Burden spreadsheet for Part 72 information collection renewal

Section & Description of
Requirement
72.7 - Request for exemption
72.11 - Notification of information
about significant implication for
public health and safety or
common defense and security
72.16, 72.22, 72.24, 72.26, 72.28,
72.30, 72.32, 72.34, 72.44(b)(4) Application for specific license
72.30(a)-(g) - Decommissioning
funding plan with application,
renewal and every 3 years
72.42 - ISFSI license renewal
72.44(b)(3) - Demand for
information
72.44(b)(6) - Notification of
bankrupt filing
72.44(d)(3) - Authorization of the
receipt, handling, and storage of
spent fuel, high-level radioactive
waste and/or reactor-related GTCC
waste
72.44(e)- Application to amend
license in order to amend security
plan
72.44(f) - Emergency plan changes

Number of
Respondents
4.0

Table 3. Annual Reporting Burden
Number of
Total Annual
Responses Per
Responses
Respondent
1.0
4.0

-

-

-

1.0

- $

1.0

1.0

1.0

12,732.0

12,732.0 $

3,539,496.00

11.0

1.0

11.0

4.0

44.0 $

12,232.00

1.3

1.0

1.3

6,000.0

7,980.0 $

2,218,440.00

-

-

-

500.0

- $

-

-

-

-

1.0

- $

-

82.0

3.0

246.0

8.0

1,968.0 $

547,104.00

2.0

1.0

2.0

10.0

20.0 $

5,560.00

2.0

15.0

30.0

10.0

300.0 $

83,400.00

227,960.00

72.48(c)(2) - Circumstances that
require a license amendment
72.48(d)(2) - Reporting a brief
description of any changes, tests,
and experiments, including a
summary of the evaluation of each
as specified in 72.4 (To be done by
a licensee and certificate holder)
72.50 (no transfers anticipated) Transfer of License
72.52(b) - (Included in 72.56) Consent from Commission without
an individual application to the
creation of any mortgage, pledge,
or other lien on spent nuclear
material
72.54(d) - Licensee shall notify
NRC in writing and submit within
12 months of the notification with a
final decommissioning plan per
72.42(b) or by administrative
directions in 72.4
72.54(f) - Commission approval to
delay or postpone initation of the
decommissioning process if it isn't
deterimental to public health &
safety
72.54(g) - (Included in 72.54(d)) Proposed final decommissioning
plan requirements
72.54(j)(2) - Requirements for
decommissioning of the entire site
72.54(k) - Commission approval for
an alternate schedule for the
completion of decommissioning
72.54(l) - Final radiation surveys
and certification of waste
disposition
72.56 - Application for an
amendment to a license

Burden Hrs
Total Annual
Per
Cost @ $278/HR
Burden (Hrs)
Response
200.0
800.0 $
222,400.00
-

Included in 72.56 and 72.244

41.0

1.0

41.0

20.0

820.0 $

-

-

-

100.0

- $

-

Included in 72.56

-

-

-

1,200.0

- $

-

-

-

-

40.0

- $

-

included in 72.54(d)
-

-

-

1,200.0

- $

-

-

-

-

240.0

- $

-

-

-

-

1,200.0

- $

-

4.0

1.0

4.0

120.0

480.0 $

133,440.00

Section & Description of
Requirement
72.62(d) - (this is a contingency
provision) - Commission
requirement for a holder of a
license to submit information
dealing with backfitting or proposed
backfitting
72.70 - (all sections included) SAR Periodic Updates
72.74 - (this is a contingency
provision) - CoC-Only Requirement
to Provide Updated SAR to New
Certificate Holder or NRC
72.75(a) - Reporting requirements:
Emergency notifications
72.75(b) - Reporting requirements:
Non-emergency notifications
(4 hr reports)
72.75(c) - Reporting requirements:
Non-emergency notifications (8 hr
reports)
72.75(d)(1) - (2) (included in
72.75(a), (b), and (c)) - Reporting
requirements: Non-emergency
notifications (24 hr reports)
72.75(e)(1)-(3): Reporting
requirements: Initial notification
72.75(f) - Reporting requirements:
Follow-up notification
72.75(g)(1)-(7) - Reporting
requirements: Preparation and
submission of written reports
72.75(h) - Reporting requirements:
Supplemental information
72.80(b) - Other records and
reports: Each licensee shall furnish
a copy of its annual financial report,
including the certified financial
statements to the Commission
72.80(e) - Other records:Before
license termination shall forward
records required by the regs to the
appropriate NRC Regional Office
72.80(g) - Other records and
reports: Each specific licensee
shall notify the Commission of its
readiness to begin operation at
least 90 days prior to the first
storage of spent fuel
72.90 - (included in 72.16 or 72.56)
- Siting Evaluation Factors:
General Considerations
72.92 -(included in 72.16 or 72.56) Siting Evaluation Factors: Design
Basis External Natural Events
72.94 - (included in 72.16 or 72.56)
- Design basis external maninduced events
72.98 - (included in 72.16 or
72.56): Siting Evaluation Factors:
Identifying Regions around an
ISFSI or MRS Site
72.100 - (included in 72.16 or
72.56) - Siting Evaluation Factors:
Defining Potential Effects of the
ISFSI or MRS on the Region

