ML20236J326

Request for OMB Review & Supporting Statement Re NRC Form 313, Application for Matl License. Estimated Respondent Burden 39,060 H

ML20236J326
Person / Time
Issue date:	02/14/1994
From:	Cranford G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20236J269	List: ML20236J266 ML20236J326 ML20236J343 ML20236K772 ML20236K795 ML20236K807 ML20236K831 ML20236K851 ML20236K871 ML20236K878 ML20236K889 ML20236L567 ML20236L576 ML20236L593 ML20236L685 ML20236L699 ML20236M005 ML20236N976 ML20236P130
References
FRN-62FR28948, RULE-PR-150, RULE-PR-30, RULE-PR-34, RULE-PR-71 AE07-2-004, AE7-2-4, NUDOCS 9807080134
Download: ML20236J326 (28)

Text

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Staa 'a,m ss Request for 0MB Revlea

(%v september 1983)

@ PDR Important Read instructions before completing form. Do not use the same SF 83 Send three copies of this form, the material to be reviewed, and for i to request both an Executive Order '

12291 review and approval under paperwork-three copies of the supporting statement, to: I the Paperwork Reduction Act. I Answer all questions in Part 1. If this request is for review ur' der E.O. Offee of Information and Regulatory Affairs 12291, complete Part 11 and sign the regulatory certification. If this Office of Management and Budget reou:st is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 3201 1320, skip Part II. complete Part !!l and sign the paperwork certification. Washington, DC 20503 i

PART l.-Complete This Part for All Requests.

{

1. Department / agency and Bureau / office onginating request 2. Agency code U.S. Nuclear Regulatory Commission 3 1 5 0

3. Name of person who can best answer questions regarding this request Teiephone number Mary Lynn Thomas ( 301 ) 492-3886

4. Titie of information collection or rulemaking l

{

NRC Form 313 - Application for Material License 1

5. LeSai autnotity for informetson conection or ruie (cite Unitec 5%es L.Me. Pubhc Law, or becutne Order) 42 use 2201(o) . or 1

l 6. Affseted pubhc (check all tnat apply) $ @ Federalagenciesoremployees l 1 Individuals or households 3 0 rarms s @ Non.profitinstitution. l 2 3 State or localgovernments 4 3 Businesses or other for. profit 7 @ Smallbusinessesororganizations i PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. RIgulatEn identifier Number (RIN) j _, or, None assigned O l 8. Type of suomussion (cneck one on each categOl, Type of revkw requested l Classification Stage of development 10 Standard 1 C Major 1 O proposed or draft 2 O Pending l

2 C Nonmajor 2 O Finalorintenmfinal,withpnorproposal 3 O Emergency 3 O Final or entenm final, without pnor proposal 4 0 statutoryorjudiciaideadhne

9. CF R section attected CFR

10. Does this regulation contain reporting or recordkeeping require nents that require oMB approval under the Paperworli Reduction Act and 5 CFR 13207 . O Yes C No

11. If a major rule. es there a regulatory impact analysis attached? 1 O yes 2 O No if ~No " did oMB waive the analysis? 3 0 ves 4 0 No C: ratification for Regulatory Submissions in submeting this reauest for oMB review, the authorized regulatory contact and the program official certify that the requirements of E.o.12291 and any applicable poney d,rectives have been comphed with S'gnsture of program official Date Signature of autnonzed regulatory contact Date

12. t0MB use only) vious eottions obsosete 83 108 stansers Form a3 (Rev 9-83)

P's*N 7540-00-634 4034 N Prescribed by OMB 5 CrR 132o and E o 12291

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9807080134 980611 WL - nd

PART lli.-Ccmpiste This P:rt only if ths Rsquist is far Approvtl af a Celltetian cf infermitian Under the Paperwork Reduction Act and 5 CFR 1320.

13. Abstract-oesenb. needs. uses and affected puboc in 50 words or iess

" Radioactive Materials, Radiation Safety" A proposed revision to 10 CFR 34 will require additional information to be submitted on NRC Form 313. This information will be reviewed to determine whether a material license applicant is qualified by training and experience and has eouipment, facilities, and procedures that are adequate to protect the health and safety of the public.

