ML20005F545

Request for OMB Review & Supporting Statement Re 10CFR71, Packaging & Transportation of Radioactive Matl

ML20005F545
Person / Time
Issue date:	01/09/1990
From:	Amenta J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
OMB-3150-0008, OMB-3150-8, NUDOCS 9001160377
Download: ML20005F545 (11)

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Request for OMB ReviewM r enwb I 5""*'" " a s g.

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Read instructions before compieting torm. Do not use the same SF 83 Send three copies of thisWm. the material to be reviewed, and for to reovest both an Erecutive Oroer 12291 review and approval unoer paperwor6-three Copics of the supporting statement, to' the ; aDerwo'lr Reduction Act Ar'swer all cuestions in Part 1. If this recuest is for review unoer E.O.

Office of Information and Reguistory Aff airs 12291, complete Part il and sign the repatatory ce'tification, if this Office of fAanagernent and Buoret reovest is tot approval under the Paperwork Recuction Act and 5 CFR Attention: Docket Library, Room 3201 13?O. skip Part il, complete Part til and sign the paperwork certification.

Washington, DC 20503 PART 1.-Complete This Part for All Requests.

' Depa'tment/ agency anc bureau /ottice ongmmmt request

2. Agency coot U. S. Nuclear Regulatory Comission 3 1 5 0 I

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- 3. H:me ci person wno car, Dest ans.$ et ouestions reparoing this recuss' leitpnone numpe r C. E. MaCDonald t 301 )492-3382

4. hto ot informauon conecten or ruiemakmg Packaging and Transportation of Radioactive Material 10 CFR Part 71

b. v:qat autnor N tot wrorrnation conoection or ru.e rcite Unite 0 btstes (coe. Fatmc cas, or becutwe Oroe')

42 2201(o)

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6. Attacte0 puMc (Check att that app))

6 3 Ftoeralagencies of employees 1

Ino+viauats or househoto.

3 O Farms 6 3 hon erhtinstitutions 3 Businesses or other toe prof 1 7 3 Small busmesses or otrancations 2 O State or totairovernments 4

PART ll.-Complete This Part Only if the Request is for OMB Review Undet Executive Order 12291

7. ReFulation Identifier Number (RIN)

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_ _ _. or. None assigned C Dyve of suom,ss,on (cnets one on eacn catego'y) lype or revrew requestec Classtitestoon Stage of stevelopment 1 D Standard

1. O uaior i O Proposedororatt 2 O pendme 2 [ Nonmag 2 C finatorentenmtina;.w:tnenorpropose 3 0 cmergency 3 C Final o'intenm nnai. without pnoe proposai 4 0 statutoryoriuoiciaice.oiine

9. CF R secten attectea CVR

10. oces this refulation contain rtp3rtmg or recordheepmg recutrements that r(Quire OMB approva6 unaer the Paperwork Reduction Act enc 5 CrR 1320?

. O Yes C No II. If a major ruie,is there a regulatory impact anaivsis attached?

1 O ves 2 O No 3 0 Yes 4 C No if"No." did oMB waive the anaysts)

Certification for Regulatory Submissions

- in submttling this request for oMB review. the authorizeo regulatory contact and the program official certify that the requirements of t.o.12291 and any app! cable policy directives have been comphed with.

i Date hign;ture of program officts)

S, nature of autnorged regulatory contact 9001160377 900109 oate PDR ORG EUSOMB PDC a

12. t0MB use enry)

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Stoneers f orm 83 Utov. 9 83)

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g3 gog Prescrited by OMS NSN 754&o0634 4034 a

,,g 5 cFR 1320 and LO.12291

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PART IM.-f r 'r; This Part Only if the Roguest is for Approval of G Collection F'

of leformation Under the Paperwork Reduction Act end 5 CFR 1320.

13. At,etract-oescribe needs, uses and eMocted pubhc 16 50 words or less

" Transportation Safety, Radioactive Materials"

10. CFR Part 71 establishes requirements for packaging, preparation for shipment, and trans -

portation of licensed material, and prescribes procedures, standards, and requirements for approval by NRC of packaging and shipping procedures for fissile material and quantities of licensed material in excess of type A ayantities.

