ML20128M267
| ML20128M267 | |
| Person / Time | |
|---|---|
| Issue date: | 03/29/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20127B584 | List:
|
| References | |
| FRN-50FR13797, RULE-PR-19, RULE-PR-39 AB35-1, NUDOCS 8505310616 | |
| Download: ML20128M267 (77) | |
Text
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[7590-01]
NUCLEAR REGULATORY COMMISSION --
A Documents Containing Reporting or Record Keeping Requirements; Office of Management and Budget Review
)h AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of the Office of Management and Budget review of information collection.
SUfHARY: The Nuclear Regulatory Commission has recently submitted to the Office of Management and Budget (0MB) for review the following proposal for the collection of information under the provision; of the Paperwork -
Reduction Act (44 U.S.C. Chapter 35).
- 1. Type of submission, new, revision or extension: liew
- 2. The title of the information collection: Licenses and Radiation Safety Requirements for Well-Logging Operations,10 CFR Part 39
- 3. The form number if applicable: ilot applicable.
- 4. How often the collection is required: On occasion.
- 5. Who will be required or asked to report: NRC licensees in oil and gas industry.
- 6. An estimate of the number of responses: 10 per year.
- 7. An estimate of the total number of hours needed annually to complete the requirement or request: 14,539 hours0.00624 days <br />0.15 hours <br />8.912037e-4 weeks <br />2.050895e-4 months <br /> per year.
- 8. An indication of vihether Section 3504(h), Pub. L.96-511 applies:
Not applicable, s
- 9. Abstract: The lluclear Regulatory Commission is proposing a new 10 CFR Part 39 that would provide a single source of application, recordkeeing, reporting, and radiation safety requirements for the use of licensed radioactive material in well-logging operations by the oil and gas industry.
5053 0616 850530 39 PDR
Sumary Sheet - 10 CFR Part 39: Licenses and Radiation Safety Requirements for Well-Logging Operations NRC is requesting OMB review and approval of information collections contained in a proposed new 10 CFR Part 39. Ten (10) reports are anticipated annually from a universe of 180 respondents with an estimated total annual burden of 14,539 hours0.00624 days <br />0.15 hours <br />8.912037e-4 weeks <br />2.050895e-4 months <br />.
The new 10 CFR Part 39 would provide a single source of application, recordkeeping, reporting, and radiation safety requirements for the use of licensed radioactive material in well-logging operations by the oil and gas industry.
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h.
o 10 CFR PART 39 Page 1-A A 3 r- t-
-SUPPORTING STATEMENT FOR p 10 CFR PART 39 LICENSES AND RADIATION ~ SAFETY REQUIREMENTS FOR WELL-LOGGING OPERATIONS GENERAL DISCUSSIONS
.; The Nuclear Regulatory Commission is proposing a regulation that would specify radiation safety requirements for the use of licensed material in well-logging operations. The proposed regulation would provide: (1) comprehensive and
'consi, stent regulations applicable to well-logging operations by consolidating essential radiation safety requirements in a new Part 39, (2) uniform safety requirements in .NRC and Agreement States regulations, and (3) safety require-
-ments- designed to reduce the likelihood of accidents involving the rupture of radioactive sources in well-logging operations.
ORGANIZATION OF'THE SUPPORTING STATEMENT The supporting statement is divided into the following two parts:
Part 1--Sumary Statement
. A summary statement is included to summarize the burdens of the recordkeeping.
and . reporting requirements. In . ddition, brief descriptions of the require-ments and their section numbers are also included.
Part 2--Detailed Statement A detailed supporting statement on each recordkeeping and~ reporting requirement is included. Section numbers are marked on the right ' upper corner of each
t-d 10 CFR PART 39-Page 2-T page. -Included.in the' detailed statement are: the description of.the require-
+ : ment,~ the justification, the records retention period, the reporting schedule, the.' number ~ of respondents, the burden to respondents, and the burden ~to the
. Federal government. -
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10 CFR PART 39-Page 3
SUMMARY
-STATEMENT FOR 10 CFR PART 39 RECORDKEEPING REQUIREMENTS
. Burden to
< Record Burden to Federal
, Retention- Respondents- Government
'Section Subject Period (hrs /yr) ($/yr) r 39.13 Internal inspection 3' years 360 900-records 39.15 1. Agreements with well 3 years q 190 900
- < owner 1 3 S
- 2. Identification plaque fixed at e > for irretrievable well site
- A sources - life ,.
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39'.31' Labels-on devices and fixed on 120 900-containers- devices or
- _ g containers
< - life
, ,,139.331 Survey instrument cali- 3-years 150 -900- y
'bration records ;
39.35. ;; Sealed-source leak test 3 years' 300 900 irecords ,
f; 39.37i Physical inventory 3 years 300 900 f , records 39.39 Radioactive source utili-- 3 years. .4,500 -900
.zation records _
39.41 Sealed source performance 3 years 30 900. ,
certification 39.43- Inspection and maintenance 3 years 1,080 900 records >
~39.49 Labels on uranium sinker fixed on 3 100 bars . bars-- life 39.61 Training-records '3 years 540 2,700 following '
termination of employ- i ment n.i
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SUMMARY
STATEMENT FOR 10 CFR PART 39 (CONTINUED)'
RECORDKEEPING REQUIREMENTS Burden to Record Burden to Federal Retention Respondents. Government Section- Subject Period (hrs /yr) ($/yr) 39.65 Personnel monitoring until 1,440 1,800 4 records Commission terminates the license 39.67 Radiation survey records 3 years 5,000 1,800 39.73 Documents to be kept at until the 540 2,700 field stations tenmination of well-logging at the station 39.75 Documents to be kept at until the 450s 3,000 temporary jobsites job is completed SUBT0TAL BURDEN (RECORDKEEPING) 14,503 20,200 t
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SUMMARY
STATEMENT FOR-10 CFR PART 39 REPORTING REQUIREMENTS-Burden to Burden to deral Report Respondents Government Section Subject Frequency .(hrs /yr) ($/yr)
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39.11- Filing application on at the time covered under covered under
.~ - Form NRC 313 of applica- 3150-0120 3150-0120 tion.for a well-logging license
.+
- 39.=35 ' Reporting source leaking within 5 days 10 1,200 radioactive material after leak test 1
_39.77- eporting of incidents immediate 26 1,700 and lost sources telephone report and '
follow-up written report TOTAL BURDEN (REPORTING) 36 2,900 ,
4 V GRAND TOTAL BURDEN (RECORDKEEPING AND REPORTING) 14,539 23,100 i
+
Sections 39.11 and 39.13 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.11 AND 39.13 APPLICATION FOR A SPECIFIC LICENSE FOR WELL-LOGGING OPERATIONS REQUIREMENTS Section 39.11 would require an applicant for a specific license _to use licensed material' in well-logging operations to submit Form NRC 313, " Application for Material. License." NRC 313 has been cleared by OMB separately u'nder 3150-0120.
Section 39.13 would require an applicant to submit the following information,
~
which also has been cleared by OMB under 3150-0120:
Paragraph-39.13(b)--Schedule and description of training programs; 39.13(c)--Radiation safety program; 39.13(d)--Internal inspection program; 39.13(e)--0verall organizational structure; 39.13(f)--(1)-Description of procedures for leak testing sealed sources, or -
(2) Manufacturer and model number of a leak test kit.
- Paragraph (d) would require a licensee to keep internal inspection records for 3 years.