Number of
Respondents

Number of
Responses Per
Respondent

Burden Hrs
Per
Response

Total Annual
Responses

Total Annual
Burden (Hrs)

Cost @ $278/HR

-

-

-

80.0

- $

-

8.0

1.0

8.0

180.0

1,440.0 $

-

-

-

40.0

- $

-

-

-

-

1.0

- $

-

-

-

-

1.0

- $

-

-

-

-

1.0

- $

-

400,320.00

Included in 72.75(a), (b), and ©
-

-

-

1.0

- $

-

-

-

-

1.0

- $

-

-

-

-

1.0

- $

-

-

-

-

1.0

- $

-

72.0

1.0

72.0

1.0

72.0 $

-

-

-

1.0

- $

-

-

-

-

5.0

- $

-

20,016.00

Section & Description of
Requirement

Number of
Respondents

72.102 - (included in 72.16 or
72.56) - Geological and
Seismological Characteristics
(Applications Before 10/16/2003
and for Wet Storage)

Number of
Responses Per
Respondent

Burden Hrs
Per
Response

Total Annual
Responses

Total Annual
Burden (Hrs)

Cost @ $278/HR

72.103 - (included in 72.16 or
72.56) - Geological and
Seismological Characteristics
(Applications On/After 10/16/2003)
72.104 - (included in 72.16 or
72.56) - Dose Criteria
72.108 - (included in 72.16 or
72.56) - Transportation of spent
nuclear fuel
72.120 - (included in 72.16 or
72.56) - General Design Criteria:
General Considerations
72.126(d) - (included in 72.16 or
72.56) - ISFSI Designed for ALARA
Effluents; Analyses to Demonstrate
Compliance with 72.104 and
72.106
(72.104 &
72.106)
72.140 thru 72.176 - (included in
72.16 or 72.56) - Quality
Assurance
72.180 - (included in 72.16) Physical protection plan
72.182 - (included in 72.16) Design for physical protection
72.184(a) - (included in 72.16) Licensee's safeguards contigency
plan for responding to threats and
radiological sabotage
72.184(b) - (included in 72.16) Licensee's safeguards contingency
plan procedures effecting the
actions and decisions contained in
the Responsibility Matrix
72.186(a) - (included in 72.56) Commission approval to change
safeguards contigency plan
(Background, Generic Planning
Base, Licensee Planning Base,
and Responsibility Matrix)
72.186(b) - Copy of changes to
physical security plan to the
Regional Administrator
72.192 - (included in 72.16) Operator training and certification
program
72.206 - Provision of MRS
Information to State Governments
and Indian Tribes: Representation
72.212(b)(1) - Notify NRC 90 days
before storing fuel under a general
license
72.212(b)(2) - Register use of each
cask w/in 30 days
72.212(b)(3) - Ensure that each
cask used by the general licensee
conforms to § 72.214.
72.212(b)(4) - Register
use/application of amended CoC to
loaded cask
72.218(c) - Provide copies of
72.218(a) and (b) submittals to
Regional office

Included in 72.16 (or 72.56)

Included in 72.56

2.0

1.0

2.0

10.0

20.0 $

5,560.00

-

-

-

-

- $

1.00

1.00

1.0

1.0

1.0 $

278.00

4.00

1.00

4.0

1.0

4.0 $

1,112.00

32.00

3.00

96.0

1.2

115.2 $

32,025.60

6.00

1.00

6.0

1.0

6.0 $

1,668.00

6.00

1.00

6.0

1.0

6.0 $

1,668.00

-

-

-

8.0

- $

-

-

Section & Description of
Requirement
72.230(a) and (b) - Spent fuel
storage application & casks that is
certified under transportation must
follow 72.4
72.232(d) - Notify NRC 45 days
before starting cask fabrication
72.240(a) & (b) - Cask renewal - 40
yrs; CoC holder or cask user may
apply; Submit renewal application
30 days before CoC expiration
72.240(c)- Renewal application
includes SAR w/ updated design
bases information, TLAA, AMP
72.242(d) - (this is a contingency
provision) - Report design or
fabrication deficiency within 30
days of discovery
72.244 - Application for an
amendment to a Certificate of
Compliance
72.248 - Safety Analysis Report
(SAR) Updating
TOTAL REQUESTED
REPORTING

Number of
Respondents

Number of
Responses Per
Respondent

Total Annual
Responses

Burden Hrs
Per
Response

Total Annual
Burden (Hrs)

