ML20196J915

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Notice of Pending NRC Action to Submit an Info Collection Request to OMB & Solicitation of Public Comment Re 10CFR20, Stds for Protection Against Radiation
ML20196J915
Person / Time
Issue date: 12/09/1998
From: Shelton B
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
NUDOCS 9812110091
Download: ML20196J915 (22)


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4 U. S. NUCLEAR REGULATORY COMMISSION Agency Information Collection Activities: Proposed Collection; Comment Request 1

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. AGENCY:

U. S. Nuclear Regu!atory Commission (NRC)

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' ACTION:

Notice of pending NRC action to submit an information collection request to OMB i

and solicitation of public comment.

SUMMARY

The NRC is preparing a submittal to OMB for review of continued approval of information collections under the provisions of the Paperwork Reduction Act of i

1995 (44 U.S.C. Chapter 35).

1 Information pertaining to the requirement to be submitted:

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1.

The title of the information collection: 10 CFR Part 20 Standards for Protection Against Radiation 2.

Current OMB Approval Number. 3150-0014.

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How often the collection is required: Annually for most reports; at license j

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termination for reports dealing with decommissioning.-

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Who is required or asked to report: NRC licensees, including those requesting j

license termination t

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The number of annual responses: The total annual number of NRC licensees 4

responding to this requirement by either reporting or recordkeeping is 5939.

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6.

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

j 165,498 (approximately 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> per licensee).

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Abstract: 10 CFR Part 20 establishes standards for protection against

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ionizing radiation resulting from activities conducted under licenses issued i

by the NRC. These standards require the establishment of radiation i

protection programs, maintenance of radiation records, recording of i

r radiation received by workers, reporting of incidents which could cause j

exposure to radiation, submittal of an annual report to NRC of the results of individual monitoring, and submittal of license termination information.

i These mandatory requirements are needed to protect occupationally 1

exposed individuals from undue risks of excessive exposure to ionizing radiation and to protect the health and safety of the public.

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Submit, by (insert date 60 days after publication in the Federal Reoister), comments that i

address the following questions:

1.

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

f 2.

Is the burden estimate accurate?

3.

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

i 4.

How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms of information technology?

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A copy of the draft suoporting statement may be viewed free of charge at the NRC Public Document Room,2120 L Street, NW, (Lower Level), Washington, DC. OMB clearance requests are avellable at the NRC worldwide web site (http://www.nrc. gov /NRC/ NEWS /OMB/index.html) under the FedWorld collection link on the home page tool bar. The document will be available on the NRC home page site for 60 days after the signature date of this notice.

4 Comments and questions may be directed to the NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 F33, Washington, DC,20555-0001, or by telephone at (301) 415-7233, or by Intemet electronic mail at BJS1@NRC. GOV.

Dated at Rockville, Maryland, this day ofA,_ly,1998.

For the U. S. Nuclear Regulatory Commission Jn Efrenda J heffon,Wiearance Officer Office of the

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DRAFT OMB SUPPORTING STATEMENT FOR 10 CFR PART 20

" STANDARDS FOR PROTECTION AGAINST RADIATION" (3150-0014)

REVISION TO CLEARANCE EXTENSION Descriotion of the Information Collection General requirements for radiation protection, that are applicable to all NRC licensees, are contained in 10 CFR Part 20, "Stan6ards for Protection Against Radiation." These standards are based, in part, upon the recommendations of the Intemational Commission on Radiological Protection (ICRP), the National Council on Radiation Protection and Measurements (NCRP),

and incorporate Federal Guicance issued by the former Federal Radiation Council and the Environmental Protection Agency. Provisione of Part 20 apply to individuals licensed by the NRC to possess byproduct, source, or special nuclear material. Part 20 also contains criteria for decommissioning of facilities and termination of the facility license. Part 20 is intended to ensure that occupationally exposed individuals and members of the public are adequately protected from the potential hazards of exposure to radiation and or radioactive materials.

This clearance package covers the requirements for all sections of 10 CFR Part 20. The recordkeeping and reporting requirements for possession of material have been centralized into two Subparts: Subpart L -Records (@@20.2102 - 2110) and Subpart M - Reports (@@20.2201-2206). Cross references to the recordkeeping requirements appear in other related portiors of j

the Part 20 rule, but these cross references do not constitute separate recordkeeping requirements. Recordkeeping and reporting requirements for license termination are contained ii1 Subpart E.

i Two record retention periods appear in Part 20: 3 year retention for most survey records and 4

retention for the lifetime of an active NRC license for those records of doses (or records that provide a basis for dose estimates) received by individual workers or members of the public.

