions about an application, and applicants can use it to assign their own reference number
to identify application documents. Block 2 requires the applicant to indicate the type of NRC
licensing action requested by checking export, import, amendment, renewal or consent request.

Block 3 requires the applicant to provide contract number(s), if known, which may be useful
references for reviewers. Blocks 4 and 5 require the anticipated date of the first and last
shipments. Block 6 requires the applicant’s proposed license expiration date.
In Part C, to be completed by applicants for export licenses, amendments, renewals or consent
requests, Block 7 requires the names of the supplier(s) and other parties to the export not listed
in Blocks 1, 8 or 9, including the complete physical address(es) where correspondence should
be sent and where export(s) could be inspected. In Block 7a, the applicant must describe the
functions to be performed and/or services to be provided by any of the parties listed in Block 7.
Blocks 8 and 9 require the names and physical address(es) for each intermediate and ultimate
foreign location. Blocks 8a and 9a require the applicant to describe how each consignee will
use the export(s), including functions to be performed and/or services to be provided. Block 10
requires a description of key characteristics, including physical and chemical forms of
radioactive materials (i.e., source, special nuclear or byproduct materials including sealed
sources or devices and radioactive waste) nuclear facilities and equipment. For source and/or
special nuclear material including as radioactive waste, in Block 10a, the maximum total
volume/element weight over license life in kilograms is required. For Appendix L byproduct
material, including radioactive waste, the maximum total activity over license life in TBq is
required. For Appendix P radioactive materials, maximum total activity per shipment in TBq for
each material, whether in bulk or sealed source or device is required. In Blocks 11b-c,
maximum enrichment/weight percentage and maximum total isotope weight over the license life
must be provided in kilograms. Block 11 requires the identification of foreign country obligations
and the percentage of the total volume that is obligated to them.
In Part D, to be completed by applicants for import licenses, amendments or renewals, Block 12
requires the name(s) and the address(es) of the foreign supplier(s) or exporters. In Block 12a,
the license number for import(s) originally exported under a specific NRC license must be
entered. Blocks 13 and 14 are to be completed if the applicant in Block 1 is not the sole
intermediate or ultimate recipient. Blocks 13a and 14a require the entry of NRC or Agreement
State Materials License number(s) including the expiration date(s) for each U.S. consignee.
Blocks 13b and 14b require a description of the use of each consignee, the functions to be
performed and the services to be provided are required. Block 15 requires a description of key
characteristics, including physical and chemical forms, of radioactive materials and nuclear
facilities. For source and/or special nuclear material including as radioactive waste, in Block
15a, the maximum total volume/element weight over license life in kilograms is required. For
Appendix L byproduct material, including radioactive waste, the maximum total activity over
license life in TBq is required. For Appendix P radioactive materials, maximum total activity per
shipment in TBq for each material, whether in bulk or sealed source or device is required. In
Blocks 15b-c, maximum enrichment/ weight percentage and maximum total isotope weight over
the license life must be provided in kilograms. Block 16 requires the identification of foreign
countries and the percentage of maximum total volume that may be obligated to them.
Part E is to be completed by all applicants. In Block 17, the applicant must indicate whether
additional information is being provided. The attached, blank continuation page can be used to
provide this information, and it can be copied for use as additional attachment sheets. In Block
17a, the applicant must check “yes” or “no” to verify whether importing recipients’ authorizations

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required for Appendix P materials are included with the application. Blocks 18a through
18c require signature certification, title of the authorized official of the legal entity applying for
the license, amendment or renewal, and date.
A.

JUSTIFICATION

1.

