Final Supporting Statement - NRC Form 531

FINAL SUPPORTING STATEMENT
FOR
NRC FORM 531 "REQUEST FOR TAXPAYER IDENTIFICATION NUMBER"
OMB 3150-0188
EXTENSION
Description of Information Collection
The Debt Collection Improvement Act of 1996 (P.L. 104-134) was signed into law on April 26,
1996. Under this law, Federal agencies are required to collect Taxpayer Identification Numbers
(TINs) from all persons who do business with the government. NRC Form 531 is used to collect
TINs and information sufficient to identify the licensee or applicant for licenses, certificates,
approvals and registrations. In 1997, requests for TINs were mailed to licensees in the vendor
database for which there was no TIN on file. Based on experience, 300 requests for TINs will
be mailed to new licensees each year.
A.

JUSTIFICATION
1.

Need for and Practical Utility of the Collection of Information
The Debt Collection Improvement Act of 1996 requires all Federal agencies to
obtain TINs from all persons who do business with the Government including
contractors and recipients of credit, licenses, permits, and benefits.

2.

Agency Use of Information
The TIN will be requested from all licensees and applicants for which we have
not previously collected a TIN. The TIN will be entered into the vendor file of the
Financial Accounting and Integrated Management Information System (FAIMIS),
the NRC accounting system. The TIN will be used on payments (refunds) made
to licensees by electronic funds transfer by the Department of the Treasury. The
Department of the Treasury will use the TIN to determine whether the refund can
be used to administratively offset any delinquent debts reported to the Treasury
by other government agencies. In addition, the TIN will be used to collect and
report to the Department of the Treasury any delinquent indebtedness arising out
of the licensee's or applicant's relationship with 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 new automated
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 CDROM, e-mail, special Web-based interface, or other means. Requests which are
not for personal records that require verification of identity of the requester are
being accepted by electronic mail and facsimile transmission in addition to mail
and in-person written request. It is anticipated that 5 percent of all requests will

be submitted electronically. The NRC Form 531, Request for Taxpayer
Identification Number, is presently on NRC’s Website where it is electronically
accessible to the licensees.
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
The information required by NRC Form 531 is needed for both small and large
businesses in order to issue refunds owed to licensees. Approximately 300
responses are received annually of which 75% are small businesses.

6.

Consequences to Federal Program or Policy Activities if the Collection is not
Conducted or is Conducted Less Frequently
The impact to the NRC of not conducting or conducting the collection of
information less frequently will result in licensees and applicants not receiving
payment due them from the NRC and will result in the Department of the
Treasury being unable to perform administrative offset of delinquent debts. The
frequency cannot be reduced because this is a one-time request for information
from the public.

7.

Circumstances Which Justify Variation from OMB Guidelines
This request does not vary from OMB guidelines.

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 July 22, 2015,
(80 FR 43477). Additionally, we contacted via email six licensees from Florida
Power and Light, Powertech Uranium, Strata Energy, Inc., Ameren Missouri,
Exelon Corp, and DTE Energy.
The following comments were received.
1. Is the proposed collection of information necessary for the NRC to properly
perform its functions? Does the information have practical utility?
Comment: Yes / Yes - the ability to accurately allocate costs/refunds is
necessary.
NRC Response: The NRC agrees with the comment that the proposed
collection of information is necessary for the NRC to properly perform its
function and has practical utility.

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2. Is the burden estimate accurate?
Comment: No - The time estimated to complete the form is shown as 5
minutes. This time is accurate once all information is at hand. However, for
some licensees this information may be readily available. Others may need to
contact internal accounting organizations which may not be immediately
known, requiring research time. Suggest changing the time estimate to 1
hour.
NRC Response: While the NRC does not agree with the comment that the
time estimate should be 1 hour, a revision to account for additional time
needed has been updated to reflect 15 minutes in the final notice.
3. Is there a way to enhance the quality, utility, and clarity of the information to
be collected?
Comment: While the form itself is very simple, it is limited to three license
numbers per form. Those entities with more than three licenses would
apparently be required to submit multiple forms for the same TIN. Suggest
the form be amended to increase the number of licenses that can be listed, or
to indicate that if more room is required that a separate sheet may be
attached listing all licenses that apply to the TIN.
NRC Response: NRC does not agree with the comment that the form should
be revised to increase the number of licenses that can be listed. The form is
used only to request taxpayer identification numbers from only licensees that
currently are not on file with the NRC. The NRC researched and found the
licensees that exceed three licenses already has a tax payer identification
number on file and would not be required to complete this form.
4. How can the burden of the information collection be minimized, including the
use of automated collection techniques or other forms of information
technology?
Comment: Because the TIN is already provided by the Federal Government,
as are the license numbers, it appears that all the information required is
already known by the Federal Government and the NRC should be able to
obtain from existing lists of companies, docket numbers, financial reports,
project managers, etc., without recourse to the licensees. To ensure
accuracy, a confirmatory report could be distributed to each TIN indicating the
current understanding of TIN vs. licenses vs. company and asking for any
corrections, if necessary.
NRC Response: The NRC does not agree with this comment as the NRC
does not have access to a government wide database to obtain tax payer
identification number information.
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
Not applicable

12.

Estimate of Annualized Burden and Burden Hour Cost
The estimated time to complete the form is fifteen minutes. The annual number
of requests for TINs is 300. The estimated annual burden is 75 hours (.25 hr x
300 TINs). The public cost is computed as follows: 75 hours x $268 per hour
equals $20,100.

13.

Estimate of Other Additional Costs
There are no additional costs.

14.

Estimated Annualized Cost to the Federal Government
The estimated annual cost to the Federal Government for data entry is $20,100
(15 minutes per form x 300)/60 x $268 = $20,100.

15.

Reasons for Change in Burden or Cost
The time estimated to complete the NRC Form 531 was shown as 5 minutes.
This time is accurate once all information is at hand. However, for some
licensees this information may be readily available. Others may need to contact
internal accounting organizations which may not be immediately known, requiring
research time. The estimated time was revised from 5 minutes to 15 minutes to
accommodate organizations which may not have the information readily
available. Due to this change, the overall burden increased by 50 hours from 25
hours to 75 hours. The cost has also increased because of the increase in the
hourly rate from $257 to $268.

16.

Publication for Statistical Use
This information will not be published for statistical use.

17.

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

18.

Exceptions to the Certification Statement
There are no exceptions.

B.

COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

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Not applicable.

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