A.

JUST.'FICATION j

The statutory authority of the NRC derives from the Atomic Energy Act of 1954 (AEA), as amended, the Energy Reorganization Act of 1974, as amended, the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA), as amended, Low-Level Radioactive Waste Policy Act of 198J (LLRWPA), Nuclear Waste Policy Act of 1982, and the National Environmental Policy Act of 1969 (NEPA). The basic authorities from the Atomic Energy Act include licensing and regulation of production, use, ownership, and distribution of special nuclear materials, source material, and byproduct materials, and licensing and control over the manufacture, production, possession, use, importation, or exportation of production and utilization facilities.

Section 161b of the AEA provides that the Commission may establish such standards as the Commission deems necessary to protect public health and safety. Section 161o gives the Commission authority to reouire by rule, regulation, or order, such reports, and keeping of such records as may be necessary to carry out the purposes of the Act.

1.

Need for and Practical Utility cf the Collection of Information The information collected is used to evaluate the effectiveness of NRC regulations and to discern any trends, problems, or special situations requiring additional controls. The NRC uses information on worker exposures and effluents from nuclear power plants to analyze trends and compare licensee performance. This information is also published in annual reports for use by industry and other interested organizations. The NRC also uses the information to assess applications for decommissioning and license termination.

Section 20.1003 defines a declared pregnant woman as someone who has declared in writing that she is pregnant. Licensees are required to maintain records of doses to the embryo / fetus of the declared pregnant woman in paragraph 20.2106. Licensees are not required to maintain the declaration itself; therefore, this does not constitute a separate recordkeeping requirement.

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Section 20.1101 requires licensees to develop, document and implement radiation protection programs; establish radiation protection procedures; and perform program reviews periodically.

This is necessary to ensure the health and safety of the workers and the general public. The burden for recordkeeping requirements is contained in Section 20.2102.

Section 20.1202 sets limits for occupational exposures. The recordkeeping requirements for this section are contained in Section 20.2106. Dose limits are necessary to ensure the health and safety of the workers and members of the public. The reporting requirements for this section are contained in Section 20.2206. Both requirements are covered under a separate OMB clearance for NRC Forms 4 and 5.

9 Section 20.1203 requires licensees to determine dose from airborne radioactive material. This is necessary to ensure compliance with dose limits. The recordkeeping and reporting requirements for this section are contained in Sections 20.2106 and 20.2206 respectively and are covered under a separate OMB clearance for NRC Forms 4 and 5.

Section 20.1204 requires licensees to make measurements as needed to assess intakes of occupationally exposed individuals. The recordkeeping and reporting requirements for this section are contained in Sections 20.2106 and 20.2206 respectively and are covered under a separate OMB clearance for NRC Forms 4 and 5.

Section 20.1206 sets limits for planned special exposures. This is necessary to ensure the health and safety of workers. The recordkeeping and reporting requirements for this section are contained in Sections 20.2105 and 20.2204 respectively.

Section 20.1208 sets limits for doses to an embryo / fetus of a declared pregnant worker. This is necessary to protect the health and safety of the unborn. The recordkeeping requirement for this section is contained in Paraoraoh 20.2106(e).

Paraoraoh 20.1301(c) allows licensees to apply to the Commission to increase the dose limit for the general public from 0.1 rem /yr to up to 0.5 rem /yr. This is needed to ensure that a temporary deviation from the established dose limits adequately protects the health and safety of workers and the public.

2

1 Paracraoh 20.1302(c) allows licensees to apply to the Commission for permission to increase the effluent concentration values from those listed in Appendix B. This is needed to ensure that any proposed deviation from established limits adequately protect the health and safety of workers and the public.

Section 20.1302(c) allows licensees to apply to the Commission for permission to use alternate effluent release concentration limits based on actual physical and chemical characteristics of the effluent released. This is needed to ensure that if alternate values are used by licensees, that they are adequate to protect the health and safety of the public.

