ML20041G544

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Request for OMB Review & Supporting Statement Re Amend to 10CFR20,stds for Radiation Protection.Estimated Respondent Burden Is 5,500-h
ML20041G544
Person / Time
Issue date: 03/09/1982
From: Donoghue D, Scott R
NRC OFFICE OF ADMINISTRATION (ADM)
To:
Shared Package
ML20041G541 List:
References
NUDOCS 8203220501
Download: ML20041G544 (4)


Text

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REQUEST FOR OMB REVIEW (Uncer the Paperwork Reduction Act and Executive Orcer 12291) important - Read instructions (SF-83 A) before completing inis Office of inf ormation and Regu ator> Aff airs f orrr. Sub, ut tne recuored number 01ccpses of SF E3.togetner Ottnce of Management and Buopet with tne material for which review is recuested to Wasningto.. D.C. 20503 1 Department / Agency anc Bureau / Office orig:nating recuest 3 Name(s) and teleonone number (s) of persontst who car. Dest answer Questions regarding recuest U.S. Nuclear Regulatory Comission Pat Woollev (301) 492-8137 2 6-d;g 1 AgencyiBureau number storstpart of 11-0;gst Treasury 4.3-0sgit funct:0nal cooe hastpart of 1101 git Treasury Account Account No )

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i T itse o' i~ormation Conection or hulemaning l

C 15 ints a tutemaning suomission uncer Section 3504thi of P.L 96 5111(Check one) 1M No ISection 3507 submission) 10 CFR 20 Amendment (20,311(h)(2))

2 C Yes NDAM. Expected cate of puotication-t A as anyinformation colrection Ireporting or recoroneepingt 3 C ves. fina' ruie Expecteo cate of oaosicatson mvolved ? (Check one)

Effective cate iG Yes and proposal is attacnec for review D. At what enase of rulemaningis this submission made?

II 2 C Yes but c'coosat is nct attached - snic tc quest on O 3 C r.o - snio to ouestion D 1 UNot applicacie B Are the responcents pnmaniy educationalagencies or 2: Masor rute.at NORM stage insrirutions oris the purpose related to Federaleducation 3 D Major Final rule for wnich no NAAM was published programs '

4 C Major Final rule af ter publication of NAAM O yes U No 5 O Nonmaior rule.at NORM stage 6 Nonmajor rule. at Final stage COMPLETE SHADED PORTION IF INFORM ATION COLLECTION PftOPOS ALis ATTACHED 7 Ourrent for former! OVB Numbe' E Recuested l 12 Agency report form number (s)

Exo: ration Date 31500-0014 N/A Expiration Date

13. Are respondents only Feceral agencies?

_12/31/82 12/31/R2 O Yes E No

9. Is proposed intert iatier coisection listed in 14 ype of reauest (Check onel the mformation cohection bucget?

yYes No l 1 O prei mina'y plan 1 C Wili tnis propose 3 inf ormation cotiectior' 2 nes (not crevioustyaccrovec o ezo.re:r more than t mcnt.~s cause tne agency to exceec its information a gor collection budget allowance? Ilt yes. attach O Yes U No 3Q revis.on amenament re: vest from agency heac I 4: extension lad.ustment to buroen only)

11. Number of report forms submittea for approvat 5 C extension Ino chanpe)

N/A 6 0 re state'ne't 'eroee *'f"'" f mon51 15 l16 Classification of Change in Burden (explarn en supporting statement)

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a. in inventory 21.915 109,614 iS r s'r' c' "m c Esi, w.cn - e-
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PDR ORG EUSOMB For Use Beginning 4 /1/81 PDR

17 ADstrcct-NICS and Us:s (50 woras orI:ss) j 10 CFR 20.311 requires licensees to provide information on existing shipping documents for low leval waste shipments.

16 R l:ted report formisi (give OMB numoer(s). lRCNIsl.

20. Catalog of Feceral Domestic Assistance Program Number int:rnal agency report form numDer(s) or symbol (s))

N/A NRC-4r 3150-0005 NRC-5 3150-0006 C Yes Q No l21. smali eusiness or organization 19 Type of affected public (Check as many as apply) 122. Type of activity of affected public-indicate 3-digit Standard 15 indiviavals or housenoids to, ' check

'f' Multiple 00 * $.. Ali U "*'

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w or 2 O state orlocalgovernments 3 C tarms a C businesses or otherinstitutions (except termsi 4

8._ 1 23 Britt descrtation of affected Duclic le c.." retail grocery stores.' " State education agencies: "housenoics in 50 largest SVSa s n NRC licensees 24 Durpose ' Check as many as acciy It more than one. unarcate

26. Collection metnc ? Check ac many as a
ch
rscomunant Oy an asterism 1 gmail self-acministerec 1 C acclication for senefits 2C other self-acmintstered 2 C program evaluation i

3C teleonone interview 3 C general purpose statistics 4 C personalinterview I

4g regulatory or compliance SC recordkeeping reauirement 5 C program planning or management Required retention period:

years 6 C research 6 0 other-describe-

),

25 Frecuency of Use

27. Collection agent (Check one, t C Nonrecurring 1 p requesting Cepartment/ Agency Recurring (Check as many as aDoly) 2 O other Federa! Decartment/ Agency 2 gen occasion 6C semiannually 3 C private contractor 3 C weekly 7C annually 4 C recordkeeping recuirement 4 C monthly 80 biennially S C other-describe:

5 C Quarterly 9C other-describe:

25 Autnority for agency for information collection or

30. D0 you promise confidentiality ?

ruismaning-indicate statute regulation, judicial oecree.

