ML20236M791

Request for OMB Review & Supporting Statement Re 10CFR39, Licenses & Radiation Safety Requirements for Well Logging. Estimated Respondent Burden Is 35,098 H

ML20236M791
Person / Time
Issue date:	07/08/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20236M793	List: ML20236M791 ML20236M802
References
OMB-3150-0130, OMB-3150-130, NUDOCS 9807140263
Download: ML20236M791 (13)

Text

e 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 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 g a. 3150-0130 b.None

3. Type of information collection (ch9ck one) 4. Type of review requested (check one)

a. New collection y a. Regular c. Delegated g b. Revision of a currently approved collection b. Emergency . Approval requested by (date):

c. Extension of a currently approved collection 5. Will this information collection have a a.Yes

~ significant economic impact on a -

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

collection for which approval has expired Y b N0

ho$"s,c o g r hfc a iovNh s e re Requested y a. Three years frvm approval date

f. Existing collection in use without an OMB control number 6e aMn dam -

b. Other (Specify):

7. Title 10 CFR 39, Licenses and Radiation Safety Requirements for Well Logging

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

N/A

9. Ksywords R:diation Protection, Nuclear Materials, Recordkeeping and Reporting Requirements

10. Abstract 10 CFR 39 establishes radiation safety requirements for the use of radioactive material in well logging operations. The information in the required applications, reports, and records is used by NRC to ensure that the hulth and safety of the public is protected and that licensee possession and use of matertalis in compliance with license and regulatory requirements.

11. Affacted public (Mark pnmary wth *P'amt an others that apply wth 'X') 12. ODllgation to respond (Mark pnmaar wth 'P'amt eR others that apply uth "X')

a. Individuals or households d. Farms a. Voluntary T

b. Business or other for-profit e. Federal Government b. Required to obtain or retain benefits

c. Not-for-profit institutions T f. State. Local or Tribal GovemmentT c. Mandatory

13. Annual reporting and recordkeeping hour burden 14. Annual reporting and recordkeeping cost burden (m thousanos ordonars)

a. Number of respondents 51 s. Total annualized capital /startup ecsts 0

b. Total annual responses 1.554 b. Total annual costs (O&M) 0

1. Percenta of these responses c. Total annualized cost requested 0 collected electronically 0.0 % d. Current OMB inventory

c. Total annual hours requested 35.098 e. Difference o

d. Current OMB inventory 13.676

'#'"' " 'd " *"**

y e. Difference 21.422

f. Explanation of difference

1. Program change g ,

2. Adjustment .

.t l

1. Program change

2. Adjustment 2I422 gi Reb a n.15. Purpose of information collection 16. Frequency of recordkeeping or reporting (check allthat apply)

(Mark prunary with 'P* and all others that apply with 'X*)

] a. Recordkeeping b. Third-party disclosure

~

a. Application for benefits

~

e. Program planning or management 7

c. Reporting

b. Program evaluation f. Research 71. On occasion 2. Weekly 3. Monthly

~

~

c. General purpose statistics T g. Regulatory or compliance 4. Quarterly 5. Semi-annually 6. Annually SJO d. Audit 7. Biennially 8. Other (describe) REewal,10 yrs k 17.Statisticalmethods 16. Agency contact (person who can best answerquestions regatoing the

( Does this information collection employ statistical methods?

'" Frank Cardile Name:

@$ Yes

}

• g.

R No Phone: 301-415-6185 Wi 3) . ,

o s es-i gp gu la e

,a n

m. w .

--- ~~-

o..e.a

~ u.e. ggp9 g -1 10/95

1 ,

FINAL OMB SUPPORTING STATEMENT FOR 10 CFR PART 39 LICENSES AND RADIATION SAFETY REQUIREMENTS FOR WELL LOGGING (3150-0130) 1 REVISION Description of the Information Collection NRC regulations in 10 CFR Part 39 establish rules that specify radiation safety requirements for the use of licensed materialin welllogging operations. The regulations provide for comprehensive and consistent radiation safety requirements in NRC and Agement State regulations, and safety requirements designed to reduce the likelihood of accidents involving the rupture of radioactive sources in welllogging operations.

