ML19311C796

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Part 34 Burden Spreadsheet for Radiographic Operations (OMB-3150-0007)
ML19311C796
Person / Time
Issue date: 01/23/2020
From:
Office of Nuclear Material Safety and Safeguards
To:
Richard Struckmeyer, NRC/NMSS
Shared Package
ML19305D100 List:
References
OMB 315-0007
Download: ML19311C796 (15)


Text

ANNUAL REPORTING BURDEN OF 10 CFR PART 34 FOR NRC LICENSEES Responses Number of Total Burden Section Description Per Total Burden hr/yr Cost at $278/hr Respondents Responses/yr Hrs/response Respondent An application for a specific license for the use of licensed material in 34.13(b)-(k) industrial radiography will be approved if the applicant meets the 8 1 8 40 320 $88,960 specified requirements Report within 5 days results of leak testing which indicates that a source 34.27(d) 0 1 0 4 0 $0 is leaking A licensee may conduct lay-barge, offshore platform, or underwater 34.41(c) radiography only if procedures have been approved by the Commission 13 1 13 20 260 $72,280 or by an Agreement State.

Report within 30 days of the occurrence of failures related to the source 34.101(a)&(b) assembly and any component critical to safe operation to properly 5 1 5 10 50 $13,900 perform its intended function Requires notification prior to conducting radiographic operations or 34.101(c) storing radioactive material in excess of 180 days at any location not 5 1 5 0.5 2.5 $695 listed on the license Requires independent certifying organizations and/or Agreement States Appendix A, Part I, Item 12 to exchange information about certified individuals with the Commission 1 6 6 0.5 3 $834 and the Agreement States TOTAL 32 37 635.50 $176,669 ANNUAL REPORTING BURDEN OF 10 CFR PART 34 FOR AGREEMENT STATE LICENSEES Responses Number of Total Burden Section Description Per Total Burden hr/yr Cost at $278/hr Respondents* Responses/yr Hrs/response Respondent An application for a specific license for the use of licensed material in 34.13(b)-(k) industrial radiography will be approved if the applicant meets the 58 1 58 40 2,320.00 $644,960 specified requirements Report within 5 days results of leak testing which indicates that a source 34.27(d) 0 1 0 4 0 $0 is leaking A licensee may conduct lay-barge, offshore platform, or underwater 34.41(c) radiography only if procedures have been approved by the Commission 94 1 94 20 1,880.00 $522,640 or by an Agreement State.

Report within 30 days of the occurrence of failures related to the source 34.101(a)&(b) assembly and any component critical to safe operation to properly 36 1 36 10 360 $100,080 perform its intended function Requires notification prior to conducting radiographic operations or 34.101(c) storing radioactive material in excess of 180 days at any location not 36 1 36 0.5 18 $504 listed on the license TOTAL 224 224 4,578.00 $1,268,184

ANNUAL RECORDKEEPING REQUIREMENTS OF 10 CFR PART 34 FOR NRC LICENSEES Number of Record Burden Hrs Per Section Description Record- Total Hr/Yr Retention Recordkeeper keepers Period Radiation survey instrument calibration & records 34.25(b)&(c) Included in 34.65 thereof 34.27(c)(1)&(2) Sealed source leak testing & records thereof Included in 34.67 34.27(e) S tube leak testing & records thereof Included in 34.67 34.29(a)&(b) Sealed source inventories & records thereof Included in 34.69 34.31(a)&(b)(1)&

Licensees program for inspection and maintenance Included in 34.73 (2)&(c)

