ML22153A109 - Final Supporting Statement

ML22153A109 - Final Supporting Statement.pdf

NRC Form 748, National Source Tracking Transaction Report

OMB: 3150-0202

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FINAL SUPPORTING STATEMENT FOR
NRC FORM 748
NATIONAL SOURCE TRACKING TRANSACTION REPORT
(OMB CLEARANCE NO. 3150-0202)
EXTENSION
Description of the Information Collection
The Energy Policy Act of 2005 required the Nuclear Regulatory Commission (NRC) to issue
regulations establishing a mandatory tracking system for radiation sources in the United States.
In response to that mandate, the National Source Tracking System (NSTS) was developed
through close cooperation with other Federal and State agencies. Under this program,
licensees are required to report information on the manufacture, transfer, receipt, and disposal
of nationally tracked sources. This information is used to maintain the NSTS and provides the
NRC with a “cradle-to-grave” account for these sources, thus improving accountability and
controls over them. Licensees can submit this transaction information by using the online NSTS
or the NRC Form 748 - “National Source Tracking Transaction Report.” The data elements
contained on the NRC Form 748 represent the information necessary to track the nationally
tracked sources from cradle to grave to ensure that all such sources continue to be accounted
for.
The online NSTS allows licensees to report transactions directly into the system. Because this
system requires a digital credential (an electronic identification which establishes a user’s
credentials when processing transactions on the web), it allows licensees to access previously
entered source data without requiring them to rekey that information. For example, once a
source is entered into the system, the licensee can enter subsequent transactions for that
source without re-entering information about the source. In the online NSTS system, licensees
can use batch uploads to submit data on multiple transactions. This ability to upload multiple
transactions represents a large time savings for manufacturers and distributors and other
licensees who perform multiple transactions on a regular basis.
Justification
1.

Need for and Practical Utility of the Collection of Information
There is broad U.S. Government and international interest in tracking radioactive
sources to improve accountability and control. Prior to implementation of the
NSTS, there was no single U.S. source of information to verify the authorized
users, locations, quantities, and movement of these materials. Separate NRC
and Agreement State systems tracked licensees and the maximum amounts of
materials they are authorized to possess but did not record actual sources or
their movements. National source tracking is part of a comprehensive
radioactive source control program for radioactive materials of greatest concern.
Although a national source tracking program cannot ensure the physical
protection of sources, it provides greater source accountability. The information
collection, in conjunction with other controls, directly supports a comprehensive

radioactive source control program for radioactive materials of greatest concern.
The information collected enhances the ability of the NRC and Agreement States
to conduct inspections and investigations, communicate information to other
government agencies, and verify legitimate ownership and use of nationally
tracked sources. In addition, the national source tracking program fulfills a U.S.
Government commitment to the International Atomic Energy Agency Code of
Conduct on the Safety and Security of Radioactive Sources.
Section 20.2207(a) requires manufacturers of any nationally tracked source to
complete and submit a National Source Tracking Transaction Report or by other
means specified in the rule. The report must include the following information:
(1) the name, address, and license number of the reporting licensee; (2) the
name of the individual preparing the report; (3) the manufacturer, model, and
serial number of the source; (4) the radioactive material in the source; (5) the
initial source strength in becquerels (curies) at the time of manufacture; and (6)
the manufacture date of the source. This information is needed to monitor on a
timely basis the location and manufacture of new nationally tracked sources.
Section 20.2207(b) requires licensees to report the transfer of any nationally
tracked source to another person on a National Source Tracking Transaction
Report or by other means specified in the rule. The report must include the
following information: (1) the name, address, and license number of the
reporting licensee; (2) the name of the individual preparing the report; (3) the
name and license number of the recipient facility and the shipping address; (4)
the manufacturer, model, and serial number of the source or, if not available,
other information to uniquely identify the source; (5) the radioactive material in
the source;(6) the initial or current source strength in becquerels (curies); (7) the
date for which the source strength is reported; (8) the shipping date; (9) The
estimated arrival date; and (10) for nationally tracked sources transferred as
waste under a Uniform Low-Level Radioactive Waste Manifest, the waste
manifest number and the container identification of the container with the
nationally tracked source. This information is needed to monitor on a timely
basis the location and transfer of the nationally tracked sources.
Section 20.2207(c) requires licensees to report the receipt of any nationally
tracked source on a National Source Tracking Transaction Report or by other
means specified in the rule. The report must include the following information:
(1) the name, address, and license number of the reporting licensee; (2) the
name of the individual preparing the report; (3) the name, address, and license
number of the person that provided the source; (4) the manufacturer, model, and
serial number of the source or, if not available, other information to uniquely
identify the source; (5) the radioactive material in the source; (6) the initial or
current source strength in becquerels (curies); (7) the date for which the source
strength is reported; (8) the date of receipt; and (9) for material received under a
Uniform Low-Level Radioactive Waste Manifest, the waste manifest number and
the container identification with the nationally tracked source. This information is
needed to monitor on a timely basis the location and receipt of the nationally
tracked sources.