Sections 39.11 and.39.13 Page 2
- 1. Justification
- a. Need for tiie Information Collection Reporting: In order to assess the ability of an applicant to protect, public health and safety from radiation hazard, it is necessary that an applicant provide pertinent information, including training, radiation safety programs, and leak test procedures, to NRC for determining whether a specific license should be issued. If the information is not provided, the NRC would not be able to determine if a person who wishes to' possess and use byproduct and source material is qualified by training and experience and has the equip-ment, facilities, and procedures which are adequate to protect health and minimize danger to life or property.
Recordkeeping: The information would document that the licensee conducted annual internal inspections. The internal inspection is needed - to ensure that the safety requirements are followed by the licensees. logging supervisors and logging assistants. The" information 'would also permit NRC inspectors to verify that the licensee conducted annual internal inspections. .
ti. Practical Utility of the Information Collection
' The'information will permit the NRC license reviewers to assess the appiicant's ability to protect health and minimize danger to life or '
c j property. The information will also permit NRC inspectors to verify, after the license is issued, the compliance of the licensee in imple- )
y 4
' Sections 39.11 and 39.13 Page 3 menting the- programs. _ A license 'should be issued within 30 days _ of
. receipt of the application if there are no deficiencies in the appli-
. cation.
- c. - Duplication with Other Collections for Information None.
- d. Consultations Outside .the NRC The draft proposed rule and the draft regulatory analysis were sent to the following groups _for review and comment:
Agreement' States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
~No comments on-information collection were received.
5
- e. Other Supporting Information None.
- 2. - Description of 'the Information' Collection a.- Number and Type of Respondents
' This . information coll'ection requirement applies only to Reporting:
applicants who 1 plan to perform well-logging operations. Based on past_ experience, it is estimated to be about 10 applicants per year.
a Sections 39.11 and 39.13 -
Page 4
- Recordkeeping: The records' will be retained by.180 well-logging
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licensees.
- b. Reasonableness'of the Schedule for Collecting Information Reporting: The information must be submitted to NRC at the time of application for a ' new specific license such that the NRC license .
reviewers would have sufficient information to determine whether a lice's'e n should be issued. An application for a byproduct or source material license is usually reviewed by,the NRC's Materials Licensing
, Branch within 30 days of receipt of the application. If'there are'no-deficiencies in the application, a license is issued. If.there are deficiencies, their resolution is by correspondence with the -appli-cant. The - average time for issuance of a license if there are
. deficiencies is approximately 60-90 days depending on how quickly the~
applicant provides the - information needed to resolve the defi-ciencies.
, Recordkeeping: Records would be kept for 3 years because---the NRC inspection period 'is every 3 years for well-logging licensees.
- c. Method of Collecting the Information The . applicant is the only source ' of the information. There is no-alternative method for collecting the information. The information
y Sections 39.11 and 39.13 Page 5 is collected by requiring an applicant to submit Form NRC 313 with
- . attached supplementary documentation. and to keep internal inspection records, w
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d.- Record Retention Period Record retention ' period would be 3 years after the internal inspection. .
- e. . Reporting Period At-.the time the license application is submitted for a new specific license.
- f. Copies Required to be Submitted The applicant.would be required to send two (2) copies of NRC 313 to the . NRC . regional . office. The regional office would distribute one copy to NRC headquarters,
- g. Format of Information to be Maintained or Submitted
'Use Form . NRC 313 with attached . supplemental documentation for the application..
- 3. . Estimate of Burden
- a. Estimated Hours Required to Respond to the Collection Reporting: The' burden.on the reporting requirement is covered under-3150-0120.
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- 3 e -p C ' , Sections 39.11 and 39.13 1 Page 6.
'Recordieeping: It is estimated . that, on the average, a licensee would need 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per year to keep annual inspection records. The
^
total' burden would be: l
, , . 180 licensees x 2 hrs /yr = 360 hrs/ yr.
- b. Estimated Cost Required to Respond to the Collection
! Estimated cost--360 hrs /yr x $60/hr = $21,600/yr.
/
.c. Source of Burden Data and Method for Estimating the Burden Thd burden data and estimates are based on the experience -of NRC staff.
d.. Reasonableness of Burden Estimates The. burden data and estimates' are based on the ' experience of NRC staff.
- 4. Estimate of the Cost to the Federal Government Reporting: Federal government cost is covered under 3150-0120.
Recordkeeping: The time for NRC inspectors to inspect selected internal inspection records is estimated to be about 15 minutes per licensee.
Assuming' the NRC inspects one-third of well-logging licensees per year, the estimated cost would be:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
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s Section 39.15 .
a
; Page 1 SUPPORTING STATEMENT FOR
. i
! - AGREEMENT WITH WELL OWNER OR OPERATOR n . REQUIREMENTS Paragraph- (a) of this section would' require that a licensee retain a copy of the ~ written agreement for 3 years after the completion of the well-logging operation.
s Paragraph (b) of this section specifies the content of the written agreement.
Subparagraph (b)(4)(iii) would require a permanent identification plaque.
- 1. - Justification
- a. Need for the Information Collection The agreement is needed to indentify the responsibility of each party for the recovery of a sealed source lost in a well and for any neces-sary decontamination. The records are needed to verify that the written agreement exists and is valid. The identification plaque is
. needed to provide a visual warning that a sealed source was abandoned in the well.
- b. - Practical Utility of the'Information Collection
' The information would document that the written agreement was executed. The information would also permit NRC inspectors to verify
- r, that'the licensee has a copy _ of the written agreement. Inspections
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are conducted at least every 3 years, c . _ _ .
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Section 39.15 4 < Page 2
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." Duplication with'0'ther' Collections for-Information c.
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" Y d. l:ConsultationsOutsidetheNRC
- The ' draft propose'd rule and the draft regulatory analysis were sent
- to the_following groups for review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
~
lNo comments'on information collection were received.-
- e. ' Other Supporting Information None. ,
4.
~2 '.- Description'of the Information Collection
'a. LNumbe'r and Type of Respondents .,
The agreements will be retained by 180 well-logging licenseesk f
The respondents for identification plaques will 6e about five per !
x year because, based on past ' 'exp'erience, there are about 'five irretrievable well-logging sources-per year for NRC, licensees. g
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. i b.1 Reasonableness df the Schedule for Collecting-Information' j ,
Acop[ofthewrittenagreementwould'bnkept'bythelicenseebefore
- *-i .. start'ing ~well-logging operations lto assure tha't the responsibilities
/ y J6f th'e. licensee and the well owner or operator are documented. The agreement would be kept.for 3 years because the NRC inspection period. '
is every 3 years for'well-logging licensees.
s c . c. Method of Coll'ecting the'Information The licensee is the'only source of information. A single copy of'the
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. written agreement would be. kept. at the licensee's address as stated -
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on Form NRC 313.
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- d.. Record Retention Period Record retention period for the written ' agreements is ' 3 years after -
the completion of the well-logging operation.
The identification plaque would be fixed at the well site for life.
w-e.. Reporting Period e s
None.-
- f. Copies Required to be Submitted None.
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- g. Format of Information to be Maintained or Submitted
' The format of' information to be maintained is a written agreement executed by the licensee and.the well owner or operator.
.3. -Estimate of Burden a.. Estimated Hours Required to Respond to the Collection It,is estimated that each licensee would need I hour per year for.-
' . copying and -filing the agreement with various well owners' or
- operators. The burden would be:
s 180 licensees x 1 hr/yr = 180 hrs /yr.
