Ml22189a146 (1)

FINAL SUPPORTING STATEMENT FOR
NRC FORM 361, "REACTOR PLANT EVENT NOTIFICATION WORKSHEET"
NRC FORM 361A, “FUEL CYCLE AND MATERIALS EVENT NOTIFICATION
WORKSHEET” NRC FORM 361N, “NON-POWER REACTOR EVENT NOTIFICATION
WORKSHEET”
(3150-0238)
Extension
Description of the Information Collection
NUREG -1022, Rev. 3, “Event Report Guidelines, Title 10 of the Code of Federal Regulation
(10 CFR) 10 CFR 50.72 and 50.73” provides guidance to licensees for meeting the
requirements of 10 CFR 50.72 “Immediate notification requirements for operating nuclear power
reactors” and 10 CFR 50.73 “Licensee event report systems.” Specifically, Section 4.2.4 of
NUREG-1022 references the Event Notification Worksheet (NRC Form 361) as a tool to
facilitate easier communication between the U.S. Nuclear Regulatory Commission (NRC)
Headquarters Operations Officers and licensees during event notifications. The use of the form
is voluntary, but the form provides the usual order of questions and discussion to enable a
licensee to prepare answers for a more clear and complete telephonic notification. The NRC
has prepared different versions of NRC Form 361 as described below for each type of licensees
with reportable events.
Additionally, the NRC launched a new non-emergency and emergency event notification (EN)
module on the self-service web-based portal (MAP-X). The EN Module provides a foundation
for more automation of interactions between the NRC and the licensees and has tremendous
long-term benefits.
Currently, there are two live modules in MAP-X which provide the reactor licensees the ability to
submit relief requests (i.e., the EN Module and the Web-based Relief Request Module). The use
of these modules is not a regulatory requirement but provides licensees with alternative
methods for submitting information and interacting with the NRC. Licensees must request a user
account to get access to the modules in MAP-X. MAP-X can be accessed at https://mapx.nrcgateway.gov/
Holders of operating licenses for commercial nuclear power plants are required to report
specified events per 10 CFR 50.72 and other requirements (10 CFR 20, 21, 26, 73, and 74) to
the NRC Operations Center via telephone. Holders of NRC Fuel Cycle Facility and Materials
licenses are required to report specified events per 10 CFR 40.60, 10 CFR 70.50 or
10 CFR 72.75 and other requirements (10 CFR 20, 21, 26, 30, 35, 36, 37, 73, and 74) to the
NRC Operations Center via telephone. Holders of NRC Non-Power Reactor licenses are
required to report specified events per their respective Technical Specifications and other
requirements (10 CFR 73 and 74) to the NRC Operations Center. While each version of the
NRC Form 361 contains unique information with respects to reference to different

-2-

sections of the 10 CFR above, the information requested for all three forms generally include
time of event, name and location of the facility, plant conditions at the onset of the events,
detailed event descriptions, effect to other or facilities on site, and status of the affected
facilities.
A.

JUSTIFICATION
1.

Need for and Practical Utility of the Collection of Information
The NRC licenses and regulates the Nation's civilian use of radioactive materials to
provide reasonable assurance of adequate protection of public health and safety,
promote the common defense and security, and protect the environment. In order
for the NRC to carry out these responsibilities, its regulations require licensees to
report significant events so that the NRC can evaluate the events to determine what
actions, if any, are warranted to ensure protection of public health and safety. In
addition, this information is needed for the NRC to carry out its responsibility to
inform Congress of those events constituting "abnormal occurrences."
As required by 10 CFR 50.72, commercial nuclear power plants to report certain
reactor events and emergencies that have potential impact to public health and
safety. In order to efficiently process the information received through such reports
for reactors, the NRC developed Form 361 as a vehicle to record the information in
a templated fashion. Similarly, the NRC also created other NRC Forms (361A,
361N) to allow for efficient collection of information for Fuel Cycle licensee, Material
Licensee, and Non-Power Reactor events with potential significance and impact to
public health and safety. Without the templated format of the NRC Forms 361, the
information exchange between licensees and NRC Headquarters Operations
Officers via telephone could result in delays due to excessive follow- on questions
for additional details, repeat-backs for confirmation, as well as unnecessary
transposition errors.

2.

