In accordance
with 5 CFR 1320, the information collection is approved for three
years.
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
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