Text

Notice of OMB Review of Info Collection & Solicitation of Public Comment
	ML20135E297
Person / Time
Issue date:	02/26/1997
From:	Cranford G; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:	;
References
	NUDOCS 9703060422
	Download: ML20135E297 (43)
	v • d • e

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a.-

PAPERWORK REDUCTION ACT SUBMISSION Please read the instructions before completing this form. For additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of IWanagement and Budget. Docket Ubrary, Room 10102,72517th Street NW. Washington, DC 20503

2. OMB control number

1. Agency / Subagency originating request d.S. Nuclear Regulatory Commission X

a.

3150 0120 b.None

3. Type of information collection (check onel

4. Type of review requested (check onel

a. New collection X

a. Regular : tmission

c. Delegated X

b. Revision of a currently approved collection

b. Emergency. Approval requested by (date):

5. Will this information collection have a a.Yes C. Extension of a currently approved collection significant economic impact on a

d. Reinstatement, without change, of a previously approved substantial number of small entities?

x b.No collection for which approval has expired

e. Rainstatement, with change, of a previously approved

a. Three years from approval date collection for which approval has expired Requested

f. Existing collection in use without an OMB control number 6* expiration date X b. Other (Specify): 07/31/99 mum===

l

7. Title Application for Material Ucense

8. Apncy form number (s) (i/ spp// cable /

NRC Form 313

9. Keywords Radioactive Materials, Radiation Safety

10. Abstract Final rule,10 CFR 34, Licenses for Radiography and Radiation Safety Requirements for RadiograpUc Operations, requires additionalinformation to be reported on NRC Form 313. Locations and descriptions of all field stations and permanent radiographic installation, designation of a Radiation Safety Office, and additionalinformation on training and testing will know be reported on NRC Form 313.

ae erhas ther aWy wirA "X*/

12. obligation to respond (Arare penary wsra *F' amr # erhas enar a#v with Jr */

i 3 Affected pubhc (Atare prsnary with "P an.

a. Individuals or households

d. Farms

a. Voluntary P

b. Busmess or other for. pro l t

e. Federal Government

b. Required to obtain of retain benefits X

c. Not for profit institutions X

f. state. Local or Tnbal Go ernment X

c. Mandatory

14. Annual reporang and recordkeeping cost burden an enoussars of domsi

13. Annual reporting and recordheeping hour burden

s. Number of respondents 18.600

a. Total annualized capital /startup costs o

b. Total annual costs (o&M) o j

b. Total annuaf responssa 11,841

c. Total annualized cost requested O

l

1. Percentage of these responses collected electronically o

d. Current OMB Inventory o

i f

c. Total annual hours requested 72.987

e. Difference o

d. Current oM8 inventory 67,137

f. Explanation of difference O

e. Difference 5.850

1. Program change

2. Adjustment o

f. Explanation of difference

1. Program change 5,850

2. Adsustment o

16 Frequency of recordkeepmg or reportmo (Check a# rhat appfyl 15, Purpose of mformation collection

k. Thord-party descSosure

a. Recordkeepmg (Mart primary with *P" and OH othergher apply with *X*)

a. Applicaten ior benefits

~

e. Program planning or management X

c. Reporting

~

b. Program evaluation

f. Research X

t. on occasion 2, Weekly

3. Monthly

c. General purpose statistics

q. Regulatory or complianca

4. ouarterly

5. semi annually

6. Annually

7. Bie.nially X

8. other toesenbel Agency contact tverson who can best answer questens regardmg tr>e 1 L statistical methods g content of this submissioni Does this mformation collection employ statistical methods ?

Name:

Mary Lynne Thomas j

Yes X No Phone: _

(301) 415-6230 9703060422 970226 PDR ORG EUSOMB 30 s 5 PDR

19. Certification for Paperwork Raduction Act Submissions i

i On behalf of this Federal agency, I certify that the col'ection of information encompassed by this request complies with 5 fFR 1320.9.

NOTFr the text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3), appear at the end of the instructions. The certification is to be made with reference to those regsdatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collectiIm of information. that the certification covers:

(a) It is necessary for the proper performance of agency functions; (b)

It avoids unnecessary duplication; (c) It reduces burden on small entities; f

(d)

It uses plain, coherent, and unambiguous terminology that is understandable to respondents; (c) Its implementation will be consistent and compatible with current reporting and recordkeeping practices:

I (f)

It indicates the retention periods for recordkeeping requirements; i

(g)

It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

J (i) Why the information is being collected; i

(ii)

Use ofinformation; (iii)

Burden estimate; (iv)

Nature of response (voluntary, required for a benefit. or mandatory);

(v)

Nature and extent of confidentiality; and (vi)

Need to display currently valid OMB control number;

)

(h)

It was developed by an office that has planned and allocated resources for the efficient ar.d effective management and use of the information to be collected (see note in item 19 of the instructions).

i i

l (i)

It uses effective and efficient statistical survey methodology; and l

(j)

It makes appropriate use of information technology.

I If you are unable to certify compliance with any of these provisions, identify the item below and explain the reaso Item 18 of the Supporting Statement.

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PAPERWORK REDUCTION ACT SUBMISSION Please feed the Inscructions before completing this form. For additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer, Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget. Docket Library, Room 10102,72517th Street NW, Washington, DC 20503 -

1. qgency/ Subagency onginating request

2. OMB contrci number U.S. Nuclear Regulatory Commission X

a.

3150- 0007

b. None

3. Type of information collection (check onel

4. Type :,i review requested (check one/

a. New collection X

4. Regular submission

c. Delegated X

b. Revision of a currently approved collection

b. Emergency. Approval requested by (date):

c. Extension of a currently approved collection

5. Will this information coilection have a a.Yes significant economic impact on a

d. Reinstatement, without change, of a previously approved substantial number of small entities?

X b No collection for which approval has expired

e. Reinstatement, with change, of a previously approved X a. Three years from approval date collection for which approval has expired Requested

f. Existing collection in use without an OMB control number 6 expiration date

b. Other (Specify):

7. Title 10 CFR 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations

8. Agency form number (s) (if applicab/e/

NRC Form 313

9. Keywords Radioactive Materials, Radiation Safety

10. Abstract 10 CFR 34 is being revised in its entirety. The part establishes rules governing the domestic licensing of radioactive byproduct matt rial for use in industrial radiography,

11. Affacted pubiac IMua prunay w*th *P2mr air others char awy werk ~x*a

12. obhgation to respond IMvh pomary work *!* and an others ther appry warh x*)

P b Busmess or other for-profit

d. Farms

a. Voluntary

a. Individuals or households X

e. Federal Government

b. Required to obtain or retain benefsts

c. Not.for. profit mstitutions X

f. state. Local, or Trabal Government X

c. Mandatory

13. Annual reportmg and recordkeepmg hour burden

14. Annusi reportmg and recordkeeping cost burden fra thousamts at do#Fs/

a. Number of respondents 450

a. Trital annuahzed capital /startup costs O

b. Total annual responses 696 b, Total annual costs to&M)

O

t. Percentage cf these responses

c. Total annualized cost requested O

collected electronicany o

d. Current OMB Inventory O

c. Total annual hours requested 42,846

e. Difference O

d. Current OMB inventory 63.938

f. Explanation of diff erence

e. Difference (21.092)

1. Program change

2. Adiustment

f. Explanation of difference

1. Program change (21,092) 2, Adiustment

15. Purpose of mformation collection 16 Frequency of recordkeeping or reportin (Check all that applyl IMark permary warh *P* and aN others that apply with *X*l X

a. Recordkeeping

b. Third party d,sclosure

b. Program evaluation

~

o. Program planning or management X

c. Reporting

2. Weekly

3. Monthly

a. Appbcation f or benefits

f. Research x' 1 On occasion

c. General purpose statistics p

g. Regulatory or comphance 4 Quarterly X

5. seme-annually X

6. Annually

d. Audit

7. 8.ennially 8, other Idescribel Agency contact Iperson who can best answer Questoons regardeng rse 11 statsst< cal methods y content of rhrs submiss on) ooes this snfo*mation collection employ statist 8 Cal methods?

unme Mary L.ynne Thomas Yes X No (30 0 415-6230 pno,,e.

10 95 OMB 83.t

19. Certification for Paperwork Reduction Act Submissions j.

4 On behalf cf this Federal agency, I certify that the collection of information encompassed by this request complies uith l CFR 1320.9.

NOTE:

ne text of 5 CFR 1320.9, and the related provisions of 5 CFR IMO.8(bX3). appear at the end of the instructions. The certifico"nn is to h. :u.!: wit reference to those regadatoryprovisions as setforth in the instructions.

He following a a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions; (b)

It avoids unnecessary duplication; (c) It reduces burden on small entities; (d)

It uses plain, coherent, and unambiguous terminology that is understandable to respondents; (c) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; (f)

It indicates the retention periods for recordkeeping requirements; (g)

It informs respondents of the information called for under 5 CFR 1320.S(b)(3):

(i) Why the information is being collected; (ii)

Use of information; (iii)

Burden estimate; (iv)

Nature of response (voluntary, required for a benefit, or mandatory);

(v)

Nature and extent of confidentiality; and (vi)

Need to display currently valid OMB control number; (h)

It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the infonnation to be collected (see note in item 19 of the instructions).