Completion of the training and testing requirements license 34.42(a) 74 4 296 of § 34.43(a) termination RSO establishes, oversees, and regularly reviews all license 34.42(c)(1) operating, emergency, and ALARA procedures as 74 8 592 termination required RSO oversees and approves all phases of the license 34.42(c)(2) 74 16 1184 training program for radiographic personnel termination RSO ensures that required radiation surveys and license 34.42(c)(3) leak tests are performed and documented in 74 8 592 termination accordance with the RSO ensures that personnel monitoring devices are calibrated and used properly, that records are kept of license 34.42(c)(4) 74 16 1184 the monitoring results, and that timely notifications termination are made as required by § 20.2203 of this chapter RSO ensures that operations are conducted safely license 34.42(c)(5) 74 8 592 and assumes control for instituting corrective actions termination Tests of controls and alarms at permanent 34.33(b) Included in 34.75 radiographic installations and records thereof Records of training, examinations, refresher safety 34.43(f) training, and semiannual inspections of job Included in 34.79 performance Program for routine operations and emergencies for 34.45(a)&(b) employees to follow in performing safety functions & Included in 34.81 copies of procedures Read and record exposure on direct reading 34.47(b) Included in 34.83(a) dosimeters; maintain records Periodic check of pocket dosimeters or electronic 34.47(c) dosimeters for correct response to radiation; Included in 34.83(a) maintain records Determination of exposure if an individual's pocket 34.47(d) Included in 34.83(d) dosimeter goes off-scale Requirements if a personnel dosimeter is lost or 34.47(e) Included in 34.83(d) damaged Requirement to maintain reports received from 34.47(f) Included in 34.83(c) personnel dosimeter processors 34.47(g)(4) Calibrate alarm ratemeters; maintain records Included in 34.83(b)

Surveys of radiographic exposure device & records 34.49(c)&(d) Included in 34.85 thereof Licensee to have a copy of the license, license license 34.61 conditions, documents incorporated by reference, 74 0.16 11.84 termination and all amendments Maintain records showing receipts and transfers of 34.63 74 1.6 118.4 3 Years sealed sources and devices using DU shielding

Maintain records of calibrations of radiation survey 34.65 74 1.6 118.4 3 Years instruments 34.67 Maintain records of leak test results 74 1.2 88.8 3 Years Maintain records of quarterly inventories of sealed sources and devices containing DU shielding &

34.69(a)&(b) 74 2 148 3 Years include specific information concerning such inventories Maintain utilization logs for each sealed radioactive 34.71(a)&(b) 74 36 2664 3 Years source & records thereof Maintain records of equipment problems and 34.73(a)&(b) 74 27 1998 3 Years maintenance Maintain records of alarm system and entrance 34.75 control device tests at permanent radiographic 12 48.2 578.4 3 Years installations Maintain records of training of radiographers and 34.79(a)&(b) radiographers' assistants in accordance with § 74 5 370 3 Years 34.43(f)

Retain records of current operating and emergency license 34.81 74 0.08 5.92 procedures specified in § 34.45 termination Maintain exposure records for direct reading 34.83(a) 74 122.5 9065 3 Years dosimeters 34.83(b) Maintain records for alarm ratemeter calibrations 74 2.5 185 3 Years Maintain records for reports from personnel dosimeter processor & for estimates of exposures 34.83(c)&(d) 74 3 222 3 Years resulting from off- scale or lost or damaged dosimeters Maintain record of last survey of each radiographic 34.85 exposure device on each day used prior to placing 74 120 8880 3 Years device in storage 34.87 Maintain each record in a legible form 74 0 0 life of program Maintain copies of records sufficient to demonstrate license 34.89(a)&(b) 74 5 370 compliance at field stations and temporary job sites termination Note: 34.87 requires the licensee to maintain all records in a legible form (including electronic storage media). This requirement does not impose additional burden beyond the burden included in other recordkeeping requirements.

Appendix A, Part ICO written by laws and policies 1 10 10 life of program I, item 6 Appendix A, Part ICO written procedures describing its certification 1 70 70 life of program I, item 9 program Appendix A, Part ICO procedures to ensure due process with respect 1 10 10 life of program I, item 10 to administration of certification program Appendix A, Part ICO procedures for proctoring examinations 1 10 10 life of program I, item 11 ICO description of procedures for choosing Appendix A, Part examination sites and for providing an appropriate 1 10 10 life of program I, item 13 examination environment CP required to provide documentation demonstrating Appendix A, Part that radiography applicants have received training 1 38 38 life of program II, item 2 and are capable of independently working as a radiographer Appendix A, Part CP includes procedures to ensure that all 1 10 10 life of program II, item 3 examination questions are protected from disclosure Appendix A, Part CP includes procedures for denying an application, 1 10 10 life of program II, item 4 revoking, suspending, and reinstating a certificate CP includes procedures for renewing certifications; Appendix A, Part renewals without examination require evidence of 1 10 10 life of program II, item 6 recent full-time employment and annual refresher training