Section 20.1403(aWc) and (e)(1) require that, if restrictions on future use of the site are proposed, the information the license must provide is, as follows: (1) further reductions in residual radioactivity necessary to release the site for unrestricted use would result in net public or environmental harm or were not being made because the residual levels associated with restricted conditions are ALARA; (2) adequate provisions for legally enforceable institutional controls provide reasonable assurance that the total effective dose equivalent (TEDE) from residual radioactivity distinguishable from background to the average member of the critical group will not exceed 25 mrem per year; (3) provisions have been made for sufficient financial assurance to enable an independent third party to assume and carry out responsibility for any necessary control and maintenance of the site; and (4) residual radioactivity at the site has been reduced so that if the institutional controis were no longer in effect, there is reasonable assurance that the TEDE from background to the average member of the critical group is as low as reasonably achievable and would not exceed 100 mrem per year. Section 1403(e)(2) requires that, as an option to the 100 mrem per year level, a level of 500 mrem / year may be a!! owed if the licensee demonstrates that further reductions in residual radioactivity necessary to comply with the 100 mrem / year value are not technically achievable, would be prohibitively expensive, or would result in net public or environmental harm, that provisions exist for durable institutional controls, and that there is sufficient financial assurance to enable a responsible government entity, or independent third party, both to carry out periodic rechecks of the site no less frequently than overy 5 years and to assume and carry out responsibilities for any necessary control and maintenance of those controls.

Section 1403(d) requires that a decommissioning plan or License Termination Plan (LTP) be submitted by the licensee indicating the licensee's intent to decommission in accordance with 10 CFR Parts 30.36(d),40.42(d),50.82(a) and (b), 70.38(d), or 72.54, and specifying that the licensee intends to decommission by restricting use of the site, and that the decommissioning plan or LTP document how the advice of individuals or institutions in the community who may be affected by the decomrnissioning has been sought and incorporated, as appropriate, following analysis of that advice. In seeking advice on issues associated with restricted use, licensees are required to provide for participation by a broad cross section of community interests who may be affected by the decommissioning, provide an opportunity for comprehensive, collective discussion on the issues by the participants represented, and prepare a publicly available summary of the results of all such discussions, including a descrlption of the individual viewpoints of the participants on the issues and the extent of agreement and disagreement among the participants on the issues.

3

I Section 20.1404 requires that, if the licensee proposes to use alternate criteria, the information the license must provide is as follows: (1) an analysis of possible sources of exposure which provides assurance that public health and safety would continue to be protected, and that it is unlikely that the dose from all man-made sources combined, other than medical, would be more i

than the 1 mSv/y (100 mrem /y) limit of Subpart D of 10 CFR Part 20; (2) an indication that restrictions on site use according to the provisions of Section 20.1403 have been employed to the extent practical to minimize exposures at the site; (3) doses have been reduced to ALARA levels; and (4) a decommissioning plan or LTP has been submitted indicating the licensee's intent to decommission in accordance with 10 CFR Parts 30.36(d),40.42(d), 50.82(a) and (b),

70.38(d), or 72.54, and specifying that the licensee proposes to decommission by use of alternate criteria, and documenting in the decommissioning plan or LTP how the advice of individurls and institutions in the community who may be affected by the decommissioning has been sought and incorporated, as appropriate, following analysis of that advice.

Section 20.1406 requires applicants for licenses to describe in the application how facility design and procedures for operation will minimize contamination of the facility and the environment, facilitate eventual decommissioning, and minimize the generation of radioactive waste.

Section 20.1501 requires licer sees to conduct surveys and to monitor radiological conditions.

These are necessary to ensure that the licensee is aware of all the radiological conditions that could contribute to dose in order to comply with dose limits. The recordkeeping requirements for this section are contained in Section 20.2103.

Paraaraoh 20.1601(c) allows licensees to apply to the Commission for approval of altemate methods for control of access to high radiation areas. This is needed to ensure that any proposed deviation from established mechanisms adequately protects the health and safety of workers and the public.

Pamaraoh 20.1703(a)(2) allows licensees to apply to the Commission for permission to use respiratory protection equipment that has not been approved for use by NIOSH/MSHA. Records of this application and its approval s.e required to ensure that licensee practices are in compliance with regulations.

Paraaraoh 20.1703(a)(3)(ii) requires licensees to perform surveys and bioassay as needed to determine dose. The recordkeeping requirement for this paragraph is contained in Section 20.2103. These records are needed so that NRC can ensure, through inspection, that the licensee is adequately protecting the health and safety of workers.

Paraaraoh 20.1703(a)(3)(iv) requires licensees to have written procedures regarding the proper issue and use of respiratory protection equipment. This is needed to ensure, through inspection, that these devices are used consistent with the goal to maintain occupational doses ALARA and in a safe manner.