A. Justification

1. Need for and Practical utility of the Information Collection Section 39.11 provides that an applicant for a specific license to use licensed material in well logging operations must submit NRC Form 313," Application for Material License." The NRC materials licensing staff will review the information submitted on NRC Form 313 to determine whether an applicant for a license has training, experience, eauipment, facilities, and procedures for the use of licensed material that are adequate to protect the public health and safety.

The use of NRC Form 313 has been previously approved by OMB under clearance number 3150-0120, which should be referred to for information collection burden and supporting data.

Section 39.13 provides that an applicant must submit the following information with the application:

39.13(b) - Schedule and description of training programs; 39.13(c) - Written operating and emergency procedures covering its radiation safety program; 39.13(d) - Internalinspection program; 39.13(e) - Description of overall organizational structure as it applies to radiation safety, including specified delegations of responsibility and authority; 39.13(f) - (1) Description of procedures for leak testing sealed sources, or (2) Manufacturer and model number of a leak test kit )

This information is reviewed by the NRC staff to determine whether the training, radiation safety, and internal inspection programs and procedures and the licensee's organizational structure will l

provide adequate protection of the public health and safety. The NRC review and the findings therefrom form the basis for NRC licensing decisions.

Section 39.13fd) provides that a licensee must keep internal inspection records for 3 years. These records are reviewed by NRC inspectors to verify that the licensee is maintaining an effective inspection program and that problems are being identified and corrected. l Sections 39.15(a) and (b) require that a licensee wishing to conduct well logging operations with a sealed source must first have, and retain as a record, a written agreement with the well owner or l

operator that identifies who will carry out responsibilities with regard to recovery of sealed sourcesj which become stuck orlost in a well, performance of radiation monitoring, decontamination of site, equipment and personnelif necessary, and that within 30 days after a welllogging source has bel l

l classified as irretrievable, certain requirements will be implemented to immobilize and protect the separated well logging tool and source. The licensee must retain a copy of the written agreement for 3 years after the completion of the welllogging operation. A permanent identification plaque must be mounted at the surface of the wellin which a welllogging source has been abandoned. in addition to a warning, the plaque must contain the date the source was abandoned, the name of the well owner or operator, the name and well identification number (s) or other designation, identification of the source by radionuclides and quantity of activity, and depth to the top of the plug.

The written agreement is needed to ensure that recovery or abandonment procedures will be implemented in the event of a stuck or irretrievable welllogging source. The agreement binds the well owner or operator (non-licensee) to immobilizing the source with a cement plug, protecting it from subsequent damage with a drill deflecting device, and posting the wellhead with an appropriate plaque. Without this agreement, the well logger would be unable to complete recovery or abandonment procedures if the well owner or operator refused. The identification plaque is necessary to provide a warning to anyone reentering the well of the presence of the abandoned source and to provide information on the source and its location within the well.

Section 39.15(c) provides that a licensee or applicant may apply to the Commission for approval of proposed procedures to abandon an irretrievable well logging source in a manner other than that currently authorized. Such an application would be reviewed by NRC to determine whether the proposed procedures would provide an adequate margin of protection of the public health and safety.

Section 39.17 provides that NRC may require further statements after the filing of the application and before expiration of the license to enable NRC to determine whether the application should be granted or denied or whether a license should be modified or revoked. Such additional information is sometimes needed to clarify information submitted in the application, or to rectify deficiencies in proposed or existing programs for protection of the public health and safety, the common defense and security, or the environment.

The additional information submitted is reviewed by various NRC organizational units to assess the adequacy of the applicant's physical plant, procedures and plans for protection of the public health and safety, common defense and security, and the environment. The NRC review and the findings therefrom form the basis for NRC decisions concerning the issuance, modification, or revocation of licenses.

Burden and cost associated with further statements is included in the burden and cost data for submittal of applications on NRC Form 313, and is covered by clearance number 3150-0120, which should be referred to for further burden and cost information.

Section 39.31(a) requires that a licensee label (1) the source, the source holder, or the logging tool containing radioactive materials; and (2) the storage or transpost container. The labels are needed to wam peop'e that these devices or containers contah radioactive materials and that persons should notify civil authorities or the company if they hno a labeled device or container.