(i)

It uses effective and efficient statistical survey methodology; and (j)

It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

l I

Date gur of Seni Offqe ~r s nee b

. *iLU

{.9

%l 10!95 6

T

[MB 83-1

r-

.e PAPERWORK REDUCTION ACT SUBMISSION Please read the instructions before completing this form. Fct additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget. Docket Library, Room 10102,72517th Street NW, Washington, DC 20503

1. Agency / Subagency originating request J OMB control number (LS, Nuclear Regulatory Commission X

a.

3150- 0008

b. None

3. Type of information collection (check one/ -

4. Type of review requested (check one/

a. New collection X

a. Regular submission

c. Delegated X

b. Revision of a currently approved collection

b. Emergency. Approval requested by (dateh

c. Extenst. :t a currentty approved collection

5. Will this information collect'MI have a

a. Yes significant economic impact on a

d. Reinstatement, without change, of a previously approved substantial number of small entities?

X b.No collection for which approval has expered

e. Reinstatement, with change, of a previously approved

a. Three years from approval date collection for which approval has expired Requested

f. Existing collection in use without en OMB control number 6 expiration date X b. Other (Specifyh 11/30/97

7. Title 10 CFR 71, Packaging and Transportation of Radiographic Material

8. Agency form number (s) (i/ epplicable/

9. Keywords Transportation Safety, Radioactive Material i

a

10. Abstract Final rule,10 CFR 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic j

Operations, deleted the information collection requirement contained in 10 CFR 71.105.

i I

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11. Atf acted pukkc tMara ornnery worn 'P* amt an erners snar appry worn ~x*/

12. obhgation to respond IMus prenary worn ~P'amt an erners enar apply worn M*)

a. Indwiduals or households

d. Farms

a. Voluntary P

b. Business or other for profst

e. Federal Government

b. Required to obtam or retain benefits

)

X

c. Not.for profit institutions X

f. State. Local. or Tribal Govemment X

c. Mandatory

13. Annual reportang and recordkeeping hour burden

14. Annual reporting and recordkeeping cost burden im enousamts or 1

a. Number of respondents 350

a. Total annualued capitsl/startup costs

b. Total annual responses 1,120

b. Total annual costs fo&M)

1. Percenta0e of these responses C. Total annualized cost requested O

collected electronically o

d. Current OMB inventory d

c. Total annual hours requested 73.897

e. Difference o

d. Current oM8 inventory 75.337

f. Explanation of difference

e. Difference 11,440)

1. Program change

f. Esplanation of difference

2. Adjustment

1. Program change 11,440) 3

2. Adjustment 2-l

15. Purpose of information collection 16, Frequency of socordkeepmg or reportm (Check all ther applyf i

IMart primary with *P* and all others that apply with *X"I X

e, Recordkeepeng

6. Third party disclosure

~

a. Application for benefits

e. Program plannmg or management X

c. Reporting

~

. Weekly

3. Monthly 2

b, Program evaluation

f. Research X

1. on occasion

c. Generet purpose statistics p

g. Regulatory or compliance

4. Quarterly

5. Semi-annually 6 Annually

d. Audit

7. Biennially B. other idescribel

17. statist cal methods 18* Agency c ntact / person who can best answer guestions regarding the content of thus submissen)

Does this information collection employ statisticat methods?

Name-Mary Lynne Thomas Yes X No Phone-(301) 415-6230 4

10/95 OMB 831

c

19. Certification for Paperwork Reduction Act Submissions On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 54CFR 1320.9.

l l

NOTE:

The text of 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3), appear at the end of the instructions. The certification is to be made..ith referer.ce to those regi..'atory provisions as setforth in the instrNClions.

l The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

j (a) It is necessary for the proper performance of agency functions; (b)

It avoids unnecessary duplication; (c) It reduces burden on small entities; (d)

It uses plain, coherent, and unambiguous terminology that is understandable to respondents; (e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; (f)

It indicates the retention periods for recordkeeping requirements; (g)

It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

j (i) Why the information is being collected; j

(ii)

Use of information; (iii)

Burden estimate; (iv)

Nature of response (voluntary, required for a benefit, or mandatory);

(v)

Nature and extent of confidentiality; and (vi)

Need to display currently valid OMB control number; (h)

It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected (see note in item 19 of the instructions).

(i)

It uses efTective and efficient statistical survey methodology; and (j)

It makes appropriate use of information technology.

If you are unab'e to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

Date Signahaet Senior O acpt esi e S*S(

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fp 10/95 OMil B31

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SUPPORTING STATEMENT FOR 10 CFR PART 34 l

l LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY REQUIREMENTS i

FOR RADIOGRAPHIC OPERATIONS FINAL RULE (3150-0007)

AND 10 CFR PART 71 PACKAGING AND TRANSPORTATION OF RADI0 ACTIVE MATERIAL (3150-0008)

AND NRC 313, APPLICATION FOR MATERIAL LICENSE j

(3150-0120)

Description of the Information Collection The information collection requirements contained in the proposed rule were approved by OMB on May 20, 1994.

Because the final rule, in response to public comments, modifies some of the information collections contained in the proposed rule, the OMB clearance package is being resubmitted. This clearance package compares the information collection requirements of the final rule to the current rule and indicates the changes from the proposed rule.

Part 34 provides certain requirements exclusive to licensees using byproduct material for purposes of industrial radiography, a technique of non-destructive testing. The byproduct material is normally employed in the form of sealed sources which emit high levels of radiation for the purpose of examining structures and various materials. Two types of radiography devices are in use.

In the first type the sealed radioactive source remains within the device and the radiation from the source is employed by opening a shielded port on the device.

In the second type, which is more commonly used, the sealed radioactive source is moved out of the device to a location adjacent to the object to be radiographed.

In these latter types, the sealed radioactive source is remotely driven from its shielded position in the radiographic device to an unshielded position up to several meters away from the device and again returned to its shielded position at the completion of each radiograph.

1

Also, these radiographic devices are often moved from location to location at a jobsite,. and transported from jobsite to jobsite. The many manipulations of the sources, movement, and transport of the devices result in unique and

' continuing potential and actual hazardous radiological conditions.

This rulemaking revises 10 CFR Part 34 in its entirety. This revision includes additional safety requirements to enhance the level of protection of radiographers and the public and clarifies the regulations so that licensees may have a better understanding of what is expected in conducting radiographic operations.

This rulemaking includes a number of updated radiography regulations that have been adopted by many Agreement States.

A.

JUSTIFICATION 1.

Need and Practical Utility for the Collection of Information The information described above is necessary for the licensee to show compliance with these regulations and to ensure that they are adequately a.ble to protect worker and public health and safety. The information described above is also necessary for the NRC to evaluate the adequacy of a licensee's operation.

The information collection requirements of the revised 10 CFR Part 34 are identified below.

I 34.11 Application for a specific license, and 5 34.13 Specific license for radiography.

Taken together, these.two sections (currently at 5 34.3 and 5 34.11) require a license applicant to submit an application on NRC Form 313 to the NRC so that the NRC may determinc whether the applicant's equipment, procedures, and personnel are adequate to protect public health and safety.

Paragraph 34.13(b), currently paragraph 34.11(b), requires applicants to have a training program for radiographers and radiogrr.phers' assistants that meets the requirements of 5 34.43.

In the case of radiographers this program may be complied with by having the radiographers trained in the subjects outlined in 5 34.43(g) or by requiring that they be certified by an appropriate certifying agency, before commencing duty as radiographers. Two years after the effective date of the rule all radiographers are required to be certified.

Both radiographers and radiographers' assistants are also required to be competent in the applicant's operating and emergency procedures and must meet the other training requirements of 5 34.43. This information is reviewed by the NRC staff to ensure that radiographers and their assistants will be sufficiently trained to enable them to work safely and in compliance with NRC regulations, license conditions, and licensee operating and emergency procedures.

Paragraph 34.13(c) is new.

It requires applicants to submit procedures to verify and document the certification status of the radiographers it employs and to submit procedures to ensure that the certification is valid. The 2

F Commiss%n reviews these procedures to ensure that the applicant is able to verify and document the certification status of its radiographers and to

,ensrre that the radiographer's certification is valid.

f aragraph 34.13(d), currently paragraph 34.11(c), requires that the applicant submits to the Commission, written operating and emergency procedures as described in 5 34.45. The operating and emergency procedures are intended to provide radiography personnel with step-by-step instructions and procedures so that the performance of industrial radiography will not endanger health or pose a danger ta life or property.

The preparation of operating and emergency procedures is intended to ensure that radiography personnel are aware of the steps to be followed in conducting radiographic operations, so that there is no misunderstanding of what is required of each person involved in the overall radiography operation.

The Commission reviews these procedures to ensure that j

they are adequate to protect the worker and.the public health and safety.

Paragraph 34.13(e), currently paragraph 34.11(d) requires that the applicant establish and submit its program for semi-annual inspections of the job performance of each radiographer and radiographer's assistant as described in 5 34.43(e). This is an increase over the proposed annual inspection. The existing rule requires quarterly inspections. The inspections are necessary to ensure that radiographers and radiographers' assistants are performing their jobs in accordance with the operating and emergency procedures set forth in their license. The Commission reviews this information to ensure that the licensee has developed an adequate program for evaluating the knowledge of radiographers to perform their duties.

Paragraph 34.13(f), currently paragraph 34.11(e), requires that the applicant submit a description of its overall organizational structure as it applies to f

the radiation safety responsibilities in radiography, including specified delegations of authority and responsibility. The NRC staff will review this information in order to ensure that the licensee's organization will provide adequate management oversight, supervision and accountability for safe operation of the radiography program and that the lines of authority and responsibility are clear and unambiguous.

Paragraph 34.13(g) is new.