Paraaraoh 20.1703(a)(4) requires licensees to issue a written policy statement on respirator usage. This is needed to ensure that workers are not dissuaded from respirator use by the misconception that production is more important than protection of health and safety.

4

i Paraaraoh 20.1703(b)(2) allows licensees to apply to the Commission for permission to apply protection factors higher than those in Appendix A for the purpose of calculating exposures.

t Records of this application and its approval a e required to ensure that respiratory protective equipment is being used in a manner that will protect the health and safety of workers.

P Egraaraoh 20.1703(d) requires licensees to notify the Commission, in writing, 30 days prior to the initiation of a respiratory protection program. This is nee @d so that the NRC can inspect prior to initiation of such a program to ensure that the program adequately protects the health and safety of workers.

Section 20.1904 requires that labels used to identify radicactive material containers use specified formats and wording. This is needed to minimize potential doses or releases of radioactive material due to worker confusion.

Earaaraoh 20.1905(e) requires that licensees maintain records of radioactive material containers that cannot be labeled in accordance with this Part due to special circumstances for the life of the container. This is necessary to ensure that radioactive material is properly monitored at all times.

Paraaraoh 20.1906(d) requires licensees to notify the carrier and the NRC regional office upon receipt of a radioactive material package which is damaged, contaminated, or where radiation levels exceed limits. This is needed so that NRC can, through inspection, ensure that shipment procedures and practices are adequate to protect the health and safety of workers and the public.

Paraaraoh 20.1906(e) requires licensees to develop and maintain procedures regarding radioactive material shipment. This is needed to ensure that the packages containing radioactive material will be opened in a manner consistent with the protection of the health and i

safety of the public and workers.

Section 20.2002 allows licensees to apply to the Commission for approval of procedures not otherwise allowed in this Part regarding the disposal of licensed material. The application must include:

(a) a description of the waste (b) an environmental analysis (c) the location (s) of other potentially affected facilities (d) analyses and procedures to ensure that doses are ALARA.

This is needed to ensure that licensed material is handled in a manner that will adequately protect the health and safety of the public and workers.

Section 20.2004 requires Part 50 licensees who incinerate waste oils onsite to report any changes or additions to the information supplied under Sections 50.34 and 50.34a, and to follow the procedures of Section 50.59 with respect to such changes. This is needed so that NRC can assure that radioactive effluents associated with incineration of waste oils conform to the i

requirements of Appendix I to 10 CFR Part 50.

Paraaraoh 20.2005(c) requires licenseer, to maintain records of waste disposal. The 5

recordkeeping requirement for this section is contained in Section 20.2108. This is needed to allow NRC to ensure, through inspection, that waste disposal is in accordance with NRC regulations.

Paraaraoh 20.2006(a) requires that licensees establish a manifest tracking system to control transfers of low-level radioactive waste intended for disposal at a land disposal facility so that NRC can inspect to ensure that adequate control of this material exists as specified in Appendix G to 69 20.1001-20.2402. Paraaraoh 20.2006(b) requires that licensees use NRC's Uniform Low-level Radioactive Waste Manifest and transfer this information to the intended consignee, as specified in Section I of Appendix G to $@ 20.1001-20.2402. Paracraoh 20.2006

{c) requires a certification by the waste generator, processor, or collector as specified in Section 11 of Appendix G to a 20.1001-20.2402.

The information in Paragraphs 20.2006 (a)-(c) is needed to control shipments and disposal of LLW to insure public health and safety and to protect the environment. The specific requirements are discussed in more detailin Appendix G.

Paraaraoh 20.2102(a) requires licensees to maintain records of the radiation protection program, including ALARA provisions and program reviews. This is needed so that NRC can ensure, through inspection, that the health and safety of workers and the public is adequately protected.

Paraaraoh 20.2102(b) requires licensees to retain records of radiation protection programs until the Commission terminates the license. This is needed so that workers will have ready access to radiation protection programs and procedures as long as the facility is in operation. This paragraph further requires that licensees retain records of radiation protection program reviews for 3 years. This is needed so that adequate records will exist at the time of inspection to determine if the radiation protection program adequately protects the health and safety of workers and the public.

Paraaraoh 20.2103(a) requires licensees to maintain records showing the results of surveys and calibrations required by this Part. This is needed to ensure, through inspection, that sunteys required for adequate radiation protection have been made.