14. Type of mformation cortection (check only one)

Information collections not contained in rules 1 { Regular submission 2 C Emergency submission (certificationattached)

Intstmation collections contained in rules 3 C Existmg regulat'on (no change proposed) e Final or interim final mthout prior NPRM 7. Enter date of expected or actual Federal 4 C Not.ce of proposed rutemaking(NPRM) A C Regular submission Register pubhcation at this stage of ruiemaking 5 C Finat NPRM was previously pubbshea B C Emergency submission (certification attached) (month, day year) l

15. Type of review requested (check only one) 1 U New collection 4 O Reinstatement of a previousiy approved coiiection for wnicn aporo,ai j 2 b Recsson of a currently approved collection has expired l 3 U Estension of the erpiration date of a currently approved collection 5 C Existmg collection in use without an oMB control number ethout any change m the substance or m the method of collection

16. Agency report form numberts)(include standard: optional form number (s)) 22. Purpose of information collection (check as many as apply) 1 Application for benefits NRC Form 313 2 O Program evaiuation

17. Annual reportmg or disclosure burden 3 C Generalpurposestatistics I I Number of respondents . '

4 C Regulatoryorcompliance 2 Number of responses per respondent i

• 5 O Program planning or management 3 Total annual responses (line I t,mes ime 2) 4.340 s O Research 4 Hours per response 9.0 7 C Audit 5 Totamours vme 3 t,mes ime 4) 39.060

18. Annual recordkeepmg butden 23. Frequency of recordkeepmg or reporting (checa att that apply) 1 Nurnber of recordkeepers 1 O Recordkeeping 2 Annuai hours per recordkeeper Reporting 3 Total recordkeepirt hours (Ime 1 times line 2) _ 2 3 onoccasion 4 Recordheepmg retention period years 3 ] w,,gy j

19. Totai annual bur den 4 O Monthiy I 1 Reavested (line 17 5 plus line 18-3) . 30.000 5 C Quarterly \

2 in current oM8 invento,y 39.060 6 0 semrannuaily 3 Difference (One J less line 2) 0 7 O Annually Explanation of difference 8 0 Brenn ally 4 Program charge 9 3 other(describe): Renewal every five years 5 Adiustment .

20. Currert(tr recent) oMB control number or comment number 24. Respondents' obbgrJtion to comply (check the strongest ochgation that applies)

M 9 ni7n

21. Requested expiration date 1 C Voluntary  ;

2 U Required to obtain or retain a benefit 6/30/96 _

3 3 Mandatory 1

25. Are the respondents pnmanly educational agencies or mstitutions or is the primary purpose of the collectior' related to Federal education programs? O Yes O No

26. Does the agene use samphng to select respondents or does the agency recommend or presenbe the use of sarrpkng or statistical analysis by respondents C Yes C No

27. Peguiatory authority fcr the miormation cokection

'10 cFR 30. 32.32.11.33.12J4.3,35.12re36.11,39.11, & 4Q,,c,p,c,,g htperwork Certification l- in submttting this request for oMB approval, tne agency head, the senior official or an authorized representative. certifies that the requirements of 5 CFR 1320, the Privacy Act. statistical standards or direttives, and any other applicable information pokcy directives have been comphed with, signature of program officias Date

. signature agency heaa. th se .or otticial or an authorized representative Date l 1 G m id F. Cranf d. DSO -

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Information Resources Management A/ fu /

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l PbR OMB SUPPORTING STATEMENT FOR 10 CFR PART 34 LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY REQUIREMENTS FOR RADIOGRAPHIC OPERATIONS (3150 0007) and NRC 313. APPLICATION FOR MATERIAL LICENSE (3150 0120)

Description of the Information Collection 10 CFR Part 34 provides certain requirements exclusive to licensees using byproduct material for aur)oses of industrial radiography, a technique of non-destructive testing. T1e )yproduct material is normally employed in the form of sealed sources which emit high levels of radiation. Those sources are remotely moved from their shielded position in the radiographic device to an unshielded position up to 15 feet away and again returned to their shielded position following each radiograph. These radiographic devices are also often moved from location to location at a jobsite, and transported from jobsite to jobsite. The?

many manipulations of the sources, movement, and transport of the devices result in unique and continuing potential and actual hazardous radiological conditions.

This rulemaking revises 10 CFR Part 34 in its entirety. This revision includes additional safety requirements to enhance the level of protection of radiographer and the public and clarifies the regulations so that licensees may have a better understanding of what is expected in radiographic o>erations. This rulemaking includes a number of updated radiography regulations t1at have been adopted by many Agreement States.

A. JUSTIFICATION

1. Need and Practical Utility for the Collection of Information The information collection requirements of the revised 10 CFR Part 34 are identified below.

S 34.11 A)olication for a specific license. and S 34.13 Soecific license for radicaraoly.

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

Paragraph 34.13(b). currently Saragraph 34.11(b). requires applicants to have a training program for radiograplers and radiographer' assistants, and to submit to the Commission a schedule or description of the program specifying (1) the initial training: (2) on the job training: (3) annual safety reviews; and (4) means to be used to determine the radiographer's and radiographer's assistant's

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knowledge and understanding of and ability to comply with the applicant's operating and emergency procedures. This information is reviewed by the NRC staff to ensure that radiographer and their assistants will have sufficient training to enable them to work safely and in compliance with NRC regulations, license conditions, and licensee operating and emergency procedures.