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- f It is estimated that a licensee would need 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to mark a plaque.
Assuming five plaques per year, the burden would be:
_;. 5 plaques /yr x 2 hrs / plaque = 10 hrs /hr.
- Total burden: 180 hrs /yr + 10 hrs /yr = 190 hrs /yr.
~
- b. EstimatedCostRequiredtoRespondtotheCollection Estimated cost--190 hrs /yr x $60/hr = $11,400/yr.
- c. Source of Burden Data and Method for Estimating the Burden
~ The burden data and estimates are based on the experience of NRC staff.
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- d. ' Reasonableness of Burden Estimates
[ , The burden data' and estimates are' based on the- experience of NRC 1
staff. . ,
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Estimate of;the Cost to the Federal Government - -
The,;timef for. NRC inspectors to inspect . selected written agreements is
. ,c estimated to:be about 15 minutes per licensee. Assuming the NRC inspects -
- one-third of well-logging licensees. per year, the estimated cost is:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
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.Page 1
' SUPPORTING STATEMENT FOR-10 CFR 39.31
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LABELS ON DEVICES OR CONTAINERS
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REQUIREMENTS Paragraph" (a) of this section would require a licensee to label (1) source, source l holder, or logging tool containing radioactive materials; and (2) stor-
. age or transporti container.
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. 1. - Justification' a '. Need for the Information Collection
~/ 'The labels are needed to warn people that these devices or containers contain radioactive materials.
t 4; j , 'b.- Practical Utility of the Information Collection
- ~- = The labels would warn people that these devices or containers contain radioactive . materials and that persons should notify civil
. authorities' or- the company if they find a labeled device: or container.
' e c. . Duplication with Other Collections for Information-
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None.
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~d. Consultations Outside the NRC The draft proposed rule and the draft regulatory analysis were sent to the following groups for review and comment:
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- Agreement States; s
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' Conference of Radiation Control Program! Directors--Task .
Force'on Well-Logging. , .
- cNo~ comments on'information collection were received.
le . .0ther Supporting Information None.
- 2.- Description of the Information Collection a.. Number and Type of Respondents The respondents will be 180 well-logging licensees.
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- b. . Reasonableness of the Schedule for Collecting Information The labels would be fixed for the life of the device or the container i
for' warning people that these devices or containers contain ' radio-active materials.
- c. Method of Collecting the Information Thc labels would be fixed to (1) sealed source 3, source holders, or logging tools, and.(2) storage or transport containers. ,
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~d. Record Retention Period For the life of these devices or containers.
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Section 39.31
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- e. ; Reporting Period .
- None. -
.f. . Copies Required to be Submitted
.None. .
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- g. Format of'Information to be Maintained or Submitted The content of the labels is specified in the proposed rule.
' 2
- 3. Estimate of Burden
- a. Estimated Hours Required to Respond to the Collection ,
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It is assumed that a licensee needs 3 minutes to attach a label to a
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'dev,1ce'or a container (annualized over 3-year. clearance). Assuming 7
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there are, on the average, 20 devices and 20 containers per licensee,
- .'~ the burden would be
180 licensees x 40 items / licensee x 1/3 yrs x 0.05 hr/ item = 120 hrs /yr.
- b. Estimated Cost Required to Respond to the Collection v , Estimated cost--70 hrs /yr x $60/hr = $4,200/yr.
- c. Source of Burden Data and Method for Estimating the Burden The, burden data and estimates are based on the experience of NRC staff.
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Section 39.31 Page 4' e-
- *-d. - Reasonableness of Burden Estimates The b'urden .dataiand estimates are based on the experience of NRC' staff.
-- 4. Estimate of'the Cost to the Federal Government
- The time for NRC inspectors to inspect selected labels is estimated to be
-about 15 minutes. Assuming the NRC inspects-one-third of the well-logging licensees per year,'the estimated cost is:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr' = $900/yr.
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.Section 39.33(d) ,
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SUPPORTING STATEMENT FOR 10 CFR 39.33(d)
RADIATION SURVEY INSTRUMENTS--RECORDKEEPING REQUIREMENTS j Section 39.33(d) would require the licensee to maintain calibration records for
.a period of 3 years after the date~af calibration of a radiation survey instru--
ment at each field station and temporary job site.
- 1. Justification -
- a. - Need for the Information-Collection This information collection is needed to verify that .a licensee l l
conducts calibration of radiation survey instruments every 6 months.
Calibration, of radiation survey. instruments is necessary .to ensure
., that these instruments function properly.
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- b. Practical Utility of the Information Collection The information would document that the calibrations were performed.
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] ' .lbe information would also permit NRC inspectors to verify Lthat -the
- . licensee is keeping a calibrated' aiid operable radiation survey-V -instrumenti at. each field ~stati'on sand temporary jobsite to make y -
-required radiation surveys. Inspections are conducted at least'everys: -
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-3 years.
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- c. : Duplication'with Other Collections for Information-
-" None.
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Page 2
- d. Consultations Outside the NRC The draft proposed. rule and the draft regulatory analysis were sent to the following groups for review and comment:
. Agreement States; i Conference of Radiation Cor+rol Program Directors--Task Force on Well-Logging.
No comments on information collection were received.
- e. Other Supporting Information None.-
- 2. Description of the Information Collection
- a. Number and Type of Respondents The. records will be retained by 180 well-logging licensees.
- b. Reasonableness of the Schedule for Collecting Information Records would be kept for 3 years after the calibration. A 3-year period would be required because the inspection period -is every 3
' years for well-logging licensees.
L ac . Method of Collecting the Information l'
The licensee is the only source of information. Copies of the record
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4 would be kept at.the field station where the radiation survey ~instru-ment is kept.
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- d. Record Retention Period Record retention period would be 3 years after the .date of cali-
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- e. Reporting Period-None..
- f. . Copies-Required to be Submitted None.
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.g. Format of Information to be Maintained or Submitted' None specified.
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- 3. Estimate of Burden i-a.. Estimated Hours Required to Respond to the Collection i
It is estimated that 'a licensee needs 5 minutes to complete each b calibration record. Assuming, on the average, five survey instru-ments per licensee, total burden would be:
, 180 licensees x 5 instr./ licensee x 2-records / instr.-yr x L
L .08 hr/ record = 150 hrs /yr.
- b. Estimated Cost Required to Respond to the Collection Estimated cost--150 hrs /yr x $60/hr = $9,000/yr.
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- c. . Source of Burden Data and Method for Estimating the Burden
, - The- burden data and . estimates are based on the . experience 'of NRC -
. staff.
f.d. Reasonableness of Burden Estimates
- The. burdenidata and estimates are based on the experience of- NRC
~
staff.
- '4 . fEstimate of the Cost to the Federal Government
' The time for NRC inspectors to inspect the calibration record is estimated
- td be'about-15 minutes per. licensee. Assuming the NRC inspects _one-third J
of'well-logging licensees-per year, the estimated cost is:
'180' licensees x .33/yr x' .25-hr/ licensee x $60/hr = $900/yr.
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s Section 39.35 Page 1:
SUPPORTING STATEMENT FOR 10 CFR 39.35 LEAK TESTING OF SEALED SOURCES 1 REQUI'REMEN'TS ,
Paragraph.(a) of Section-39.35 would require a licensee to keep records of the leak-test results for sealed sources containing licensed material.