It requires the applicant to identify and list the qualifications of an individual designated as the Radiation Safety Officer (RS0), responsible for implementing the licensee's radiation safety program, as described in 5 34.42.

This requirement, albeit new to the regulation, is not a new requirement.

This has been addressed as Item 7, " Individual Responsible for Radiation safety Program," on NRC Form 313.

It was separated from paragraph 34.13(f) in order to make it clear to the licensee / applicant that the individual listed on NRC Form 313 has specific dutics and responsibilities. This information is reviewed by the NRC staff to ensure that the individual assigned for this purpose has the appropriate qualifications to ensure that he/she will be able to fulfill the role of overseeing the radiation safety program.

Paragraph 34.13(h), currently paragraph 34.11(f), requires an applicant that desires to perform leak testing of sealed sources or exposure devices 3

containing depleted uranium (DU) shielding, to describe the procedures for performing the tests and the qualifications of the person (s) authorized to do

}heleaktesting.

If the applicant intends to analyze its own leak-test wipe samples, the application must include a description of the procedures to be followed.

The description must include the instruments to be used, the methods of performing the analysis and the pertinent experience of the person who will analyze the leak-test wipe samples. The NRC staff reviews the procedures to ensure that the method of obtaining the leak-test wipe sample will be adequate to determine if there is any leakage or contamination, and that the person who will perform the leak tests has sufficient training and experience in performing such tests.

Paragraph 34.13(i) is new. This is a new section not in the proposed rule and was added in response to comments.

It requires an applicant to describe calibration procedures for survey instruments, if the applicant intends to perform their own calibrations.

If a licensee chooses to do this it also requires them to submit the relevant experience of the person (s) who will perform the calibrations.

Calibrations are to be performed according to procedures described and at intervals specified in 5 34.25. The NRC staff reviews the procedures specified and the qualifications of the persons performing the calibrations to ensure that they have appropriate training and experience.

Paragraph 34.13(j) is new. This section was designated 34.13(i) in the proposed rule.

It requires the appH cant to identify the locations and describe all field stations and permanent radiographic installations and the locations where records will be maintained.

This requirement, albeit new to the regulation, is not a new requirement. This has been included under

" Facilities and Equipment," Item 9, on NRC Form 313.

It is addressed in the regulation in order to make it clear to the licensee / applicant that they need to provide this information in their application.

This information is needed so that NRC can inspect locations where radioactive material could be stored and/or used to verify the adequacy of that use and/or storage.

Paragraph 34.13(j) of the proposed rule was incorporated into 5 34.13(b) of the final rule.

Paragraph 34.13(k) is new.

This is a new section not in the proposed rule and was added in response to comments that proposed requirements to maintain specific records at specific locations was overly burdensome.

It requires the applicant to specify where all documents and records required by this part and other parts of this chapter will be maintained as specified in 5 34.89. This information is needed by NRC to ensure easy availability of records in cases of emergency related to public health and safety.

The information required by sections 34.11 and 34.13 are submitted on the NRC Form 313, OMB Clearance number 3150-0120, as part of the application process.

l All information required by the revised sections is required by the current regulation except for refresher safety training, required by paragraph 34.13(b). The increase in burden for NRC Form 313 due to these added requirements is included in the licensee burden table.

4

1 l 34.20 Performance reauirements for radiography eauipment.

faragraph34.20(b)(1)isunchangedfromthecurrentruleandrequiresthat each radiographic exposure device have an attached label bearing information identifying the radionuclide in the device, its activity and the date that this activity was last measured, the manufacturer, model and serial number, and the licensee's name, address, and telephone number.

This information will serve as a safety notice to users and members of the public. The label requirement has been incorporated in the regulations, in part, in conformance with ANSI Standard N432.

The burden associated with the proposed and final 5 34.20(b)(2) has been incorporated into the burden for 5 34.35(b)(2).

j i

The proposed 5 34.20(f) has been deleted from the final rule.

5 34.25 Radiation survey instruments.

i Paragraph (b) of 5 34.25 requires that each radiation survey instrument be calibrated at intervals not to exceed 6 months and after each instrument servicing, and 5 34.25(c) requires that a record of the calibration be maintained in accordance with 5 34.65.

The radiation survey is one of the j

most important aspects of radiation safety and the instruments must be

)

periodically calibrated to assure a reasonable accuracy to the measurement of radiation levels to which individuals are being exposed during conduct of radiographic operations.

The current rule requires that radiation survey instruments be calibrated at 3 month intervals and a record maintained of the calibrations. The calibration interval is now being extended from 3 months to 6 months because survey instruments are now sturdier and more reliable. The records allow NRC inspectors to verify that required calibrations have been performed. The licensee will use the records to assure itself that the instruments available to radiographers and radiographers' assistants are properly calibrated.

This requirement results in a burden reduction, since licensees will be required to maintain fewer records under the revised rule.

5 34.27 Leak-testino and replacement of sealed sources.

Paragraph 34.27(c)(2), requires the licensee to maintain recor " ef leak test results in accordance with 5 34.67 and is the same as the exb 3

requirements in 5 34.25(c).

This section was designated 34a s)(2) in the proposed rule.

Paragraph 34.27(b)(3) in the proposed rule has been re-designated 5 34.27(c)(3) in the final rule and was determined to not have a burden associated with it.

Paragraph 34.27(d) requires that licensees report within 5 days results of j

leak testing which indicate that a source is leaking is the same as the previous requirement in paragraph 34.25(d). The report must describe the l

equipment involved, the test results, and the corrective action taken. The NRC staff uses the report in assessing whether the corrective actions 5

F l

initiated by the licensee are adequate to protect workers and the public from the hazards of a leaking source. The NRC staff also uses the report to

. identify generic problems with respect to source design, radiographic equipment design, or problems in source manufacturing and quality control.

The only new requirement in this subsection is the addition of a requirement for leak testing of the "S" tubes of those radiographic devices that use l

depleted uranium (DU) for shielding.

Paragraph 34.27(e) requires licensees to conduct leak' tests for DU in the "S" tubes of such devices at least annually, and to maintain records of these tests in accordance with 5 34.67. A leak test of the "S" tube for DU contamination is to provide an indication that the "S" tube may be wearing and could result in seizure of the control cable in the groove cut in the "S" tube by the cable. The records kept under i 34.67 allow the licensee and the NRC to verify that the required tests have been performed to verify the condition of the "S" tube.

l 5 34.29 Ouarterly inventory.

Paragraph 34.29(a) requires the licensee to conduct a quarterly physical inventory to account for all sealed sources and for all devices containing DU received-and possessed under the license, and paragraph 34.29(b) requires.the licensee to maintain records of the inventory under i 34.69 and retain such records for 3 years. This requirement is similar to the requirements of 5 34.26 in the existing rule except for the additional requirement to include devices containing DU. This information is used by the licensee and NRC to verify that all radioactive material is accounted for and is properly stored.

6 34.31 Inspection and maintenance of radioaraphic exposure devices, transport and storace containers, associated eauipment, source chanaers and survey instruments.

Paragraph 34.31(b)(1) requires that the licensee have written procedures for inspection and maintenance of radiography devices, source changers, associated equipment, transport and storage containers, and survey instruments.

Paragraph 34.31(b)(2) requires that the licensee have written procedures for 1

inspection and maintenance of Type B packaging used to transport radioactive materials. This is a new section added to the final rvle as a result of public comment.

It eliminates the burden associated wi ' the requirement in 10 CFR 71.105 to submit a QA program to the NRC for apy oval.

j Paragraph 34.31(c) requires that the licensee make a record of any equipment problems and any maintenance performed during the daily visual and operability checks specified in 5 34.31(a), or during the inspections specified in 5 34.31(b), and specifies that these records must be made in accordance with 5 34.73 and each record retained for 3 years after it was made.

If equipment problems are found at any time, the equipment must be removed from service until repaired. This is a new requirement that was added to ensure that i

licensees take appropriate actions if equipment problems are found. The revised recordkeeping requirements in 5 34.73(b) are an expansion of what was in 5 34.28(b) which required that records be kept of inspections for 3 years 6

but did not specify what information to keep.

The record is needed for the licensee and NRC to verify that appropriate actions have been taken if problems are found, and assist the licensee in keeping track of when the equipment was last inspected and maintained and when the inspection is next due.

The records are used by NRC staff to determine the extent of licensee compliance and to detect problems with equipment that may be generic so that corrective action might be taken promptly.

5 34.33 Permanent radiographic installations.

Paragraph 34.33(b) requires that entrance controls and/or the visible and 4

audible alarms on permanent radiographic installations required by paragraph 34.33(a) be tested and records of the tests maintained.

Entrance controls are to be tested monthly while both visible and audible alarms must be tested at the beginning of each day the installation is to be used in order to ensure that they are functioning properly to prevent inadvertent entry into a radiographic installation (cell) while a source is in the unshielded position.

Improperly operating control devices or audible or visible alarms are to be immediately labeled defective and repaired before industrial radiographic operations are resumed.

This is necessary to warn personnel of potential radiation hazards. The testing frequency has increased from quarterly in the previous rule to daily for audible and visible alarms and monthly for entrance controls in the revised rule to ensure that personnel overexposures due to faulty control devices are minimized.

Records of the alarm tests and entrance control tests are to be maintained under 5 34.75 for 3 years after it is made, which is the same as the previously required under 5 34.29(c), but the number of records required has been significantly increased.

These alarms are an important backup to-the radiation survey instrument and are intended to prevent inadvertent entry into a radiographic installation (cell) while a source is in the unshielded position. These records enable the licensee to verify that the alarms are functional and that repairs have been made when required.