14, Type of mtormation conection (check onry one)

' Information collectrons not containedin rules 1 C Recuiar submission 2 C tmergency suom>$sion esertitwar,on attacheoi Information collections containee in rules 3 b Existmg reguistion(nochangeproposed) 6 Imal or intenmimal without poor NPRM

7. Enter cate of expected or actual Federal I

4 C Notice of proposed rulemaiorig(NPRM)

A C Regular sobrnisoon Reg: ster pubbcation at this stage of ruiemaking 5 C Final. NPRM was previousiy puohshec B C [mergency subm:ssion(ce fthcotion attached)

(month, car, year):

11 Type of review reovested (checa enfy one) 1 C Newcohection 4 C Re.nstatement r:f a previously approvec coHectioit fo' which aporoval

"*' "D"'O 2 C RevSion of a currently approved collection 3 $ Extension of the expiration cate of a current!y approved coHection E C Erstmg cei'ection m use without an OMB control number without any chance m tne s W, stance or m the metnoc of coilaction

.1 Ag;ncy rep 9rt form nurt bens)(incluae stanc.ted/cottones form nurnoer;s);

22. Pepo:,e of mformation conectio't(checA as many as apply)

Not Applicable 1 E """"' " ' ' **d

2L Aogram evatuation

7. Annual reportmg or cisclosure tauraen 3 C General purpose statistics 4 b] Regulatoryor compnance 1 Number of responcents.

? Numoer of responses per responcent.

5 C Dregram plannmo or management 3 Total annual responses (hne 1 times trne 2)

'i C Researen 07*44 7 [ Audit 4 Hours per resporse 3 Tntal hours r6ne J t"res hne C l

66 db2 g

.9. Annues recorckecome oureen j 23. f recuency of recoromecomg or iepurting tchecar all that appry) 350

y n,co, ate,oi,.g

IJumber of record *eepers 10 Reportmg 2 Annuai hours per recoro>eeper.

b 300 2 [ en occas,on 2 Total reco ekeeping ncurs (tme J tmes sine 2) a 4 R;cordkeeping retenten reneo

[Qg _+ 3 'e rs t 3 C Weendy

7. Total annua 4 Durcers a [ Montnty 1 Reovested (hne i 7 5 olus hne 183).

IS.t?

5 C Qaarter:v 72,752 e

s mi.annuany 2 in current OMB insentory 0

C annua,iy

' 3 oifference tune 1 ! css one a isolanation of dotterence l

8 Brenn'a;>y

' 4 Program change 9 C Other(vesence):

i 5 Adiustment 20 current (most recent)OMB contro' numoer or comment numcer

24. Resconcents ool.gationto compey(check ti,estrongestochgation thatappnes)

-3150-0008 1 C voivntary Lt. R:questec etoiration cate

] PeQuired to enta

n or retain a benefit 3 years from approval date

{ vansatory

15. Are therespondents onman!y eccat'enal agencies or inst:tutions or is the o* na'y pu' case et the cohection re.ated to Federal ecucation programs? C Yes $ No 1

6. Do;s the agency use sampang to seiect responoents or ooes tne egency recommeno or presence the use ut $ampiing or statistical analysis

. C Yes $ No by responcents?

J 7. Reg cry autnonty for or tion conection CFR

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, cr.Ciner (spem)

Japerwork Certification o seemitting tNs request for OMB epo*ovat tre egency heac, tre tenior cif et er :n authon:ec representatwe. certifies that the reavirements of 5 CFR 1320. the i

'nvacy Act, statistical stancarcs or directwes. and any other aDoncaole information poi ev otrectr.es have t'een comphed witn.

Sgnature of program otticial Date

~Date Ig39ture et ?h'ency head.19e senior cScia, or an authori2eo repfe5enta?'ve 1 oyce.

Amenta, Designated Senior Offic

/ f1 [9 0 for Information Resources Management 9m h

" cro a 1994 0 - 453-776 e

i SUPPORTING STATEMENT FCR 10 CFR PART 71 PACKAGING AhD TRAhSPORTATION OF RADIOACTIVE MATERIAL L

Justification L

Need for and Agency Use of the Information Collection hRC regulations in 10 LFh Fart il esteblish rec;uirements for packaging, preparation for shipment, and transportation of licenseo material, and

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prescribe procedures, standards, ano requirements for approval by NRC of packaging and shipping procedures for fissile material ano for quantities of licenseo material in excess of Type A quantities.

L Secticn 71.5 requires that licensees transporting licenseo material outside the confines of their plant or other place of use, or celisering licensed material to a carrier for transport, including cases when Department of Transportation (00T) regulations are not applicable, conform to the stcndards ano requirements of DOT specified in Section 71.5(c), including marking and lebeling of packages. Licensees are also requireo tc file with the Commission any requests for modifications, waivers, or excmptions from the requirements of DOT regulations apprcpriate to the mode of transport.