Cost @ $278/HR

4.0

0.2

0.8

1,200.0

960.0 $

266,880.00

4.0

0.5

2.0

2.0

4.0 $

1,112.00

4.0

1.75

7.0

600.0

4,200.0 $

1,167,600.00

4.0

1.75

7.0

40.0

280.0 $

77,840.00

15.0

4.0

60.0

2.0

120.0 $

33,360.00

4.0

2.5

10.0

110.0

1,100.0 $

305,800.00

4.0

1.5

6.0

40.0

240.0 $

66,720.00

86.0

628.1

33,712.2

$

9,371,991.60

Section &
Description of
Requirement
72.80(f) - Licensee
transfer the records to
new licensee
72.234(d)(3) Certificate holder
supplies the licensees
using the spent fuel
storage cask with the
original record of CoC
number

Table 5. Annual Third-Party Disclosure Burden

Number of
Number of
Responses Per
Respondents
Respondent

Total Annual
Responses

Burden Hrs Per
Response

Total Annual
Burden (Hrs)

Cost @
$278/Hr

82

1

82

10

820.0

$227,960

4

16

64

8

512.0

$142,336

72.234(f) - Certificate
holder provides copy of
procedures and tests
to licensee using the
spent fuel storage cask

4

2

8

190

1,520.0

$422,560

TOTAL REQUESTED
3RD PARTY
DISCLOSURE

86

2,852.0

$792,856

154

Table 4. Annual Recordkeeping Burden

Section & Description of
Requirement
72.30(f) - Records of information
important to the decommissioning
of a facility
72.48(d)(1) - Records of changes
in the facility or spent fuel storage
cask design, of changes in
procedures, and of tests and
experiments
72.72(a) - Records showing the
receipt, inventory (including
location), disposal, acquisition, and
SNM and source material
72.72(b) and (d) - Copy of the
current inventory of all spent fuel,
high-level radioactive waste, and
reactor-related GTCC waste
containing special nuclear material,
including a duplicate record in a
separate location
72.72(c) - Written material control
and accounting procedures
72.80(a)&(c) - (included in other
specific reqmts) - GENERAL (no
additional burden). Each licensee
shall maintain any records and
make any reports that may be
required by the conditions of the
license or by the rules, regulations,
and orders of the Commission,
unless specified, retain Part 72
records until license termination.
72.80(e) - Other records: Record
Retention Periods
72.140(d) & 72.174 - Quality
Assurance Programs; Quality
Assurance programs for previously
approved programs
72.180 - Physical Protection Plans
72.184(b) - Licensee's safeguards
contingency plan procedures
effecting the actions and decisions
contained in the Responsibility
Matrix
72.212(b)(5),(6), &(8) - Record of
written evaluations before cask
use
72.212(b)(7) - Evaluate changes to
72.212 evaluations and conditions
not bound by FSAR, per 72.48;
maintain records until SNF not
stored under GL
72.212(b)(11) - Maintain a copy of
CoC and referenced/supporting
documents
72.212(b)(12) - Maintain cask
records
72.212(b)(13) - Written procedures
for ISFSI activities

Record
retention
period

Number of
Hours Per
Recordkeepers Recordkeeper

Total Annual
Cost @ $278/Hr
Burden Hours

L

82

10.0

820.0

$227,960

2 yrs

82

10.0

820.0

$227,960

5 yrs

82

42.0

3,444.0

$957,432

12 mos. 72.72(b)
5 years 72.72(d)

82

78.0

6,396.0

$1,778,088

L

78

40.0

3,120.0

$867,360

L

Included in other specific requirements

L

78

6.0

468.0

$130,104

L

78

50.0

3,900.0

3 yrs

17

10.0

170.0

$47,260

3 yrs

17

5.0

85.0

$23,630

L

65

6.0

390.0

$108,420

L

8

1.0

8.0

L

65

8.0

520.0

L

65

60.0

3,900.0

$1,084,200

L

65

120.0

7,800.0

$2,168,400

$1,084,200

$2,224

$144,560

Section & Description of
Requirement
72.234(d) - Establish and maintain
cask records; provide records to
users; send composite records to
NRC if cease production of casks
72.234(f) - CoC holder establishes
written procedures and tests and
provides copy to users before cask
use
72.236(k) - Mark cask with a model
number, unique identification
number, empty weight
72.242 (a)-(c) - Maintain records;
Record retention periods; Original
record or clear reproduced copy
TOTAL REQUESTED
RECORDKEEPING

Record
retention
period

Number of
Hours Per
Recordkeepers Recordkeeper

Total Annual
Cost @ $278/Hr
Burden Hours

L

65

120.0

7,800.0

L

4

24.0

96.0

L

65

60.0

3,900.0

L

4

5.0

20.0

86

43,657.0

$2,168,400

$26,688

$1,084,200

$5,560
$12,136,646

Table 1. Annual Burden Estimates for 10 CFR Part 72
Responses
Burden
Cost at $278/hr
628.1
33,712.2
$9,371,992
Reporting
86.0
43,657.0
$12,136,646
Recordkeeping
154.0
2,852.0
$792,856
Third-Party Disclosure
868.1
TOTAL
80,221.2
$22,301,494

Recordkeeping costs

$

4,855