In accordance with 5 CFR 1320, the information collection is approved for three years.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
06/30/2019
36 Months From Approved
06/30/2016
2,945
0
2,598
929
0
780
47,103
0
41,553
Persons in the U.S. who export or import nuclear material or equipment under a general or specific authorization must comply with certain reporting and recordkeeping requirements under 10 CFR Part 110.
The estimated annual public burden increased by 149 hours from 780 hours up to 929 hours, while annual responses increased by 347 responses, from 2,598 responses to 2,945 responses. There have been no changes to the requirements under 10 CFR Part 110 that would affect public burden. Furthermore, no change was made to the estimated hours per response, whether or not an NRC form or a custom form was used for submitting notices. NRC increased the estimated number of annual responses in the table to reflect an increase in annual activity subject to the notification requirement. The table of data was also expanded to identify the burden associated with the use of custom reporting forms for notices, the typical practice used by most Ir-192 licensees. These respondents account for the greatest number of annual responses, and essentially expend the same per-response public burden as the respondents who submit notices on the NRC forms. Notices on non-standard forms are typically submitted by licensees with fewer transactions. These notices are not custom-designed, and usually contain other unrelated data. Most respondents use non-standard forms, but they report much less frequently than those that use either custom forms or NRC forms. The number of individual respondents increased from 108 to 136 from the last clearance cycle.
The primary reason for the increase in responses is due to an adjustment in the number of export and import transactions subject to the notification requirement. Use of the NRC notification forms is also increasing. As a result, the number of respondents using neither the NRC form nor a custom form is decreasing. Most of these respondents export and import radioisotopes with longer half-lives such as Am-241 (432.7 years) and Cs-137 (30 years) and therefore, require fewer notifications. As a result, there is less incentive for these respondents to develop a custom form for their notification requirements. On the other hand, respondents that export and import radioisotopes with shorter half-lives such as Ir-192 (74 days) and Se-75 (120 days) make many more shipments and benefit from development of custom forms and automated notification capabilities. The NRC notification forms only became available years after the notification requirement was implemented. As a result, respondents are reluctant to adopt use of the form as it would be of no benefit. However, new respondents prefer to use NRC forms, as they serve as a template for the required data elements and therefore, reduce errors.
Lastly, the NRC has increased the follow-up time from 15 minutes to 5 hours for each of 20 annual responses to account for time spent resolving or clarifying omitted information submitted on the advanced notification of shipments. The NRC may require licensees to obtain additional or corrected information and re-submit the corrected information to the Headquarters Operations Office or the Office of International Programs. The corrections might require licensees to search for or request documentation from foreign regulators to prove authorization to export radioactive materials. In some cases, NRC takes enforcement action with a licensee, requiring the licensee to respond to a Notice of violation. This may require the licensee to develop and document corrective actions taken or to be taken to prevent recurrence in the future, re-train personnel, or submit a written response to the Office of Enforcement. In some cases, licensees may hire consultants and attorneys to assist them in properly addressing our concerns.
The cost increase also reflects an increase in the annual labor cost for reactor and materials licensees from $274.00 to $279.00 per hour.
There has been no regulatory changes made that would result in a change in the information being collected. Furthermore, there are no plans to make any changes to the NRC forms used to obtain the information.
$28,319
No
No
No
No
No
Uncollected
Stephen Baker 3014153329
Reginfo record details
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form NRC Form 830 10 CFR 110 Part 110, Export and Import of Nuclear Equipment and Material
Final SS 10 CFR Part 110.docx
10 CFR 110 Part 110, Export and Import of Nuclear Equipment and Material