NRC FORM 741 REVISION doc (2) -SS

FINAL OMB SUPPORTING STATEMENT
FOR
DOE/NRC FORM 741, NUCLEAR MATERIAL TRANSACTION REPORT
AND
NUREG/BR-0006, REVISION 9
“INSTRUCTIONS FOR COMPLETING NUCLEAR MATERIAL TRANSACTION REPORTS
(DOE/NRC FORMS 741)”
(3150-0003)
--EXTENSION
Description of the Information Collection
U.S. Nuclear Regulatory Commission (NRC) regulations require licensees who ship, receive, or
adjust their physical inventory of source or special nuclear material (SNM) to document and
report such activities. The reports are submitted by using U.S. Department of Energy
(DOE)/NRC Form 741, "Nuclear Material Transaction Report." Licensees may need to provide
additional information on some imports or exports of source or SNM. The additional
information is reported using DOE/NRC Form 740M, "Concise Note." In addition to collecting
nuclear material transaction information for domestic safeguards use, the NRC is required to
make the information available to the International Atomic Energy Agency (IAEA).
DOE/NRC Form 741 is used to document inventory changes for special nuclear material and
source material in the Nuclear Materials Management and Safeguards System (NMMSS). The
licensees who are primarily affected are any facilities that possess or are licensed to possess
source and special nuclear materials within the United States (US). The NRC provides the form
and instructions to all affected licensees, who must submit reports in computer readable format.
Licensees submit reports on a continuing basis when specified events occur, such as the
receipt, transfer, or inventory adjustment of licensed material. The instructions for completing
DOE/NRC Form 741 are in NUREG/BR-0006, “Instructions for Completing Nuclear Material
Transaction Reports (DOE/NRC Form 741), Revision 9.”
Collection of the subject information corresponds to the physical movement or transmutation
of special nuclear material or source material covered by the regulation. The information is
required by regulations in Title 10 of the Code of Federal Regulations (10 CFR) Parts 74
(Section 74.15) and 75 (Sections 75.12, 75.33 and 75.34) to be collected from the shipper
immediately following dispatch and from the receiver within 10 days of receipt.
A.

JUSTIFICATION
1.

Need for and Practical Utility of the Information Collection
For the United States to fulfill its responsibilities as a participant in the US/IAEA
Safeguards Agreements and satisfy its domestic safeguards responsibilities, it is
necessary for licensees to submit DOE/NRC Form 741, "Nuclear Material
Transaction Report," whenever an inventory change occurs involving source or
special nuclear material. This submittal informs NMMSS of the inventory
change, so that the facility’s inventory will be maintained as up-to-date, within
NMMSS.

2.

Agency Use of Information
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The NRC is required to collect nuclear material transaction information for
domestic safeguards use and to make it available to the IAEA. NRC uses
DOE/NRC Form 741, together with NUREG/BR-0006, Revision 8 (the instructions
for completing the forms), to collect, retrieve, analyze, and maintain relevant
inventory data. Without the report form, NRC's ability to collect and maintain
these data would be severely limited.
3.

Reduction of Burden through Information Technology
The NRC has issued Guidance for Electronic Submissions to the NRC , which
provides direction for the electronic transmission and submittal of documents to
the NRC. Electronic transmission and submittal of documents can be
accomplished via the following avenues: the Electronic Submittals application,
which is available from the NRC's “Electronic Submittals” Web page, by Optical
Storage Media (OSM) (e.g. CD-ROM, DVD), by facsimile or by e-mail. The
Electronic Submittals application allows electronic transmission of information to
the NRC pertaining to licensing actions, associated hearings, and other regulatory
matters. The application ensures that information sent to the NRC via the Internet
is secure and unaltered during transmission. It operates 24 hours a day, except
when it is taken down for scheduled maintenance. The application serves as a
secure portal that respondents may use to transmit documents to the NRC.
It is estimated that approximately 95% of the responses are filed electronically.
Form 741 is a common form hosted by the NRC that is also used by the DOE.
The NRC provides the form and instructions to all affected NRC licensees who
must submit reports in a computer readable format. Once submitted by licensees,
information from these forms is saved in a Nuclear Materials Management and
Safeguards System (NMMSS). The use of common reporting forms minimizes
the reporting burden on industry members required to provide regulations or
contractual obligations. The licensee is thus able to file one report to meet the
requirements of both agencies. Compliance with specific reporting requirements is
monitored by the agency for which the specific data are required. Currently DOE
has no burden hours associated with the use of this form.