Paraoraoh 20.2103(b) requires licensees to maintain records required by Paraaraoh 20.2103(a) for 3 years, unless they form the basis of dose estimates in which case they must-be maintained for allong as the facility is licensed by NRC. This is needed to ensure that adequate records exist at the time of routine inspection to support an assertion that adequate radiation surveys have been performed and to ensure that adequate records exist to reconstruct a worker's dose estimate at any time during the period in which the facility is licensed by NRC.

Section 20.2104 requires licensees to attempt to obtain records of prior occupational exposures prior to authorizing entry into restricted or controlled areas by individuals for whom personnel radiation monitoring is required. This recordkeeping requirement is covered in a separate OMB clearance for NRC Form 4.

Section 20.2105 requires that records of planned special exposures be maintained until the 6

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Commission terminates the license since they form the basis for assessing dose to an individual.

I Section 20.2106 requires that results of individual monitoring be recorded and maintained until the Commission terminates the license. This recordkeeping requirement is covered in a separate OMB clearance for NRC Form 5.

Paraaraoh 20.2107(a) requires information on the identity and quantity of radionucliQs released by a licensee in effluents to unrestricted areas. This is needed to permit assessment of the dose to the public that might result from these radionuclide releases in order to confirm compliance with dose limits. Paraaraoh 20.2107(b) requires that these records be maintained until the license is terminated by the Commission as they form the basis for estimating dose.

Paraaraoh 20.21081a} requires records of waste disposal to permit (1) routine inspection for 4

compliance with the provisions of the sections in Part 20 related to waste disposal, (2) i inspection against constraints on the kinds and quantities of licensed material in the possession of the licensee at any given time, and (3) assessment of the kinds and quantities of radioactive material disposed of by various methods and the potential dose to the public. Paraaraoh 20.2108(b) requires that these records be retained until the termination of the license by the Commission.

Section 20.2110 establishes the quality, format and retention of records required by this Part.

There are no additional recordkeeping or reporting requirements associated with this section.

This only establishes a common format to minimize confusion for workers moving from licensee to licensee in the course of their employment, and to facilitate inspection.

Paraaraoh 20.2201(a) requires licensees to report any theft or loss of licensed material by telephone immediately or in writing within 30 days, dependent upon the potential risk to the health and safety of the public associated with the missing radioactive material. This is needed so that prompt corrective action can be taken.

Paraaraoh 20.2201(b) requires licensees to follow up telephone reports with written reports of the incident within 30 days of the telephone report. This is needed to ensure that proper follow-up actions were taken by the licensee.

Paraaraoh 20.2201(d) requires that any additional information relevant to the loss of radioactive material, discovered subsequent to the written report, be submitted within 30 days of discovery.

This is needed to ensure that NRC actions takea to protect the health and safety of workers and the public are based on complete information regarding the event.

Paraaraoh 20.2202(a) requires that the licensee immediate!v notify NRC upon becoming aware i

of specific incidents causing substantial exposures to or release of licensed material. This is needed so that NRC can identify possible generic problems and notify other licensees.

Paraaraoh 20.2202(b) requires that the licensee notify NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> upon becoming aware of specific incidents involving licensed material. This is needed to allow early evaluation of the incident by NRC to ensure that appropriate action can be taken to protect against further 7

1 hazard to life or property.

Paraaraoh 20.2203(a) establishes that, in addition to the notification required by Section 20.2202. each licensee shall submit a written report within 30 days after learning of specific incidents involving doses or concentrations of radioactive materials in excess of limits. This is needed to ensure that there are appropriate follow-up actions to avoid a recurrence.

Paraaraoh 20.2203(b) contains the requirements for the content of reports required by Paraaraoh 20.2203(a).

Section 20.2204 requires a report to the NRC within 30 days after a planned special exposure.

This is needed to ensure that the use of planned special exposures are in accordance with requirements.

Paraaraohs 20.2206(b)&(c) require licensees to report tne results of individual monitoring annually to NRC on NRC Form 5 or equivalent electronic media. These requirements are covered under a separate OMB clearance for NRC Form 5.

Section 20.2301 allows licensees to apply to the Commission for exemption from this rule.

Accendix G.Section I requires that waste generators, collectors, and processors of LLW intended for ultimate disposal at a licensed low-level radioactive waste facility must prepare a manifest on NRC Forms 540,541, and 542 as appropriate. The justification for the information collection requirements in these forms are covered in a separate OMB clearance for NRC Forms j

540,541, and 542.

i This section specifies the specific data to meet NRC manifeat requirements (i.e., shipper, date, total radioactivity, container identification and description, physical and chemical description of the waste, cheleting agents, classification of the waste, radiation levels, etc). This information, and its electronic submittal to the NRC (discussed in Section 61.80(l)), will enhance the ability of NRC and State regulatory agencies to control and safely regulate disposal of LLW. Without this information the ability for the licensee and the regulatory agencies to assess the site's performance would be severely impacted and thus our responsibility to protect public health and safety and the environment could not be adequately accomplished.