Section 71.6a(b) requires that an appifcant er licensee notify the Comission of information which the licensee recognizes as hoving significant implications for the public health and safety or the ecm on defense end security.

This requirement applies only to intorn.aticn which is not ecvtred by other reporting or updating requirements. The information must be provided within two working days.

This requirement is necessary because there may be some circumstances in which a iicensee pessesses some information which could be important to the prctection of public health and safety or the common defense and security but which is not otherwise required to be reported. The codification of this full aisclosure requirement should not result in significant additional buroens on applicants or licensees.

No formal program is required. What is expected is that licensees will maintain a professional attituce towaro safety and that if some potential safety information is ioentified by the licensee, the information will be provided freely and promptly to the ARC so that the agency can evaluate it and act on it if necessary.

Section 71.7 specifies that licensees may submit an application for an I

exemption from the requirements of the regulations contained in 10 CFR Part 71.

i Upon receipt cf the application, the NRC may grant an exemption from any particular part of the reaulatien if it is cetermined that the exemption is authorized by law and will not endanger life or property or the common cefense and security.

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2-Section 71.12(c)(3) requires that prior to a licensee's first use of a package under the generai 'icense established by this section, the licensee must submit to the hRC the licensee's nan,e and license number, and the package identifica-tion r.utber specified in the package approval. The information submitted pur-suant to this requirement icentifies to the NRC licensing staff the licensees who are using peckages approved for use by another licensee. The licensee also comits to certply with the terms and ccoditions of the specific apprcval.

Unless users are required to register prior to first use of a package, it would not be possible to notify users of changes to the packace desi ns which could 5

affect safety.

Knowledge of the identity of users is also essential to the in-spection program. This is a coe-time requirement.

Persons need only report if they plan to make use of a particular pckage design.

Sections 71.31, 71.33, 71.35. and 71.37 specify the information required in a license apphcation under Part 71 for each proposed packaging design and rethod of transport.

Section 71.31 sets fcrth the gereral requirements, including the tutmission cf infern.ation specified in sections 71.33 through 71.37 cno, in the case et fissile material, an identification of the proposed fissile class.

Section 71.33 specifies requirements for package dcscription. Section 71.35 specifies requiren.ents for package evaluation.

Section 71.37 specifies requirements for identification and descriptien ct the quality assurance preg ram.

The NRC Transportation Licensing staif will review the inforniation submittea with the application to determine vtether an applicant's package design, description, evaluation, cuality tusurance program, and other prcccoures cr.d programs described in the applicaticn are acequate tc treet all specified requirements.

Ecction 71.39 specifies that the Ccmission may at any time require further inicrration in order to etable it to determine whether a license, certificate of ccupliance, or other upprosci should be grantec, denico, acdified, susperded, or revoked.

Such additicnal it.fcreation is scmetimes neeccd to clarify in1ormation submitted in the application, er to rectify ceficiencies in proposed er existing programs fcr protecticn cf the public health ano safety and the ccianon defense ard security.

The accitional information submitted is reviewed by the NRC Transportation Licensirs staff to assess the acequacy of the applicant's design, procedures, ano other measures for protection ci the public health aro safety and the common defense ano security and to meet all specified requirements. The hkC review end the findings cerived therefron forn the Lctis for NRC decisions concerning the issuance, mooification, or revoca-tion of licenses, certificates of compliance, or other approvals.

Section 71.85(c) requires that the licensee mark the packaging with its mocei number, gross weight, and a package identification number assigned by NRC. This inioimaticn is necessary to icentify the packaging and provide assurance to others that the packaging k.eets the recuirements of 10 CFR Fart 71.

Section 71.87(e) and (f) require that the licensee have written preceoures "for setting any pressure relief devices en the package and for loading anc cicsing the package. These written precedures are neces: cry to provide assurance that the packa5e ano any pressure relief device provide the proper

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protection to the licensed material during both ncrmal and accident conditions of transport.

Section 71.89 requires that prior to delivery of a package to a carrier for transport, the licensee shall assure that any special instructions needed to i

safely cren the package are sent to or have been made available to the censignee.