Paragraph 34.13(c), currently paragraph 34.11(b)(5) has been rewritten, it now l requires applicants to establish and submit to the Commission a description of its procedures for verifying and documenting the certification status of its radiographer and for ensuring that the certification of individuals acting as rcdiographers remains valid. The procedures are intended to ensure the licensee has an adequate program in place for assuring that individuals acting as radiographer are certified as required and that the licensee is aware when an individual's certification needs to be renewed. The NRC reviews the procedures to ensure that the licensee is able to adequately administer the certification program. A record of the verification is to be maintained in accordance with 6 34.79.

Paragraph 34.13(d), currently paragraph 34.11(c), requires that the applicant establish and submit to the Commission satisfactory written operating and emergency procedures. The operating and emergency procedures are intended to provide radiography personnel with step by step instructions and )rocedures so that the performance of industrial radiography will not endanger 1ealth or pose 4 danger to life or property. The preparation of operating and emergency procedures is intended to ensure that radiography personnel are aware of the steps to be followed in conducting radiogra> hic operations, so that there is no misunderstanding of what is required of eac1 person involved in the overall radiography operation. The Commission reviews these procedures to ensure that they are adequate to protect the worker and the public health and safety.

Paragraph 34.13(e), currently paragraph 34.11(d). requires that the applicant establish and submit its program for annual inspections of the job performance of each radiographer and radiographer's assistant as described in S 34.43(d). The existing rule requires quarterly inspections. The frequency was reduced to annual to reduce the burden on licensees. The inspections are necessary to

~sure that radiogra>hers and radiographer' assistants are performing their jobs in accordance with t1e operating and emergency procedures set forth in their license. The Commission reviews this information to ensure that the licensee has developed an adequate program for evaluating the knowledge of radiographer to perform their duties.

Paragraph 34.13(f), currently paragraph 34.11(e), requires that the applicant submit a description of its overall organizational structure as it applies to the radiation safety responsibilities in radiography, including s)ecified delegations of authority and responsibility. The NRC staff will review t11s information in order to ensure that the licensee's organization will provide adequate management oversight, su>ervision and accountability for safe o>eration of the radiography program and t1at the lines of authority and responsi)ility are clear and unambiguous.

Paragraph 34.13(g) is new. It requires the applicant to designate and identify a Radiation Safety Officer (RS0) responsible for implementing the licensee's radiation safety program. This requirement, albeit, new to the regulation, is not a new requirement. This has been addressed as Item 7. " Individual

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

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Paragraph 34.13(h), currently )aragraph 34.11(f). requires an a>plicant that desires to conduct its own lea ( tests to determine possible leacage or contamination from sources used in industrial radiography to identify the manufacturers and model numbers of the leak test kits to be used, and to provide its specific procedures for performing the tests. The )rocedures for performing I the tests must specify the method of performing the lea ( test the instrumentation to be used for measurement of the leak test sample, and the experience of the person who will perform the tests. The NRC staff reviews the procedures to ensure that the method of obtaining the leak test sample will be adequate to determine if there is any leakage or contamination. and that the person who will perform the leak tests has sufficient training and experience in performing such tests.

Paragraph 34.13(1) is new. It requires the applicant to identify the locations and describe all field stations and permanent radiographic installations. This ,

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

been included under " Facilities and Equipment." Item 9. on NRC Form 313. It is addressed in the regulation in order to make it clear to the licensee / applicant that all field stations and permanent facilities need to provide this information in their ap)lication. This information is needed so that NRC is aware of all locations w1ere radioactive material could be stored and/or used to verify the adequacy of that use and/or storage for ensuring adequate protection of the public health and safety.

Paragraph 34.13(j) is new. It allows the applicant from the effective date of the final rule to 2 years after its publication in the Federal Register, the option to affirm that all individuals acting as radiographer will be certified in radiation safety by a certifying entity before commencing duties as radiographer. This affirmation could be used in lieu of describing the means used to determine the radiographer's knowledge and understanding of the subjects outlined in S 34.43(f). It allows the applicant the option to substitute radiographer certification in lieu of the described means to determine the radiographer's knowledge and understanding of the subjects outlined in S 34.43(f). This information would be submitted in lieu of the inforniation in S 34.43(f) and would be used by the NRC to ensure that the licensee has sufficient training to enable them to work safely and in compliance with NRC regulations, license conditions. and licensee operating and emergency procedures.

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

All information required by the revised sections is required by the current i regulation except for annual safety reviews, required by paragraph 34.13(b), and identification of manufacturers and model numbers of leak test kits. required by l paragraph 34.13(h). and the new requirements of )aragraphs 34.13(g) and 34.13(1).

The increase in burden for NRC Form 313 due to t1ese added requirements is included in the licensee burden table.