4.

Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no duplication of
requirements. In addition, the use of common reporting forms by DOE and NRC
minimizes the reporting burden on industry members required to provide nuclear
material data to one or both agencies.

5.

Effort to Reduce Small Business Burden
The burden on licensees will vary with the size and type of licensed operation.
Further burden reductions for small businesses would prevent the NRC from
fulfilling its international or domestic responsibilities.

6.

Consequences to Federal Program or Policy Activities if the Collection is not
Conducted or is Conducted Less Frequently
Collection of the subject information corresponds to the physical movement or
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transmutation of special nuclear material or source material covered by the
regulation. The information is required by regulations in Title 10 of the Code of
Federal Regulations (10 CFR) Parts 74 (Section 74.15) and 75 (Sections 75.12,
75.33 and 75.34) to be collected from the shipper immediately following dispatch
and from the receiver within 10 days of receipt. This is the minimum frequency of
collection required to satisfy reporting regulations and as required by the facility’s
license to possess material.
7.

Circumstances which Justify Variation from the Office of Management and Budget
(OMB) Guidelines
There is no variation 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 April 29, 2020 (85 FR
23870). As part of the consultation process, the NRC staff directly contacted, via
email, four fuel cycle licensees. No responses or comments were received as a
result of the FRN or the NRC staff’s direct solicitation of comment.

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). However, no information
normally considered confidential or proprietary is requested.

11.

Justification for Sensitive Questions
None.

12.

Estimated of Annualized Burden and Burden Hour Cost
Licensees submit reports on a continuing basis when specified events occur, such
as the receipt, transfer, or inventory adjustment of licensed material. They must
submit the reports in computer readable format. The data are then entered into
the NMMSS, maintained by a NRC contractor, and the information is not compiled
or published.
The NRC expects approximately 344 licensees to submit an estimated annual
average of 11,143 DOE/NRC 741 forms each year. This estimate is based on
recent historical data and the NRC anticipates that the number of annual
submissions will remain stable during the next 3 years. The burden of preparation
and submission of each report is estimated to be 1.25 hours. The total resulting
burden for required submissions of the form by all licensees will be 13,928 hours
(11,143 reports x 1.25 hours/report).
The total annual cost to all respondents to comply with this requirement is
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estimated to be $3,871,984 (13,928 hours x $278/hour). Cost estimates are
calculated at a rate of $278 per hour, which is based on NRC's fee recovery rate.
The $278 hourly rate used in the burden estimates is based on the Nuclear
Regulatory Commission’s fee for hourly rates as noted in 10 CFR 170.20
“Average cost per professional staff-hour.” For more information on the basis of
this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2019
(84 FR 22331, May 17, 2019).
13.

Estimate of Other Additional Costs
There are no additional costs.

14.

Estimated Annualized Cost to Federal Government
The collected information is not submitted to the NRC. Licensees report directly
to the DOE NMMSS contractor. The data contained in the NMMSS is available t
o various NRC staff that uses it to perform their assigned job functions; however,
the individual submissions are not reviewed by NRC staff. The NRC costs for
NMMSS operations are approximately $1,900,000 per fiscal year This is the
NRC’s contribution for the operations of the NMMSS to support the collection of
Forms 740M, 741, 742, and 742C data, in addition to other data collections and
operations.
The staff has developed estimates of annualized costs to the Federal
Government related to the conduct of this collection of information. These
estimates are based on staff experience and subject matter expertise and include
the burden needed to review, analyze, and process the collected information and
any relevant operational expenses

15.

Reason for Change in Burden or Cost
The estimated burden for the NRC Form 741 has increased by 1,428 hours, i.e.,
from 12,500 hours to 13,928 hours. These increases are due to changes to 10
CFR 75 to implement the U.S.-IAEA Caribbean Territories Safeguards
Agreement. Specifically, the 6 licensees reporting under the Small Quantities
Protocol, as defined in 10 CFR 74.5, must report their physical inventories of
special nuclear material (SNM) and source material even if the quantities are
below the domestic reporting requirement for SNM (less than 1 gram). The
respective reporting requirements are contained in 10 CFR 75.6(e), Nuclear
Material Outside Facilities, which provides specific information regarding nuclear
material outside facilities in the U.S. Caribbean Territories.

16.

Publication for Statistical Use
None.

17.

Reason for Not Displaying the Expiration Date
The expiration date is displayed on DOE/NRC Form 741.

18.

Exceptions to the Certification Statement
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None.
B.

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

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