Text

Request for OMB Review & Supporting Statement Re 10CFR72, Licensing Requirements for Independent Storage of Spent Nuclear Fuel & High-Level Radwaste. Estimated Respondent Burden Is 21,529 H.Supporting Statement Encl
	ML20155E756
Person / Time
Issue date:	10/08/1998
From:	Shelton B; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:	;
Shared Package
ML20155E242	List: ML20155E238; ML20155E756;
References
	OMB-3150-0132, OMB-3150-132, NUDOCS 9811050172
	Download: ML20155E756 (15)
	v • d • e

I PAPERWORK REDUCTION ACT SUBMISSION Pl: ass 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 Management and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503.

1. Agency / Subagency onginating request 2 OMB control number

)

U.S. Nuclear Regulatory Commission J

a 3150-0132 b None

3. Type of information collection (checA one) 4 Type of review requested (check one)

s. New collection J

a Regular

' c. De!egated b Revision of a currently approved collection b Ernergency Approval requested by (date)

c. Extension of a currently approved collection

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

d. Re nstatement, without change, of a previously approved substantal number of small ent' ties?

i collection for which approval has expired J

b.No

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

f. Existing collection in use without an OMB control number

304999

7. Title 10 CFR 72, Licensing Requirements for the hdependent Storage of spent Nuclear Fuel and Iligh-Level Radioactive Waste

8. Agency form number (s) (if apphcacle)

N/A

9. Keyworcs Nuclear Materials, Recordkeeping and Reporting Requirements, Spent Nuclear Fuel

10. Abstract Proposed rule,10 CFR 50,52,72," Changes, Tests, and Experiments" revises requirements pertaining to changes, tests, and experiments, and for updating final safety analysis reports. The purpose of the rulemaking is to clarify requirements and to allow more ficxibility for ce'tain changes that a licensee could make without r

receiving prior NRC approval.

11. Affected pubhc tMare unwy wrn vsms en orners that awy worn v)

12. Obligation to respond wvs wmem e,th v ano an amers that acm e v a Individuals or households d Farms a Voluntary T

b. Business or other for-profit T e FederalGovernment b Required to obtain or retun benetts

c. Not-for-profit institutions f State. Local or Tribal Government P

c Mandatory

13. Annual reporting and recordkeeping hour burden 14 Annual reporting and recordkeeping cost burden e moosamn o r. e<s a Total annuahzed capital /startup costs a Number of respondents 102 b Total annua costs (O&M) r

b. Totalannualresponses

c. Total annushzed cost requested

1. Percentage of these responses collected electronically d Current OMB inventory

c. Total annual hours requested 21.529 e Difference

d. Current OMB inventory 21.529 t

f Explanaton of di+ference e D#m 0

l' Prograrn change

f. Explanation of difference

2. Ad;ustment

1. Program change

2. Adjustment g

'h

15. Purpose of information collection

16. Frequency of recordkeeping or reporting (check all tur opty)

' eta (Maris pnmary with *P"and allorhers that apply with T)

]

a. R8CGIdkeeping b Thirdga4 disclosure i

a. Application for benefits

~

e. Program planning or management 7-7 1. On occasion

~

2. Weekly 3 Monthly

c. Reporting

~

( gg

b. Program evaluation

f. Research 4 Quarterly 5 Semi-annually 6 Annually lh

c. General purpose statistics [ g. Regulatory or compliance 7 Biennially 8 Other(describe) d Audit l hog

17. Statistical methods 18 Agency contact (person who can best answer questico regareng the content r1 tnis sumsson)

'e Does this information collection employ statistical methods?

q

!Go Name Roberta Ingram lh Yes

]No 301-415-1219 Phone.

l 10/95 OMB 83-1

8 '*" *** esrgned useg inF orms

19.Cartifictti:n fcr Pcp:rwork Rzduction Act Submincions On behalf of this Federal agency,I certify that the collection ofinformation encompassed by this request complies with

' 5 CFR 1320.9.

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 with reference to Ihose regulatory provisions as setforth in the instructions.