Section 39.33(d) provides that a licensee must maintain calibration records for a period of 3 years I after the date of calibration of a survey instrument at each field station and temporary job site.

Calibration of radiation survey instruments is necessary to ensure that these instruments function properly.

l 1

1 The information documents that the calibrations were performed. The records also permit NRC inspectors to verify that the licensee is keeping a calibrated and operable radiation survey instrument at each field station and temporary jobsite to make required radiation surveys.

Inspections are conducted at least every 3 years.

Section 39.35(a) requires the licensee to keep a record of the results of leak testing of sealed sources for 3 years after the leak test is performed. The leak testing is needed to ensure the sealed sources maintain their integrity.

The information contained in the records documents that the leak tests were performed. The information also permits NRC inspectors to verify that licensees have the source tested for leakage at least every 6 months and record the leak test results in units of microcuries. Inspections are conducted at least every 3 years.

- Section 39.35(d)(2) provides for reporting of leak test failures by the licensee to the NRC within 5 days of receiving the test results. The reporting requirement is needed to inform the NRC that the licensee has taken actions to remove the leaking source from service and to check for radioactive contamination.

The information contained in the report allows NRC regional offices to determine, within approximately 1 week, whether an inspector should be sent to check potential problems that may affect public health and safety.

Section 39.37 provides for a licensee to keep records of each semiannual physical inventory to account for alllicensed material received and possessed under the license. The record of inventory must be retained for 3 years. The information is needed to indicate that the licensee has conducted semiannual inventories to account for licensed material received and possessed under the license.

The information documents that sources possessed under the license were accounted for at the time of inventory. The information also permits NRC inspectors to verify that the licensee has conducted an inventory at least every 6 months. Inspections are conducted at least every 3 years. I Section 39.39 requires that a Ucensee keep utilization records for sources of licensed material. The records must be retained for three years. This information permits the licensee to trace the history of the use of sources, radioactive markers, or unsealed licensed materialif there are any questions concerning licensed material.

The information also permits NRC inspectors to verify that the licensee is utilizing licensed material appropriate to particular welllogging operations. Inspections are conducted at least every 3 years.

Section 39.43(a) requires that a licensee maintain a record of defects found and repairs made as a result of visual checks of source holders, logging tools, and source handling tools. The record must be retained for 3 years. The records are reviewed by NRC inspectors to ensure that the licensee is maintaining an effective program for identification and correction of defects.

Section 39.43(b) provides that a licensee must maintain records of semiannualinspections and maintenance for 3 years. The inspection and maintenance are needed to ensure that the sealed sources and source holders are in good working condition.

The information permits NRC inspectors to verify that the licensee conducted the required semiannualinspection and maintenance. Inspections are conducted at least every 3 years.

1 L

l l

Section 39.61(a)(2) requires that the licensee provide copies of and instruction in the applicable NRC regulations in 10 CFR Parts 19,20, and 39, the NRC license under which the well logging will be performed, and the operating and emergency procedures, to each well logging supervisor.

Section 39.61(b)(2) requires that the licensee provide copies of and instruction in the licensee's operating and emergency procedures to each welllogging assistant.

These documents are needed to ensure that we3 logging supervisors and assistante have been given instruction in and have available for reference, the NRC requirements and the operating and emergency procedures needed for safe operation.

l Section 39.61(d) requires that a licensee maintain records of training and of the annual safety review for each logging supervisor and logging assistant. The training records must include copies of written tests and dates of oral tests given. The records are needed to confirm that the logging supervisors and logging assistants received the required training. The training records must be retained until 3 years after termination of employment. Records of annual safety reviews must be retained for 3 years.

Section 39.63 requires that licensees maintain and follow written operating and emergency i procedures that cover handling and use of licensed material, use of remote handling tools, surveys, control of personnel exposures, locking and securing of sources, personnel monitoring, transportation, receipt, recordkeeping, inspection and maintenance, reporting, and actions in case of a stuck or ruptured source.

The information is used by the licensee and its employees to guide the handling and use of radioactive materialin normal and emergency situations. Submission of the procedures is covered by Section 39.13(c). The procedures must be retained as a record until the Commission terminates the license, in accordance with 10 CFR 30.51(b). i Section 39.65(c) requires that a licensee keep records of badge, TLD and bioassay results until termination of the license. The badge, TLD and bioassay results are needed to measure exposure received by workers during welllogging operations.