5 34.35 Labels. storage. and transportation precautions.

Section 34.35 is a new section not found in the existing regulation.

Paragraph 34.35(a) requires that the licensee not use a source changer or container to store licensed material unless the source changer or the container has securely attached to it a durable, legible, and clearly visible label.

This requirement ensures that any individual who may come in contact with the source changer or storage container is made aware of the presence of radioactive material. This section was designated 34.34(a)(1) in the proposed rule.

Paragraph 34.35(b)(2) requires that the licensee not transport licensed material unless the material is packaged, labeled, marked, and accompanied with appropriate shipping papers in accordance with regulations set out in 10 CFR Part 71. This is necessary so that the licensee may demonstrate that it is in compliance with regulations stated in Parts 34 and 71. This section was designated 34.35(a)(2) in the proposed rule.

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l 5 34.41 Conductina industrial radiographic operations.

faragraph34.41(c)requiresthedevelopmentofCommissionapprovedprocedures for any licensee who wishes to conduct lay barge, offshore platform, or underwater radiography. These procedures must be included with license submission by licensees who elect to perform these activities. The NRC staff reviews these procedures to ensure that the procedures are adequate for the activities to be performed. This is a new section added to the final rule as a result of public comment.

I 34.42 Radiation Safety Officer for industrial radiography.

This section requires that the RSO ensure that radiation safety activities are performed in accordance with approved procedures and regulatory requirements.

These procedures and requirements are part of the specific license and are covered under i 34.13.

I 34.43 Trainina.

Paragraph 34.43(a)(2) requires that radiographers not yet certified through a radiographer certification program demonstrate appropriate capability through successful completion of a written examination previously approved by the Commission. This requirement is met through the specific license provision under i 34.13(b) and the training and examination requirements specified in 534,43(a)(2).

Paragraph 34.43(b)(1), previously 34.31(a)(2), contains a new requirement for the licensee to provide radiographers with copies of pertinent sections of Part 30, and instructions in applicable Department of Transportation regulations as referenced in 10 CFR Part 71, in addition to the existing requirement to provide copies of pertinent sections of Parts 19, 20, and 34; the NRC license; and the licensee's operating and emergency procedures.

These are needed to ensure that radiographers are sufficiently knowledgeable of applicable regulations prior to using licensed material.

This section was designated 5 34.43(a)(3) in the proposed rule.

Paragraph 34.43(c)(1), previously 34.31(b)(1), contains a new requirement for the licensee to provide radiographers' assistants with copies of pertinent sections of Parts 19, 20,and 30, and instructions in applicable Department of Transportation regulations as referenced in 10 CFR Part 71, and the NRC license under which the assistant will perform radiography, in addition to the existing requirement to provide copies of the licensee's operating and emergency procedures.

This is needed to ensure that radiographers' assistants are sufficiently knowledgeable of applicable regulations prior to using licensed material. This section was designated 5 34.43(b)(1) in the proposed rule.

I Paragraph 34.43(f) requires that the licensee maintain records of training to l

include oral, written, and practical examinations, refresher safety training, and semi-annual inspections of job performance. The licensee shall maintain records of the aforementioned items in i 34.79 and maintain such records for 3 l

8

years after the record is made. This is essentially what is currently required in the existing regulation 5 34.31(c) except for the addition of the pew requirement for documenting the information covered in refresher safety training. The existing regulation does not have a specific recordkeeping requirement except for tests administered. The revised rule requires licensees to keep track of when and what training was provided, and who provided and received the training.

This is needed to enable licensees to 1

adequately administer their training program and to demonstrate compliance with NRC requirements.

The records of the semi-annual inspections of job i

performance will be used by the licensee to keep track of deficiencies, if noted, so that they can be corrected.

Section 34.79 stipulates retention of these records for a period of 3 years after the record is made so that the NRC can inspect to ensure that these individuals are properly trained. This section was designated 5 34.43(e) in the proposed rule.

i 5 34.45 Operating and emeraenc_y procedures.

Paragraph 34.45(a), previously 34.32, requires that licensees develop procedures for routine operations and emergencies for employees to follow in performing safety functions. Operating and emergency procedures are necessary to ensure that individuals handling radioactive material will have guidance in appropriately carrying out safety functions. These include the safe handling and use of sealed sources and radiographic exposure devices; conducting radiation surveys; controlling access to radiographic areas; locking and securing radiographic exposure devices, storage containers, and sealed sources; personnel monitoring; transporting sealed sources; inspection, maintenance, and operability checks of radiographic exposure devices. Also, procedures are needed for transport and storage containers, and survey instruments; steps to be taken if a pocket dosimeter is off-scale; procedures for identifying and reporting defects and noncompliance; accident procedures; minimizing exposure; a source recovery procedure; and maintenance of records.

Paragraph 34.45(a)(6), previously 34.32(f), is not new, the word " posting" has been changed to " placarding" to fit better when discussing transportation issues, and the reference to the Department of Transportation, 49 CFR Parts 171, 172, and 173 has been added to provide further information regarding transportation of radioactive materials. The requirement for a source recovery procedure in paragraph 34.45(a)(12) is new.

It would only be necessary for the licensee to have this procedure if they were going to recover sources thamselves.

Paragraph 34.45(b) requires that the licensee maintain copies of current operating and emergency procedures in accordance with 5 34.81 and 5 34.89 which is essentially the same as the requirements previously in 5 34.32. This information is necessary to ensure that individuals have current procedures to use in the conduct of radiographic operations.

5 34.47 Fersonnel monitorina.

Paragraph 34.47(b) requires radiographers to read and record the exposure on their direct reading dosimeters (pocket dosimeters or electronic personal dosimeters) at the beginnig and end of each shift, and that records be 9

l maintained for 3 years after the record is made, as specified in paragraph 34.83(a).

This to ensure that radiographers determine and maintain adequate records of their occupational exposures in order to ensure they do not exceed the dose limits. The previous rule required pocket dosimeters to be read and i

exposures recorded daily, but many have misinterpreted this requirement, so the language was revised to clarify the intent that the only exposure that needs to be recorded is the one received during the shift.

The intent here is to ensure that the licensee knows the radiation exposure a worker received during a given shift in case their film badge or TLD is lost, so that the i

licensee can take appropriate action (e.g., adjust the worker's assignments so as to maintain their accumulated dose within regulatory limits or provide training to improve their work habits and thus reduce their dose) in event of an overexposure.

Paragraph 34.47(c) requires that pocket dosimeters er electronic personal dosimeters be checked at periods not to exceed 12 monchs (rather than 1 year as in the previous rule) for correct response to radiation, and that records shall be maintained for 3 years after the record is made as specified in 534.83(a). The changes are to clarify that 1 year means not to exceed 12 months, and to include maintenance of records of these checks. These records are necessary for the licensee to be able to verify that the pocket dosimeter is responding correctly to radiation.

Paragraph 34.47(d) requires that a determination of exposure be made if an individual's pocket dosimeter goes off-scale and that the result of the l

determination be maintained in accordance with 5 34.83(d). This is revised from the previous rule to restrict individuals from working with a discharged dosimeter, unle.s any exposure to radiation can be ruled out or the RSO makes a determination of the individual's exposure and makes a record of that determination. This determination is needed to verify that an individual's dose does not exceed regulatory limits.

Paragraph 34.47(e) requires that if a film badge or TLD is lost or damaged, the worker is required to cease work immediately until a replacement film badge or TLD is provided and the exposure is calculated for the time period from issuance to loss or damage.

In addition, the results of the calculated exposure and the time period involved must be included in the records as specified in 5 34.83(d).

This requirement is also to ensure that a worker's dose does not exceed regulatory limits.

Paragraph 34.47(f) requires that the licensee maintain reports received from film badge and TLD processors until the license is terminated as specified in the previous rule under i 34.33(e) and that the record be maintained in accordance with 5 34.83(c) of the revised rule. This information may be needed to reconstruct a worker's dose history in the event they lose their records, and to permit a planned special exposure.

Paragraph 34.47(g) requires that alarm ratemeters be calibrated at periods not to exceed one year for correct response to radiation. A new requirement is added in paragraph 34.47(g)(4) that the licensee must maintain records of the l

calibrations for 3 years after the record is made as specified in 5 34.83(b).

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a This was added to provide a means for the licensees to demonstrate that their alarm ratemeters are properly calibrated.

'l 34.49 Radiation survevs.

Paragraph 34.49(c) requires that radiography licensees conduct a survey of the radiographic exposure device whenever.a source is exchanged or before placing a radiographic exposure device in storage if that survey is the last one performed on the workday, and 5 34.49(d) requires these surveys be recorded as specified under 5 34.85. This differs from the previous rule in that it requires a survey whenever the source is exchanged. This information is needed to demonstrate that the radioactive source is in the fully shielded i

position at the end of the work day after the device has been placed in its storage location.

Without such a survey, the device could, if the source is not fully shielded, cause excessive and unnecessary radiation exposure to workers and members of the public.

This section was designated 5 34.49(f) in the proposed rule.

1 I 34.53 Postina.

i This section requires that all areas in which industrial radiography is being performed must be conspicuously posted as required by 5 20.1902 of this chapter.

This burden is covered under the burden for 10 CFR Part 20. This posting is necessary to protect public nealth and safety.

The following sections are not entirely new. Most[ of the requirements contained in these sections were imbedded throughout the previous rule. This Subpart E has been added to place recordkeeping requirements in one location i

in the rule.

5 34.61 Records of specific licenses for radiography.