The following is 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; (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 lbt under 5 CFR 1320.8 (b) (3):

(i)

Why the information is being collected; Oi) the ofinformation; (iii) Burden estimate; (iv) Nature of response (voluntary, required for a benefit, or mandatory);

l (v) Nature 01 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 etlicient and effective manage.

t (i)' I?IfseNYINfive$n# "bScTenk Efat'fshc# fS!ff@v McE"8dfog'y;'aEh19 f the instructions);

i I de a

(j) It makes appropriate use of infnrmation 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 Sgnature of Autnonzed Agency Offical Date Sqnature of Senior Official or designee..

Date

.m m

i u

4-Sh

!/

X

/

Jo. She$n.NRCFDiestanciOfficer. Office of the Chief Information Officer

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OEAS 83-1 10/95

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l OMB SUPPORTING STATEMENT FOR PROPOSED RULE 10 CFR PARTS 50,52 and 72 CHANGES, TESTS, AND EXPERIMENTS AND UPDATING OF FINAL GAFETY ANALYSIS REPORTS 3150-0011 and 3150-0132 REVISION Descriotion of the Information Collection The existing regulations under 10 CFR 50.59 (OMB Clearance No. 3150-0011) specify record-keeping and reporting requirements of changes, tests and experiments performed by licensees of production and utilization facilities. Section 72.48 (OMB Clearance No. 3150-0132) specifies requirements similar to those in section 50.59, but applicable to independent spent fuel storage installations (ISFSI). In particular, these sections require licensees to maintain records of evaluations of changes, tests and experiments and to periodically subn.it a report with a brief description of the change, test or experiment and a summary of the evaluation. In the subject proposed rulemaking, the NRC is proposing to revise certain provisions of these regulations as they pertain to the conduct of evaluations of such changes, tests, and experiments. The purpose of the rulemaking is to clarify the requirements through definitions, and to provide some flexibility for licensees to make changes without NRC approval that have only minimal impact on safety. These revisions may impact upon the recordkeeping and reporting burden of the existing rules; in addition, some revisions to the recordkeeping and reporting requirements.themselves are being proposed.

Existing requirements in sections 50.71(e) (OMB Clearance No. 3150-0011) and 72.70 (OMB Clearance No. 3150-0132) require power reactor licensees and ISFSI licensees, respectively, to periodically submit updates to their Final Safety Analysis Reports (FSAR). The proposed rule would modify in certain respects the form of the information to be included in these updates to the FSAR. In addition, the proposed rule would add sections pertaining to update requirements for FSARs with respect to general licensees under Part 72, and to Certificate holders, sections 72.216(d) and 72.248 respectively.

The proposed rule would also make changes to 10 CFR Part 52 that have no effect on its information collection.

A. JUSTlFICATION 1.

Need for the Collection of Information.

Section 50.59(a) throuch (d)

The proposed rule would add definitions to clarify which changes require evaluation to determine if prior NRC approvalis needed. There may be a slight increase in burden for licensees who have not previously interpreted the rule requirements as requiring l

evaluations of additions, or of changes to evaluation methods and analyses. There may

2 be a slight unquantifiable decrease in burden from the clarification that changes to procedures do not require evaluation pursuant to section 50.59 if other provisions (such as in section 50.54) apply. Records and reports of changes that meet the specified definitions and criteria are needed to enable the NRC to assure that the licensee has properly exercised the authority granted by this section.

The proposed rule would also specify more cicarly that reference to " safety analysis report" should be read to mean the FSAR, as updated. Further, explicit language would be added to require that the evaluation of changes consider other changes already implemented, but not yet reflected in the submitted FSAR. These proposed rule changes are not viewed as adding additional reporting or record keeping burden; rather, these changes would align the stated rule requirements with standard implementation practice.

Were a licensee to conduct its evaluations against a version of the safety analysis report that did not include consideration of other changes made, such as those that were to be reflected in the required updates, those evaluations would not provide needed assurance that the licensee-planned change (to be rnade without prior NRC review and approval) would not impact the licensing basis of the facility.