Section 71.91 requires the licensee to maintain records of each shipment of licensed material not exempt under Sectich 71.1C fcr two years and to main-tain quality assurance records for the life of the packaging. The licensee must also maintain records of the determinations required by Section 71.65, of nionitoring, inspection, and auditing of work performance during design, fabri-I caticn, esserrbly, testing, nodification, maintenance, eno repair of the pack-aging. These records are requireu to determine whettur the licensee's shipping activities are conducted in accordance with the authorization in the license.

i tection 71.93(c) requires that the licensee notify MRC at least 45 cays prior to fabricaticn of a package to be useo for the shiprrent of licenseo material having a decay heat load in excess of 5 W cr with a maximum normal operating pressure in excess of 103 kilcpascal guage.

This inforniaticn is needed to give hRC inspectors the oppcrtunity tc verify indererder.tly that a package (cask) for the shipment of hazardcus quantities of radioactive material (spent nuclear fuel) is constructed in accordance with the apprcved package design and quality assurance program.

Certain vital parts of casks are covered up by other ccmpcnents during fabrication ano are not inspectable after the conipletien of fabrication.

Section 71.95 requires that licensees report to the NRC within 30 cays -1y instance in which there is a significant reduction in the effectiveness of any authori:ed packaging curing use, and details of any cefect with safety signi-ficance in the packaging after first use, with the means employed to repair the oefects and prevent their tecurrence.

This recuirement is needed to provice feectack to NRC ccncerning the odecuacy of approved packages and package appro-val technio9s.

This is a one-time recuirement.

Only those persons who note a substtntial reduction in the effectiveness of an authorized package during use, or a defect with safety significance, are required to report under this previ-sien, an.ounting to only one or tm reports a year. The reports are an important part of the program to imprcyc tl.e quality of packaging for licensed raoicactive traterial and the related regulatory review process, and to provide asstrance that any cefective packages will Le ren.oved from use withcut incident..

Section 71.97 requires each licensee to give advance notification to the gover-nor 01 c State or the governor's cesignee for the transport of certain nuclear wastes to, through, or across the boundary of the state.

The notificaticn must be in writirg, raust centain the name, accress, and telephone number of the shipper, carrier, and receiver of the nuclear waste shipment; a oescription of the nuclear waste, the point of origin of the shipment, the seven-day period during which ceparture of the shipment is expected to occur, and the seven-cay period during which a: rival of the shipment at State bounoaries is estimated tc occur; the destination ci the shipment and the seven-ooy period during which arrival of the shipment is estimated to occur, anc a point of contact with a

telephone number for current shipment information. Licensees must also give notice of revisions to schecules anc cf cancellaticns of shipments for which notification was given. Licensees are requireo to retain a copy of the notifi-cations and cancellations as a record for one year.

In nooition, licensees must keep for one year a record of the name of the individual in the Governur's office who was contacted and informed concerning a revision in shipment schedule information.

The records are requireo in order to permit NRC inspectors to determine compliance with the regulations.

Sections 71.101 through 71.137 establish cuality assurance (QA) requirements which apply to all activities affecting the components of packaging which are significant to safety. Sections 71.101 and 71.103 specify licensee responsibi-lity for establishing a QA program.

Pricr to use of any package for shipment of licensed material, the licensee shall file a descriptien cf its QA program with NRC and cbtain its approval.

The licensee must also notify NRC of its intent to use a previously-approved QA program.

Section 71.103 requires licensees to clearly establish and delineate in writing the authority and duties of persons and crgani:aticns performing activities affecting the safety-related functions of structures, systems and components.

Section 71.105 recuires the establishment of a QA program, documented by written proceaures or instructions.

Section 71.107 requires the establishment of written procedures for package design control. Section 71.109 requires licensees to establish measures to assure that adequate quality is required in procurement documents.

It also requires that licensees shall, to the extent necessary, require contractors or subcontractors to provice a OA program consistent with the applicable provisions of Part 71.

Section 71.111 recuires that activities affecting e clity shall be prescribed by dccumented instructions, prcceoures, ur orawing.t.

Section 71.113 requires the establishment of measures to control the issuarce of documents, such as instructions, procedures, and drawings, inclucing changes thereto, which prescribe all activities affecting cuality.

Section 71.115 requires the establishment of measures to assure that purchased material, ecuipment, ano services ccnform to the precurement dccuments, and requires that such cccumentary evidence be available prior to installation cr use of the material ano equipment. The documentary evidence must be retainea by or available to the licensee and must be sufficient to identify the specific requirements met by the purchased material ano equipment.