Need for and Practical Utility of the Collection of Information
The NRC Form 7 is a multipurpose license application designed to allow persons to
provide the minimum amount of information necessary for NRC to fulfill the statutory and
regulatory requirements governing exports and imports of nuclear material and
equipment under the NRC's authority. The form is clear, concise, easy to understand,
and simple to prepare.
Completion of the NRC Form 7 is required to obtain an authorization to import or export
nuclear equipment and material under NRC jurisdiction. The form supports an agency
reporting requirement from the public to provide information to the NRC for its review
and consideration in granting authorization to import or export nuclear equipment and
material.
Section 110.19, Types of licenses, states that licenses for the export and import of
nuclear equipment and material in this part consist of general licenses and specific
licenses. A specific license is issued to a named person and is effective upon approval
by the Commission of an application filed pursuant to the regulations in this part and
issuance of licensing documents to the applicant.
Section 110.20 states that if an export or import is not covered by the NRC general
licenses described in §§ 110.21 through 110.27, a person must file an application with
the Commission for a specific license using NRC Form 7 in accordance with §§ 110.31
through 110.32.
Section 110.21 states that in paragraph (d) of this section, a general license is not
applicable to export to any country listed in § 110.28, and does not authorize the export
of special nuclear material in radioactive waste. These types of exports require
licensees to file an application for a specific license using NRC Form 7.
Section 110.22 states that in paragraph (e) of this section, a general license is not
applicable to export source material to any country listed in § 110.28, and does not
authorize the export of source material in radioactive waste. These types of exports
require licensees to file an application for a specific license using NRC Form 7.
Section 110.23 states that a general license is not applicable to export byproduct
material (see Appendix L to this part) to any country listed in § 110.28 and that use of
the general license is subject to certain limitations. If a limitation applies, the export
requires licensees to file an application for a specific license using NRC Form 7.

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Section 110.31, states that a person shall file an application for a specific license to
export or import with the Deputy Director of the NRC’s Office of International Programs,
using an appropriate method listed in § 110.4. Applications for an export, import,
amendment, renewal license, consent request, or a request for an exemption from a
licensing requirement under this part shall be filed on NRC Form 7. The application
must be accompanied by the appropriate fee in accordance with the fee schedules in
§§ 170.21 and §§ 170.31 of this chapter. A license application will not be processed
unless the specified fee is received. Each application on NRC Form 7 shall be signed by
the applicant or licensee or a person duly authorized to act for and on behalf of the
applicant or licensee. Each person shall provide in the license application, as
appropriate, the information specified in § 110.32. The Commission also may require the
submission of additional information if necessary to complete its review. An application
may cover multiple shipments and destinations. The applicant shall withdraw an
application when it is no longer needed. The Commission’s official files retain all
documents related to a withdrawn application.
Section 110.32, states that the following information is required on an application: name
and address of applicant, supplier, intermediate and ultimate consignees; foreign
obligations by country and percentage; shipment dates; and description of export and
end use. Applications for import and export of radioactive waste require the volume,
classification, physical and chemical characteristics, route of transit, and ultimate
disposition. Applications for renewal of a specific license shall be filed on NRC Form 7
in accordance with §§ 110.31 and §§ 110.32.
2.

Agency Use of Information
The Commission and the Executive Branch review the license applications submitted on
NRC Form 7 to make required licensing determinations and ensure compliance with
regulations. If applicable statutory, regulatory, and policy considerations are satisfied,
the NRC will issue a license.

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
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. However, currently no responses are submitted electronically because the
non-recurrence of each individual collection makes it difficult to reduce the burden
through the use of technology. Each submittal is unique and is unlikely to be developed
from other compiled information sources.

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.

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5.

Effort to Reduce Small Business Burden
The requirements specified in 10 CFR §§ 110.20, 110.31, and 110.32 are the same for
large and small businesses, because the nuclear proliferation, security and policy
concerns are the same; therefore, all businesses must provide the same data. To
reduce the burden to small businesses, the NRC has established general licenses which
exempt from new controls many of the shipments that were of particular concern to small
businesses. Further, the NRC allows small businesses to apply for broad, long-term
licenses to export materials to reduce burdens associated with paperwork expenses,
license application fees, and uncertainties in delivery.

6.

Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted
or Is Conducted Less Frequently
The information requested in 10 CFR §§ 110.20-110.23 cannot be collected on a less
frequent basis because it reflects the International Atomic Energy Agency Code of
Practice on the International Transboundary Movement of Radioactive Waste to help
ensure that radioactive waste coming into or leaving the U.S. is subject to U.S.
Government approval and consent of other involved parties.
The information requested in 10 CFR §§ 110.31-32 is submitted only when deemed
necessary by respondents and is keyed to the decision criteria that guides the NRC in
approving or denying applications. It specifically incorporates the requirements of the
Atomic Energy Act of 1954, as amended. Therefore, if the collection is not conducted or
is conducted on a less frequent basis, a person who wishes to export under NRC's
export authority would be unable to do so because the NRC could not make the
necessary determination on whether a license should be issued.

7.

Circumstances which Justify Variation from OMB Guidelines
None.

8.

Consultations Outside the Nuclear Regulatory Commission
Opportunity for public comment on the information collection requirements for this
clearance package was published in the Federal Register on March 17, 2015 (80 FR
13901). No comments were received.
As part of the Public Consultation process, nine potential respondents who are current
NRC licensees also received a written request for comments. Surveys were sent to
EnergySolutions, International Isotopes, Inc., QSA Global, Inc., RGB Logistics, SigmaAldrich Corporation, Specialty Alloys, Transport Logistics Int'l Inc., Weatherford
International, and Westinghouse Electric Co LLC. No comments were received.

9.

Payment or Gift to Respondents
Not applicable.

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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
There are no sensitive questions.

12.

Estimated Burden and Burden Hour Cost
All licensees comply equally with the requirements of 10 CFR §§ 110.19, 110.20,
110.21, 110.22, 110.23, 110.31, 110.32, and 110.51. Based upon our experience, for
the collection in 10 CFR § 110.31, we estimate 105 applications will be filed annually on
NRC Form 7(in the previous renewal cycle we estimated 120 applications were filed
annually). Using an average cost of $279 per hour for reactor licenses and material
licensees, the annual cost required to prepare the NRC Form 7 is estimated as follows:
Annual Reporting or Disclosure Burden for NRC Form 7:
Annual Number
of Respondents

Annual Number
of Responses
per Respondent

Hours
per
Response

1

2.4

105

Total
Hours

Cost

252

$70,308

The total annual burden is estimated at hours at a cost of $70,308 (252 x $279).
13.

Estimate of Other Additional Costs
There are no additional cost.

14.

Estimated Annualized Cost to the Federal Government
The collection of information under the NRC Form 7 is estimated to require a total of
4,800 hours annually. Approximately 3,000 professional staff hours per year are
required to investigate, review and take action on the reported information referred to
above in 10 CFR §§ 110.19-110.23, and 10 CFR §§ 110.31-110.32 as well as respond
to public inquiries and to maintain and store the files. An additional 1,575 professional
staff hours annually are required for NRC Form 7 to process 105 export, import, and
consent requests. This is based on an average of 15 hours to process each of the
estimated 105 annual responses processed annually (15 x 105 = 1,575). Therefore, the
revised total annual cost to the Federal Government, at $279 per hour for licenses, is
$1,276,425 (4,575 professional staff hours x $279). The previous total annual cost to
the Federal Government, at $273 per hour for licenses was $1,310,400 (4,800
professional staff hours x $273). The cost of NRC Form 7 and Part 110 is recovered

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through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and 171.
15.

Reasons for Changes in Burden or Cost
The overall burden decreased by 36 hours, from 288 to 252, with a corresponding
reduction in the number of respondents from 120 to 105 because of a reduction in the
number of forms received, which resulted in a reduction of 15 responses and 36 burden
hours.
There was a change in the overall cost because the hourly rate increased from $273 to
$279.

16.

Publication for Statistical Use
Not applicable.

17.

Reason for Not Displaying the Expiration Date
The expiration date is displayed.

18.

Exceptions to the Certification Statement
Not applicable.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not used in the collection of information.

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