Another proposed change in this rulemaking is the requirement in section 50.59(d) that records be retained until the termination of a license granted pursuant to Part 54. Part 54 contains the provisions for renewal of a power reactor license originally issued under Part 50. The records to be retained contain vitalinformation about reactor facility changes, tests and experiments made without prior NRC approval. Without these records, NRC's ability to protect the health and safety of the public would be reduced.

There is no increased burden unless a licensee applies for and receives a renewed license. Further, the burden associated with the additional record retention would likely be incurred by licensees in the course of doing business.

Section 50.71(e)

The proposed rule would add language that explains in more detail what is meant by the existing requirements that the update to the FSAR should reflect the effects of changes made pursuant to section 50.59. Since as part of the proposed rule the NRC is proposing some relaxation m the criteria such that more changes can be made without prior NRC approval, NRC needs to have greater confidence that the updates to the FSAR will show the corabiNd effect of multiple changes if they are made. In the Statement of Considerations for promulgation of 10 CFR 50.71(e) (45 FR 30615), the NRC commented on the relationship between changes made under 10 CFR 50.59 and FSAR updating, stating: "The 50.59(b) reporting may not be detailed sufficiently to be considered adequate to fulfill the FSAR updating requirement. The degree of detail required for updating the FSAR will be generally greater than a 'brief description' and a

' summary of the safety evaluation'." Further, it said: "New analyses...which were required during consideration of unreviewed safety questions, technical specifications or other licensing questions may be incorporated as appendices or otherwise inserted within the FSAR." Thus, the Commission clearly expected the update submittal to include sufficient information to appropriately reflect the changes that were made. The increased burden associated with explicitly documenting in the update the effects of the

4 3

changes on event probabilities and consequences and related information is at most small (and arguably was required by the rule as originally written).

Section 72.48 The proposed rule would add to section 72.48(a) definitions to clarify which changes require evaluation to determine if prior NRC approvalis needed. There may be a slight increase in burden for licensees who have not previously interpreted the rule i

requirements as requiring evaluations of additions, or of changes to evaluation methods and analyses. There may be a slight unquantifiable decrease in burden from the clarification that changes to procedures do not require evaluation pursuant to section 72.48 if other provisions apply. On balance, the NRC estimates at most a slight net increase of a few hours per year. Records and reports of changes that meet the specified definitions and criteria are needed to enable the NRC to assure that the licensee has properly exercised the authority granted by this section.

The proposed revision to section 72.48(b) would also grant authority to holders of Certificates of Compliance for a spent fuel storage cask to make changes to the cask design without prior NRC approvalif specified conditions are satisfied. Recordkeeping and reporting as specified in section 72.48(c)(renumbered from (b)) will be required by the certificate holders. Records and reports of changes are needed to enable the NRC to assure that the licensee has properly exercised the authority granted by this section.

l As part of the proposed rule, NRC would add in section 72.48(c) an explicit requirement to retain, until termination of the license or CoC, records that provide the basis for the determination that changes did not involve significant occupational exposure or environmentalimpact. This is not viewed as posing an increased burden for licensees because the evaluations were already required, and the rule already required maintaining records that provided the basis for determining that other evaluation criteria were satisfied. For a holder of cask CoC who permanently ceases operation, any such records shall be provided to the new holder of cask CoC or to the Commission pursuant to section 72.234(d)(3). The burden associated with recordt.eeping for CoC holders results from the requirements of proposed section 72.48(b) to prepare these records;'his section then discusses the retention requirements.

Section 72.70 The proposed rule provides more specificity on filing of updates to the FSAR, such as by use of replacement pages. The proposed rule would also explicitly state that the FSAR update is to include description of changes to procedures made pursuant to section 72.48. On balance, these requirements are considered to not increase the burden; there may be a slight increase for descriptions of procedures, and there may be burden reduction by limiting the number of pages that need to be submitted in accordance with existing requirements for submittal of updates to the FSAR.

j 4

Sgqtiqq 72.216(d)

This section adds requirements for the annual filing of updates to FSARs for certified casks that a generallicensee has changed through use of the authority under section 72.48 (as noted above). The rule would require that the updates be provided both to the NRC and to the certificate holder. There is no burden if no changes are made; however, should a generallicensee make changes, reports are needed to enable the NRC to maintain cognizance of the licensed facility, and thus assure public health and safety.