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' Paragraph (d)(2). of Section 39.35'would require a licensee to file a report to
'NRC.if the test sh' owed that a source is leaking licensed material.
- 1. Justification
- a. Need for the Information Collection The recordkeeping requirement is -needed to indicate the results of leak testing of sealed sources. The leak testing is needed to ensure the sealed source maintain their integrity. The reporting requirement is needed to inform the NRC that the licensee has taken actions to remove the leaking source from service and to check for radioactive contamination.
- b. Practical Utility of the Information Collection The information contained in the record would document that the leak tests were performed. The information would also permit NRC inspec-tors-to verify that licensees have the source tested for leakage at least every 6 months and record the leak test results in units of
.microcuries. Inspections are conducted at least every 3 years.
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Section 39.35 Page 2 t
The 'information- contained in the report would allow NRC --regional offices to determine, within approximately one week, whether an inspector should be sent to check potential problems that may affect
- public health and safety.-
c.. Duplication with Other Collections for Information None.
- d. Consultations Outside the NRC The draft proposed rule and the draft regulatory analysis were sent to the following groups for review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
- No coments on information collection were received. .
, e. Other Supporting Information None.
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- 2. Description of the Information Collection
.a. Number and Type of Respondents The records will be retained by 180 well-logging licensees.
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5 Section 39.35 Page 3 The number of respondents for reporting requirements will be about 20 per' year (assuming 20 leaky sources per year).
- b. Reasonableness of the Schedule for Collecting Information Recordkeeping: The period of 3 years for recordkeeping is specified
, because the. inspection period for well-logging licensees is every 3 i'
. years.
eN Reporting: The report must be filed within 5 days to permit the NRC.
regional office to ' receive the report, review the situation and. if i necessary, [would ~ allow NRC to take action in a' relatively quick ~
l manner..
1 h
- c. Method of Collecting the Information
~
The licensee is the only source of information. The licensee would
_ submit a written report.
- d. Record Retention Period r .
Record retention period is 3 years after the required leak test is performed.
- e. Reporting Period i Reporting would be required only if the test reveals the presence of 0.005 microcurie or more of removable radioactive material.
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- Section' 39.35 '
Page 4 i
if.- Copies Required to be Submitted -
I0necopy.-
g.. Format'of Information to be Maintained or. Submitted I ~
None specified. '
' ~
'3 . Estimate'of Burden -
'a . - Estimated Hours Required to Respond to the Collection Recordkeeping:- Assuming ~'a licensee would take 5 minutes to complet'e
.a - record ~ and have . ten ' sources per - licensee, the estimated burden would be:
180 licensees x 10 sources / licensee x 2 records / year x 0.08 hr/ record = 300 hrs /yr.
s
~
Reporting: Assuming 20 leaky sources per year and 30 minutes to complete a report,.the estimated burden would be:
20 leaky sources /yr x .5 hr/ leaky source = 10 hrs /yr.
Total. burden: 300 yrs /yr + 10 hrs /yr = 310-hrs /yr.
p:
, :b. Estimated Cost Required to Respond to the Collection
. Estimated cost--310~ hrs /yr x $60/hr_= $18,600/yr.
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Section 39.35
-Page 5 V
L
[ . c. Source of Burden Data and Method for Estimating-the Burden
- The burden data and estimates are based on the: experience of NRC staff.
- d. Reasonableness of Burden Estimates The burden data and estimates are based. on the' experience of ~ NRC ,
staff.
,1
- 4. '
- Estimate of the Cost to the-Federal Government si - ~
s L : Recordkeeping: 'The time for NRC inspectors to inspect selected leak test-l >-
j records: is' estimated to be about- 15 minutes. Assuming -the NRC inspects o,
I "' ' onesthird of'well-logging licensees per year, the estimated cost is: .
l r -180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
t.
Ii Reporting: The time for receiving, reviewing and filing a report is estimated to be'one hour. The estimated cost is:
~
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o 20 reports /yr x 1 hr/ report x $60/hr;= $1,200/yr.
Total Cost: $900/yr + $1,200/yr = $2,100/yr.
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4 Section 39.37 Page 1 SUPPORTING STATEMENT FOR 10 CFR.39.37 PHYSICAL INVENTORY REQUIREMENTS Section 39.37 would require a licensee to keep records of each semiannual physical ~ inventory to account for all licensed material received and possessed under the license.
- 1. Justification
- a. Need for the Information Collection This information is needed to indicate that the licensee has con-
. ducted semiannual physical inventories to account for licensed material received and possessed under the license.
~b. Practical Utility of the Information Collection This information would document that sources possessed under _ the license were accounted for at the time of inventory. The information would also permit l'RC inspectors to verify that the _ licensee has conducted an inventory at least every 6 months. Inspections are conducted at least every 3 years,
- c. Duplication with Other Collections for Information
-g E None.
a s
-Section 39.37-
., Page 2
- d. Consultations Outside the NRC
+ The draft proposed rule and the draft regulatory analysis were sent to the following grc. for review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task
-:~ Force on Well-Logging.
No comments on information collection were received. ,
- e. Other Supporting Information None.
- 2. Description of the Information Collection
- a. Number and Type of Respondents The records will be retained by 180 well-logging licensees,
- b. Reasonableness of the Schedule for Collecting Information The period of 3 years for recordkeeping is specified because 'the inspection period for well-logging licensees is every 3 years.
- c. Method of Collecting the Information The licensee is the only source of information. Records would be s-kept at the field station where the source is kept.
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. Section 39.37-Page 3 Ed. = Record Retention ~ Period
- Record retention ' period would be 3 ' years from the date of the inven-tory.
- ; _. _e. Reporting Period.
s None.
f .' Copies Required to be Submitted None.
- g. Format'of Information to be Maintained or Submitted None specified.
- 3. Estimate of Burden
. a. Estimated Hours Required to Respond to the Collection Assuming a licensee would take 5 minutes to complete a record and assuming ten sources per licensee, the burden would be:
180 licensees x 10 sources / licensee x 2 records /yr x -
O.08 hr/ record = 300 hrs /yr. ,
- b. . Estimated Cost Required to Respond to the Collection Estimated cost--300 hrs /yr'x $60/hr = $18,000/yr.
p A
Section 39.37
-Page 4 l'
. c. .. Source of Burden Data and Method for-Estimating the Burden 1
~ " '
The burden data and estimates are based on the experience of 'NRC staff. .
s , ,
- d. . Reasonableness of Burden Estimates 4' .
The burden data and estimates are based on the experience of NRC '
~
- 4. . staff.-
- - 4. Estimate of the Cost to the Federal Government
- The time for NRC inspectors to inspect the inventory record is estimated to be about 15 minutes.- Assuming the NRC inspects one-third of well-logging licensees per year, the estimated cost is:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
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Section 39.39 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.39 UTILIZATION RECORD REQUIREMENTS Section 39.39 would require a licensee to keep utilization records for sources of licensed material.
- 1. Justification
- a. Need for the Information Collection This information is needed to indicate that the licensee recorded the required information on the use of licensed materials. The utili-zation record is needed for tracing the record of using each source location.
- b. Practical Utility of the Information Collection This information would permit the licensee to trace the history of the use of sources, radioactive' markers, or unsealed licensed material if there are any questions concerning licensed material.
