Supplementary burden spreadsheet for 10 CFR Part 72 information collection

Table 1. Annual Reporting Burden
Section & Description of
Requirement
72.7 - Request for exemption

Number of
Respondents
4.0

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

4.0

-

-

1.0

1.0

11.0
1.3

Total Annual
Burden (Hrs)

Cost @ $300/HR

200.0

800.0 $

1.0

- $

1.0

12,732.0

12,732.0 $

3,819,600.00

1.0

11.0

4.0

44.0 $

13,200.00

1.0

1.3

6,000.0

7,980.0 $

2,394,000.00

-

-

-

500.0

- $

-

-

-

-

1.0

- $

-

-

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

Burden Hrs
Per
Response

Total Annual
Responses

1.0

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

Number of
Responses Per
Respondent

240,000.00
-

85.0

3.0

255.0

8.0

2,040.0 $

612,000.00

72.44(e)- Application to amend
license in order to amend security
plan

2.0

1.0

2.0

10.0

20.0 $

6,000.00

72.44(f) - Emergency plan changes

2.0

15.0

30.0

10.0

300.0 $

90,000.00

860.0 $

258,800.00

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)
72.48(d)(5) – Transfer records to
new certificate holder or the
Commission upon ending
operations
72.50 (no transfers anticipated) Transfer of License

Included in 72.56 and 72.244

43.0

1.0

-

-

-

-

20.0

20.0

-

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

-

$

-

100.0

- $

-

-

1,200.0

- $

-

-

40.0

- $

-

Included in 72.56

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

43.0

-

-

included in 72.54(d)

72.54(j)(2) - Requirements for
decommissioning of the entire site

-

-

-

1,200.0

- $

-

72.54(k) - Commission approval for
an alternate schedule for the
completion of decommissioning

-

-

-

240.0

- $

-

72.54(l) - Final radiation surveys
and certification of waste
disposition

-

-

-

1,200.0

- $

-

1.0

4.0

120.0

480.0 $

72.56 - Application for an
amendment to a license
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

4.0

Number of
Respondents

-

8.0

Number of
Responses Per
Respondent

Burden Hrs
Per
Response

Total Annual
Responses

-

-

1.0

8.0

Total Annual
Burden (Hrs)

144,000.00

Cost @ $300/HR

80.0

- $

180.0

1,440.0 $

-

432,000.00

72.74 - (this is a contingency
provision) - CoC-Only Requirement
to Provide Updated SAR to New
Certificate Holder or NRC

-

-

-

40.0

- $

-

72.75(a) - Reporting requirements:
Emergency notifications

-

-

-

1.0

- $

-

72.75(b) - Reporting requirements:
Non-emergency notifications
(4
hr reports)

-

-

-

1.0

- $

-

72.75(c) - Reporting requirements:
Non-emergency notifications (8 hr
reports)

-

-

-

1.0

- $

-

72.75(d)(1) - (2) (included in
72.75(a), (b), and (c)) - Reporting
requirements: Non-emergency
notifications (24 hr reports)

Included in 72.75(a), (b), and ©

72.75(e)(1)-(3): Reporting
requirements: Initial notification

-

-

-

1.0

- $

-

72.75(f) - Reporting requirements:
Follow-up notification

-

-

-

1.0

- $

-

72.75(g)(1)-(7) - Reporting
requirements: Preparation and
submission of written reports

-

-

-

1.0

- $

-

72.75(h) - Reporting requirements:
Supplemental information

-

-

-

1.0

- $

-

1.0

72.0 $

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

72.0

1.0

72.0

21,600.00

72.80(e) - Other records:Before
license termination shall forward
records required by the regs to the
appropriate NRC Regional Office

-

-

-

1.0

- $

-

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

-

-

-

5.0

- $

-

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

Number of
Respondents

Number of
Responses Per
Respondent

Total Annual
Responses

Burden Hrs
Per
Response

Included in 72.16 (or 72.56)

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 contingency
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 contingency plan
(Background, Generic Planning
Base, Licensee Planning Base,
and Responsibility Matrix)

Included in 72.56

Total Annual
Burden (Hrs)

Cost @ $300/HR

72.186(b) - Copy of changes to
physical security plan to the
Regional Administrator

2.0

1.0

2.0

10.0

-

-

-

20.0 $

6,000.00

72.192 - (included in 72.16) Operator training and certification
program

-

72.206 - Provision of MRS
Information to State Governments
and Indian Tribes: Representation

1.00

1.00

1.0

1.0

1.0 $

300.00

72.212(b)(1) - Notify NRC 90 days
before storing fuel under a general
license

4.00

1.00

4.0

1.0

4.0 $

1,200.00

72.212(b)(2) - Register use of each
cask w/in 30 days

24.00

3.00

72.0

$

25,920.00

72.212(b)(3) - Ensure that each
cask used by the general licensee
conforms to § 72.214.