Submittal of a copy of the report to the certificate holder is a small burden that provides usefulinformation that the certificate holder might need to exercise its responsibilities under the certificate.

Section 72.244 This section adds a requirement for a certificate holder to file an amendment application with the Commission whenever the certificate holder desires to amend the CoC. The application shall describe the changes desired and the reasons for such changes. This information is needed so that NRC can determine whether the amendment can be issued without endangering public health and safety. The burden is expected to be 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months l

per change that a certificate holder wishes; the NRC estimates that there may be one l

such application every two years per CoC holder.

Section 72.248 This section adds requirements for filing of updates to FSARs by holders of certificates of compliance for a spent fuel storage cask. In particular, CoC holders are to submit an update 90 days after Commission approval of the cask design (per paragraph (a)), and annually thereafter to reflect changes to facility and procedures made by the CoC holder (per paragraph (b)). The updates are to be provided to the NRC and to each general licensee that uses the certified cask as.specified in paragraph (c). Other rule provisions proposed to be added in this rulemaking would grant authority to CoC holders to make changes to the certified cask design without prior NRC approval, under specified conditions. Updates to the FSAR that include descriptions of the changes made under this authority are needed for NRC to maintain cognizance of the certified cask design as it is used at licensed facilities, and thus to assure public health and safety. Submittal of reports to the generallicensees is a very small burden necessary to ensure that users of the cask are familiar with changes that the holder has made so that the licensees can maintain cognizance of the design and operational features of that cask type.

2.

Acency Use of Information The records are used by licensees to interrelate subsequent changes and to prepare reports concerning changes, tests, and experiments as required by this section of the regulations. These records are also frequently used by NRC inspectors. The records provide the background information needed by the NRC inspector during his or her visit l.

to a licensed facility. The inspector uses these records to confirm the appropriateness of changes, tests or experiments, or during evaluations of abnormal occurrences. Also, the I

i 5

1 inspector uses these records to ensure that changes and modifications to the facility do not compromise its licensing basis.

The agency uses the updated FSAR information supplied by the licensees in response to the reporting requirements (sections 50.71(e) and 72.70) as a primary reference source to be employed during the numerous safety studies undertaken by licensees, the Commission, and other interested parties.

3.

Reduction of Burden Throuoh Information Technolooy There is no legal obstacle to the use of information technology. Moreover, NRC encourages its use and has a goal of receiving at least 70 percent of all documents in electronic format by the year 2000. At the current time, however, no responses are submitted electronically.

4.

Efforts to identify Duolication and Use Similar Information The information is not required by any other Federal regulation. The information Requirements Control Automated System (IRCAS) was searched, and no duplication was found. This information can only be obtained from licensees of power and nonpower (research/ test) reactors, or from licensees and certificate holders for independent spent fuel storage installations, monitored retrievable storage or spent fuel storage casks.

S.

Effort to Reduce Small Business Burden The burden on small businesses affects 55 licensees of nonpower reactors and 7 holders of certificates of compliance for spent fuel storage casks. This burden only occurs when licensees or certificate holders choose to make changes, tests or experiments and cannot be further reduced without endangering the health and safety of the public.

6.

Consecuences to Federal Prooram or Poliev Activities if the Collection is not Conducted or is Conducted Less Frecuentiv The NRC would not be able to ensure public health and safety with respect to changes made to the facility without prior NRC approval.

7.

Circumstances which Justifv Variation from OMB Guidelines The information required pursuant to 10 CFR 50.59 is submitted annually or along with FSAR updates, or at shorter intervals as may be specified in the license and, therefore, does not vary from OMB guidelines. The record retention periods specified in 50.59(d)

(5 years, and until termination of the license (either under Part 50 or under Part 54)) are required because these records provide the NRC with vitalinformation about reactor l

facility changes, tests and experiments made without prior NRC approval. Without these records, NRC's ability to protect the health and safety of the public would be reduced.