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4 S 34.20 Performance requirements for radicaraohv eauioment.

Paragraph 34.20(b)(1) is unchanged from the current rule and requires that each  ;

radiographic exposure device have an attached label bearing information identifying the radionuclides in the device, its activity and the date that this activity was last measured, the manufacturer, model and serial number, and the licensee's name, address, and telephone number. This information will serve as a safety notice to users and members of the public. .The label requirement has been incorporated in the regulations, in part, in conformance with ANSI Standard N432.

Paragraph 34.20(b)(2) requires that radiographic ex>osure devices intended for use as Type B transport containers meet the applica)le requirements of 10 CFR Part 71.

Paragraph 34.20(f) is new. It requires that all associated equipment acquired after January 10, 1996, be labelled to identify that the components have met the requirements of section 34.20. This was added to reduce the burden of proof on the licensee and to speed up the inspection process by reducing record searches  ;

for a component to ensure that it meets the requirements of Part 34.  !

S 34.25 Radiation survey instruments.

Paragraphs (b) and (c) of S 34.25 require that each radiation survey instrument ,  ;

be calibrated at intervals not to exceed 5 months and after each instrument servicing, and that a record be maintained in accordance with 5 34.65. The existing rule requires that radiation survey instruments be calibrated at 3 month intervals and a record maintained of the calibrations. The i calibration interval is being extended from 3 months to 6 months because survey instruments are now sturdier and more reliable. The making of radiation surveys is one of the most important aspects of radiation safety and the instruments must provide reasonable accuracy in the measurement of the levels of radiation to which individuals are exposed during conduct of radiographic operations. The  ;

records allow NRC inspectors to verify that required calibrations have been performed. The licensee will use the records to assure itself that the instruments available to radiographer and radiographer' assistants are properly calibrated. This is a burden reduction, since licensees will be required to maintain fewer records under the revised rule.

S 34.27 Leak testina and replacement of sealed sources.

Paragraph 34.27(b)(2) requires the licensee to maintain records of leak test results in accordance with S 34.67 and is the same as the existing requirements in S 34.25(c).

Paragraph 34.27(b)(3) requires that the licensee not use a sealed source in the absence of a certificate from the transfsror that the source has been leak tested within the 6 months before the transfer, and is the same as the existing wording in paragraph 34.25(b). This is necessary to ensure that the licensee is aware that a source is not leaking prior to use.

Paragraph 34.27(c) requires that the licensee perform the leak test required by paragraph 34.27(b)(1) using a leak test kit or a method approved by the Commission or an Agreement State. and that the person performing the leak test be f

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a) proved by the Commission or an Agreement State. This is necessary to ensure tlat the licensee performs the test properly.

Paragraph 34.27(d) requires that licensees report within 5 days of the leak testing any result which would indicate that a source is leaking and is the same as the existing requirement in paragraph 34.25(d). The report must describe the equipment involved, the test results, and the corrective action taken. The NRC staff uses the report in assessing whether the corrective actions initiated by the licensee are adequate to protect workers and the public from the hazards of a leaking source. The NRC staff also uses the report to identify generic problems with respect to source design, radiographic equipment design, or problems in source manufacturing and quality control.

I The only new requirement in this subsection is the addition of leak testing of i "S" tubes. Paragraph 34.27(f) requires licensees to conduct leak tests of "S" '

tubes manufactured using depleted uranium for shielding, at least annually, and to maintain records of these tests in accordance with $ 34.67. A leak test is the only effective method of determining the integrity of the sealed source.

Serious health hazards could result from a leaking source. The records allow the licensee and the NRC to verify that the required tests to detect radioactive contamination have been performed.

S 34.29 Ouarterly inventory. ,

Paragraph 34.29(a) requires the licensee to conduct a quarterly physical-inventory to account for all . sealed sources received and possessed under the i license, and paragraph 34.29(b) requires the licensee to maintain records under S 34.69 of the material inventoried for 3 years and is similar to the existing requirements in 34.26. This is used by the licensee and NRC to verify that all radioactive material is accounted for and is properly stored.

S 34.31 Inspection anc maintenance of radicara> hic exoosure devices, storace containers. associatec eauioment. and source clanaers.

Paragraph 34.31(a) requires that the licensee visually check for obvious defects in radiographic exposure devices, storage containers, associated equipment and source changers prior to use each day the equipment is used to ensure that the equipment is in good working condition and that required labeling is present.

While the current rule requires a daily check. no requirement for follow up actions was included and associated equipment is not included in the current rule. Associated equipment has been added to the new rule because experience has shown that defects in this equipment can affect safety. The revised rule specifies that if defects are found, the equipment must be removed from service until repaired, and a record must be made in accordance with 6 34.73. The new requirement was added to ensure that licensees take appropriate actions if defective equipment is found. A record is needed for the licensee and NRC to verify that the appropriate actions have been taken if defects are found.

