ML20215L226

Request for OMB Review & Supporting Statement Re 10CFR33, Specific Domestic Licenses of Broad Scope for Byproduct Matl. Estimated Respondent Burden Is 2,400 H

ML20215L226
Person / Time
Issue date:	10/23/1986
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0015, OMB-3150-15, NUDOCS 8610280536
Download: ML20215L226 (6)

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1. -- A Important ,

Read instructior.s befure conspletmg forrn Do not use the same SF 83 Send three copies of this form, the matenal to be reviewed, and for to request both an E=ecuSve Order 12291 review and approval under paperwork-three copies of the supporting statement, to the Paperwork Reduction Act Answer all questions in Part l ll thK request is fur review under E O. Office of Information and Regulatory Aff airs 12291. cnmplete Part Il and sign the regulatory certification. If this Office of Management and Budget request is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 3201 1320. ship Part II. complete Part til and sign the paperwork certification. Washington, DC 20503 PART 1.-Complete This Part for All Requests.

1. Departmert/rigancy anr1 Hureau/of fice enginateg request 2. Agency code U.S. Nuclear Regulatory Commission 3 1 5 0 l~Name of person who can t'est answer questions regarding this request Telephone number Sterli n_g_B_ ell (301 A27-9026

4. Titte of informat nn conection or rulemaking 10 CFR Part 33 - Specific 00mestic Licenses of Broad Scope for Byproduct Material

5. Legal autnanty for ntormat,on collect on or tule cote united States Code, Pubhc Lan. or becutive Order) 42 usc 2201(o) ,o,

6. Affected put,lic (check all that Jpp4) 5 h federaf agencies or employees 1 O Ind'viduals or bousehoics 3 0 rarms s O non-profitinstitutions 2 @ stateorlocalgovernments 4 @ Businesses or other for-profit 7 h small businesses or organizations PART ll.-Comp!ete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulation Identif er Number (RIN)

_ _ ___ _ ~ _ _. _._

_ __ , or. None assigned O 8.1ype of subemssion (check one un each category) Type of review requested Classification Stage of development 1 standard 1 O Major i O Proposed or draft 2 O eend1ng 2 Ne mair 2 O rinaior intenm f.nai.w.tn aner proposai 3 O Emergency 3 0 Finai or intenm finai. w.tnout onor proposai 4 statutory or iud.ciai deadune

9. CF R section af fected CFR

10. Does this regulation contarn renort og o recoroceping requirements that require OM8 approval under the Paperwork Reduction Act and 5 CFR 1320?

Yes O no

11. lf a major rule, is there a reguiatory impact analfs:s attached?

1 O yes 2 O no if"No," d o OMO wame the ariatyses' 3 C Yes 4 0 no Cirtificrtion for Regulatory submissions In submitting this request for OMB review, the authorized regulatory contact arid the program official certify that the reqwrements of E o.12291 and any appbcable pohty direct.yes have treen Lomphed Mth l, segnature of program etfiaai cate l

Lgnature of authonred encalator r cont.w t 8610280536 861023 EUSD l g,,,

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Prev.oss e11.onwbw4 bi108 p', , o e NsN 7540 rH r44 40 9 5 CF N 1320aN E O 122M

.7 PART lil.-Complete This Part Only if the Request is for Approval of a Collection of Information Under the Paperwork Reduction Act and 5 CFR 1320.

13. Abstract-Dest ribe needs, uses and affected public in 50 mords or less

" Radioactive Materials, Radiation Safety" 10 CFR Part 33 specifies requirements for applying for and being granted licenses authorizing broad scope use of radioactive byproduct material.

14. Type of information col:ection (checA only one)

Information coIIections not containedin rules 10 Regular submission 2 O Emergency submission (cert,f,cationatrached)

Information collections containedin rules 3 00 Existing regulation (nochangeproposed) 6 Final or intenm final without pnor NPRM 7. Enter date of expected or crtual Federal 4 O Notice of proposed rulemakmg(NPRM) A O Regular submission Register publication at this stage of rulemaking 5 0 rinai, NeRM was previousiy pubiished B O Emergency submission (certif, cation attached) (month. day, year)-

15. Type of review requested (chec A only one) 1 O New coirection 4 0 Reinstatement of a previously approved collection for which approval 2 O Revision of a currentir approved coiiection has expired 3 @ Extension of the expirat:on date of a currently appiowed collection 5 O Existing collection in use without an oMB control number without any change in the substance or in the method of collection

16. Agincy teport form number (s)(include standard / optional form number (s)) 22. Purpose of intormation collection (check as many as apply)

N/A 1 O Application for benefits 2 O Prc, gram evaluation

17. Annual reportmg or disclosure burden 3 0 ceneraipurpose statistics 1 Number of respondents . l 4 b Regulatoryorcompliance 2 Number of responses per respondent. l 5 0 Program planning or management 3 Totai annual responses (line I times line 2) l 6 O Research 4 Hours per response l 7 O Audit 5 Total hours (kne 3 t.mes line 4) ]

18. Annual recordkeeping burden 23. Frequency of recordkeeping or reporting (Check all that apply) 1 Number of recordheepers 1 O Recordkeeping 2 Annual hours per recordkeeper. Reporting 3 Total recordkeeping hours (line 1 times line 2) 2 O onoccasion 4 Recordkeeping retention period years 3 0 weekiy