This information would also permit NRC inspectors to verify that the licensee is utilizing licensed material appropriate to particular well-logging operations. Inspections are conducted at least every 3 years.
l' p-6 Section 39.39' Page 2
- c. Duplication with Other Collections for Information
.None.
e
- d. Consultations Outside the NRC The draft proposed -rule and the draft regulatory analysis were sent to the following groups for review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
No comments on information collection were received.
e.- Other Supporting Information None.
~
- 2. Description of the Information Collection 4
- a. Number and Type of Respondents The records will be retained by 180 well-logging licensees.
- b. Reasonableness of the Schedule for Collecting Information The period of 3 years for recordkeeping is specified because the inspection period for well-logging licensees is every 3 years.
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': Section 39.39
.3 -
Page 3 e.
'/ 4 c., . Method of Collecting the Information -
~
TheJ 11censee is the only source of information. .The record would~be
- kept at the' field station where the licensed material is kept.
'd. Record Retention Period Record- retention period would be 3 years from the date of the recorded event.
- e. . Reporting Period 4
None.
- f. Copies Required to be Submitted None.
.g. Format of Information to be Maintained'or Submitted None specified.
- 3.. Estimate of Burden
- a. Estimated Hours' Required to Respond to the Collection Assuming, on the average, a licensee records 5 sources per day ,for 150 days per year, and assuming it would take 2 minutes / source to record, the burden would be:
180 licensees x 5 sources / licensee-day x 150 days /yr x
.033 hr/ source = 4,500 hrs /yr.
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. A I Section 39.39 Page 4 4
- b. Estimated Cost Required to Respond to the Collection Estimated cost--4,500 hrs /yr, x $60/hr = $270,000/yr.
- c. Source of Burden Data and Method for Estimating the Burden The -burden . data and estimates are based on the experience of NRC staff.
- d. Reasonableness of Burden Estimates The burden data and estimates are based on the- experience of NRC '
staff.-
4.. Estimate of the Cost to the Federal Government The time for NRC inspectors to inspect the utilization record is estimated-to be about 15 minutes. Assuming the NRC inspects one-third of wel,1-logging licensees per year, the estimated cost is:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
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Section 39.41 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.41 DESIGN AND-PERFORMANCE CRITERIA FOR SEAL.ED SOURCES REQUIREMENTS Paragraph (c) of section 39.41 would require a licensee to keep-the certifica-tion documents of sealed sources.
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- 1. Justification.
- a. Need for the Information Collection This information is needed to indicate that the sealed sources meet the criteria prescribed in section.39~.41..
- b. Practical Utility of the Information Collection ,
This information would document that sealed sources used by well-logging licensees are certified by manufacturer or qualified testing organizations. The information would also permit NRC inspectors to.
verify that the licensee uses certified sources. ,
Inspections are conducted at least every 3 years.
- c. Duplication with Other Collections for Information None.
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[."i Section 39'.41'
- Page 2-
~~ d . Consultations Outside the~NRC s
The draft. proposed rule ~ and,the draft regulatory analysis were sent
~
. to the following groups for. review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
, Pk) comments on-information collection were' received.
- e. Other Supporting Information
- None.
~
i E "I '22 Description of the Information Collection
- a. Number and Type of Respondents -
~The records will be retained by 180 well-logging licensees.
l
- b. ' Reasonableness-of the Schedule for Collecting Information .
The period -of 3 years for recordkeeping is specified' because1 the inspection period for well-logging licensees -is every 3 years.
ic. Method of Collecting the Information The licensee is the only source of information. 'The records would be 6 kept at the licensee's address as stated in the license.
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'Section 39.41 Page 3
- d. Record Retention Period-Record; retention period-would be 3 years after transfer or disposal a.
+
,- of the" source or.its abandonment in a well.
- e.;_ Reporting Period
- None.
- f. Copies Required to be Submitted None.
. g .' ~ Format of Information to be Maintained or Submitted None specified._ ,
13 . Estimate of Burden a .- Estimated Hours Required to Respond to the Collection
' Assuming each licensee has, on the average,- two new sources;per year and it would take 5 minutes to file the manufacturer's certificate, at the licensee's address, the burden would be:
.180 licensees x 2 sources / licensee-yr x .083 hr/ source =
30 hrs /yr.
- b. Estimated Cost Required to Respond to the Collection
^
Estimated cost--30 hrs /yr x $60/hr = $1,800/yr.
F
3 Section 39.41 Page 4 m
'c. Source of Burden Data and-Method for Estimating the Burden The burden data and estimates are based on the = experience of NRC
'~
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2 9 ,.
d; Reasonableness ~of Burden Estimates The burden data and estimates are based on the experience of. NRC
^
staff. <
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' 4. ;
. Estimate of the Cost to the Federal Government
-The time' for NRC. inspectors to inspect selected certification documents is estimated to be about 15 minutes. Assuming the NRC inspects one-third of '1 well-logging licensees per year, the estimated cost is:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
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SilPPORTING STATEMENT FOR.
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, INSPECTION AND MAINTENANCE OF SEALED SOURCES OR HOLDERS ,
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, -REQUIREMENTS' -
4 Paragraph (b) of section 39.43 would require a licensee to maintain records of semiannual inspection and maintenance for 3 years.
- 1. Justification
-a. Need for the Information Collection. -
t This information is needed to indicate that a licensee conducts the
- required inspection and maintenance of sealed sources and holders. ,
The inspection and maintenance are needed to ensure that the sealed source and source holders are in good working condition.
- b. Practical Utility of the Information Collection This information. would document that semiannual inspections and maintenance of equipment were performed. The information would also permit NRC inspectors to verify that the .lic'ensee conducted the=
required semiannual inspection and maintenance. Inspections are ,
. ' conducted at'least every 3 years.
- c. Duplication with Other Collect 1cns for Information ;
None.
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Section 39.43 Page 2 t
id . Consultations Outside the NRC LThe draft proposed rule and the draft regulatory analysis were sent 1
- to the following groups for review and comment:
Agreement States; .
Conference of Radiation Control Program Directors--Task -
. Force on Well-Logging.
- s. ,
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. No comments on information collection were received.
- r
- e. . 0ther Supporting Information t
None.
p 2. - Description of the Information Collection
- a. Number and Type of Respondents The records will be retained by 180.well-logging licensees.
- i. >
- b. Reasonableness of the Schedule for Collecting Information The period of 3 years for recordkeeping is specified because the inspection period for well-logging licensees is every 3 years.
- c. Method of Collecting the Information
- The licensee 'is the only source of information. The records would be kept at the field station where the equipment is kept.
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.Page 3
- d. Record Retention Period Recordfretention period would be 3 years. -i
- e. Reporting Period .
A None.
f.- Copies Required to be Submitted:
, 'None.
- g. Format of Information to be Maintained or Submitted None specified.
1
- 3. Estimate of Burden
.a. Estimated Hours Required-to Respond to the Collection.
It is estimated that-each licensee would need I hour per. inspection /
maintenance to record the inspection or maintenance information for each field station. Assuming, on the average, three field stations per licensee, the total burden would be:
180 licensees x 3 field stations / licensee x 2 inspections / field station-yr x 1 hr/ inspection
= 1080 hrs /yr.
- b. . Estimated Cost Required to Respond to the Collection Estimated cost--1080 hrs /yr x $60/hr = $64,800/yr.
L__.
r-Section 39.43 e Page 4
- c. Source of Burden Data and Method for Estimating the Burden The burden data and estimates are based on the experience of NRC staff.
