FR 2021-03450

The U.S. Energy Information Administration (EIA), part of the Department of Energy (DOE), has issued a notice seeking public comments on the proposed extension of a form used for managing nuclear waste fees. This form, referred to as Form NWPA-830G Appendix G, is integral to the Standard Contract for the disposal of spent nuclear fuel and high-level radioactive waste. Generators and owners of such waste pay fees based on the net electricity they generate and sell. These fees support the Nuclear Waste Fund, a crucial component in managing the country's nuclear waste. The public is invited to provide feedback by April 23, 2021.

General Overview

The proposed action aims to extend the form collection process by three years without any modifications. This allows the EIA to continue collecting data essential for assessing energy resources and adhering to statutory requirements. Furthermore, this process supports compliance with the Paperwork Reduction Act of 1995, which aims to minimize the paperwork burden for individuals and businesses.

Significant Issues and Concerns

A significant concern is the lack of transparency around the cost burden estimation. The document states an annual estimated cost burden of $158,401 but provides no detailed breakdown of how the 1,940 estimated burden hours contribute to this figure. Moreover, the calculation of the average loaded wage rate of $81.65 per hour is not clarified, leaving the methodology behind these numbers opaque to the public.

Another point of ambiguity is what the document means by "the normal course of business." Without a clear definition, respondents might find it challenging to distinguish which costs they are expected to bear beyond those naturally occurring in their operations. Additionally, while the document solicits public comments, the process for making these submissions might not be clear to everyone, especially those unfamiliar with federal procedures.

Potential Public Impact

This document affects multiple stakeholders, including energy producers, nuclear waste management entities, and potentially the broader public who value safe and effective waste management. The extension facilitates ongoing compliance and ensures continued funding for nuclear waste management, supporting public safety and environmental protection.

Impact on Specific Stakeholders

For nuclear energy producers, the document represents continuity in their regulatory obligations without additional burdens from form changes. This stability allows them to plan with greater certainty regarding their fee payments and data submissions. On the downside, the lack of clear cost guidelines could lead to misunderstandings about the form's financial implications.

For the general public, particularly those concerned with environmental issues, the document might be reassuring. It demonstrates a structured approach to dealing with nuclear waste, ensuring that funds remain available for waste management activities. However, without transparent reporting of cost and effort estimates, public confidence in the fairness and efficiency of this process might be lessened.

In summary, while the proposed extension aligns with regulatory compliance and waste management needs, clearer explanations of costs and submission processes would benefit all stakeholders. Enhanced transparency would foster trust and more informed participation in the regulatory process.

The Energy Information Administration (EIA) has proposed a three-year extension for the collection of certain data related to nuclear waste management. This involves information gathering through Form NWPA-830G, connected to the Standard Contract for the Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste. The focus on Form NWPA-830G is partly due to its role in facilitating the payment of fees into the Nuclear Waste Fund by generators and owners of spent nuclear fuel.

Financial Overview

The document estimates the annual reporting and recordkeeping cost burden to be $158,401. This figure is based on an estimated 1,940 burden hours, multiplied by a current average loaded wage rate of $81.65 per hour. However, the explanation behind these financial details is somewhat opaque. The estimated number of respondents is 97, generating a total of 388 responses annually.

Issues Related to Financial References

1. Breakdown of Costs: A key issue is the lack of detailed explanation on how the estimated burden hours translate into the total cost burden of $158,401. Without a breakdown, it's challenging for stakeholders to assess the accuracy or reasonableness of these figures.

2. Wage Rate Calculation: The document does not clarify how the $81.65 wage rate was determined, leading to potential confusion about if this average wage accurately represents the wages in sectors concerned with nuclear waste management obligations.

3. Definition of Terms: Terms like "burden hours" and "current average loaded wage rate" may not be easily understood by all readers. Simplifying or explaining these terms could improve the document's accessibility, helping stakeholders better comprehend how these financial metrics are calculated and applied.

4. Normal Course of Business: The document claims respondents will not face additional costs beyond the burden hours due to the "normal course of business." However, it fails to specify what activities fall under this category, leaving room for ambiguity and possible additional, unacknowledged expenses for the respondents.

Conclusion

Overall, while the document gives an estimated cost and workload for complying with the proposed data collection, the lack of detailed explanations for these financial estimates can be challenging for both laypersons and stakeholders to assess. Improvements could include a more transparent breakdown of how burden hours and wage rates are calculated and applied, aiding in clearer understanding and evaluation of the proposed financial burdens.