9 6

A similar need exists for retention of records as required by section 72.48 for changes, tests or experiments performed by licensees of ISFSI or CoC holders.

l The updated FSAR must be retained until the operating license is terminated because, in order for the NRC to ensure the public health and safety at all times, the staff must be certain of the current status of a facility's design and supporting analysis requirements.

8.

Consultations Outside the NRC Opportunity for public comment for the revised reporting and recordkeeping requirements associated with sections 50.59,50.71(e),72.48,72.70,72.216,72.244 and 72.248 has been published in the Federal Register.

9.

Payment or Gift to Resoondents Not applicable.

l 10.

Confidentiality of Information No confidential information is generally received. However, proprietary or confidential information is handled in accordance with 10 CFR 2.790 of the NRC regulations.

11.

Justification for Sensitive Questions This information collection does not require sensitive information.

12.

Estimated Industry Burden and Burden Hour Cost The burden from recordkeeping and reporting requirements arising from the proposed rule is estimated as shown in the attached Tables. For purposes of this estimate, NRC has used the assumptions used in its most recent information collection request to the Office of Management and Budget concerning the existing regulations, except for those aspects specifically impacted by the proposed rulemaking. The burden estimate, including an estimate of one-time costs as a result in changes to the rule requirements, is shown in the attached table. As noted, the NRC concludes that the effect of the proposed changes on recordkeeping and reporting requirements will be at most a small increase over the existing burden.

For Part 72 facilities, the existing burden for reporting and recordkeeping is quite smallin comparison to that for Part 50 facilities. This is because the number of licensees is smaller and the expected number and complexity of changes is less than would be expected for reactors. The NRC estimates the change in burden for Part 72 as being

~ _ _ -.

7 only a slight increar,a over the existing burden and the increase is associated with the proposed rule changes related to CoC holders.-

While one-time costs will be incurred for procedure revisions and training, NRC expects savings to result from the flexibility provided forlicensees to implement certain changes without the need to submit a license amendment request for NRC approval.

13.

Estimate of Other Additional Costs None.

14.

Estimateo Annualized Cost to the Government The utimated annualized cost to the government is not expected to change as a result i

of the proposed rule except for a one-time burden to revise existing procedures and to train staff. The estimated burden is 6,100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months at a cost of $756,400 ($124 an hour).

4 The cost is fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Pads 170 and 171.

15.

Reasons for Chanae in Burden or Cost The proposed rule would increase the information collection burden by an estimated 66,099 hours0.00115 days 0.0275 hours 1.636905e-4 weeks 3.76695e-5 months . This burden increase is as follows and is shown on the attached Tables.

Under Part 50, the reporting burden would increase per response for 50.59(d) from 400 l

to 412 hours0.00477 days 0.114 hours 6.812169e-4 weeks 1.56766e-4 months ; 50.71(e), for operating power reactors, from 1,000 to 1,040 nours; and 50.71(e), for decommissioning power reactors, from 250 to 260 hours0.00301 days 0.0722 hours 4.298942e-4 weeks 9.893e-5 months for a total Part 50 reporting burden increase of 3,450 hours0.00521 days 0.125 hours 7.440476e-4 weeks 1.71225e-4 months . The recordkeeping burden under Part 50 increases by 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months per recordkeeper for a total of 8,544 hours0.0063 days 0.151 hours 8.994709e-4 weeks 2.06992e-4 months , and also includes a one-time annualized burden of 52,115 hours0.00133 days 0.0319 hours 1.901455e-4 weeks 4.37575e-5 months to revise existing procedures. The total Part 50 burden increase for the proposed rule is thus 64,109 hours0.00126 days 0.0303 hours 1.802249e-4 weeks 4.14745e-5 months , i

For Part 70, the proposed rule adds 7 respondents under 72.48,72.244 and under i

72.248. The reporting burden per response for 72.216(d) increases from 0 to 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months ; for 72.244 from 0 to 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months ; and for 72.248 from 0 to 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months for a total Part 72 reporting increase of 930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months . The recordkeeping burden under Part 72 adds 7 recordkeepers and increases the burden per recordkeeper from 10 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for a total of 106 hourc. As in Part 50, Part 72 also includes a one-time annualized burden of 954 hours0.011 days 0.265 hours 0.00158 weeks 3.62997e-4 months to revise existing procedures. The total Part 72 burden increase for the proposed rule is thus 1,990 hours0.0115 days 0.275 hours 0.00164 weeks 3.76695e-4 months .

