Final Supporting Statement -NRC Form 7 ML21266A326

FINAL SUPPORTING
STATEMENT FOR
NRC FORM 7, “APPLICATION FOR NRC EXPORT/IMPORT
LICENSE, AMENDMENT, RENEWAL OR CONSENT REQUEST(S)”
(3150-0027)
--EXTENSION
Description of the Information Collection
The United States (U.S.) Nuclear Regulatory Commission (NRC), under the Atomic Energy Act
of 1954, as amended, (AEA) and Title II of the Energy Reorganization Act of 1974, as
amended, has authority for exercising export and import controls over nuclear equipment and
material. All persons who wish to export or import nuclear equipment and material as specified
in 10 CFR Part 110, Sections 110.8, 110.9, and 110.9a must provide certain information to
enable the NRC and the Executive Branch to make required export and import licensing
determinations to ensure compliance with NRC regulations and to satisfy statutory
requirements of the AEA. The most common form of information requested is that provided on
the NRC Form 7 application.
“NRC Form 7, Application for NRC Export/Import License, Amendment, Renewal, Or
Consent Request(s),” is used to collect the information needed for compliance with the
requirements in the AEA.
A.

JUSTIFICATION

1.

Need for and Practical Utility of the Collection of Information
Pursuant to the Atomic Energy Act of 1954, as amended, the NRC uses NRC Form 7 as
a multipurpose license application form designed to allow persons to provide the
minimum amount of information necessary for NRC to fulfill the statutory and regulatory
requirements governing exports and imports of nuclear material and equipment under
the NRC's authority. The form is clear, concise, easy to understand, and simple to
prepare.
Completion of the NRC Form 7 is required to obtain an authorization to export or
import certain nuclear equipment and material under NRC jurisdiction. The form
supports an agency reporting requirement from the public to provide information to the
NRC for its review and consideration in granting authorization to export or import
nuclear equipment and material.

2.

Agency Use and Practical Utility of Information
Data collected on the NRC Form 7 provides the Commission with the information
needed to describe the materials proposed for export or import, identifies the countries
receiving the materials, names any other parties to the transaction, and provides
multiple means to contact the applicant if the Commission has additional questions.
With this information, the Commission and the Executive Branch are able to

2
easily review the license application and make the required licensing determinations to
ensure compliance with regulations. If all the applicable statutory, regulatory, and
policy considerations are satisfied, the NRC will issue a license.
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 information technology when it
would be beneficial to them. 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. NRC Form 7 has electronic signature capability and licensees
can submit by email. The NRC staff estimates the 90% of submissions are electronic.
Some licensees (approximately 10%) choose to submit a paper copy rather than an
electronic submission. Since working during the pandemic, all applications were filed
electronically, and the NRC has established an email account for filing all export and
import license applications. The email for submitting applications to obtain a specific
license is [email protected] .

4.

Effort to Identify Duplication and Use Similar Information
No sources of similar information are available. There is no duplication of
requirements.

5.

Effort to Reduce Small Business Burden
The requirements specified in 10 CFR §§ 110.20-110.27, 110.31, and 110.32 are the
same for large and small businesses, because the nuclear proliferation, security and
policy concerns are the same; therefore, all businesses must provide the same data.
The NRC issued general licenses in the 1980s, which has been of more benefit to
small businesses. The NRC also allows businesses to apply for broad, long-term
licenses to export materials which are particularly beneficial to small businesses in
reducing burdens associated with paperwork expenses and uncertainties in delivery.

6.

Consequences to Federal Program or Policy Activities if the Collection Is Not
Conducted or Is Conducted Less Frequently
If an export or import is not authorized by one of the general licenses in10 CFR §§
110.20-110.27, a specific license is required, which requires completion and submittal
of the NRC Form 7 license application. The information requested to complete the
Form 7 in 10 CFR §§ 110.31-32 is submitted only when deemed necessary by
respondents and is keyed to the decision criteria that guides the NRC in approving or
denying applications for the different types of equipment or materials that must be
licensed. It specifically incorporates the requirements of the Atomic Energy Act of
1954, as amended. Therefore, if the collection is not conducted or is conducted on a
less frequent basis, a person who wishes to export under NRC's export authority would
be unable to do so because the NRC could not make the necessary determination on
whether a license should be issued.

7
The information cannot be collected on a less frequent basis because it would delay
or prevent exports or imports from being approved by the NRC. .
7.

Circumstances which Justify Variation from OMB Guidelines
None.

8.

Consultations Outside the Nuclear Regulatory Commission
Opportunity for public comment on the information collection requirements for this
clearance package was published in the Federal Register on August 26, 2021 (86 FR
47661). In addition, NRC sent the following survey to nine persons in the public who
were required to complete an NRC Form 7. No comments were received.

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).

11.

Justification for Sensitive Questions
There are no sensitive questions.

12.

Estimated Burden and Burden Hour Cost
The NRC estimates 64 applications will be filed annually on NRC Form 7. Using an
average cost of $279 per hour for reactor licenses and material licensees, the annual
cost expended by the public to prepare 64 NRC Form 7s is estimated as follows:
Annual Reporting or Disclosure Burden for NRC Form 7:
Annual Number
of Respondents
64

Annual Number
of Responses
per Respondent

Hours
per
Response

Total
Hours

Cost

1

2.4

153.6

$42,854

The total annual burden is estimated to cost $42,854 (153.6 x $279).
The $279 hourly rate used in the burden estimates is based on the Nuclear Regulatory
Commission’s fee of 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 2021 (86 FR 32146; June16, 2021).

7
13.

Estimate of Other Additional Costs
There are no additional costs.

14.

Estimated Annualized Cost to the Federal Government
The collection of information under the NRC Form 7 is estimated to require a total of
1,984 hours annually. This estimate is based on license processing data collected
during the agency’s most recent Biennial Fee Review conducted in August 2020 using
data from the most recent 2 years at the time the review was performed. This review
calculated that each NRC Form 7 required an average of 31 hours of staff time to
process each of the estimated 64 annual responses processed annually
(31 x 64 = 1,984 hours). Therefore, the revised total annual cost to the Federal
Government, at $279 per hour for licenses, is $553,536 (1,984 professional staff hours
x $279).
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 include the burden needed to review, analyze, and process the
collected information and any relevant operational expenses.

15.

Reasons for Changes in Burden or Cost
The overall burden decreased by 50 hours, from 204 to 153.6 in response to a reduction
in the number of respondents from 85 to 64. Fewer applications were received because
of the pandemic as export orders were either canceled or delayed.
There was a decrease in the overall cost because although the hourly rate increased
from $263 to $279, the number of responses decreased from 85 to 64.

16.

Publication for Statistical Use
Not applicable.

17.

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

18.

Exceptions to the Certification Statement
Not applicable.

B.

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