The information documents the radiation doses received by the licensee's employees. This I

information also permits NRC inspectors to verify that the licensee kept dosimetry and bioassay records. Inspections are conducted at least every 3 years.

Section 39.67(f) requires that a licensee must maintain radiation survey records for 3 years. j Radiation survey records are needed to warn the workers of the level of radiation exposure at that location.

The information documents that the licensee conducted radiation surveys. The information also permits NRC inspectors to verify that the licensee complies with the survey requirements. 4 Inspections are conducted at least every 3 years.

Section 39.73 requires that a licensee maintain certain documents and records at each field station.

This information is needed so that the licensee's operating personnel can have easy access to the documents they need to perform the job safely. Also, when an NRC inspector inspects a field station, the information provides the inspector with indications that the licensca complies with NRC requirements. I

+

These documents provide information on safety requirements and procedures to the licensea's personnel at the field station. The information also permits NRC inspectors to inspect these records at the field station. Inspections are conducted at least every 3 years.

Section 39.75 requires that a licensee conducting operations at temporary job sites maintain certain documents and records at each temporary jobsite. This information is needed so that the licensee's operating personnel can have easy access to the documents they need to perform the job safely.

The records provide information on safety requirements and procedures to the licensee's personnel at the temporary jobsite. The information also permits NRC inspectors to inspect these records at the temporary jot, site, inspections are conducted at least every 3 years.

Section 39.77(a) requires that a licensee report immediately by telephone if a sealed source has been ruptured Paragraph (b) reminds licensees to follow Part 20 reporting requirements for certain incidents. Requirements under 10 CFR Part 20 have been cleared under OMB No. 3150-0014.

Paragraph (c) provides that licensees must notify NRC by telephone if a sealed source becomes irretrievable and file a written report on the abandonment of the sealed source. The licensee must also nci:fy the well owner or operator of the abandonment procedures. If abandonment procedures cannot be completed within 30 days, the licensee must request an extension of time. Paragraph (d) requires that the licensee must make a written report to NRC within 30 days after the source has been classified as irretrievable, and must send a copy of the written report to each State or Federal agency that issued permits or otherwise approved the drilling operction. This information collection is needed so that NRC regional offices would be informed of any incidents involving licensed materials, lost sources or irretrievable well logging sources. l The information permits NRC regional offices to make a determination whether an inspector should be dispatched to a site and to assure that corrective actions have been taken. When the licensee, in consultation with the well owner or operator, determines that a sealed source lost in a well becomes irretrievable, the licensee is required to notify NRC regiona.1 offices by telephone to request  ;

approval to implement abandonment procedures. The NRC regional office, based on the information supplied by the licensee, approves the abandonment if all reasonable efforts at recovery have been expended.

Section 39.91 provides that the Commission may grant exemptions from the requirements of 10 CFR Part 39 under specified conditions, upon the application of any interested person or on its own initiative. Applications under this section are examined by the NRC materials licensing staff to determine whether the requested exemption is authorized by law and whether it will not endanger life or property or the common defense and security, and to determine if it is otherwise in the public interest.

2. Acency Use of the Information The records that 10 C' R part 39 requires licensees to maintain are reviewed by the NRC staff l

during inspections, license renewals, and license amendment reviews to evaluate compliance with NRC radiation safety requirements for possession and use of licensed radioactive materialin well logging.

For example, intemal inspection records are reviewed by NRC inspectors to verify that the licensee is maintaining an effective inspection program and that problems are being identified and corrected.

The written agreement with a well owner or operator is needed to ensure that recovery or l

abandonment procedures will be implemented in the event of a stuck or irretrievable well logging l

1

source. The identification plaque is necessary to provide a warning to anyone reentering the well of the presence of the abandoned source and to provide information on the source and its location within the well. Labels required on the source, the source holder, or the logging tool containing radioactive materials, and the storage or transport container, are needed to warn people that these devices or containers contain radioactive materials and that persons should notify civil authorities or the company if they find a labeled device or container.