(if yes. explain Dasis forplecge stc. '

in supporting statement.)

C Yes b No ER Act of 1974 E M of 1954 ici.willtne pr p sed int rmation coitection create a new or become part of an extsting Privacy Act system of records 0 29 Rispondent's obligation to repiy (Check as many as apply)

(If yes. attach Feaeral Register notice or proposed craft of 1 C voluntary notice.)

C Yes M No

M required to obtain or retain benefit
32. Cost to Federal Government of 3 C mandatory-cite statute. not CFR (attaen copy of information collection or rulemaking S 12.800 statutory authority)

COMPLETE ITEMS 33 THRU 35 ONLY IF RULEMAKING SUBMISSION 33 Compisance costs to the oublic 34 is there a regulatory impact

' 35. Is enere a statutory er judicial analysis attached?

deadline affecting issuance' I

C Yes C No C Yes. Enter cate C No CERTIFIC ATION SY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certify tnat trie information collection or rulemaking summittec ter review es necessary for the proper performance of the agency s functions.tnat the proposat represents tne mmimum ouDisc Durden and Feceral c0st consistent witn need. and is consistent with aposicaoie OMB and agency policy 12irectives Signature anc titie of.

LoostoviNG Policy oFFIClat rosa aGENCv DATE suBwTTING NF6CIAL DATE

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3. f. k

}Q}y Danie J. Donoghue R. Stephen Scott i

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l SUPPORTING STATEMENT FOR 10 CFR 20 Amendments incorporated in 10 CFR 61 Rulemaking Justification 10 CFR Part 20 is being amended to require licensees to include specified information on existing shipping documents for low level waste shipments and to forward an advance copy to the intended receiver.

If the shipment is not received when expected, the intended receiver notifies the shipper who must conduct an investigation and report the results to the NRC. There are about 9,000 NRC licensees, approximately 2,250 of which might make waste shipments at some time.

The only information submitted to the NRC directly-will-be reports of licensee's investigation of late or missing shipments (see 520.311(h)(2)).

This informa-tion goes directly to the nearest Regional Inspection and Enforcement Office of NRC.

The manifest system proposed in Part 20 will address the need for more complete information for accoLntability of waste shipments. The EPA has recently instituted a. manifest tracking system for hazardous wastes. The General Accounting Office (GA0) noted the need for improvements in its March 30, 1980 report entitled "The Problem of Disposing of Nuclear Low-Level Waste: Where Do We Go From Here?". The GA0 recommeaded that the Commission " Establish a method to track waste from the point of generation to the point of disposal."

Use of manifests is provided in 520.311 which provides a. tracking system that is inspectable.

Description of Survey Plan Covers all licensing requirements for level disposal of radioactive waste in regard to shipment of low level ~ waste. There are approximately 9,000 licensees affected.

Tabulation and Publication Plans Not applicable.

Time Schedule for Data Collection and Publication Data will not be published. NRC staff will immediately review reports for possible safety significance.

Consultations Outside the Agency This amendment has been subject of rulemaking. This rulemaking was coordinated with Dr.

w. Alexander Williams of the Office of Federal Activities of the U. S. Environmental Protection Agency. EPA endorses NRC's promulgation of this rulemaking. This rulemaking is not duplicative of any EPA rulemaking.

4 Estimate of Respondent Burden Although the specified information required on the manifest document is sent to the disposal site operator and not to NRC, cn estimate of the additional time required by individual licensees to,irovide such information is included here for completeness.

If the previous experiences hold, there would be about 4,500 shipments originated each year by NRC licensees. Acquiring and recording the information will require an estimate of one staff-hour per shipment. The total estimated annual burden'for the public to comply with this requirement is 4,500 staff-hours.

If 25 of these licensees investigate late or missing shipments each year, as assumed above, and each spends 5 staff-days per investigation, the total effort expended by the public would amount to about 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year. The total annual burden is 5,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />.

The NRC rulemaking is at the proposed stage. No burden will be imposed until the rule is finalized and an effective dat.c for compliance is established. At such time as the rule is finalized, the necessary action will be initiated to incorporate the burden into the NRC inventory.

Sensitive Questions Noite Estimate of Cost to Federal Government There are no data on which to base the cost:: directly, but the costs can be t

inferred from the following assumptions. The NRC has approximately 9,000 licensees, about one-fourth of which would be expected to make a waste shipment at some time.

If, on the average, each licensee makes 2 shipments per year and if one-half of one percent of all shipments are late or missing, this would result in about 25 investigations per year being reported.

If half of these warrant followup investigation by NRC, with each followup requiring 3 staff-days, somewhat less than 40 staff-days per year would be required, for a total of $12,800 annually.