Accendix G. Section il requires that all generators, processors, and collectors certify, by signing and dating the shipment manifest, that the shipment is properly classified, described, packaged, marked and labeled to meet Department of Transportation, NRC, and State requirements. This is necessary to insure that the proper company official verifies that appropriate requirements have been met prior to shipment.

Apoendix G. Section Ill. Paraaraohs (Al-(D) provides the specific manifesting procedures for generators, processors, collectors, and the land disposal facilhv operators during shipment and receipt of the LLW. This includes classification of and labeling the LLW, conducting a quality assurance program to~ assure compliance with @ 61.55 and 61.56, the requirement to use the NRC Uniform Low-Level Radioactive Waste Manifest, requirements to provide the intended consignee the manifest information and acknowledgement of its receipt and procedures in the 8

event acknowledgement is not received, and storage of manifest data. These procedures are i

necessary to insure that LLW is tracked from generator shipment to ultimate disposal and that no LLW is unaccounted for. A quality assurance program is necessary to ensure companies are

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properly following the procedures. Acknowledgement of receipt is necessary to ensure investigations are undertaken when LLW is not where it is supposed to be. Storage of manifest information is recessary to conduct audits and in the event that any discrepancies or other j

problems needed to be investigated.

1 l

Sections A.5 (generators), B.3 (collectors), and C.6 (processors) authorize that manifest data may be transmitted electronically instead of by hard copy. This is a voluntary option designed to allow the manifest system to work more effectively and efficiently.

Accendix G. Section Ill. Paracraoh (E) requires investigations and reporting to NRC when LLW has not been accounted for. This information is needed to identify and locate missing LLW and to identify improper procedures.

2.

Aaency Use of Information NRC uses the required information collection and reports to ensure that doses to workers and members of the public do not exceed limits, are as low as is reasonably achievable, and to i

ensure that radioactive materials are stored and handled, and facilities are decommissioned, in 1

a way that will adequately protect the health and safety of workers and the public.

3.

Reduction of Burden Throuah Information Technoloav NRC encourages licensees to file responses electronically and to utilize any technology that would reduce the burden of recordkeeping and reporting. Section 20.2110 permits the use of electronic media for recordkeeping. Of the approximately 100 NRC reactor licensees,67 submitted required occupational dose information electronically in 1995. NRC allows the maximum flexibility possible in the use of information technology to minimize the financial impact on licensees.

4.

Effort to identify Duolication and Use Similar Information '

The information Requirements Control Automated System was searched, and no duplication was found. There is no similar information available to the NRC. With regard to the LLW shipping manifests, duplication will be reduced by requiring all LLW shipment manifests to use the NRC forms to satisfy the requirements of multiple agencies. Information requirements on the forms have been developed in coordination with the Department of Transportation, the Host State Technical Coordinating Committee (TCC), the LLW Forum, States, and LLW Compacts, and with the input from public commenters.

5.

Effort to Reduce Small Business Burden Some of the licensees who use byproduct, source, and special nuclear materials are small businesses. However, since the health and safety consequences of improper handling or use of these materials are the same for large and small entities, it is not possible to reduce the burden 9

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on small businesses by less frequent or less complete reporting, i

and control procedures.

6.

oris Conducted Less FreauentivConsecuences To F Required reports are collected and evalyated on a continuing basis as even Applications for new licenses and amendments are submitted only on in previous applications may be referenced without being resubmitted Th me collecting the information is the minimum frequency necessary to assure the public. If the information were not collected, it w safety were to decline at a licensed facility in order to ensure the con ervene if l

the public and workers.

7.

Circumstances That Justifv Variation From OMB Guidelines 24-hour reporting requirements are necessary for and to assure public health and safety, Apoendix G 111 (E) requires reporting in less than 30 days. This notification needed so that state and local authorities can be mobilized to assist in locatin material as quickly as possible to minimize the potential hazard to members of Records pertaining to the radiation doses and radionuclide intakes by individ must be retained for the life of the license and transf i

licence. This retention is required so that the past exposure history of any wori the identification of trends, so that declining licensee pe corrected.

8.