CP provides timely response to inquiries from Appendix A, Part members of the public about an individual's 1 50 50 life of program II, item 7 certification status Written examinations have test items drawn from a Appendix A, Part question bank containing psychometrically valid 1 120 120 life of program III, item 3 questions based on the material in § 34.43(g)

TOTAL 74 29.611.76 ANNUAL RECORDKEEPING BURDEN OF 10 CFR PART 34 FOR AGREEMENT STATE LICENSEES Record Number of Burden Hrs Per Section Description Total Hr/Yr Retention Recordkeepers Recordkeeper Period Radiation survey instrument calibration & records 34.25(b)&(c) thereof Included in 34.65 34.27(c)(1)&(2) Sealed source leak testing & records thereof Included in 34.67 34.27(e) S tube leak testing & records thereof Included in 34.67 34.29(a)&(b) Sealed source inventories & records thereof Included in 34.69 34.31(a)&(b)(1)&

(2)&(c) Licensees program for inspection and maintenance Included in 34.73 Tests of controls and alarms at permanent 34.33(b) radiographic installations and records thereof Included in 34.75 Completion of the training and testing requirements license 34.42(a) of § 34.43(a) 533 4 2132 termination RSO establishes, oversees, and regularly reviews all operating, emergency, and ALARA procedures as license 34.42(c)(1) required by 10 CFR part 20 of this chapter 533 8 4264 termination RSO oversees and approves all phases of the license 34.42(c)(2) training program for radiographic personnel 533 16 8528 termination RSO ensures that required radiation surveys and leak tests are performed and documented in license 34.42(c)(3) accordance with 533 8 4264 termination RSO ensures that personnel monitoring devices are calibrated and used properly, that records are kept of the monitoring results, and that timely notifications license 34.42(c)(4) are made as required by § 20.2203 of this chapter 533 16 8528 termination RSO ensures that operations are conducted safely license 34.42(c)(5) and assumes control for instituting corrective actions 533 8 4264 termination Records of training, examinations, refresher safety training, and semiannual inspections of job Included in 34.79 34.43(f) performance Program for routine operations and emergencies for employees to follow in performing safety functions &

34.45(a)&(b) copies of Included in 34.81 Read and record exposure on direct reading 34.47(b) dosimeters; maintain records Included in 34.83(a)

Periodic check of pocket dosimeters or electronic dosimeters for correct response to radiation; 34.47(c) maintain records Included in 34.83(a)

Determination of exposure if an individual's pocket 34.47(d) dosimeter goes off-scale Included in 34.83(d)

Requirements if a personnel dosimeter is lost or 34.47(e) damaged Included in 34.83(d)

Requirement to maintain reports received from 34.47(f) personnel dosimeter processors Included in 34.83(c) 34.47(g)(4) Calibrate alarm ratemeters; maintain records Included in 34.83(b)

Surveys of radiographic exposure device & records 34.49(c)&(d) thereof Included in 34.85 Licensee to have a copy of the license, license conditions, documents incorporated by reference, license 34.61 and all amendments 533 0.16 85.28 termination Maintain records showing receipts and transfers of 34.63 sealed sources and devices using DU shielding 533 1.6 852.8 3 Years Maintain records of calibrations of radiation survey 34.65 instruments 533 1.6 852.8 3 Years 34.67 Maintain records of leak test results 533 1.2 639.6 3 Years Maintain records of quarterly inventories of sealed sources and devices containing DU shielding &