Calibration records are needed to permit NRC inspectors to verify that the licensee is keeping a calibrated and operable radiation survey instrument at each field station and temporary jobsite to make required radiation surveys. Similarly, records of the results of leak testing of sealed sources are reviewed by NRC inspectors to verify that licensees have the source tested for leakage at least every 6 months, to ensure the sealed sources maintain their integrity.

The required reports regarding ruptured or irretrievable sources permit the NRC staff to make a determination whether an inspector should be dispatched to a site and to assure that corrective actions have been taken. When the licensee, in consultation with the well owner or operator, determines that a sealed source lost in a well becomes irretrievable, the licensee is required to notify NRC regional offices by telephone to request approval to implement abandonment procedures. The NRC regional office, based on the information supplied by the licensee, approves the abandonment if all reasonable efforts at recovery have been expended.

3. Reduction of Burden Throuah Information Technoloav There are no legal obstacles to reducing the burden associated with this information collection.

Applicants and licensees are encouraged to use automated information technology when it would be beneficial to them. However, because of the types of information and the infrequency of submission, the applications and reports may not lend themselves readily to the use of automated information technology for submission.

4. Effort to Identifv Duplication and Use Similar Information The Information Requirements Control Automated System (IRCAS) was searched to determine duplication. None was found. There is no similar information available to the NRC.

5. Effort to Reduce Small Business Burde.0 The majority of licensees who use byproduct material are small businesses. Since the health and safety consequences of improper handiing 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 reporting, recordkeeping, or accounting and control procedures.

6. Consequences to Federal Proorams or Poliev Activities if the Collection is not Conducted or is Conducted Less Freauentiv If the information were not conducted, or were conducted less frequently, NRC would not have the information needed to assure that licensees are conducting and will continue to conduct programs in a manner that will assure adequate protection of the public health and safety. Required reports are collected and evaluated on a continuing basis as events occur. Applications for new licenses and amendments are submitted only once. Applications for renewal of licenses are submitted every 10 years, Information submitted in previous applications may be referenced without being resubmitted.

L_____.__________

7. Circumstances Which Justifv Variation from OMB Guidelines Contrary to the OMB Guidelines in 5 CFR 1320.5(d), Section 39.35(d)(2) requires that licensees submit a report to NRC within 5 days of a failed leak test. However, reporting would be required only if the test reveals the presence of 0.005 microcurie or more of removable radioactive material.

The report must be filed within 5 days to permit the NRC to ensure that the licensee has taken action to remove the leaking source from service and to check for radioactive contamination. It also permits NRC to determine whether inspection or other response may be required to deal with potential problems affecting the public health and safety.

Section 39.77(a) requires immediate telephone notification, with a written report within 30 days, because the loss of licensed material and rupture of a sealed source could cause extensive radioactive contamination. Immediate notification would permit NRC to judge the severity of the situation and consider whether NRC should take immediate action. The confirmatory letter within 30 days is needed to permit NRC to judge whether the licensee has taken corrective actions and whether NRC should consider follow up actions.

Section 39.77(c) requires licensees to notify NRC by telephone if a source becomes irretrievable i i

and obtain NRC approval for abandoning a sealed source in a well. The requirement for prompt notification is needed to permit the NRC to judge whether all reasonable effort at recovery has been )

1 expended.

Section 39.77(d) requires that the licensee must make a written report to NRC within 30 days after the source has been classified as irretrievable. The written report within 30 days is needed to assure that the abandonment procedures are carried out promptly and satisfactorily. Furthermore, the report constitutes a record to alert state regulatory agencies that a sealed source is in the well if permission is requested to reenter the well.

8. Consultations Outside the NRC An invitation to comment on the information collection requirements in 10 CFR Part 39 was j published in the Federal Reoister on April 9,1998 (63 FR 17467). There were no comments.

9. Pavment or Gift to Respondents Not applicable.

l

10. Confidentiality of Information i

None, except for proprietary information.  !

l

11. Sensitive Questions None.

l l

~

12. Estimated Burden and Burden Hour Cost Reoortina Requirements No. of Licensee Licensee Staff Total Licensee Resoonses Annually Hours oer Submittal Burden Hours Section 39.11 See OMB Clearance No. 3150-0120 39.13(b),(c),(e),(f) included'in 39.11 1 5 5 39.15(c) 39.17 included in 39.11 1 4 4 39.35(d)(2)-

510 0.25 127.5 39.61(a)(2)&(b)(2) 39.63 included in 39.11 1 12 12 39.77(a) 39.77(b) See OMB Clearance No. 3150-0014 5 0.5 2.5 39.77(c) 5 4.0 20 39.77(d) 39.91 Included in 39.11 518 171 Total l-E ---- _ _ _ _ - - .

i l -

c .