Section 20.2207(d) requires licensees to report the disassembly of any nationally
tracked source on a National Source Tracking Transaction Report or by other
means specified in the rule. The report must include the following information:
(1) the name, address, and license number of the reporting licensee; (2) the
name of the individual preparing the report; (3) the manufacturer, model, and
serial number of the source or, if not available, other information to uniquely
identify the source; (4) the radioactive material in the source; (5) the initial or
current source strength in becquerels (curies); (6) the date for which the source
strength is reported; and (7) the disassemble date of the source. This
information is needed to monitor on a timely basis the status of the nationally
tracked sources.
Section 20.2207(e) requires licensees to report the disposal of any nationally
tracked source on a National Source Tracking Transaction Report or by other
means specified in the rule. The report must include the following information:
(1) the name, address, and license number of the reporting licensee; (2) the
name of the individual preparing the report; (3) the waste manifest number;
(4) the container identification with the nationally tracked source; and (5) the date
of disposal; and (6) the method of disposal. This information is needed to know
the final dispensation of a nationally tracked source.
Section 20.2207(g) requires licensees to correct errors in previously filed reports
or file any missed transaction reports within 5 business days of the discovery.
The section also requires licensees to reconcile and verify the inventory of
nationally tracked sources possessed by the licensee against the licensee’s data
in the NSTS on an annual basis. This verification is necessary to maintain the
accuracy and reliability of the system over time. The burden to correct errors and
file missed transaction reports is included in this clearance. The burden to
conduct an annual reconciliation with the NSTS is accounted for in the OMB
clearance for 10 CFR Part 20 (3150-0014).
Section 20.2207(h) requires licensees to report their initial inventory of nationally
tracked sources to the NSTS. Category 1 sources must be reported by
January 31, 2009 and Category 2 sources must be reported by January 31,
2009. The initial inventory report must include the following information: (1) the
name, address, and license number of the reporting licensee; (2) the name of the
individual preparing the report; (3) the manufacturer, model, and serial number of
each nationally tracked source or, if not available, other information to uniquely
identify the source; (4) the radioactive material in the sealed source; (5) the initial
or current source strength in becquerels (curies); and (6) the date for which the
source strength is reported. This information will populate the NSTS and form
the baseline for the system. This is a one-time collection that was included in the
clearance package for 10 CFR Part 20, clearance number 3150-0014. The
burden for this one-time collection is accounted for in the OMB clearance for
10 CFR Part 20 (3150-0014)

Section 32.201 requires licensees who manufacture nationally tracked sources
after the effective date of the rule to assign a unique serial number to each
nationally tracked source. In order to track the movement of sources, a unique
way to identify the specific source is necessary. The NSTS uses the combination
of the manufacturer, model, and serial number to track the sources. This
requirement is included in the clearance package for 10 CFR Part 32, clearance
number 3150-0001.
When the NSTS was developed, the NRC added 97 additional optional data
fields for the benefit of licensees (such as package ID and shipping ID). To date,
no licensees have used the additional fields. Although these additional data
fields are not being used, NRC staff do not plan to remove them from the system,
due to the cost associated with contractor modifications of the system.
2.