34.69(a)&(b) include specific 533 2 1066 3 Years Maintain utilization logs for each sealed radioactive 34.71(a)&(b) source 533 36 19188 3 Years Maintain records of equipment problems and 34.73(a)&(b) maintenance 533 27 14391 3 Years Maintain records of alarm system and entrance control device tests at permanent radiographic 34.75 installations 86 48.2 4164.5 3 Years Maintain records of training of radiographers and radiographers' assistants in accordance with § 34.79(a)&(b) 34.43(f) 533 5 2665 3 Years Retain records of current operating and emergency license 34.81 procedures specified in § 34.45 533 0.08 42.64 termination Maintain exposure records for direct reading 34.83(a) dosimeters 533 122.5 65292.5 3 Years 34.83(b) Maintain records for alarm ratemeter calibrations 533 2.5 1332.5 3 Years Maintain records for reports from personnel dosimeter processor & for estimates of exposures 34.83(c)&(d) resulting from off- 533 3.2 1705.6 3 Years Maintain record of last survey of each radiographic exposure device on each day used prior to placing 34.85 device 533 120 63960 3 Years 34.87 Maintain each record in a legible form 533 0 0 life of program Maintain copies of records sufficient to demonstrate license 34.89(a)&(b) compliance at field stations and temporary job sites 533 5.4 2878 termination Note: 34.87 requires the licensee to maintain all records in a legible form (including electronic storage media). This requirement does not impose additional burden beyond the burden included in other recordkeeping requirements CP required to provide documentation demonstrating that radiography applicants have received training Appendix A, Part and are capable of independently working as a II, item 2 radiographer 9 14 126 life of program Appendix A, Part CP includes procedures to ensure that all II, item 3 examination questions are protected from disclosure 9 10 90 life of program Appendix A, Part CP includes procedures for denying an application, II, item 4 revoking, suspending, and reinstating a certificate 9 10 90 life of program CP includes procedures for renewing certifications; renewals without examination require evidence of Appendix A, Part recent full-time employment and annual refresher II, item 6 training 9 10 90 life of program

CP provides timely response to inquiries from Appendix A, Part members of the public about an individual's II, item 7 certification status 9 25 225 life of program Written examinations have test items drawn from a Appendix A, Part question bank containing psychometrically valid III, item 3 questions based on the material in § 34.43(g) 1 120 120 life of program TOTAL 533 211837.22

ANNUAL THIRD PARTY DISCLOSURE REQUIREMENTS OF 10 CFR PART 34 FOR NRC LICENSEES Number of Responses Total Burden Section Description Total Burden hr/yr Cost at $278/hr Respondents Per Responses/yr Hrs/response 34.20(b)(1) Labels on radiographic exposure devices 74 1 74 0.4 29.6 $8,229 Requires durable, legible, and clearly visible label on source 34.35(a) 74 1 74 0.8 59.2 $16,458 changer or container that indicates whom to notify Requires appropriate packaging, labeling, and shipping 34.35(b) 74 1 74 36 2,664.00 $740,592 papers for transport of licensed material Requires the licensee to provide radiographers and assistants with copies of pertinent sections of NRC and DOT 34.43(b)(1)&(c)(1) 74 1 74 2.5 185 $51,430 regulations, the NRC license, and operating and emergency procedures TOTAL 74 296 2,937.80 $816,708 ANNUAL THIRD PARTY DISCLOSURE BURDEN OF 10 CFR PART 34 FOR AGREEMENT STATE LICENSEES Number of Responses Per Burden Section Total Responses/yr Total Burden hr/yr Cost at $278/hr Respondents Respondent Hrs/response 34.20(b)(1) Labels on radiographic exposure devices 533 1 533 0.4 213.2 $59,270 Requires durable, legible, and clearly visible label on source 34.35(a) 533 1 533 0.8 426.4 $118,539 changer or container that Requires appropriate packaging, labeling, and shipping 34.35(b) 533 1 533 36 19,188.00 $5,334,264 papers for transport of licensed Requires the licensee to provide radiographers and 34.43(b)(1)&(c)(1) 533 1 533 2.5 1,332.50 $370,435 assistants with copies of pertinent sections of NRC and DOT TOTAL 533 2,132.00 21,160.10 $5,882,508

TOTAL BURDEN FOR 10 CFR 34 Agreement State NRC Licensees TOTAL Cost @$278/hr Licensees Reporting 635.50 4,578.00 5,213.50 $1,449,353.00 Recordkeeping 29,611.76 211,837.22 241,448.98 $67,122,816.44 Third-Party Disclosure 2,937.80 21,160.10 24,097.90 $6,699,216.20 TOTAL 33,185.06 237,575.32 270,760.38 $75,271,385.64