16.

Publication for Statistical Use The collected information is not published for statistical use.

4

1 8

1 17.

Reason for not Disolavina the Exoiration Date 1

The requirements are contained in regulations. Amending the Code of Federal Regulations to display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.

18.

Exceotions to the Certification Statement None.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.

I 1

l

9 ANNUAL REPORTING BURDEN (INCREASE)

ANNUAL SECTION NO.OF RESPONSES PER TOTAL BURDEN PER BURDEN COST RESPONDENTS RESPONDENT RESPONSES

RESPONSE

(HRS /YR)

@$124/HR 50.59(d) 135 1

135 412 (+12) 55,620 (+540) 56,896,880 50.71(e) (Power 71 1

71 1,040 (+40) 73,840(+2,840)

$9,156,160 Rx) 50.71(e)(Decomm 7

1 7

260 (+10) 1,820 (+70)

$225,680 Pwr Rx) 72.48(c) 18(+7) 1 18(+7) 10 180 (+70)

$22,320 72,70*

7 1

7 120 840

$104,160 72.216(d) 4 1

4 40 (+40) 160 (+160)

$19,840 72.244 7(+7) 0.5 3.5(+3.5) 120(+120) 420 (+420) 52,080 72.248(a), (b),(c) 7(+7) 1 7 (+7) 40 (+40) 280 (+280) 534,720 TOTAL REPTG 252.5 (+17.5) 133,160 (+4,380)

S16,511,840 BURDEN

No change.

Note: Section 50.71(e) requires the filing of updates annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. For operating reactors that are decomrnissioning, updates are required every 24 months. The reports filed under section 50.59 are to be submitted annually, or along with the update to the FSAR per section 50.71(e).

i 10 j

ANNUAL RECORDKEEPING BURDEN (INCREASE) i NO.OF BURDEN PER BURDEN COST SECTION RECORDKEEPERS RECORDKEEPER (HRSNR)

@$124/HR l

50.59(a)-(d) 178 1,648 (+48) 293,344 (+8,544)

$36,374.656 72,48(aHc) 18 (+7) 12 (+2) 216 (+106)

G26,784

{

t TOTAL RECORD-293,560(+8,650)

$36,401,440

[

KEEPING BURDEN t

i i

ANNUALIZED ONE-TIME RECORDKEEPING BURDEN i

I NO.OF BURDEN PER BURDEN COST i

SECTION RECORDKEEPERS RECORDKEEPER (HRSNR)

@$124/HR 50.59(Power Rx) 123 400 49,200 56,100,800 50.59 (Non-pwr Rx) 55 53 2.915 5363,733 f

I 72.48 18 53 954

$119,040 f

i 1

TOTAL ONE-TIME 53.069 56,583,573 RKPG BURDEN l

i i

i h

9

(

11 PART50 PART 72 TOTAL RULE REPORTING BURDEN 131,280 HRS (+3,450) 1,880 HRS (+930) 133,160 HRS (+4,380)

RECORDKEEPING BURDEN 293,344 HRS (+8,544) 216 HRS (+106) 293,560 HRS (+8,650)

ANNUALIZED ONE-TIME 52,115 HRS (+52,115) 954 HRS (+954) 53,069 HRS (+53,069)

RECORDKEEPING BURDEN TOTAL BURDEl,'

476,739 HRS (+64,109) 3,050 HRS (+1,990) 479,789 HRS (+66,099) h i

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ML20155E756

Text

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