- d. Reasonableness of Burden Estimates The burden data and estimates are based on the experience of NRC staff.
- 4. Estimate of the Cost to the Federal Government The time for NRC inspectors to inspect selected inspection and maintenance records is estimated to be about 15 minutes. Assuming the NRC inspect one-third 'of well-logging licensees per year, the estimated cost is:
180 licensees x .33/yr x .25 hr/ licensee x $60/hr = $900/yr.
i..m
i Section 39.49 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.49 LABELS ON URANIUM SINKER BARS REQUIREMENTS
~
Section 39.49 would require a licensee to label uranium sinker bars.
- 1. Justification
- a. Need for the Information Collection The labels are needed to warn people that the bar contains uranium,
- b. Practical Utility of the Information Collection The labels are needed to warn people that these uranium sinker bars contain radioactive materials and that persons should notify civil authorities or the company if they find a labeled uranium sinker bar.
- c. Duplication with Other Collections for Information None,
- d. Consultations Outside the NRC The draft proposed rule and the draft regulatory analysis were sent to the following groups for review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
1 n Section 39.49 Page 2
' ~
No comments on information collection were received.
- e. Other Supporting Information None.
- 2. , Description of the Information Collection
- a. Number and Type of Respondents The number of respondents would be 18,well-logging licensees (assume 10% of NRC licensees use uranium sinker bars).
- b. Reasonableness of the Schedule for Collecting Information The licensee would be required to ensure that, within one year after the effective -date of the final rule, the sinker bars contain the -
warning words as specified in this Section.
- c. Method of Collecting the Information The words would be impressed on uranium sinker bars,
- d. Record Retention Period For the life of these bars,
- e. Reporting Period
- None.
- f. Copies Required to be Submitted None.
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_z Section 39.49 Page 3 r g. Format of Information to be Maintained or Submitted The words are specified in the proposed rule.
- 3. Estimate of Burden
- a. Estimated Hours Required to Respond to the Collection It is estimated that a licensee needs 10 minutes to check the wards on a sinker bar. Assuming 10% of licensees have sinker bars, the burden would be:
L L 18 licensees x 0.17 hr/ licensee = 3 hrs /yr.
bl Estimated Cost Required to Respond to the Collection Estimated cost--3 hrs /yr x $60/hr = $180/yr.
t
- c. Source of Burden Data and Method for Estimating the Burden t
The burden data and estimates are based on the experience of NRC staff.
- d. Reasonableness of Burden Estimates The burden data and estimates are based on the experience of NRC staff.
- 4. Estimate of the Cost to the Federal Government The time for NRC inspectors to inspect selected labels on sinker bars is estimated to be about 5 minutes. Total burden is:
18 licensees /yr x 0.1 hr/ licensee x $60/hr = $100/yr.
%i
~% Section 39.61-
- ' Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.61 TRAINING REOUIREMENTS Paragraph-(d) of section 39.61 would require that a licensee maintain records of training for logging supervisors and logging assistants. .
Subparagraphs (a)(2) and (b)(2) would _ require that certain documents be )
provided to trainees.
- 1. Justification l
- a. Need for the Information Collection The recordkeeping is needed to indicate that the logging supervisors l and logging assistants received training.
The documents to be provided to trainees are needed to ensure proper training.
V
! Practical Utility of the Information Collection
_b.
This information would document the training received by logging supervisors and logging -assistants. The information would also permit NRC inspectors to verify that the licensee has trained-logging supervisors and logging assistants. Inspections are conducted at least every 3 years.
r Section 39.61 Page 2 c.- Duplication with Other Collections for Information None.
- d. Consultations Outside the NRC The. draft proposed rule and the draft regulatory analysis were sent to the following groups for review and comment:-
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
No comments on information collection were received,
- e. Other Supporting Information None.
~2. Description of the Information Collection
- a. Number and Type of Respondents -
The records will be retained by 180 well-logging licensees.
- b. Reasonableness of the Schedule for Collecting Information ,
~ The period of years for recordkeeping is specified b'ecause the'
, inspection period for well-logging licensees is every 3 years.
Section 39.61 Page 3
- c. Method of Collecting the Information The licensee is the only source of information. The. records would be kept at the field station from which the logging supervisor and logging assistants were dispatched,
- d. Record Retention Period Training records for an employee would be retained until 3 years following the termination of the employment.
- e. Reporting Period The documents would be provided to the trainee at the time of training.
- f. Copies Required to be Submitted One copy per. trainee. ,
- g. Format of Information to be Maintained or Submitted .
None specified.
- 3. Estimate of Burden s
- a. Estimated Hours Required to Respond to the Collection It is ~ estimated that a licensee needs 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per year per field station to complete _ training records and to provide documents to trainees. The total burden would be:
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'Section 39.61 Page 4 180 licensees x 3 field stations / licensee x 1 hr/ licensee-yr = 540 hrs /yr.
- b. Estimated Cost Required to Respond to the Collection Estimated cost--540 hrs /yr x $60/hr = $32,400/yr.
- c. Source-of Burden Data and Method for Estimating the Burden The burden data and estimates are based on the -experience of NRC staff.
- d. Reasonableness of Burden Estimates
.The burden data and estimates are based on the experience of NRC
-staff.
- 4. ' Estimate of the Cost to the Federal Government The time for NRC inspectors . to inspect' selected training records is "
-N ? estimated to be about 15 minutes. Assuming the~NRC inspects one-third of-f,ield stations'per year, the estimated. cost is:
180 licens'ees x 3 field stations / licensee x .33/yr x
.25 hr/ field station x $60/hr = $2,700/yr.
4
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Section 39.65 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.65 PERSONNEL MONITORING REQUIREMENTS Paragraph (c) of section 39.65 would require that a licensee keep reports received from the badge or TLD processor and from the bioassay service lab.
- 1. Justification
- a. Need for the Information Collection This information collection is needed to verify that the licensee has subscribed to dosimetry and bioassay services. The badge, TLD and bioassay are needed to measure radiation exposure received by workers during well-logging operations.
- b. Practical Utility of the Information Collection This information would document the radiation doses received by the licensee's employees. This information would also permit NRC inspectors to verify that the licensees kept dosimetry and bioassay records. Inspections are conducted at least every 3 years.
- c. Duplication with Other Collections for Information None.
p, .
Section 39.65' Page 2'
~
- d. Consultations Outside the NRC The draft proposed rule and the draft regulatory analysis were sent.
to the following groups for review and coment:
-Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
No comments on information collection were received.
- e. Other Supporting Information
~
None.
- 2. Description of the Information Collection
,- a. Number and Type of Respondents
," . The records will be retained by 180 well-logging licensees'.
J \
- b. Reasonableness of the Schedule for Collecting,Information The - personnel monitoring records would be kept until, the Commission tenninates the licensee because the records are needed to_ verify the:
cumulative exposures received by the employees.
c.- ' Method of Collecting the Information
- -The' records _ would be kept at the licensee's address stated on the
- . license. -
-Section 39.65'
'Page 3
, d .- Record Retention Period
. -These' records would be maintained until the Commission terminates the l icense.
- e. Reporting' Period None,
- f. Copies Required to be Submitted None.
-g.. Format of Information to be Maintained or Submitted None specified.