Consultations Outside the NRC An opportunity to comment on the information collection requirements for this clearan extension has been published in the Federal Reaister.

9.

Payment or Gift to Resoondents Not applicable.

10.

Confidentiality of information information on doses to named individuals will be protected under the Privacy Act. _

10

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i 20.2106(d) states that these records are covered under the Privacy Act.

I 11.

Justification for sensitive Questions i

- No sensitive information is requested under these regulations.

i 12.

Estimated Burden and Burden Hour Cost i

The estimated annual burden to NRC licensees from these requirements is 165,498 hrs (see i

attached tables). This is the sum of the reporting and recordkeeping burdens in the attached tables. The cost to licensees and applicants is $20,025,258 calculated at a rate of $121/hr. This rate is based on NRC's fully recoverable fee rate.

i 13.

Estimate of Other Additional Costs l

None

-14.

Estimated Annualized Cost to the Federal Govemment The estimated annualized cost to the Federal Government is $1,133,528 (see attached table).

l These costs are calculated using a rate of $121/hr and are fully recovered through license fees assessed to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

l 15.

Reasons fcr Chanoe in Burden or Cost There is a net decrease in the burden hour cost resulting from the following three causes:

(1) there is a small increase based on inclusion of the burden estimates for the final rule on radiological criteria for license termination (62 FR 39058, July 21,1997). The sections in the t

final rule with information collection requirements are 20.1403(a)-(d) and (e)(1) and (2), 20.1404, and 20.1406. These sections result in an increme in the burden of 590 hours0.00683 days <br />0.164 hours <br />9.755291e-4 weeks <br />2.24495e-4 months <br />. This burden was j

approved by the OMB for the final rule on August 6,1997; (2) there is a decrease in the burden l

estimates based on a reduction in the number of NRC licensees from 6625, as estimated in the

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- last OMB clearance extension for 10 CFR Part 20, to a current level of 5939; (3) there is a i

decrease in the burden indicated based on the final rule on " Low-Level Waste Shipment Manifest information and Reporting" (60 FR 15649, March 27,1995) and the final rule on

}

" Transfer for Disposal and Manifests; Minor Technical Conforming Amendment" (63 FR 50127, September 21,1998) which provide manifest requirements in Appendix G to 10 CFR Part 20 i.

(including Forms 540-542) that replace Appendix F. The burdens associated with Appendix G (and its associated forms) were approved by OMB at the time of the final rule (the OMB clearance for Forms 540-542 was reapproved May 31,1998).

4 16.

Publication for Statistical Use i

None.

3 17.

- Reason for Not Disolavino the Exoiration Date 4

4-f 11 i

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  • -J7 e't

'?-4'---m g.

e 9

r-v a-y*

P y

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1 9

l-

- The requirement is contained in a regulation. Amending the Code of Federal Regulations to j

display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.

i 18.

Exceotions to the Certification Statement None.

l B.

Collections of Information Emolovino Statistical Methods Statistical methods are not used in this collection of information.

i

)

l l

i l

1 t

12 i

ANNUALIZED COSTTO THE FEDERAL GOVERNMENT (NRC Staff Burdens Associated with 10 CFR Part 20)

SECTl' N=

oT' TAL NOTES O

O

! s,_

. HOURS 20.1101 0.00 see 6 20.2102 20.1202 0.00 see 9 20.2106 20.1203 0.00 see f 20.2106 20.1204 0.00 see 9 20.2106 20.1206 0.00 see 6 20.2106 20.1208 0.00 see 6 20.2106 20.1301(c)

-- 0.00 none expected 20.1302(c) 4 20.1403(a-e) 180.00 20.1404 2.00 20.1406 200.00 20.1501 0.00 see $ 20.2103 20.1601(c) 8 20.1703(a)(2) -

0.00 none expected 20.1703(a)(3)(ii) 0.00 see 9 20.2103 20.1703(a)(3)(iv) 200 20.1703(a)(4) 10 20.1703(b)(2) 0.00 none expected 20.1703(d) 25 20.1904 50 20.1905(e) 10 20.1906(d) 6 20.1906(e) 10 20.2002 150

'i 20.2004 Burden included in OMB Clearance for Part 50 13 m.

g 7

rw-'t--

  • -'t

-'--w

-~"