Paragraph 34.31(b) requires that the licensee have a program to inspect for obvious defects of radiographic exposure devices, source changers, associated equipment and storage containers at three month-intervals to ensure the proper functioning of equi) ment, to remove defective equipment from service until it is repaired, and to mace a record under S 34.73 of each quarterly inspection and any defects found during the inspection and to keep these records for 3 years. The l

6 revised recordkeeping requirements in paragraph 34.73(b) are an expansion of what is presently in 5 34.28(b) which requires that records be kept of inspections for hat information to keep. The records assist the 3licensee years but did nottrack in keeping specify of w'when the equipment was.last inspected and maintained and when inspection'is next due. The records are used by NRC staff to determine I the extent of compliance by the licensee, and to detect problems that may be

. generic to the equipment so that corrective action might be taken.

S 34.33 Permanent radioarachic installations.

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- Paragraph 34.33(b) requires that the alarms on permanent radiographic installations required by $ 34.33(a) be tested at the beginning of each day of equ poent use in order to ensure that they are functioning )roperly to prevent ina vertent entry into a radiographic installation (cell) w1ile a source is in the unshielded position. Defective control devices on alarms are to be immediately labeled as such and repaired before use. This is necessary to warn personnel of tential radiation hazards. The testing frequency has increased from quarterl in the current rule to daily in the revised rule to prevent

. personnel overexposure due to defective alarms. Records of the alarm test are to be maintained under S 34.75 for 3 years, which is the same as tbc current

- requirement in'$ 34.29(c), with the additional requirement of recording the alarm system tests performed before each day of use. These alarms arr; an important backup to the radiation survey instrument and are intended to prevent inadvertent entry into a radiographic installation (cell) while a source is in the unshielded

)osition. These records verify that the alarms are functional and that repairs lave been made when required.

.S 34.35 Labels.'storace. and transportation precautions.

Paragraph 34.35(a)(2) is a.new sectirn that requires that the licensee not transport licensed material unless the material is packaged, labeled. marked and accompanied with appropriate shipping papers in accordance with regulations set out in 10 CFR Part 71, including documentation of the QA program requirements -

. outlined in S 71.105. This is necessary so that the licensee may demonstrate that it.is in compliance with regulations stated in this part and in Part 71.  ;

$ 34.42 Radiation Safety Offigt This is a newlsection that establishes training and experience requirements for the Radiation Safety Officer (RS0). The RSO is res)onsible for establishing and j overseeing the development of procedures required >y S 34.45:.ALARA procedures as recuired by 10 CFR Part 20; overseeing the training program required by 5 34.43: '

anc overseeing the performance of radiation' surveys and leak tests required by 5 l 34.49 and 5 34.27 respectively: that records of personnel monitoring results'are maintained and that timely notifications are made as required by 5 20.2203. The

RSO is to be listed on the license application as required in S 34.13(g). This information is reviewed by the NtC to ensure the adequacy of the training and

. qualifications of the RSO. whose job _is critical to ensuring the safety of the .

radiographer and the public.

S'34.43 Traini k I . Paragraph 34.43(a)(2)'is new. It requires that radiographer be certified by a ,

l certifying entity according to the criteria in 10 CFR Part 34, Appendix A. An

7 i independent organization must submit a request to NRC to be recognized as a  ;

certifying entity. The request is reviewed by the NRC to verify that

. radiographer receive sufficient training to meet minimum qualifications with respect to radiation protection and safety.

-. Paragraph 34.43(a)(3), currently 34.31(a)(2), contains a new requirement for the licensee to provide radiographer with copies of pertinent sections of Parts 30 and 71, and instructions in applicable Department of Transportation regulations

-as referenced in 10 CFR Part 71. in addition to the existing requirement to provide copies of pertinent sections of Parts 19, 20, and 34: the NRC license:

and operating and emergency procedures. This is needed to ensure that-radiographer are sufficiently knowledgeable of applicable regulations prior to using licensed material.

Paragraph 34.43(b)(1), currently 34.31(b)(1), contains a new requirement for the  !

licensee to provide radiographer's assistants with copies of pertinent sections of Parts 30, and 71, and instructions-in applicable Department of Transportation regulations as referenced in 10 CFR Part 71, and the NRC license under which the a:sistant will perform radiography, in addition to the existing requirement to provide copies of pertinent sections of Parts 19, 20, and 34: and operating and emergecy procedures. This is needed to ensure that radiographer's assistants  !

are sufficiently knowledgeable of applicable regulations prior to using licensed material'. .