Agency Use of Information
The NRC staff uses the information reported using these forms for responding to
emergencies, monitoring ongoing events, confirming licensing bases, studying
potentially generic safety problems, assessing trends and patterns of operational
experience, monitoring performance, identifying precursors of more significant
events, and providing operational experience to the industry.

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 (EIE) process, which is
available from the NRC's “Electronic Submittals” Web

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page, by Optical Storage Media (OSM) (e.g., CD-ROM, DVD), by facsimile or by
email. It is estimated that approximately 0% of the potential responses are filed
electronically.
The information collections related to the requirement to make an initial event report
telephonically are covered under OMB Clearance Number 3150-0011. NRC Forms
361 provide a tool that allows licensees to relay by phone specific details in a
templated and sequenced fashion to minimize follow up questions for additional
details and repeat-backs for confirmation. The form also provides a template for
licensee’s follow-on event reports, if required, to be written in a manner consistent
with their event reporting procedures.
It is estimated that approximately 97% of reactor licensees use the format of NRC
Form 361 to prepare their event report notification, and these licensees also
typically follow telephonic notifications with electronic confirmation via email or
facsimile.
It is estimated that one Fuel Cycle Facility use the NRC Form 361 format and
approximately 20% of the 31 Non-Power Reactor licensees use the format.
Approximately three Fuel Cycle Facilities, and Non-Power Reactors licensees follow
their required telephonic notifications with electronic confirmation via email or
facsimile.
4.

Efforts 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
Efforts have been made to keep the requirements for information to a minimum.
However, since the health and safety consequences of the events being reported
are likely to be the same for large and small entities, it is not possible to further
reduce the burden on small businesses by less frequent or less complete
recordkeeping or reporting.

6.

Consequences to Federal Program or Policy Activities if the Collection is Not
Conducted or is Conducted Less Frequently
Not collecting the information, or collecting it less frequently, would degrade the
NRC’s ability to determine in a timely manner what actions, if any, may be needed
to resolve potential threats to public health and safety or the environment and
inform Congress of those events constituting “abnormal occurrences.”

7.

Circumstances Which Justify Variation from OMB Guidelines
Not applicable.

-48.

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 27, 2022,
(87 FR 25056). As part of the consultation process, staff reached out to the
licensing managers at four nuclear power plants initially by phone to three of the
plants (Hope Creek, Palisades, and Columbia) followed by emails to four plants
(Hope Creek, Palisades, Columbia, and Diablo Canyon). No comments were
received in response to these consultations.

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
No sensitive information is requested.

12.

Estimated Burden and Burden Hour Cost
There are no record keeping or third-party disclosure burden associated with
licensees’ telephonic reporting requirement.
Table 1 reflects the estimated annual burden to different types of licensees to
provide a written event report, whereas Table 2 is total burden. The estimate
includes the time to complete and submit the form since the reporting requirements
have not changed. However, the estimates include only additional time needed
above those already expended by licensees to comply with regulatory notification
requirements, such as the requirements of 10 CFR 50.72.
Operating reactor licensees have submitted (on average) approximately 500
telephonic reactor event report notifications per year (initial event reports, updated
event reports, and retractions) over the past three years. The licensees operating
the 95 power reactors are expected to continue to submit a maximum of about 500
telephonic event reports per year for the foreseeable future. The hourly additional
licensee burden associated with these event reports is estimated at 0.5 hour per
report. The burden estimate of 0.5 hours per each event report is valid since the
reporting requirements of 10 CFR 50.72 have not changed. Therefore, the
estimated annual reporting burden is 250 hours (500 event reports x 0.5 hours per
event report) at a cost of $72,000 (250 hours x $288 per hour).
Fuel Cycle Facility licensees have submitted (on average) approximately 32
telephonic reactor event report notifications per year (initial event reports, updated
event reports, and retractions) over the past three years. The licensees are