This new section requires the licensee to have a copy of the license, license conditions, documerits incorporated by reference, and all amendments until the NRC terminates the license. The purpose is so that the licensee will review i

the documents regularly to verify that they are in compliance with the conditions of the license and the commitments that it has made.

l 34.63 Records of receipt and transfer.

This section requires that the licensee maintain records showing receipts and transfers of sealed sources and devices using depleted uranium (DU) shielding for 3 years after the record is made.

Section 30.51 already requires radiography licensees covered under Part 34 to maintain records of byproduct i

material receipt and transfer for 3 years.

This provision was added to Part 34 because some licensees misunderstood the applicability of this requirement.

The following information must be included in the record:

the date, the individual making the record, the radionuclide, number of becquerels (curies) or mass (for DU), and manufacturer, model, and serial number of each sealed source and device, as appropriate. The records allow NRC inspectors to verify the sources the licensee is presently using.

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$ 34.65 Records of radiation survey instruments.

.This new section requires that the licensee maintain records of the calibrations of their radiation survey instruments, and that the records be retained for 3 years. The records allow NRC inspectors to verify that required calibrations have been performed. The licensee will use the records to assure itself that the instruments available to radiographers and radiographers' assistants are properly calibrated.

Because instruments will only have to be calibrated semi-annually under the revised rule versus quarterly under the previous rule, this is a burden reduction, since licensees will be required to maintain fewer records.

In addition, these records are necessary to verify that the licensee is in compliance with NRC requirements as described in i 34.25, and to ensure the safety of the users of these instruments.

I 34.67 Records of leak-testino of sealed sources.

This new section requires that the licensee maintain records of leak test results and that the records be retained for 3 years.

These requirements are the same as those in the previous i 34.25(c). These records are necessary to verify that the licensee is in compliance with NRC requirements as described in the new 5 34.27, and for the licensee to ensure the integrity of the sealed sources in use.

5 34.69 Records of ouarterly inventory.

This section requires that the licensee maintain records of quarterly inventories of sealed sources and devices containing depleted uranium (DU) shielding as specified in 5 34.29.

Paragraph (a) requires that each record be re ained for 3 years after it is made. Most of these requirements are the same as those in the previous i 34.26.

Paragraph (b) requires that the record include the date of the inventory, the name of the individual conducting the inventory, the radionuclide and the number of becquerels (curies) in each device, location of sealed source and/or devices, and the manufacturer, model, and serial number of each sealed source and /or device, as appropriate.

For devices containing DU shielding the record must also show the mass of DU in each container.

These new requirements were added to ensure that licensees maintain complete records to ensure traceability of sealed sources.

The inventories are used by the licensee to verify the location of sources and to control the type, quantity and use of byproduct material. The records allow NRC Inspectors to verify that the required inventories have been conducted and to ensure that the licensee is in compliance with authorized possession limits.

I 34.71 Utilization logs.

Paragraph (a) of this section requires that the licensee maintain utilization logs showing for each sealed radioactive source:

(1) a description, including the make, model number and serial number of the radiographic exposure device or transfer or storage container in which the sealed source is located; (2) the identity and signature of the radiographer to whom assigned; 12 l

(3) the plant or site where used and dates of use, including the dates removed from and returned to storage. The new requirements in this section are the serial number of the radiographic exposure device, the signature of the

' radiographer to whom assigned, and the dates the device is removed from and returned to storage.

These requirements were added to verify that the i

licensee is maintaining adequate control of licensed material. The previous regulation ($ 34.27), only required a description (or make and model number) of the device or storage container, the identity of the radiographer to whom assigned and the plant or site where used and the dates of use.

Paragraph (b) of this section requires that the licensee retain these records for a period of 3 years after the record is made. The records required by this section allow NRC inspectors to determine whether the licensed material has been properly controlled and used.

5 34.73 Records of inspection and maintenance of radiographic exposure devices. transport and storage containers. source changers. and survey instruments.

Paragraph (a) of this new section requires that the licensee maintain records of any equipment problems and any maintenance performed under i 34.31(a) and (b) during inspection and maintenance of radiographic exposure devices, transport and storage containers, associated equipment, source changers, and survey instruments and that the records be retained for 3 years after they are made. The previous rule required that these records be retained in accordance with 5 34.28(b).

Paragraph (b) of this new section states that the record must include the date of check or inspection, name of inspector, equipment involved, any problems found and what repair and/or maintenance, if any were done. The records are needed to enable the licensee to keep track of when the equipment was last inspected and maintained and when inspection is next due.

The records are used by NRC staff to determine the extent of compliance by the licensee, and to detect problems that may be generic to the equipment so that corrective action might be taken.

5 34.75 Records of permanent radiographic installations.

This new section requires that the licensee maintain records of the alarm system and entrance control device tests at permanent radiographic installations as specified under i 34.33 and retain each record for 3 years after it is made.

The previous rule required that these records be retained in accordance with 5 34.29(c).

The records are needed to enable the licensee to keep track of when entrance control and alarm system tests were last performed and when they are next due. The records are also used by NRC inspectors to determine compliance with required testing of important safety equipment and to verify that personnel are not inadvertently exposed by the existence of malfunctioning alarms.

5 34.79 Records of training.

)

This new section requires that the licensee maintain records of training of l

radiographers and radiographers' assistants in accordance with 5 34.43(f).

l Paragraph (a) of this section requires that the record includes certification 13

documents, copies of written tests, dates of practical examinations, and names of individuals conducting and receiving the practical examinations.

Paragraph (b) of this section requires that records of refresher safety training and

' semi annual inspections for each radiographer and each radiographer's assistant be maintained. The records must list the topics discussed, the 4

dates of the training, and names of the instructors and attendees.

For the semi-annual inspections of each radiographer and radiographer's assistant by the RSO or designee, specified in 5 34.43(e), the records must also include a list of the questions asked and any non-compliances observed. The previous regulation did not have a specific recordkeeping requirement except for tests administered. The revised rule requires licensees to keep track of the dates of specific training provided, who provided it, and who received training.

This is needed to enable licensees to demonstrate compliance with NRC requirements and to keep track of when training is required.

The records of the semi-annual inspections of job performance will be used by the licensee to keep track of deficiencies, if noted, so that they can be corrected. This section covers both training records and records of semi-annual inspections, thus the increased inspection frequency from the proposed annual to the final semi-annual and the allowance of oral or written examinations of the licensee's license and operating and emergency procedures do not result in changing the overall burden of this section.

5 34.81 Records of operatina and emeroency procedures.

This new section requires the licensee to retain records of current operating and emergency procedures specified in i 34.45, until the Commission terminates the license.

The records allow the operators to have access to an up-to-date set of written operating procedures so that they can operate the radiography equipment properly. The NRC inspectors review these procedures to ensure that previous instructions are being provided to the workers.

5 34.83 Records of personnel monitorino.

Section 34.83 revises the previous 5 34.33(b) and (e), and requires licensees to maintain exposure records specified in 5 34.47 as follows: (a) direct reading dosimeter readings and yearly operability tests and retain for 3 years after the record is made, (b) records of alarm ratemeter calibrations and retain them for 3 years from the date the record was made, (c) reports from film badge or TLD processor until the Commission terminates the license, and (d) records of estimates of exposures as a result of off-scale personal direct reading dosimeters or lost or damaged film badges or TLDs untii the Commission terminates the license.

The records serve as an important mechanism for controlling exposure on a day-to-day basis, provide indications of inadvertent exposure, and provide a backup record of estimated exposure in case a film badge or thermoluminescent dosimeter is lost.

Direct reading personal dosimeter readings are often the first indication a radiographer has of an overexposure or an improperly stored source.

Records of such dosimeter readings are needed in investigations of incidents and overexposures, since they are the only available record for the exposure received that day.

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l 34.85 Records of radiation survevs.

,This new section requires the licensee to maintain a record of the last survey made on each radiographic exposure device on each day it is used, just prior l

to placing the device in storage, as specified in 5 34.49(c). Also a record l

must be made of the survey taken on a device whenever the sealed source is exchanged as specified in i 34.49(c).

Each record must be maintained for ?

l years after it is made. These records enable the licensee to verify that the required radiation surveys have been.done and that they are in compliance w?th the radiation dose limits.

I 34.87 Forms of records.

This section describes allowable forms for official records. This section (previously at i 34.4) is not new. The word " maintenance" was changed to

" form" in keeping with the latest language used in NRC regulations.

It requires that the records required by Part 34 be legible throughout the specified retention period. The record may be the original or a reproduced copy or a microform provided that the copy or microform is authenticated by authorized personnel and that the microform is capable of reproducing a clear copy throughout the required retention period.

The record may also be stored in electronic media with the capability for producing legible, accurate, and complete records during the required retention period.

Records, such as letters, drawings, and specifications, must include all pertinent information, such as stamps, initials, and signatures.

The licensee is to maintain adequate safeguards against tampering with and loss of records.

I 34.89 Location of documents and records.

1 This section is new.

Paragraph (a) of this section a6s the requirement to maintain copies of records required by this part and itt er applicable parts of this chapter at the location specified in i 34.13(k) to demonstrate compliance i

with NRC regulations in conducting radiographic operations and to ensure that adequate information is available to safely handle radioactive material.

Paragraph (b) of this section adds the requirement to maintain copies of the following documents and records sufficient to demonstrate compliance at any field stations and each temporary jobsite as applicable. The purpose is to demonstrate compliance with NRC regulations in conducting radiographic operations and to ensure that adequate information is available at sites where radioactive material is handled:

(1).