6.00

1.00

6.0

1.0

6.0 $

1,800.00

72.212(b)(4) - Register
use/application of amended CoC to
loaded cask

6.00

1.00

6.0

1.0

6.0 $

1,800.00

-

8.0

- $

72.218(c) - Provide copies of
72.218(a) and (b) submittals to
Regional office

-

Section & Description of
Requirement

Number of
Respondents

-

Number of
Responses Per
Respondent

Total Annual
Responses

-

$

1.2 86.4

Burden Hrs
Per
Response

Total Annual
Burden (Hrs)

-

-

Cost @ $300/HR

72.230(a) and (b) - Spent fuel
storage application & casks that is
certified under transportation must
follow 72.4

4.0

0.2

0.8

1,200.0

960.0 $

288,000.00

72.232(d) - Notify NRC 45 days
before starting cask fabrication

4.0

0.5

2.0

2.0

4.0 $

1,200.00

72.234 - Transfer records to the
Commission
upon
ending
operations using instructions in
72.4.

-

-

72.240(a) & (b) - Cask renewal - 40
yrs; CoC holder or cask user may
apply; Submit renewal application
30 days before CoC expiration

4.0

1.75

7.0

600.0

4,200.0 $

1,260,000.00

72.240(c)- Renewal application
includes SAR w/ updated design
bases information, TLAA, AMP

4.0

1.75

7.0

40.0

280.0 $

84,000.00

72.242(d) - (this is a contingency
provision) - Report design or
fabrication deficiency within 30
days of discovery

15.0

4.0

60.0

2.0

120.0 $

36,000.00

72.244 - Application for an
amendment to a Certificate of
Compliance

4.0

2.5

10.0

110.0

1,100.0 $

330,000.00

72.248 - Safety Analysis Report
(SAR) Updating

4.0

1.5

6.0

40.0

240.0 $

72,000.00

TOTAL REQUESTED
REPORTING

89.0

20.0

-

615.1

-

33,615.4

$

-

$
10,084,620.00

Table 3. Annual Third-Party Disclosure Burden
Section &
Description of
Requirement

Number of
Number of
Responses Per
Respondents
Respondent

Total Annual
Responses

Burden Hrs Per
Response

Total Annual
Burden (Hrs)

Cost @
$300/Hr

72.80(f) - Licensee
transfer the records to
new licensee

85

1

85

10

850.0

$255,000

72.234(d)(3) Certificate holder
supplies the licensees
using the spent fuel
storage cask with the
original record of CoC
number

4

16

64

8

512.0

$153,600

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

$456,000

2,882.0

$864,600

TOTAL REQUESTED
3RD PARTY
DISCLOSURE

86

154

Table 2. Annual Recordkeeping Burden
Section & Description of
Requirement

Record
retention
period

72.30(f) - Records of information
important to the decommissioning
of a facility

Number of Hours Per
Recordkeepers Recordkeeper

Total Annual
Cost @ $300/Hr
Burden Hours

L

85

10.0

850.0

$255,000

72.44(e) – Maintain record of
changes to physical security plan

3 yr

85

10.0

850.0

$255,000

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

L

85

10.0

850.0

$255,000

72.72(a) - Records showing the
receipt, inventory (including
location), disposal, acquisition, and
SNM and source material

5 yrs

85

42.0

3,570.0

$1,071,000

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

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

85

78.0

6,630.0

$1,989,000

L

78

40.0

3,120.0

$936,000

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.

L

72.80(e) - Other records: Record
Retention Periods

L

78

6.0

468.0

72.140(d) & 72.174 - Quality
Assurance Programs; Quality
Assurance programs for previously
approved programs

L

78

50.0

3,900.0

72.180 - Physical Protection Plans

3 yrs

17

10.0

170.0

$51,000

72.184(b) - Licensee's safeguards
contingency plan procedures
effecting the actions and decisions
contained in the Responsibility
Matrix

3 yrs

17

5.0

85.0

$25,500

72.212(b)(5),(6), &(8) - Record of
written evaluations before cask
use

L

68

6.0

408.0

$122,400

Included in other specific requirements

$140,400

$1,170,000

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

L

8

1.0

8.0

72.212(b)(11) - Maintain a copy of
CoC and referenced/supporting
documents

L

68

8.0

544.0

72.212(b)(12) - Maintain cask
records

L

68

60.0

4,080.0

$1,224,000

72.212(b)(13) - Written procedures
for ISFSI activities

L

68

120.0

8,160.0

$2,448,000

Section & Description of
Requirement

Record
retention
period

72.234(d) - Establish and maintain
cask records; provide records to
users; send composite records to
NRC if cease production of casks

L

68

72.234(f) - CoC holder establishes
written procedures and tests and
provides copy to users before
cask use

L

4

24.0

96.0

72.236(k) - Mark cask with a
model number, unique
identification number, empty
weight

L

68

60.0

4,080.0

72.242 (a)-(c) - Maintain records;
Record retention periods; Original
record or clear reproduced copy

L

4

5.0

20.0

TOTAL REQUESTED
RECORDKEEPING

Number of Hours Per
Recordkeepers Recordkeeper

86

60.0

$2,400

$163,200

Total Annual
Cost @ $300/Hr
Burden Hours

4,080.0

41,969.0

$1,224,000

$28,800

$1,224,000

$6,000
$12,590,700.0

Table 4. Annual Burden Estimates for 10 CFR Part 72
Responses
Reporting
Recordkeeping
Third-Party Disclosure
TOTAL
Recordkeeping costs

628.1
89.0
154.0
871.1

Burden

Cost at $300/hr

33,615.4

$10,138,620

41,969

$10,142,700

2,882.0
78,466.4
$5,036

$864,600
21,145,920.0