.g.

I Recordkeeoina Requirements No. of Annual Hours Records oer Record Total Burden Hrs i Section 255 0.25 65 39.13(d) 55 2.00 110 39.15(a)(&(b) 510 0.05 25 39.31(a) 1,020 0.08 82 39.33(d) 0.08 41 39.35(a) 510 0.08 41 39.37 510 38,250 0.03 1,148 i 39.39 1 0.5 408 39.43(a)&(b) 816 0.75 380 39.61(d) 510 39.63 included in 39.11 1.00 440 39.65(c) 440 38,250 0.16 6,120-39.67(f)

I 1.00 153 I 39.73 153 k

0.05 1,910 39.75 38,250

)

51 l Total Number of Recordkeepers:

l i

10,923 Total Recordkeeping Hours Annually:

! 11,094 TOTAL ANNUAL BURDEN HOURS - NRC LICENSEES:

l 1

l Aareement State Burden and Cost It is estimated that, for Agreement state licensees and applicants, there will be 1,036 responses l 342 burden hours annually, there will be 102 recordkeepers and a recordkeeping burden of 23,6!

hours annually, and the total Agreement State burden will be 24,004 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, at a cost of $1,588

- l l

L -. . -

\.

Estimated Cost to the Public to Resoond Section Annual Cost to Resoond 39.11- See OMB Clearance No. 3150-0120 39.13(b),(c),(e),(f) included in 39.11' 39.13(d) 8,125 39.15(a)&(b) 66,300

'39.15(c) 625 included in 39.11 - q

~ 39.17 -

1,625 39.31(a)1 5,330 39.33(d) 2,600

' 39.35(a)

- 39.35(d)(2)' 500 39.37. . 2,600 39.39 74,620 39.43 26,520 39.61 40,638 39.63 included in 39.11 28,600

, 39.65(c) 39.67(f) 397,800.

39.73- 9,945 39.75 124,150

. 39.77 ' 4,313~

39.91 included in 39.11 TOTAL $794,291

' Source of Burden and Cost Data and Method of Estimatino Cost The estimates are based on submittals to NRC in past years. Cost to licensees and applicants is calculated at a rate of $125 per hour for technical or management time and $65 per hour for other time. These figures include salaries and overhead.

13. Estimate of Other Costs None. For licensees under 10 CFR Part 39, it is most likely that purchases of equipment and services were made (1) prior to October 1,1995,' (2) to achieve regulatory compliance with requirements not acsociated with the information collection, (3) for reasons other than to provide

. Information or keep records for the governrnent, or (4) as part of customary and usual business or private [.ractices.-

~

14. Estimated Annualized Cost to the Federal Government Annual Cost - NRC Staff Review (Professional effort - 173 hours0.002 days <br />0.0481 hours <br />2.86045e-4 weeks <br />6.58265e-5 months <br /> at $125/hr) = 521,625 for activities other than application review.

Application review activities are accounted for and reported under NRC Form 313, OMB Clearance No. 3150-0120. These costs are fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and 171.

15. Reason for Chanae in Burden or Cost The number of NRC licensees has decreased from 63 to 51, responses decreased from 643 to 518, and the NRC licensee burden decreased from 13,676 to 11,094 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br />. However, Agreement States are captured for the first time resulting in an increase in burden of 24,004 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 1,036 responses. Hence, the combined effect is an increase in burden of 21,422 hours0.00488 days <br />0.117 hours <br />6.977513e-4 weeks <br />1.60571e-4 months <br />, and an increase in responses of 911. i

16. Publication for Statistical Use  !

)

None.

I

17. Reason for Not Disclavina the Exoiration Date The requirement is contained in a regulation 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. ,

l B. Collection of information Emolovina Statistical Methods Statistical methods are not used in this collection of information.

l f

r

_