The license authorizing the use of licensed material; (2)

A copy of Parts 19, 20, and 34 of NRC Regulations; (3)

Utilization records for each radiographic exposure device dispatched l

from that location as required by 6 34.71; (4)

Records of equipment problems in daily checks of equipment as required l

by 5 34.73(a);

i (5)

Records of alarm system and entrance control checks required by 5 34.75, if applicable; (6)

Daily pocket dosimeter readings as required by 6 34.47(b);

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i (7)

Operating and emergency procedures required by 5 34.45 (8)

Evidence of the latest calibration of the radiation survey instrument in use at the site, as required by 5 34.65; I9)

Evidence of the latest calibration of alarm ratemeters and operability checks of pocket dosimeters as required by 5 34.47(c);

(10) Latest survey records required by 5 34.85; j

(11) The shipping papars for the transportation of radioactive materials required by 5 71.5 of this chapter; and (12) When operating under reciprocity pursuant to i 150.20 of this chapter, a copy of the Agreement State license authorizing the use of licensed materials.

These sections were designated 55 34.89 and 34.91 in the proposed rule.

In response to comments these sections were combined to eliminate duplication of records and still ensure that a minimum set of records will be available at any jobsite.

5 34.101 Notifications.

This section, [previously at i 34.30], contains notification requirements.

Paragraph 34.101(a) requires written repoits within 30 days of the occurrence of 1) unintentional disconnection of the source assembly, 2) inability to retract the source assembly to its fully shielded position and secure it in this position, and 3) failure of any component critical to safe operation t properly perform its intended function.

Paragraph 34.101(b) specifies that the report required under paragraph (a) of l

this section includes: 1) description of the equipment problem, 2) cause of j

the problem, 3) manufacturer name and model number of equipment involved,

4) date, time and place of the incident, 5) actions taken to establish normal operations, 6) corrective action (s) taken to prevent recurrence, and

7) qualifications of personnel involved in incident.

Paragraph 34.101(c) is a new paragraph that requires the licensee to notify the appropriate NRC regional office in writing within 30 days prior to conducting radiographic operations or storing radioactive material in excess of 180 days at any location not listed on the license. These requirements are necessary in order to provide the NRC with information in a timely manner to permit inspection of radioactive material at these locations !

rasure that they are in compliance with NRC safety regulations.

Appendix A Appendix A would specify the requirements to be an independent organization and the certification program criteria all organizations must address.

Appendix A does not impose new requirements on NRC's radiography licensees.

l Part I of this Appendix provides the requirements to be an independent certifying organization.

Parts 11 and Ill provide the requirements for the certification program and written examinations for a certifying entity, including the Agreement States. NRC anticipates that certifying entities will 16

maintain their program procedures as long as the organization is identified by NRC as a certifying entity.

' Appendix A,.Part 1, item 3 would require that an independent certifying organization have a "rtification program that is open to non-members. This ensures that the independent certifying organization will uphold 10 CFR Part 4, Subpart A -- Regulations Implementing Title VI of the Civil Rights Act of 1964 and Title IV of the Ene.rgy Reorganization Act of 1974 with respect to prohibiting discriminatory actions.

Appendix A, Part I, item 5 would require that an independent certifying organization have an adequate staff, a viable system for financing its operations, and a policy-and decision-making review board. This provides information to the NRC that the organization will have the resources to maintain an adequate program.

Appendix A, Part I, item 6 would require that an independent certifying I

organization have a set of written organizational by-laws and policies that pro. tide adequate assurance of lack of conflict of interest and a system for monitoring and enforcing those by-laws and policies.

The procedures are needed to ensure the independent certifying organization has a program in place for monitoring and enforcing its by-laws and policies. NRC would review the program description to ensure that it includes this element.

Appendix A, Part I, item 9 would require that an independent certifying organization have written procedures describing all aspects of its certification program, maintain records of the current status of each individual's certification and the administration of its certification program. The procedures are needed to ensure that the independent certifying organization has an adequate certification program.

The records are needed by the certifying organization to maintain an awareness of each individual's certification, and to record its activities on the administration of its certification program. They would review the records during periodic program reviews. NRC would review the program description to ensure that it includes this element.

Appendix A, Part I, item 10 would require that an independent certifying organization have procedures to ensure that certified individuals are provided j

due process with respect to the administration of its certification program, including the process of becoming certified and any sanctions imposed against certified individuals. The procedures are needed to ensure that the independent certifying organization provide certified individuals adequate due process. NRC would review the program description to ensure that it includes this element.

Appendix A, Part I, item 11 would require that an independent certifying organization have procedures for proctoring examinations and for ensurn

' st the individuals proctoring each examinauon are not employed by the same company or corporation (or a wholly-owned subsidiary of such company or corporation) as any of the examinees. The procedures are needed to help ensure fairness in the examination process.

NRC would review the program description to ensure that it includes this element.

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Appendix A, Part I, item 12 would require that independent certifying l

organizations and/or Agreement S u tes exchange ~information about certified

, individuals with'the Commission and the Agreement States and allow periodic review of their certification programs and related records.

The exchange of information and periodic review are to ensure that all. individuals' i

certifications are current and valid. NRC would review the program l

description to ensure that it includes this element.

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Appendix A, Part I, item 13 would require that an independent certifying organization provide a description to the Commission of its procedures for choosing examination sites and for providing an appropriate examination environment. The procedures are needed to ensure that the independent j

certifying organization provide for appropriate examination sites and environments.

NRC would review the program description to ensure that it includes this element.

J Appendix A, Part II, item 2 would require that a certification program must require applicants for certification to provide documentation that demonstrates that the applicant has: (a) received training in the topics set forth in Appendix A to this part; (b) satisfactorily completed a minimum period of on-the-job training; and (c) received verification by an Agreement State or a NRC licensee that the applicant has demonstrated the capability of independently working as a' radiographer.

Submission of this documentation to the certifying organization is necessary for the certifying organization to j

verify an applicant's training and to determine that the applicant meets certain certification criteria. NRC would review the program description to ensure that it includes this element.

Appendix A, Part II, item 3 would require that a certification program must include procedures to ensure that all examination questions are protected-from disclosure. The procedures are intended to ensure that the examinees will not have access to certification examination questions. NRC would review the program description to ensure that it includes this element.

Appendix A, Part II, item 4 requires that a certification program must include procedures whereby an application can be denied or a-certification revoked, suspended, and reinstated.

NRC would review the program description to ensure that it includes this element.

The procedures are intended to ensure that the certification. program include provisions for denying applications, revoking, suspending, and reinstating an individual's certification. NRC would review the program description to ensure that it includes this element.

Appendix A, Part II, item 6 would require that a certification progr.am must i.nclude procedures for renewing the certifications and, if the procedures allow renewals without examination, require evidence of recent active I

full-time employment and annual refresher training. The procedures are intended to ensure that the certification program include provisions for certification renewal.

NRC would review the program description to ensure that it includes this element.

Appendix A, Part II, item 7,-- items 7-9 of the proposed rule covering procedures for revocation, suspensions, and sanctions, have been dropped in 18

the final rule in response to comments and this item 7 [ item 10 in the proposed rule), requires that the certification program provide for timely

, responses to public enquiries concerning an individual's certification status.

Appendix A, Part III, item 3 requires that test items be drawn from a question bank containing psychometrically valid questions.

This requirement implies the existence of such a question bank or requires the developrrent of such a bank. At least one such question bank is available for a fee oi as part of an Independent Certifying Organization's certifying program.

Use of examinations utilizing such question banks are addressed in 5 34.13(b)(2) and 5 34.43(a)(2) and the required content of such banks are addressed in 5 34.43(g).

I 71.105 Quality assurance programs.

In response to public comment on 5 34.35 requesting placing the transportation requirements in 10 CFR Parts 71 in Part 34 to reduce the confusion to licensees, the QA requirements for maintenance of transport packages have been included in this section. This, together with a minor conforming change to 10 CFR Part 71, will relieve an existing burden on radiography licensees, who will no longer need to separately submit a transport package QA program description for approval, provided they submit written procedures required by 5 34.31(b)(2) for inspection and maintenance of Type B packaging used to transport radioactive material.

2.

Agency Use of Information The NRC uses the information to ensure that licensees are complying with the appropriate regulations in a manner adequate to protect worker and public safety. The information is also used by the NRC to evaluate licensees' operations to ensure that they are meeting the requirements of their licenses.

3.

Reduction of Burden through Information Technology There are no legal obstacles to reducing the burden associated with this information collection. The revision to 10 CFR Part 34.87 permits licensees to retain records in electronic format.

Reports must still be submitted in writing, since these reports require the signattre of a responsible official.

4.

Effort to Identify Duplication and Use Similar Information The Information Requirements Control Automated System (IRCAS) was searched and no duplication was found. There is no similar information available to the NRC.

5.

Effort to Reduce Small Business Burden Many NRC radiography licensees are small businesses.

Efforts have been made to keep the requirements for information to a minimum.

However, since the consequences of mishandling a radiography source are likely to be the same for large and small entities, it is not possible to further reduce the burden on small businesses by less frequent or less complete recordkeeping or reporting.

19

6.

Consecuences to Federal Program Activities if the Collection is not Conducted or is Conducted Less Freauently Applications are only required to be submitted for the initial license, for amendments, and for renewal every 5 years.

The application process requires that applicants and licensees perform a comprehensive review of their entire radiation safety program to assure that all activities will be or are being conducted safely and in accordance with NRC regulations. The review and submission of the information required for the application is essential to NRC's determination of whether the applicant has training, experience, equipment, facilities and procedures for the use of byproduct material that are adequate to protect the public health and safety. Other reporting and recordkeeping requirements are occasioned by specified events such as leak tests, instrument calibrations, and inventories of licensed material.