Paragraph 34,43(e) requires that the licensee maintain records of training to j include certification documents, certification status verification, written and i field examinat!ons,. annual safety reviews, and annual inspections of job l performance. TN licensee shall maintain records of the aforementioned items in  :

5 34.79, which is currently required in 5 34.31(c) with the addition of the new  !

requirement for documenting the information covered in annual safety reviews.  !

The existing regulation does not have a specific recordkeeping requirement except  !

for tests administered. The revised rule requires licensees to keep track of I

.when and what training was provided, and who provided and received the training.

This is needed to enable' licensees to a ately administer their training i program and to demonstrate compliance wit NRC requirements. The records of the annual. inspections of job prformance will be usec by the licensee to keep track of deficiencies, if noted, sa that they can be corrected. Section 34.79 requires.  !

that the licensee retain these records for a period of 3 years after the record is made so that the NRC can inspect to ensure that these individuals are properly trained. l

-5 34.45 Doeratina and eneroency orocedures. l Paragraph 34.45(a). current 1'/34.32, requires that licensees develop procedures l for routine operations and emergencies for employees to follow in performing i safety functions. These irclude the safe' handling and use of sealed sources and '

radiographic exposure devices: conducting radiation surveys: controlling access to radiographic areas: locking and securing radiographic exposure devices,  ;

storage containers, and sealed sources: personnel monitoring: transporting sealed sources: inspection and maintenance of radiographic exposure devices and storage containers; steps to be token if a pocket dosimeter is off scale: procedures for ,

identifying'and reporting defects and noncompliance; accident procedures: l l minimizing exposure: a source recovery procedure if the licensee will perform this function rather than using a consultant (which is a new requirement); and p .

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' maintenance of records. Paragraph 34.45(a)(6), currently 34.32(f), is not new, the word " posting" has been changed to " placarding" to fit better when discussing transportation issues, and the reference to the Department of Transportation, 49 l CFR Parts 171,172, and 173 has been added to provide further information  !

regarding transportation of radioactive materials. The requirement for a source recovery procedure in paragraph 34.45(a)(12) is new. It is only necessary for the licensee to have this procedure if a licensee is going to recover sources. <

Operating and emergency procedures are necessary to ensure that individuals handling radioactive material will have guidance in appropriately carrying out safety functions.

Paragraph 34.45(b) requires that the licensee maintain copies of current 1 operating and emergency procedures and is unchanged from the requirements currently in S 34.32. This is necessary to ensure that individuals have current procedures to use in the conduct of radiographic operations.  !

S 34.47 Personnel monitorino, ,

Paragraph 34.47(b) requires radiographer to read and record the exposure on the their mcket dosimeters at the beginning and end of each shift. and that records I shall a maintained for 3 years as specified in paragraph 34.83(a). This to ensure that radiographer determine and maintain adequate records of their occupational exposures in order to ensure they do not exceed the dose limits. e The current rule requires pocket dosimeters to be read and exposures recorded daily, but many have misinterpreted this requirement, so the language was revised I to clarify the intent that the only exposure that needs to be recorded is the one received during the shift. This is for the licensee to know the amount of exposure a worker received during a given shift in case the film badge or TLD is lost, so the licensee can take appropriate action (e.g., adjust the worker's assignments so as to maintain their accumulated dose within regulatory limits or provide training to improve their work habits and thus reduce their dose) in event of an overexposure.

Paragraph 34.47(c) requires that the pocket dosimeters be checked at periods not to exceed 12 months (rather than 1 year as in the current rule) for correct response to radiation, and that records shall be maintained for 3 years as specified in S 34.83(a). The changes are to clarify that 1 year means not to exceed 12 months, and to include maintenance of records of pocket dosimeter checks. These records are necessary to for the licensee to be able to verify that the pocket dosimeter is responding correctly to radiation.

Paragraph 34.47(d) requires that a determination of exposure be made if a individual's pocket dosimeter goes off-scale and that the result of the determination be maintained in accordance with S 34.83(d). This is revised from the current rule to restrict individuals from working with a discharged dosimeter, unless any exposure to radiati6n can be ruled out or the RSO makes a determination of the individual's exposure and makes a record of that determination. This determination is naeded to verify that an individual's dose does not inadvertently excesd regulatory limits.

Paragraph 34.47(e) requires that if a film badge or TLD is lost or damaged that the exposure be calculated for the time perioc, from issuance to loss or damage, and that a record be mintained of the calcuhtion in accordance with

9 9 34.83(d). This also is required to ensure that a worker's dose does not exceed regulatory limits.

I Paragraph 34.47(f) requires that the licensee maintain reports received from film

, badge and TLD processors until the license is terminated as specified in the l current rule under S 34.33(e) and in S 34.83(c) of the revised rule. This information may be needed to reconstruct a worker's dose history in the event they lose their records, and to permit a planned special exposure.