Agency Use of the Information
The NRC will use the information to identify licensees that possess nationally
tracked sources so they can be contacted or inspected and to better understand
and monitor the location and movement of high-risk sealed sources

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 Information Exchange
process, which is available from the NRC’s “Electronic Submittals” Web page,
by Optical Storage Media (e.g. CD-ROM, DVD), by facsimile, or by e-mail.
Approximately 1 percent of responses are mailed or faxed versions of the NRC
Form 748. Another 26 percent of responses are electronically submitted
(emailed) versions of the NRC Form 748. The remaining 73 percent of
responses are electronically submitted using NRC’s online NSTS reporting
system or submitted by batch upload in a computer-readable format. Therefore,
approximately 99 percent of responses are submitted electronically.

4.

Effort to Identify Duplication and Use Similar Information
Some information on plutonium (Pu) and thorium (Th) would be collected by both
the Nuclear Materials Management Safeguards System (NMMSS) and the
NSTS. The current regulations require reporting transfers, receipts, and
inventory to NMMSS for one gram or more of Pu and any Th that has foreign
obligations. However, because NMMSS does not collect information at the item
level, information (e.g., manufacturer, model, serial number, source strength) on
sealed sources would not be reported to NMMSS. Therefore, the NRC would not
be able to extract the information for the NSTS from NMMSS.
Conversely, the NSTS contains information only on nationally tracked sources
and not information on sources that are not considered sealed or any bulk

material that a licensee may possess. Therefore, the NRC is not able to extract
information from the NSTS to support NMMSS. Neither system would be able to
collect the needed information for the other system without modifications to the
database and the regulations.
In practice, the NRC has found that nationally-tracked Pu and Th sealed sources
are typically held by licensees for long time periods and are not routinely
transferred to other licensees; so incidences of double-reporting are expected to
be rare. Only 10 licensees have indicated that they possess Pu or Th sources
that will need to be reported to the NSTS. The NRC does not believe that the
limited number of licensees and transactions likely to be affected by this dual
reporting requirement would impose an unnecessary burden. The NMMSS and
the NSTS would collect information on these isotopes but in different formats and
with different levels of detail as needed by each system.
5.

Effort to Reduce Small Business Burden
While some licensees who possess nationally tracked sources are small
businesses, the concerns associated with the safe and secure use of nationally
tracked sources are the same for large and small entities. It is not possible to
reduce the burden on small businesses by less frequent or less complete
reporting or control procedures while maintaining the required level public health
and safety of common defense and security. It is estimated that 40 percent of
respondents to this collection are small businesses.

6.

Consequences to Federal Program or Policy Activities if the Collection is Not
Conducted or is Conducted Less Frequently
If the information is not collected, the NRC will have no way to identify licensees
that possess nationally tracked sources or monitor the location and movement of
the sources.

Required reports are collected and evaluated on a continuing basis as
transactions and events occur. The schedule for collecting the information is the
minimum frequency necessary to monitor the location and movement of
nationally tracked sources from a security standpoint and ensure that the
information in the NSTS is accurate and up-to-date.
7.

Circumstances Which Justify Variation from OMB Guidelines
Contrary to OMB Guidelines in 5 CFR 1320.5(d)(2), Sections 20.2207(a) through
(e) of 10 CFR Part 20 require licensees to complete and submit a National
Source Tracking Transaction Report by the close of the next business day after
the transaction. Section 20.2207(g) of 10 CFR Part 20 requires licensees to
correct errors and file reports for any missed transaction within 5 business days.
This information collection frequency is necessary to monitor the current location
of nationally tracked sources from a security standpoint and ensure that the
information in the NSTS is accurate and up-to-date.

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 6, 2022
(87 FR 19983). The NRC also contacted six industrial licensees (e.g.,
radiography companies) by email as part of the public consultation process. No
comments were received in response to these consultations.

9.

Payment or Gifts 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).
The information reported to the NSTS is “Official Use Only-Security-Related
Information”, which is a category assigned to certain sensitive unclassified nonsafeguards information at the NRC. Licensees will only have access to their own
information.”

11.

Justification for Sensitive Questions
This information collection does not contain sensitive questions.

12.