Conduct of these tests and other events and collection of irformation concerning them at the.renuired frequency is essential to provide the assurance of protection for the health and safety of workers and the public.

7.

Circumstances Which Justify Variation from OMB Guidelines Section 34.27(d) varies from OMB guidelines in requiring that licensees report within 5 days of the leak testing any result which would indicate that a source is leaking.

This requirement for a report in less than 30 days is necessary because a leaking source could present a radiological hazard to workers and the public, and NRC must be notified promptly in order to be able to assess whether corrective actbns initiated by the licensee are adequate.

Section 34.83(c) restates existing requirements in 10 CFR Part 20, which is cleared under OMB clearance number 3150-0014. Section 34.83(c) requires that licensees maintain reports received from the film badge or TLD processor.

Section 34.83(d) varies from OMB guidelines by requiring that licensees maintain records of estimates of exposures as a result of off-scale pocket dosimeters or lost or damaged film badges or TLDs until the Commission terminater the license.

This information may be needed to reconstruct a worker's dose history in the event they lose their records, and to permit a planned special exposure.

8.

Consultations Outside the NRC The requirements included in the revised rule were extensively discussed in public workshops held in Mobile, Alabama in May 1992, and Dallas, ' Texas in November 1992, comments obtained in these workshops were included in developing the proposed rule.

The proposed rule was published for comment in the Federal Register on February 28, 1994 (59 FR 9429).

In addition, the requirements included in the draft final rule were extensively discussed in a public workshop held in Houston, Texas in December 1994, comments obtained in that workshop were included in revising the final rule.

f 9.

Payment or Gifts to Respondents.

Not applicable.

20

\\

9.

Payment or Gifts to Resnonigd i.

Not applicable.

10.

Confidentiality of Information None, except for proprietary information.

11.

Justification for Sensitive Questions There are no questions regarding sensitive issues.

12.

Estimate of Burden See Tables 1, 2, 3 and 4.

Total 10 CFR Part 34 burden fcr recordkeeping and reporting is estimated to be 43,196 hours0.00227 days 0.0544 hours 3.240741e-4 weeks 7.4578e-5 months . The reduced 10 CFR Part 71 burden for recordkeeping and reporting for radiography licensees is estimated to be

-1,440 hours0.00509 days 0.122 hours 7.275132e-4 weeks 1.6742e-4 months . Total cost for licensees is estimated at $4,960,700 ($120 X 41,406 hrs).

In addition, there is an increase in burden for NPC Form 313 of 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months each for 450 licensees, or an increase of 5,850 hours0.00984 days 0.236 hours 0.00141 weeks 3.23425e-4 months and a cost of

$702,000 ($120 X 5,850 hours0.00984 days 0.236 hours 0.00141 weeks 3.23425e-4 months ).

13.

Est'imate of Other Additional Cost.

Not applicable.

14.

Estimated Annualized Cost to the Federal Governc*n See Table 4.

The estimated annual cost of professional staff effort for activities other than application review, which is included in OMB Clearance 3150-0120, NRC Form 313 for NRC licensees,-is $20,280. This is the staff's best estimate based on the time it takes the staff to review reports sent in by the licensees and the inspection time and frequency of inspection of the licensees. The NRC costs are fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and 171.

15.

Reasons for Chance in Burden or Cost The change in burden in this final rule is due to the revision of 10 CFR Part 34 in its entirety requiring additional information to be submitted on NRC Form 313, cleared under OMB Clearance number 3150-0120.

In addition, changes were scde in the final rule to reflect the reduction in the number of licensees from 700 for the proposed rule to 450 in the final rule, and the reduction in the recordkeeping and reporting burden from $132/hr in the proposed rule to $120/hr in the final rule. Other changes in burden, from the proposed to the final rule, are the result of responses to comments received on the provisions of the proposed rule and are as follows:

Paragraph 34.13(e), currently par wraph 34.11(d) requires that the applicant establish and submit its program for semi-annual inspections of the job performance of each radiographer and radiographer's assistant as described 21 1

quarterly inspections and recommended keeping the quarterly requirement.

Nevertheless, the NRC believes that the increased training required for radiographers' assistants, the requirement for the certification of

'radiographers, and the appointment of an RSO to oversee training and job performance, will compensate for the reduction in the numbers of inspections performed and that a semi-annual frequency may be preferable and has modified the final rule to require semi-annual inspections. This change is also reflected in section 34.79, which covers bot.h training records and records of semi-annual inspections.

The change in burden for 5 34.79 merely reflects the decrease in the number of licensees affected by this rule.

There were 700 licensees at the time of the proposed rule. There are 450 licensees at the time of the final rule.

Paragraph 34.13(i) is new.

This is a new section not in the proposed rule and was added in response to comments.

It requires an applicant to describe calibration procedures for survey instruments, if the applicant intends to perform their own calibrations. A commenter suggested that a requirement be added to license individuals who perform survey instrument calibrations.

Because the NRC believes that the suggested requirement would be an unnecessary burden a requirement to submit calibration procedures as part of their operating and emergency procedures with the application was included in the final rule. This is an increase in the overall burden for NRC Form 313 of 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months per licensee.

Paragraph 34.13(k) is new.

This is a new section not in the proposed rule and was added in response to comments received on 5 34.89 that provisions in the proposed rule requiring retention of records at specific locations was overly burdensome.

Paragraph 34.13(k) requires license applicants to identify the locations where all records will be mainhined. This provides the licensees with greater flexibility.

In addition, 55 34.89 and 34.91 in the proposed rule have been combined into one section ($ 34.89).

In response to comments these sections were combined to eliminate duplication of records and still ensure that a minimum set of records will be available at any jobsite.

The change in burden for 5 34.89 reflects the combination of 55 34.89 and 34.91 and the decrease in the number of licensees affected by this rule.

There were 700 licensees at the time of the proposed rule. There are 450 licensees at the time of the final rule.

Paragraph 34.20(f) in the proposed rule, which specified that all associated equipment acquired after January 10, 1996, had to be labelled to identify that components met the requirements of 5 34.20, is deleted in the final rule. This is in response to a commenter who was concerned that a large amount of associated equipment that meets ANSI N432-1980 and 10 CFR 34.20, and is currently in use is not labelled.

Because compliance can be determined only at the time equipment is manufactured, the commenter was concerned that qualified associated equipment may not be authorized for use. The NRC is currently re-evaluating the applicability of the ANSI Standard N432-1980 for associated equipment.

In response to comments raised on the proposed rule and subsequent comments from a number of licensees requesting interpretation of Information Notice 96-20, issued on April 4,1996, the NRC will consider the need for an amendment to i 34.20.

This is an overall decrease from the l

22

l l

l i

i l

proposed rule of I hour per licensee of the 700 licensees in place at the time i

l of the proposed rule, Appendix A, Part II, item 7,.-- items 7-9 of the proposed rule covering procedures for revocation, suspensions, and sanctions, have been dropped in the final rule in response to comments and this item 7 (item 10 in the proposed rule), requires that the certification program provide for timely l

responses to public inquiries concerning an individual's certification status.

The Agreement States expressed concerns that laws within their state may prevent them from taking these actions so the rule was changed.

This is an overall increase from the proposed rule of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per licensee per item that may have submitted a certification program for approval. The final rule assumes that 50 licensees will submit certification programs for approval at a burden of I hour per licensee.

16.

Publication for Statistical Use None.

17.

Rearon for Not Displaying the Expiration Date.

The requirement will be contained in a regulation.

Amending the Code of Federal Regulations to display information that, in an annual publication, could become out of date would confuse the public.

18.

Exceptions to the Certification Statement.

Not applicable.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not employed in the collection of information.

l i

23 i

(

TABLE 1 INFORMATION COLLECTION BURDENS ASSOCIATED WITH RECORDKEEPING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION LIC HRS /

TOTAL COST AT REC.

NOTES AFFECTED LIC BilRDEN

$120/HR RET.

34.20(b)(1) 450 1

450 54,000 3 Yrs Labels 34.20(b)/*)

360 0

see OMB Clearance No. 3150-0008 34.25(c) 450 0

0 3 Yrs see 1 34.65 34.27(c)(2) 450 0

0 3 Yrs see 1 34.67 34.27(e) 225 0

3 Yrs see 1 34.67 34.29(b) 450 0

0 see 1 34.69 34.31(b)(1) 450 3

1,350 162,000 34.31(b)(2) 360 3

1,080 129,600 34.31(c) 450 0

0 see 1 34.73 34.33(b) 112 0

0 see 1 34.75 4.35(a) 450 1

450 54,000 3 Yrs 34.35(b)(2) 360 2

720 86,400 3 Yrs 34.41(c) 90 4

360 43,200 34.43(b)(1) 450 1

450 54,000 some new 34.43(c)(1) 450 1

450 54,000 some new 34.43(f) 450 0

0 0

see i 34.79 34.45(b) 450 0

0 RULT' see i

, 6 34.81

{

SUBTOTAL 5,310 637,200 i

' Retain until license is terminated.

24

f TABLE 1 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH RECORDKEEPING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION LIC HRS /

TOTAL COST AT REC.

NOTES AFFECTED LIC BURDEN

$120/HR RET.