Paragraph (g) of S 34.47 requires that alarm ratemeters be calibrated at periods not to exceed one year for correct response to radiation. A new requirement is added that the licensee must maintain records of the calibrations for 3 years after the record is made as specified in S 34.83(b). This was added to provide a means for the licensees to demonstrate to NRC that their alarm ratemeters are properly calibrated.

S 34.49 Radiation surveys.

Paragraph (f) of 9 34.49 requires that radiography licensees maintain cords of storage surveys required by paragra>hs (d) and (e) in accordance with 5 34.85 for 3 years. A record of t1e survey is required by paragraph (d) of S 34.49 when that survey is the last one that is performed on that day and is unchanged from the current rule. It is needed to demonstrate that the ,

radioactive source is in the fully shielded position at the end of the work day after the device has been placed in its storage location. A device may remain stored for an extended period and, if the source is not fully shielded, it could cause excessive and unnecessary radiation exposure to workers and members of the public. Records of surveys conducted initially with the maximum amount of radioactive material present in the storage location and thereafter at the time of the quarterly inventory and whenever storage conditions change as required by paragraph (e), are needed for the licensee to demonstrate that radiation levels do not exceed the limits specified in 10 CFR 20.1301.

The following sections are not entirely new. Most of the requirements contained in these sections are imbedded throughout the current rule. This subpart has been added to place recordkeeping requirements in one location in the rule.

S 34.61 Records of specific licenses for radioaraohv.

This new section requires the licensee to have a copy of the license license conditions, documents incorporated by reference, and amendments until the NRC terminates the license. The purpose is so that the licensee will review the documents regularly to verify that they are in compliance with the conditions of the license and the commitments that it has made.

S 34.63 Records of receiDt and transfer. '

This section requires that the licensee maintain records showing receipts and transfers of sealed sources for 3 years after the record is made. Section 30.51 already requires radiography licensees covered under Part 34 to maintain records of byproduct material receipt and transfer for 3 years. This provision was added to Part 34 because some licensees misunderstood the applicability of this requirement. The following information must be included in the record: the date, the individual making the record, the radionuclides, number of curies, and

l 10 make, model, and serial number of each sealed source and device as appropriate.

The records allow NRC inspectors to verify the sources the licensee is presently using.

S 34.65 Records of radiation survey instruments.

This new section requires that the licensee maintain records of the calibrations of their radiation survey instruments, and that the records be retained for 3 years. These requirements are the same as those in the current S 34.24. The records allow NRC inspectors to verify that required calibrations have been performed. The licensee will use the records to assure itself that the instruments available to radiographer and radiographer's assistants are properly calibrated. Because instruments will be required to be calibrated semiannually under the revised rule versus quarterly under the current rule, this is a burden reduction, since licensees will be required to maintain fewer records. These records are necessary to verify that the licensee is in compliance with NRC requirements as described in S 34.25, and to ensure the safety of the users of these instruments.

S 34.67 Records of leak testino and replacement of sealed sources.

This new section requires that the licensee maintain records of leak test results and that the records be retained for 3 years. These requirements are the same as, those in the current S 34.35(c). These -ecords are necessary to verify that the licensee is in compliance with NRC requirements as described in S 34.27, and to ensure the integrity of the sealed sources in use.

S 34.69 Records of cuarterly inventory.

This section requires that the licensee maintain records of quarterly inventories. Paragraph (a) requires that the records be retained for 3 years.

Most of these requirements are the same as those in the current S 34.26.

Paragraph (b) requires that the record include the quantities and kinds of byproduct material (including the model number, the serial number and manufacturer), location of sealed sources, the name of the individual conducting the inventory and the date of the inventory. The new requirements are the model and serial numbers, the manufacturer of the sealed source, and the name of the individual conducting the inventory. These new requirements were added to ensure that licensees maintain complete records to ensure traceability of sealed sources. The inventories are used by the licensee to verify the location of sources and to control the type, quantity and use of byproduct material. The records allow NRC inspectors to verify that the required inventories have been conducted and to ensure that the licensee is in compliance with authorized possession limits.

S 34.71 Utilization loos.

Paragraph (a) of this section requires that the licensee maintain current utilization logs. These logs must show for each sealed source the following information: (1) a description, including the make, model number and serial number of the radiographic exposure device or storage container in which the sealed source is located: (2) the identity and signature of the radiographer to whom assigned: (3) the plant or site where used and dates of use, including the dates removed from and returned to storage. The new requirements in this section

l 11 are the model and serial numbers and the manufacturer of the radiographic exposure device, the signature of the radiographer to whom assigned, and the dates the device is removed from and returned to storage. These requirements were added to verify that the licensee is maintaining adequate control of licensed material. The current regulation only requires a description ~of the device or storage container, the identity of the radiographer to whom assigned and the plant or site where used and the dates of use. Paragraph (b) of this section requires that the licensee retain these records for a period of 3 years '

after the record is made. The records required by this section allow NRC inspectors to determine whether the licensed material has been properly controlled and used.