- 3. Estimate of Burden
- a. Estima'ted Hours Required-to Respond to the Collection It is estimated that each licensee would ' need - I hour to ~ file' ^}the' exposure record each month for badges, or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> each quarter.to' file TLD records. Assuming one-half of~the licensees use film badges'and the other half use TLD, the total burden would be:
(90 licensees x.12 months /yr + 90 licensees x 4 quarters /yr) x 1 hr/ record 1=-1440 hrs /yr.
b.- Estimated Cost Required to Respond to the Collection
-Estimated cost--1440 hrs /yr x $60/hr = $86,400/yr.
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'The burden datac and estimates are based on the experience of NRC' [
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st'aff.
- ;x. _;
- d. ': Reason' ableness of Burden Estimates
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~ The ' burden ' data-~and estimates are based on the experience of NRC
. staff.
I4.- ' Estimate of-the Cost ~to the Federal Government
~
-The time' for; NRC inspectors to inspect selected exposure records is estimated'.to be about-30 minutes. Assuming the NRC inspects one-third of.
well-logging licensees -per year, the estimated cost is:
180 licensees x '.33/yr x .5 hr/ licensee x $60/hr =.$1,800/yr.
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Section 39.67 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.67 RADIATION SURVEYS REQUIREMENTS Paragraph (f) of section 39.67 would require a licensee to maintain radiation survey' records.
- 1. Justification
- a. Need for the Information Collection This information collection is needed to indicate that a licensee
-conducts radiation surveys. Radiation Survey is needed to warn the workers of the level of radiation exposure at that location. ,
e
- b. Practical Utility of the Information Collection The information would document that the licensee conducted radiation surveys. The .ikformation would also permit NRC inspectors to verify
,that the licensee complies with the survey requirements. Inspections are conducted at least.every 3 years.
c.- Duplication with Other Collections for Information None.
- d. Consultations Outside the NRC The draft proposed rule and the draft regulatory analysis were sent to the following groups for review and comment:
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'Section 39.67
, . Page 2
. Agreement States;
! Conference of Radiation Control Program Directors--Task _
Force on Well-Logging.
No comments on information collection were received.
- e. Other-Supporting Information None.
1 2._ Description of the Information Collection
- a. Number'and Type of Respondents The records.will;be retained by 180 well-logging licensees.
- b. Reasonableness of'the Schedule for Collecting Information
?
- The period of- 3 years for recordkeeping is specified .because~ the
-inspection period for well-logging licensees is every 3 years.-
- c. Method of Collecting the Information
. The licensee is the only source of information.. The records would be~
s kept at _ field stations.
.d. Record Retention Period Record retention period is-3 years after the surveys are made.
, ~
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Section 39.67 Page 3
- e. Reporting Period None.
- f. Copies Required to be Submitted None.
- g. Format of Information to be Maintained or Submitted None specified.
- 3. Estimate of Burden
- a. Estimated Hours Required to Respond to the Collection It is estimated that each licensee would need 15 minutes to record survey results per well-logging operation. Assuming 20,000 well-logging operations per year are conducted by NRC licensees, the total burden would be:
20,000 operations /yr x .25 hr/ operation = 5,000 hrs /yr.
- b. Estimated Cost Required to Respond to the Collection Estimated cost--5000 hrs /yr x $60/hr = $300,000/yr.
- c. Source of Burden Data and Method for Estimating the Burden The burden data and estimates are based on the experience of NRC staff.
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p::,['r!"d. . Reasonableness of' Burden Estimates
- 1. s The.- burden data aid estimates are based on the experience of. NRC
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4.. Estimate:of'the Cost to the Federal Government >
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The time for NRC inspectors to inspect selected radiation survey records
- 1's' es'timated to be about 30 minutes. Assuming the NRC in'spects one-third N of well-logging licensees per year, the estimated cost is:
180 licensees x .33/yr x .5 hr/ licensee x $60/hr = $1,800/yr.
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Section 39.73 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.73 DOCUMENTS AND RECORDS REQUIRED AT FIELD STATIONS REQUIREMENTS
- Section ' 39.73 would require a. licensee to maintain certain documents and records at each field station.
1.- Justification
- a. Need for the Information Collection This information is needed so that the licensee's operating personnel can have easy access to the documents they need to perform the job safely. Also, when an NRC inspector inspects a field station, the information would provide the inspector indications that the licensee
. complies with NRC requirements.
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- b. Practical Utility of the Information Collection This information would provide information on safety requirements and procedures to. the licensee's personnel at the field station. The information would also permit NRC inspectors to inspect these records t-at the field station. Inspections are conducted at least every 3 years.
'c. Duplication with Other Collections for Information None.
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Section 39.73
. Page 2
'd. Consultations Outside the NRC The-draft proposed rule and the draft regulatory analysis were sent
'to the following groups for review and comment:
Agreement States; Conference of Radiation' Control Program Directors--Task Force on Well-Logging.
No comments on information collection were received.
- e. Other Supporting Information None.
- 2. Description of the Information Collection
- a. Number and Type of Respondents
' Assuming on the average three field stations per licensee, the infor-mation would be maintained by 180 x 3 = 540 locations.
-b. Reasonableness of the Schedule for Collecting Information The information is needed as long as the licensed materials are stored and used or dispatched to the temporary _jobsite from the field stations ~ because the field station personnel would need to consult regulations, the license, operating or emergency procedures, and would need to assure' that safety requirements, such as calibration of
Section.39.73 Page 3.
survey ' instruments and leak testing ofisealed sources,'are ' performed according to the regulation.
~/ c. Method of Collecting the Information The licensee is the only source of information. The records would be kept at the field station.
- d. Record Retention Period Record retention periods would be 3 years for subparagraphs' (d)-(j).
The records require'd by subparagraphs (a)-(c) would be maintained at the . field station until the' licensee terminates its well-logging.
operations at the field station.
-e. Reporting-Period None.
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- f. : Copies Required to be Submitted None, g ._ Format of Information to be Maintained or Submitted None specified.
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Section 39.73
" Page 4
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'3. -Estimate of Burden-
, ca. Estimated Hours Required to Respond to the Collection Assuming each . field station would need I hour per year to file the records, to total burden would be:
540 stations x 1 hr/ station-yr = 540 hrs /yr.
- b. Estimated Cost Required to Respond to the Collection Estimated cost--540 hrs /yr x $60/hr = $32,400/yr.
- c. Source of Burden Data and Method for Estimating the Burden
.The burden data and estimates are based on the experience of NRC staff.
- d. Reasonableness of Burden Estimates The burden data and estimates are based. on the experience of NRC staff.
- 4. Estimate of the Cost to the Federal Government The time for NRC inspectors to inspect selected records at'a field station is estimated to be about 15 minutes. Assuming the NRC inspects one-third of field stations per year, the estimated cost is:
L 540 stations x .33/yr x 0.25 hr/ station x $60/hr = $2,700/yr.
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m Section 39.75 Page 1 SUPPORTING STATEMENT FOR 10 CFR 39.75 DOCUMENTS AND RECORDS REQUIRED AT TEMPORARY JOBSITES REQUIREMENTS-Section 39.75 would require a licensee conducting operations at temporary job-sites' to maintain certain documents and records at each temporary jobsite.
- 1. ' Justification
- a. Need for the Information Collection a
This information is needed so that the licensee's operating personnel can have easy access to the documents they need to perform the job safely,
- b. Practical Utility of the Information rollection This information would provide information on safety requirements and procedures to the licensee's personnel at the temporary jobsite. The information would also permit NRC inspectors to inspect these records at the temporary jobsite. Inspections are conducted at least every 3 years.