-4expected to continue to submit a maximum of about 32 telephonic event reports per
year for the foreseeable future. The hourly additional licensee burden associated
with these event reports is estimated at 0.5 hour per report. The burden estimate of
0.5 hours per event report is valid since the reporting requirements for Fuel Cycle
Facilities have not changed. Therefore, the estimated annual reporting burden is 16
hours (32 event reports x 0.5 hours per event report) at a cost of $4,608 (16 hours x
$288 per hour).
Non-Power Reactor licensees have submitted (on average) approximately 14
telephonic reactor event report notifications per year (initial event reports, updated
event reports, and retractions) over the past three years. The licensees are
expected to continue to submit a maximum of about 14 telephonic event reports per
year for the foreseeable future. The hourly additional licensee burden associated
with these event reports is estimated at 0.5 hour per report. The burden estimate of
0.5 hours per event report is valid since the reporting requirements of Non-Power
Reactor licensees have not changed. Therefore, the estimated annual reporting
burden is 7 hours (14 event reports x 0.5 hours per event report) at a cost of $2,016
(7 hours x $288 per hour).
Materials licensees have submitted (on average) approximately 366 telephonic
materials event report notifications per year (initial event reports, updated event
reports, and retractions) over the past three years. The licensees are expected to
continue to report a maximum of about 366 events per year for the foreseeable
future. However, only a small number of the reports (approximately 10) are
estimated to have NRC Form 361A follow the telephonic reports. The hourly
additional licensee burden associated with these event reports is estimated at 0.5
hour per report. One new reporting criterion was added since original issue of the
form 361A, but the increase in reports is negligible over the past 3 years. The
burden estimate of 0.5 hours per event report is valid since only one reporting
requirement of Materials licensees has been added, which affects a small number of
respondents. Therefore, the estimated annual reporting burden is 5 hours (10 event
reports x 0.5 hours per event report) at a cost of $1,440 (5 hours x $288 per hour).
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 based on this rate, see the Federal Register notice at:
(86 FR 32170, Jun. 16, 2021).
13.

Estimate of other Additional costs
There are no additional costs.

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.

-6Operating reactor licensees represent the bulk of required event reports processed
by the NRC. These licensees have submitted (on average) approximately 500
telephonic reactor event report notifications per year (initial event reports, updated
event reports, and retractions) over the past three years.
The licensees operating the 95 power reactors are expected to continue to submit a
maximum of about 500 telephonic event reports per year for the foreseeable future.
The burden associated with processing each event report by the NRC Headquarters
Operations Officers is reduced by the licensee voluntary use of the NRC Forms 361
format to provide event descriptions via telephonic notification. Without the use of
the NRC Form 361 event description information, the Headquarters Operations
Officers would be required to take slower notes of the event description, keeping the
licensee on the phone longer, and rely on use of telephonic notification audio
recordings to transcribe the detailed event description information into the HOO
database for processing and distribution. It is estimated that the use of the NRC
Forms 361 saves the NRC Headquarters Operations Officers approximately 0.5
hours of processing time per report. The burden estimate of 0.5 hours per written
submission of each event report is valid since the reporting requirements of
10 CFR 50.72 have not changed. Therefore, the total estimated annual reporting
burden reduction is 250 hours (500 event reports x 0.5 hours per event report) at a
cost of $72,000 (250 hours x $288 per hour).
15.

Reasons for Change in Burden or Cost
The previous burden for this collection was 268.5 hours and 537 responses. Based
on data from the last three years, the burden is expected to slightly increase to 278
hours and 556 responses (an increase of 9.5 hours and 19 responses). One
reporting criterion was added for Materials licensee, but given the few licensees this
affects, and the few numbers of reports taken over three years of the criterion, this
adds negligible additional burden or cost. The NRC Form 361 hourly rate has
increased since the initial clearance from $263/hr to $288/hr.

16.

Publication for Statistical Use
Not applicable.

17.

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

18.

Exceptions to the Certification Statement
Not applicable

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B.

Collection of Information Employing Statistical Methods
The collection of information does not employ statistical methods.
Description

No. of
Respondent
s

Responses
per
Responden
t

Number of
Response
s

Burden
Hours per
Response

Total
Annual
Burden
Hours

Cost at
$288/hr

Operating
reactor
licensees

95

5.3

500

0.5

250

$72,000

Fuel Cycle
Facility
licensees

8

4.0

32

0.5

16

$4,608

Non-Power
Reactor
licensees

31

0.45

14

0.5

7

$2,016

Materials
licensees
TOTAL

2796

.004

10

0.5

5

$1,440

278

$80,064

2930

556

TABLE 2: BURDEN TOTALS
Total Annual Burden:
278 (556 event reports x 0.5 hours per event
report) Total Burden Hour Cost:
$80,064 (278 hours x $288/hour)
Total Responses:
556 event reports