Estimated Burden and Burden Hour Cost
The $288 hourly rate used in the burden estimates is based on the NRC’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 (86 FR 32146, June 16, 2021).
As shown in Table 1, the estimated annual burden to licensees to report to the
NSTS is estimated to be 2,093 hours at a cost of $602,784 (2,093 hours x
$288/hour). A total of approximately 1,160 licensees (210 NRC licensees +950
Agreement State licensees) report NSTS data to the NRC.
Licensees have several options for reporting transaction information to the
NSTS:
1) Secure Web-based access to the NSTS database
2) Submittal of files in computer-readable format (e.g., batch upload)
3) Submittal of the National Source Tracking Transaction Report NRC (Form
748) by email, fax, or mail, or
4) Telephone reporting to the NSTS Help Desk, with follow up by fax or mail
The burden varies by the method of reporting. The NRC developed a “short form” of
NRC Form 748 to report single transactions of any transaction type, and a “long
form” to report multiple transaction types for licensees to submit data. The majority
of licensees reporting by NRC Form 748 are using the short form instead of the long
form, which reduces the burden on the respondent (0.156 hours for the short form as
compared to 0.25 hours for the long form). In addition, the majority of licensees who
report using the NRC Form 748 submit the form by email or fax.
Based on annual averages from calendar years 2019, 2020, and 2021, the NRC
receives approximately 3,500 online transactions a month, or 42,000 transactions
per year. However, licensees typically report an average of three transactions in a
single submission. As a result, the NRC receives approximately 14,000 submissions
a year (42,000 transactions / 3 transaction per submission), with an estimated
burden of 0.08 hours per submission.
Licensees may also report their information using the computer-readable file
format (batch upload). The NRC receives approximately 2 batch uploads each
business day. With approximately 20 business days per month, and 12 months
per year, the NRC receives an estimated 480 batch uploads per year
(2 batches/day x 20 days x 12 months). Batch uploads are estimated to take
approximately 15 minutes (0.25 hours) per batch.

Table 1.
Annual Licensee Reporting Burden

Reporting Method
NRC Form 748 – Email
NRC Form 748 – Fax
NSTS Online Submission
Batch Upload
Total

13.

Responses

Burden per
Response

Total Annual
Burden
(hours)

5,235

0.156

817

$235,296

230

0.156

36

$10,368

14,000

0.08

1,120

$322,560

480

0.25

120.0

$34,560

19,945

2,093

Cost at
$288/hr

$602,784

Estimate of Other Additional Costs
The NRC estimates that licensees would experience an annual cost of about
$129 in printing and faxing costs. The additional cost varies by reporting method.
As shown in Table 2, the NRC estimates that, on average, licensees would incur
a materials cost of $0.56 for each report they fax to the NSTS. This estimate
includes printing of the NRC Form 748 and a two-minute State-to-State
telephone call.
Table 2
Licensee Additional Costs

Reporting Method
NRC Form 748 – Email
NRC Form 748 – Fax
NSTS Online Submission
Batch Upload
Total

5,235

Additional
Cost Per
Report
$0.00

Total
Additional
Cost
$0

230

$0.56

$129

14,000

$0.00

$0

480

$0.00

$0

# Reports

19,945

$129

Internet access is considered a standard business practice. Therefore, the cost
associated with the purchase of Internet access services is not considered an
incremental cost to licensees that email the NRC Form 748 or report NSTS data
using the online system or batch upload.
14.

Estimated Annualized Cost to the Federal Government
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.

The estimated cost of operating the NSTS is approximately $3,096,864 per year.
This cost was calculated by multiplying the current fee rate of $288/hr by the total
number of hours (10,753) that the NRC estimates it will expend annually to
process data in the NSTS, the hosting environment of NSTS, annual NSTS
software maintenance, cost of automated data processing, record holding, and
clerical processing of the NRC Form 748.
15.

Reasons for Change in Burden
The previous burden for this collection was 1,963 hours and 18,927 responses.
Based on data from the last three years, the burden is expected to slightly increase
to 2,093 hours and 19,945 responses (an increase of 130 hours and 1,018
responses). The estimated burden has increased since the average number of
NSTS transactions has slightly increased over the last three years. In addition, the
fee rate has increased from $263 to $288/hr.

16.

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

17.

Reason for Not Displaying the Expiration Date
The clearance expiration date is displayed on NRC Form 748. Due to costs
associated with contractor modifications of the NSTS, the expiration date is not
displayed on the first screen of the system. All other required information
(burden estimate, mandatory nature of the collection, agency use of the
information, etc.) is included in a PRA statement on the first screen of the
system.

18.

Exceptions to the Certification Statement
None.

B.

Collection of Information Employing Statistical Methods
Not applicable.


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