Section 71.117 requires the establishment of measures to assure identificction ar.o control of materials, parts, and ccmponents, either by number on the item or on records traceable to the item. Section 71.119 requires the establishment of measures to assure that special prcccsses, including welding, heat-treating, and r.ct-oestructive testing, are controlled and accomplished by qualified personnel usine cualified proceoures, in accordance with applicable codes, standaros, specifications, criteria, and other special requirements.

Section 71.121 requires the establishment of a program for inspection of activities affecting quality, including specification of any necessary mandatory hold points in appropriate documents. Section 71.123 requires written procedures for a test l

program to dEmenstrate that the packaging components wW perform L

satisfactorily in service, and requires that the test results be oocumented and evaluated. Section 71.125 requires the establishment of measures to assure the proper centrcl, calibration, ano aojustment of tools, gages, instruments, and other reasuring ano testing devices. Secticn 71.127 requires the establishment of measures to centrol the handling, storage, shipping, cleaning and l

preservation of materials and equipment to be used in packaging in accordance l

1.

with instructions to prevent damage or oeterioration. Section 71.129 requires establishment cf measures to indicate, by the use of raarkings such as stamps, tags, labels, routing cards, or other suitable means, the status of inspections and tests performed on individual items of the packaging. Measures are also required for indicating the cperating status of components of the packaging, such as tagging valves and switches, to prevent inadvertent operation.

Secticn 71.131 requires the establishment of documented procecures 1cr controlling materials, parts, or components which do not conform to requirements in orcer to prevent their inadvertent use or irstellation.

Section 71.133 requires establishment of measures for documenting the identi-fication, cause, and correcticn of significant cenditiens adverse to quality.

Section 71.135 requires that the licensce maintain sufficient recoros to furnish evidence of activities affecting quality, including design recoros, records of use and the results of reviews, inspections, tests, audits, monitoring of work performance, anc raaterials analyses, as well as cicsely relateo data such as qualifications of personnel, procecures, and scuipment.

Reccrds must be identifiable and retrievsble.

Records pertaining tc the fabricaticn cf the package must be retair.eo for the life of the package to which they apply. Recercs pertaining to the use of the package for shipmert of I

radioactive material must be retained fcr 6 periou of C years after the shipment.

Cctsistent with applicable regulatory requirements, the licensee is requireo to establish rcquirements concerning recoro retention, such as duration, lccation, ar.d assigned responsibility. Section 71.137 rce, Lites that a ccmprehensivt system of 0A aucits be carried cut in accorcance with vritten procedures or check lists, and that auuit nsults be documented ano revitked by management.

The purpcse of these requirements is to assure that packages are desist.eo, fabricated, testeo, procured, used, maintaineo, repaired, and modified in accorcance with the Certificate of Compliance (approvci) 1ssuec f cr the package.

Use of Impreved Information Management Technolooy There are no legal obstacles to recucing the burden associated with this intortnation ecliecticn.

Applicants and licensees may use electrcnic information processir4 :.ystems to prepare and submit nquireo information.

Efforts to Avoid Luplicaticn The Information Pequirements Control Automated System (IRCAS) was searchec to determine cuplication.

None was fcund, hhc has edepted a single package approval sys1.em (Certificate of Compliance for each packaSe oesign) and subsequent registration of other users withcut additienal technical data that has minimized duplication by licensees and others (DOE, State licensees).

Effort to use Similar Information There is no similar information available.

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o Effort to Reduce $ mall Euriness Burden l

In previous years the requirc:r,ent for each package user to have a copy of the entire safety analysis repor: for each package has deleted in favor of a requirement only to have a topy of the drawings and operating procedures. This results in a recuced burden for small businesses.

Consequer.ccs cf Less Frccuent Collecticn Applications for new package certifications are submitted only once.

Other infcrmation is collected as dictated by specified events.

Less frequent collection would impair the ability of NRC te evaluate the adequacy of the safety'of package designs for transport.

Circumstances Which Justify Variation from OMB Guidelin_es Contrary to the OMB Guidelines in 5 CFR 1320.6(b). Section 71.6a(b) requires thct licensees submit a notification tc TRC in less than thirty days frem the cate of identifying infcrmation having significant implications for the public health and safety or the common defense and security anc which is not covered by other reporting requirements.

The recuirement to provide notification within two working days following the identification of the information is necessary to ensure that NRC is made aware of the significant safety infor-rnatiot, so as to take prempt effective action to protect the public health and safety.