- c. Duplication with Other Collections for Information None.
.e Section 39.75 Page.2 l
- d. Consultations Outside the NRC The ~ draft proposed rule and the draft regulatory. analysis -were sent to the following groups for review and comment:
' Agreement States;.
Conference of Radiation Control Program Directors--Task Force on Well-Logging.
No comments on information collection were received.
-e. Other Supporting Information None.
2 . -2 Descrip' tion of the Information Collection
- a. Number and Type of Respondents Assuming, on the average, 50 temporary . jobsites per licensee per year, the information would be maintained by 180 licensees x
- 50. temporary jobsites/ licensee = 9,000 locations.
- b. Reasonableness of the Schedule for Collecting Information The information is needed when the licensee's personnel are con-ducting well-logging operations at the temporary jobsite. Records
-must be kept for the radiation surveys performed at the temporary jobsite for the current well-logging operations.
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. . ,., Section 39.75 Page 3
- c. ' Method of Collecting the Information Th'e licensee is the only source of information. The records would be kept with the. crew when they are stationed at the temporary jobsite.
- d. ' Record Retention Period Records will be maintained at the temporary jobsite until the job is
-completed.
- e. Reporting Period None.
i
- f. Copies Required to be Submitted None,
- g. Format of Ir. formation to be Maintained or Submitted None specified.
- 3. Estimate of Burden
- a. Estimated Hours Required to Respond to the Collection Assuming each working crew would need 3 minutes to assemble the re-cords, the total burden would be:
-9,000 locations /yr x .05 hrs / location =. 450 hrs /yr. ,
.m Section 39.75 Page 4
' b ~. Estimated Cost Required to Respond to the Collection Estimated cost--900 hrs /yr x $60/hr = $54,000/yr.
c.. Source of Burden Data and Method for Estimating the Burden The . burden - data and estimates are based on the experience of NRC -
staff.
^d.. Reasonableness of Burden Estimates
-q The - burden data and ' estimates are based on the experience of NRC staff.
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. .4. Estimate of the Cost to the Federal Government _,'
.The.. time' for NRC inspectors to inspect' selected records at a tempor'ary.
- jobsite' -is--estimated to be about 15 minutes. Assuming the NRC inspects
- 200 temporary'jobsites per year, the estimated cost is:
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200 jobsites/yr x 0.25 hr/jobsite x $60/hr = $3,000/yr.
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- Section 39.77 Page 1 SUPPORTING STATEMENT FOR 10 CFR-39.77 NOTIFICATION OF INCIDENTS AND LOST SOURCES; ABANDONMENT PROCEDURES FOR IRRETRIEVABLE SOURCES
-- REQUIREMENTS Paragraph- (a) would require a licensee to report a source has been lost in fresh water aquifer or a sealed source has been ruptured.
Paragraph (b) would remind the licensees of the Part 20 reporting requirement for incidents other than those included in paragraphs (a) and (c).
~
Paragraph (c) ~ would transfer reporting requirements in 630.56 and 670.60 to
-639.77. This paragraph would require licensees to notify NRC if a sealed source becomes irretrievable and file a written report on the abandonment of the sealed source.
- 1. Justification
- a. Need for the Information Collection This information collection is needed so that NRC regional offices would be informed of any incidents involving licensed materials, lost
-sources or irretrievable well-logging sources.
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Section 39.77-~
Page 2 L
- b. ' Practical Utility of the Information Collection This information will permit' NRC regional offices to make a deter-mination whether an inspector should be dispatched to a site and to assure that corrective actions have been taken. When the licensee, in consultation with the well owner or operator, determines that a sealed source lost in a well becomes irretrievable, the licensee would be required to notify NRC regional offices by telephone to
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request approval to -implement abandonment procedures. The NRC regional office would, based on the information supplied by the
. licensee, approve the abandonment if all reasonable effort at recovery had been expended.
- c. Duplication with Other Collections for Information None,
- d. Consultations Outside the NRC The: draft proposed rule and the draft regulatory analysis were sent to the following groups for review and comment:
Agreement States; Conference of Radiation Control Program Directors--Task Force on Well-Logging.
No comments on information collection were received.
- e. Other Supporting Information None.
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. -Section 39.77 Page 3,
- 2. Description of the -Information Collection
- a. : Number and Type of Respondents -
Assuming 10.' incidents per year: for NRC licensees, the number. of.
. respondents would be 10 licensees..
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- b. Reasonableness of the-Schedule for Collecting Information
' Paragraph (a) would require imediate telephone notification because Ll - ' the loss iof ~ licensed ! material and rupture of a sealed source could cause - extensive radioactive contamination. Imediate ~ notification would permit NRC to judge the severity of the situation and consider.
whether NRC should' takeimmediate action. The confirmatory letter l' within 5 days is needed to permit NRC to judge whether the licensee H
-_has taken corrective actions and whether NRC should consider fallow-up actions.
u Paragraph (c) would require licensees to request approval- for aban--
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doning a sealed source in- a well.- The requirement is needed ito,
= permit NRC - to judge whether all reasonable effort 'at ; recovery has-If been expended. The written report within 30 days is'needed to assure-
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- that the ' abandonment procedures- are' carried - out promptly- and ' satis-a i
( b;
'factorily. Furthermore, the -report constitutes La record : to alert
- state . regulatory agencies that --a sealed' source 'is in the well - if M w a .-pennission is requested to reenter the well.
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Section39.77
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tri Jc. Method of Collecting the Information The licensee is the only~ source of information.
- d. Record Retention Period -
- None.
- e. Reporting Period The reporting periods would be:
paragraph (a): (i) telephone report--immediately (ii) written report--within 5 days of the event (i) telephone report--when it becomes apparent
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paragraph (c):
that the source is irretrievable (ii) written report--within 30 days,after the source has been classified as irretrievable.
- f. Copies Required to be Submitted Paragraph (a): one_ copy.
Paragraph (c): one ' copy to the apnropriate NRC. regional office and one copy to.each appropriate State agency that has authority over the"well drilling.
- g. Format of Information to be Maintaired or Submitted None specified.
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t f3. Estimate'of-Burden
( a. . Estimated Hours Required to Respond to the Collection Assuming ~ 2 ruptured sources or sources . lost in fresh water aquifers per year . the burden would be:
Telephone notification: .5 hr x 2 = 1 hr Confirmatory letter: I hr x 2 = 2 hrs Subtotal 3 hrs.
Assuming 5 irretrievable sources per year, the burden would be:
Telephore notification: .5 hr x 5 = 3 hrs Written report: 4 hrs x 5 = 20 hrs Subtotal 23 hrs.
Total burden = 23 + 3 = 26 hrs.
< b. - Estimated Cost Required to Respond to the Collection.
l Estimated cost--26 hrs /yr x $60/hr = $1,560/yr.
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-c. - Source of Burden Data and Method for Estimating the Burden The ' burden data and estimates are based on the experience of .NRC ,
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, d.. ~ Reasonableness of Bur' den Estimates The burden data' and estimates are -based on the experience Hof NRC ;
staff.
4.- Estimate of the Cost to the Federal Government
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~ Assuming 2 ruptured cn lost . sources and 5 ~ irretrievable sources per year and 4 hrs / case for NRC regional offices to receive'the telephone calls and to review the reports, the estimated cost is:
- 7 cases /yr x 4 hrs / case 'x $60/hr = $1,680/yr.
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