34.47(b) 450 0

0 3 Yrs see i 34.83(a) 34.47(c) 450 0

0 3 Yrs see 1 34.83(a) j 34.47(d) 25 0

0 RULT' New, see l 34.83(d) 34.47(e) 25 0

0 RULT' New, see 1 34.83(d) 34.47(f) 450 0

0 RULT' see 1 34.83(c) 34.47(g)(4) 450 0

0 3 Yrs New, see 5 34.83(b) 34.49(d) 450 0

0 3 Yrs see 5 34.85 34.53 450 0

0 See OMB Clearance No, 3150-0014 34.61 450 1

450 54,000 RULT' New 34.63 450 1

450 54,000 3 Yrs 34.65 450 1

450 54,000 3 Yrs 34.67 450 3

1,350 162,000 3 Yrs j

34.69 450 2

900 108,000 3 Yrs 34.71(a, b) 450 50 22,500 2,700,000 3 Yrs some info new 34.73(a,b) 450 2

900 108,000 3 Yrs some new info 34.75 112 3

336 40,320 3 Yrs some new info l

34.79(a, b) 450 6

2,700 324,000 3 Yrs l

34.81 450 2

900 108,000 RULT' 34.R3(a) 450 4

1,800 216,000 3 Yrs some new i

l SUBT0TAL 32,736 3,928,320 l

' Retain until license is terminated.

25

TABLE 1 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH RECORDKEEPING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION LIC HRS /

TOTAL COST AT REC.

NOTES AFFECTED LIC BURDEN

$120/HR RET.

34.83(b) 450 2

900 108,000 3 Yrs some new 34.83(c) 450

.0 0

See OM8 Clearance No. 3150-0014 34.83(d) 25 2

50 6,000 RULT' some new 34.85 450 1

450 54,000 3 Yrs some new i

34.87 450 0

0 Format only 34.89 450 3

1,350 162,000 3 Yrs Appendix A, 1

0 0

life of See Part I, program Appendix item 3 A, Part I, l

Item 9 Appendix A, 1

0 0

life of See Part I, program Appendix item 5 A, Part I, Item 9 Appendix A, 1

10 10 1,200 life of Part I, program item 6 Appendix A, 1

40 40 4,800 life of Part I, program item 9 Appendix A, 1

10 10 1,200 life of Part I, program item 10 Appendix A, 1

10 10 1,200 life of Part I, program

. item 11 Appendix A, 1

10 10 1,200 life of Part I, program j

item 13 Appendix A, 450 1

450 54,000 Part II, item 2 SUBT0TAL 3,280 393,600

' Retain until license is terminated.

26

TABLE 2 INFORMATION COLLECTION BURDENS ASSOCIATED WITH REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION NUMBER OF HOURS /-

TOTAL COST AT REP.

NOTES RESPONSES

RESPONSE

BURDEN

$120/HR RET.

34.27(d) 15 2

30 3,600 34.43(a) 225 2

.450 54,000 (2) 34.101 5

10 50 6,000 (a and b) 34.101 450 2

900 108,000 New (c)

Appendix 1

10 10 1,200 life of A, Part program I, Item 12 TOTAL 1,440 172,800 28

i TABLE 3 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 34 j

THAT ARE COVERED BY OM8 CLEARANCE NO. 3150-0120 J

SECTION LICENSEES HOURS /

TOTAL COST AT REP.

NOTES AFFECTED LICENSEE BURDEN

$120/HR RET.

34.11 450 RULT' See OMB Clear-ance No.

3150-0120 34.13(b) 450 1

450 54,000 RULT' In-crease i

over OMB Clear-ance No.

3150-0120 34.13(c) 450 0

RULT' See OMB Clear-ance No.

3150-0120 34.13(d) 450 0

RULT' See OMB Clear-ance No.

3150-0120 34.13(e) 450 0

RULT' See OMB Clear-ance No.

3150-0120

' Retain until license is terminated.

29

TABLE 3 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 34 THAT ARE COVERED BY OM8 CLEARANCE NO. 3150-0120 SECTION LICENSEES HOURS /

TOTAL COST AT REP.

NOTES d

AFFECTED LICENSEE BURDEN

$120/HR RET.

34.13(f) 450 0

See OMB Clear-ance No.

3150-0120 34.13(g) 450 1

450 54,000 RULT' In-crease over DMB Clear-ance No.

3150-0120 34.13(h) 450 5

2,250 270,000 RULT' In-crease over OMB Clear-ance No.

3150-0120 34.13(i) 450 5

2,250 270,000 RULT' In-crease over 0MB Clear-ance No.

3150-0120 34.13(j) 450 0

0 See OMB Clear-ance No.

3150-0120 i

+

' Retain until license is terminated.

f 30 i

1

l TABLE 3 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 34 THAT ARE COVERED BY OMB CLEARANCE NO. 3150-0120 SECTION LICENSEES HOURS /

TOTAL COST AT REP.

NOTES AFFECTED LICENSEE BURDEN

$120/HR RET.

34.13(k) 450 1

450 54,000 In-crease over 0MB Clear-ance No.

3150-0120 TOTAL N/A 5,850 702,000 31

TABLE 4 l

'INFORMATION COLLECTION BURDENS ASSOCIATED WITH REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 71 I

I SECTION NUMBER OF HOURS /

TOTAL COST.AT REP.

NOTES RESPONSES

RESPONSE

BURDEN

$120/HR RET.

l 71.105 360 4

1,440

-172,800 L

1 i

i 32

f.,

l TABLE 5 ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT J

FOR REVIEW 0F REPORTS ASSOCIATED WITH THE REVISED 10 CFR PART 34 SECTION NUMBER OF STAFF FEDERAL GOVERNMENT RESPONSES HOURS / RESPONSE COST AT $120/HR 34.27(d) 2 1

240 j

34.101(a and b) 4 4

1,920

'{

18,000

.{

34.101(c)-

150 1

Appendix A, Part 1

1 120 I, Item 12 TOTAL 157 7

20.280 l

l 1

l l

I i

i i

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I 33

[7590-01-P]

U. S. NUCLEAR REGULATORY COMMISSION Documents Containing Reporting or Recording Requirements:

Office of Management and Budget (OMB) Review AGENCY:

U. S. Nuclear Regulatory Commission (NRC).

ACTION:

Notice of the OMB review of information collection and solicitation of public comment.

SUMMARY

The NRC has recently submitted to OMB for review the following l

proposal for collection of information under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35).

1.

Type of submission, new, revision, or extension:

Revision.

2.

The title of the information collection:

10 CFR Part 34,

" Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations," 10 CFR Part 71, " Packaging and Transportation of Radioactive Material," and NRC Form 313,

.4 Application for Material License.

(. f"$

3.

The form number if applicable:

NRC Form 313.

h' rf ' g M'

060052

[\\,,

appsppppptp

4.

How often is the collection required: On occasion, such as upon submittal of an application for a materials license or renewal or upon discovery of a leaking source.

5.

Who will be required or asked to report:

Licensees and applicants requesting approvals in accordance with 10 CFR Part 34.

6.

An estimate of the number of responses:

Part 34 - 696.

Part 71 - (-)450. NRC Form 313 - 450.

7.

The estimated number of annual respondents: 450.

8.

An estimate of the number of hours needed annually to complete the requirement or request:

Part 34 - 1.440 hours0.00509 days 0.122 hours 7.275132e-4 weeks 1.6742e-4 months for reporting (approximately 3.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per response) plus an additional 41.406 hours0.0047 days 0.113 hours 6.712963e-4 weeks 1.54483e-4 months for recordkeeping (approximately 92 hours0.00106 days 0.0256 hours 1.521164e-4 weeks 3.5006e-5 months per licensee):

Part 71 - (-)1.440 hours0.00509 days 0.122 hours 7.275132e-4 weeks 1.6742e-4 months for reporting and recordkeeping i

(approximately (-)3.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months eor response): 'NRC Form 313 - 5.850 hours0.00984 days 0.236 hours 0.00141 weeks 3.23425e-4 months for 450 licensees (apprcanetely 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months per response).

9.

An indication of whether Section 3507(d). Pub. L.104-13 applies:

Applicable.

10.

Abstract:

The NRC regulation.10 CFR Part 34. specifies the information and data to be provided by applicants and licensees l

using byproduct material for industrial radiography.

10 CFR Part 1

2 l

34 has been revised in its entirety. The revision adds to or modifies the' requirements to include additional training of radiographers' assistants, leak tests of "S" tubes, and specifies 1

j records to be kept at various locations. The revision deletes the requirement for radiography licensees to submit a Quality Assurance program under 10 CFR Part 71. The revision requires the following additional information to be reported on NRC Form 313, Application for Materials License:

locations and descriptions of 1

all field stations and permanent radiographic installations, designation of a Radiation Safety Officer, and additional information on training and testing. This information is reviewed by NRC to ensure that the safety of radiographers and the public is protected.

F 4

Submit by (insert date 30 days after publication in the Federal Reaister),

comrents that address the following question:

1.

Is the proposed collection of information necessary for the NRC to properly perform its functions? Does the information have practical utility?

i 2.

Is the burden estimate accurate?

3.

Is there a way to enhance the quality, utility, and clarity of the information to be collected?

4 3

l

s a

Coments can also be submitted by telephone at (202) 395-3084.

The NRC Clearance Officer is Brenda Jo Shelton, (301) 415-7233.

i

./

O day of M4%

1997.

Dated at Rockville, Maryland, this

/

l For the Nuclear Regulatory Comission.

-liLCr' lk.d.gf&

/

2 M

. Gerald F. Cranford, Desigtfated Senibr Official for Information Resources Management.

J 1

5

-

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