SECTION TOTAL NOTES-HOURS 20.2005(c) 0.00 see 9 20.2108 20.2006 0 Burden included in OMB clearance for-NRC Forms 540-542 20.2102(a) 3000 20.2102(b) 0.00 see 20.2102(a) 20.2103(a) 4000 20.2103(b) 0.00 see 9 20.2103(a) 20.2104 0.00 see 9 20.2106 20.2105 0.00 none expected 20.2106 0.00 Burden included in OMB Clearance for NRC Forms 4 and 5 20.2107(a) 8 20.2107(b) 0.00 see 9 20.2107(a) 20.2108(a) 600 20.2108(b) 0.00 see 5 20.2108(a) 20.2110 0.00 format requirement only 20.2201(a) 90 20.2201(b) 90 20.2201(d) 5 20.2202(a) 60 20.2202(b) 120 20.2203(a) 320 20.2203(b) 0.00 see 5 20.2203(a) 20.2204 100 20.2206(b)&c) 0.00 Burden included in OMB Clearance for NRC Forms 4 and 5 20.2301 100 App G 20.00 For Sections I and 11, Burden included in OMB Clearance for NRC Forms 540-542 14

I l

ESTIMATED RECORDKEEPING BURDEN

'AFFECTED'-

HOURS / '

iTOTAL:

RECORD NOTES SECTION L LICENSEES' LICENSEE.

HOURS RETENTION

{

i 20.1003 0

see 6 20.2102 20.1101 0

see 6 20.2106 20.1202 0

see $ 20.2106 20.1203 0

see 6 20.2106 20.1204 0

see 6 20.2106 20.1206 0

see $ 20.2105 20.1208 0

see f 20.2106 20.1403(d) 9 20 180 20.1501 0

see 6 20.2103 20.1703(a)(3)(iv) 100 80 8,000 RULT 20.1703(a)(4) 100 2

200 RULT 20.1904 0

posting only 20.1905(e) 700 0.2 140 LOC 20.1906(e) 2700 1

2700 20.2005('c) 0 see f 20.2108 20.2006 Burden included in OMB clearance for Forms 540-542 20.2102(a)&(b) 5939 4

23,756 1=RULT 2=3 yrs 20.2103(a)&(b) 5939 8

47,512 RULT 20.2104 0

see 20.2106 20.2105.-

0 3

0 RULT none expected 20.2106 0

Burden included in OMB Clearance for NRC Forms 4 & 5 20.2107(a) 5939 5

29,625 RULT 15

.,,y,>w w--

--- 9

4 4

d SECTION..

.AFFECTED'

' HOURS /

TOTAL RECORD NOTES

- LICENSEES LICENSEE

. HOURS RETENTION 20.2108(a) 5939 8

47,512 RULT 20.2110 i

0 App. G format only 11 160 1760 Burden for Sections I i

and 11 included in OMB Clearance for NRC Forms 540-542 f

i 16

)

ESTIMATED REPORTING BURDEN SECTION LICENSEES.

. RE_SPONCES/

HOURS /

TOTAL NOTES:

AFFECTED

. LICENSEE

RESPONSE

BURDEN 20.1101 0.00 see 20.2102 j

20.1202 0.00 see S 20.2206 20.1203 0.00 see 9 20.2206 20.1204 0.00 see 20.2206 i

i 20.1206 0.00 see $ 20.2204 20.1208 0.00 see 20.2206 20.1301(c) 300 0.00 2

0.00 None expected I

20.1302(c) 2 1

10 20 20.1403(a,c,d,e(1))

9 1

23 210 20.1403(e)(2) 0.2 1

10 2

20.1404 0.1 1

10 1

t 20.1406 10 1

20 200 20.1601(c) 10 1

8 80 20.1703(a)(2) 0.00 none anticipated 20.1703(b)(2) 0.00 none anticipated 20.1703(d) 1 1

50 50 20.1906(d) 25 5

1 125 20.2002 20 1

20 400 20.2004 Burden included in OMB Clearance for Part 50 20.2006 Burden included in OMB Clearance for NRC Forms 540-542 20.2201(a) 30 1

3 90 20.2201(b) 30 1

3 90 20.2201(d).

5 1

3 15 20.2202(a) 10 1

1 10 17

l SECTION '

LICENSEES RESPONSES /

HOURS /

. TOTAL NOTES AFFECTED LICENSEE

RESPONSE

BURDEN i

20.2202(b) 40 1

40 1,600 20.2203(a)

.70 1

6 420

)

20.2204 100 1

5 500 20.2206 0.00 Burden included in I

OMB Clearance for NRC Forms 4 and 5 i

20.2301 20 1

5 100 App G 10 1

20 200

)

18

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