19. Total annual burden 4 0 Montniy 1 Requested (line 17 5 plus line 183) , l 5 0 Quarterly 2 fn current oM8 inventory I 6 0 semi-annuaisy 3 Difference (line l less i,ne 2) 0 7 O Annually Lspl: nation of difference 8 O Baennially 4 Program change 9 0 other(desenbe): Initial _ application and 5 Adjustment .

five-year renewal

20. Current (most recent) oMB control number or comment number 24. Respondents' obligation to comply (check the strongesr obligation thatapplies) llEQ-a0.15 1 O voiuntary

21. Requisted empiration date 2 O RmW N N m em W4

_3 years frDa_apJlrnval date 3 O Mandatory

25. Are the respondents pnmanly educational agencies or institutions or is the pomary purpose of the collection related to Federaleducation programs? O ves G No

26. Does the agency use sampling to select respondents or does the agency recommend or prescribe the use of sampling or statistical analysis by respondents? . O yes G No N. Regulatory authority for the inermation collection 10 cf R .. Par _t 33  ; or FR  ; or,other (specify)

PJ pirwirk Certification in submitting this request for oMB approval. the agency head. the semor official or an authonzed representative. certifees that the requirements of 5 CFR 1320, the Privacy Act. statistical standards or directives and any other applicable information pohcy directives have been comphed with signature of program official Date

$gnature of agency berd, the semor official or an authorized representative Date Patricia G. Norry, Director Office of Administration [ _s 8k WW

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Supporting Statement for 10 CFR Part 33 Specific Domestic Licenses of Broad Scope for Byproduct Material Justification Need for the Collection of Information 10 CFR Part 33 specifies requirements for applying for and being granted licenses authorizing broad scope use of byproduct material. Three types of licenses may be issued: Type A, Type B, or Type C, with Type A being the 4

largest program. The types of licenses are defined by Section 33.11.

Applicants and licensees are primarily medical institutions, colleges, universities, government agencies, and large private companies engaged in broad educational, research, and development activities.

Section 33.12 specifies that an applicant for a broad license must complete NRC Form 313, " Application for Materials License." Form 313 has previously been cleared under OMB Clearance No. 3150-0120, which should be referred to for further supporting information and burden and cost data.

Sections 33.13, 33.14, and 33.15 specify the information which must be included in an application in order for NRC to issue a license based on a finding that the public health and safety will be adequately protected.

Section 33.13 specifies the requirements for a Type A broad license. It requires that an applicant have equipment and facilities adequate to protect health and minimize danger to life or property, have personnel with adequate training and experience, and have adequate administrative controls and

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l procedures, including a radiation safety committee and radiation safety officer. The applicant must describe his program for meeting these requirements when he submits a license application, in order to establish that he can safely use radioactive material.

Section 33.14 specifies the requirements for a Type B broad license. The requirements are similar to those specified in Section 33.13, except that the applicant need not demonstrate as extensive experience in use of radioactive materials, and need not have a radiation safety committee. The application submitted by the applicant must demonstrate that he can meet these requirements.

Section 33.15 specifies the requirements for a Type C broad license. It requires that an applicant have equipment and facilities adequate to protect health and minimize danger to life or property, have personnel meeting certain training and experience requirements, supervise use of radioactive material, and have adequate administrative controls and procedures to assure safe use of radioactive material. The application submitted by the applicant must

' demonstrate that he can meet these requirements.

Agency Use of Information NRC reviews the information submitted in order to determine whether the applicant's training, experience, equipment, facilities, and procedures for the use of byproduct material are adequate to protect the public health and safety as required by the Atomic Energy Act, so that the Commission may determine whether to issue, amend, or renew a broad license.

Reduction of Burden Through Information Technology l There are no legal obstacles to reducing the burden associated with this information collection. Applicants and licensees may use electronic information processing systems to prepare and submit required information.

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3 Effort to Identify Duplication The Federal Information Locator System was searched to determine NRC and other Federal agency duplication. None was found.

Effort to Use Similar Information There is no similar information available to the NRC.

Effort to Reduce Small Business Burden The majority of licensees who use byproduct material are small businesses.

Since the health and safety consequences of improper handling or use of radioactive byproduct material are the same for large and small entities, it is not possible to reduce the burden on small businesses by less frequent or less complete accounting or control procedures.

Consequences of Less Frequent Collection Applications for new licenses and amendments are subaitted only once.

Applications for renewal of licenses are submitted every five years. This is the minimum frequency necessary to assure that licensees will continue to conduct programs in a manner that will assure adequate protection of the public health and safety.

Circumstances Which Justify Variation from OMB Guidelines There are no variations from OMB Guidelines.

Consultations Outside the Agency There have been no outside consultations since the previous clearance.

4 Confidentiality of Information None, except for proprietary information.

Sensitive Questions None.

Estimate of Compliance Burden Reporting Requirements (s933.12 33.15 Combined)

Annual Responses Staff Hours per Submittal Annual Licensee Burden

[120] [20] [2,400]

This burden data is provided for information only. The burden for this information collection is attributable to and is reported for inventory purposes under NRC Form 313, OMB Clearance No. 3150-0120.

Estimated annual cost to the industry to respond to the collection requirements is $144,000 (2,400 hrs 0 $60/hr).

I Burden and cost estimates are based on the number of applications received by NRC annually in previous years and on staff experience

! and discussions with a small number of licensees, t

Estimated Annual Cost to the Federal Government Professional: 120 responses x 5 hrs / response x $60/hr = $360,000 annually Clerical and other: See OMB Clearance No. 3150-0120 l

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