Contrary to the OMB guidelines in E CFR 13'0.6(b), Section 71.95 requires that 2

licensees report to the NRC within 30 cays any instance in which there is a significant reduction in the effectiveness of any authori:ed packaging curing use, and detaiis of any cefect with safety sign 1Ticance in the packaging aftcr first use, with the means employeo to repair the defects and prevent their recurrence.

This requirement is needed to provide feedback to NRC concerning the adequacy of approved packeyes and package apprcval techniques.

This is a cne-time requirement. Only those persons who note a substantial reduction in the offectiveness of an authorized package during use, or a defect with safety significance, are required to report urder this provisicn, amounting tc enly one or two reports a year. The repcrts are an important pLtt of the program to improve tl quality of packaging for licensec radioactive material and the rehteo regulatory review prccess, and reperting within the prescribed tine is needed tc provido assurance that any defective packages will be removed frcm use without incident.

Sections 71.91 and 71.135 require that quality assurance records br retcinec for the life cf the package to which they apply, which period may exctec the 3-year CMB guideline certair.ed in E CFR 1320.6(f).

These records are needed in order to be able tc den:custrate und permit a determinaticn at any time during the life of the pachage, and a1ter any cccident involving the package, that. the package has been design %, t'abricated, tested, procured, used, maintained, repaired, and modified in 6ccordance with the approved pekage design ano c,uality cssurance prcgram.

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. Ccosultations Outside the Agency There have been no'outside consultations since.the previous clearance.

Assurance of Confidentiality.

- None, except for proprietary information.

S_en_si_tive Ouestions Ec0e Publicttien fcr Statistical Use None Estimate of Compliance Burden Reporting Requirements No. of Licensee Staff Hours Total Annual Section Responses Annually Per Submittal Licensee Burden (Hrs)

- 71.5 2-0.5 1

71.6a(b) 35 1

35 71.7'

- Included in 71.31 71.12 200 1

200 71.31 100 300 30,000 i

71.33

- Included in 71.31

'i

- 71.35

- Included in 71.31

-71.37-

- Included in 71.31 71.39 20 1,000 20,000 71.85(c) 100 0.5 50 71.89 100 0.17 17

. 71.93 1

1 1

71.95 2

24 48 71.97 100 1

100 l

71.101 thru 71.137 100 160 16,000 Total 760 66,452 l

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M V, :,.4 Recorckeepindeouirements No. of Annu61 Mcurs per Recordkeeping Retention Recordkeepers Recordkeeper Hourt Period 71;87

- Included in 71.91 3 yrs 71.91 350 18 6,300 Life of Pkg

+ 3 yrs 71.97

- Included'in 71.91 3 yrs i

71.135

- Included in 71.91 Life of Pkg Total f: umber of Recordkeepers 350 Total Recorakeeping Fours Annually 6,500 TOTALANNUALBURDEN(ERS)

-72,752 Estimated Cost to Public to Respond Section Annual Cost to Respond 71.5

$95 71.6a(b)

$3,325 71.7-

- Included in 71.31 71.12 19.000 71.31 2,850,000 71.33

- Included in 71.31 71.35

--Included in 71.31 71.37

- Included in 71.31 71.39 1,900,000 71.ES(c) 4,750 71.87(e) & (f)

- Included in 71.91 71.89 1,615 71.91 598.500 71.93 95

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Estimated Cost to Public to Respond (cont'd)

>71.95 4,560 a

71.97 9.500 71.101 thru'71.137 1,510,000 t

TOTAL.

$6,911.440 a

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Source of Burden and Cost Data and Vethoo of Estint.tir.c Burden and Cost This data is tesec on info 11,ui censultations by the staf f-with a small number j-of typical licensees and cn the r. umber of submittals to KRC in past years.

Cost to licensees and applicants is cciculated at a rate of 595 per hour, i-Chance in Burden None.-

Estimat'e cf Cost to the Federal Goverrrent Arrual Cost - hkC Staff Review (Professicr.al' effort - 20.800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> G 5%/hr)

= $1.976,000 Annual Cost - Clerical Processing

.(Clorical: effort - 4,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> G S45/hr)

=$

187,200 Annual Aaniinistrative Costs (Postage,har.dling, envelopes,etc.)

=$

1,004 Annual Cost for Recora Holdings (1,4t.0cL. ft x SE09/cu. ft.)

=$ 300,960 Annual _Printire Costs

=$

200 L

Annual Cost for Storage of Foilus in NRC Supply

($2.10per1,000)

=$

4 Annual ADP Cost

=$

30,000 l

Total Ar.r.ual Cost

= 10.495,948 I

i

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