S 34.73 Records of inspection and maintenance of radiocrachic exoosure devices.

storace containers. and source chanaers.

This new section requires that the licensee maintain records of inspection and maintenance of radiographic exposure devices, storage containers and source changers, and that the records be retained for 3 years. The records specified at S 34.73 must include the date of check, equipment inspected, name of inspector, and any defects found and repairs made. The records are needed to enable the licensee to keep track of when the equipment was last inspected and maintained and when inspection is next due. The records are used by NRC staff to determine the extent of compliance by the licensee, and to detect problems that may be generic to the equipment so that corrective action might be taken.

• S 34.75 Records of oermanent radiocraohic installations.

This new section requires that the licensee to maintain records of the alarm checks at permanent radiographic installations, and that the records be retained for 3 years. The records are needed to enable the licensee to keep track of when entrance control tests were last performed and when they are next due. The records are also used by NRC inspectors to determine compliance with required testing of important safety equipment and to verify that personnel are not inadvertently exposed by the existence of malfunctioning alarms.

S 34.79 Records of trainino and certification.

This new section recuires that the licensee maintain records of training and certification of raciographers and radiographer' assistants. Paragraph (a) requires that the record include radiographer certification documents.

certification status verification, copies of written tests, dates of field examinations, and names of individuals conducting the field examinations.

Paragraph (b) requires that records of annual safety reviews and annual inspections for each radiographer and each radiographer's assistant be maintained. The records must list the topics discussed, the dates of the reviews, and names of the instructors and attendees. For annual inspections the records must also include a list of the questions asked and any non compliances observed. The existing regulation does not have a specific recordkeeping requirement except for tests administered. The revised rule requires licensees' to keep track of the dates of specific training provided, and who provided and received training. This is needed to enable licensees to demonstrate compliance with NRC requirements and to keep track of when training is required. The records of the annual inspections of job performance will be used by the licensee to keep track of deficiencies if noted. so that they can be corrected.

l

$ 12 S 34.81 Records of operatina and emeraency orocedures.

l-a This new section requires ~the licensee to retain records of operating and emergency procedures until the Commission terminates the license and that the

[ licensee retain copies of superseded material for 3 years after each change. The records allow the operators to have. access to an up to date set of written omrating procedures so that they can operate the radiography equipment properly.

T1e NRC inspectors review these procedures to ensure that current instructions are being provided to the workers.

S 34.83 Records of personnel monitorino.

Section 34.83 revises the current 5 34.33(b) and requires licensees to maintain records of alarm ratemeter calibrations, pocket dosimeter readings and operability checks for 3 years from the date the record was made, and to maintain records of film badge or TLD reports, and records of estimates of exposures as a result of off-scale pocket dosimeters or lost or damaged film badges or TLDs-l until the Commission terminates the license.

l l- The records serve as an important mechanism for controlling exposure on a day-to-day basis, provide indications of inadvertent exposure, and provide a backup o record of estimated exposure in case a film badge or thermoluminescent dosimeter is' lost. Pocket dosimeter readings are often the first indication a radiographer, has of an overexposure or an improperly stored source. Records of pocket dosimeter readings are needed in investigations of incidents and overexposure, since they are the only available record for the exposure received that day.

S 34.85 Records of radiation surveys.

This new section requires that the licensee maintain records of each exposure i: device survey conducted before placing the device in storage for 3 years after the record is made in accordance with $ 34.49(e) if that survey is the last one performed in the work ~ day. . The records enable the licensee to verify that the required radiation surveys have been done and that they are in compliance with the radiation dose limits.

S'34.87 Forms of records.

. This section describes allowable forms for official records. This section i

.(currently at 5 34.4) is not new. The word " maintenance" was changed to " form" in keeping with the latest language used in NRC regulations. It requires that the records required by Part 34 be legible throughout the specified retention

, period. The record may be the original or a reproduced copy or a microform i

- provided that the copy or microform is authenticated by authorized personnel and i 1that the microform is capable of reproducing a clear copy through out the required retention period.' The. record may also be' stored in electronic media with the  ;

capability for producing legible, accurate, and complete records during the required retention period.- Records, such as letters drawings, and -

specifications, must include all pertinent information, such as stamps, initials, and signatures. The licensee is to maintain adequate safeguards against

tampering with and loss of records.

1 L

9....

13 5 34.89 Documents and records reauired at field stations and oermanent instal ations. ,

This new section adds the requirement to maintain copies of the following records at field stations and permanent. installations to demonstrate compliance with NRC regulations in conducting radiographic operations and to ensure that adequate information is available to safely handle radioactive material:

(2). ~ A copy of Parts'19. 20. and 34 of NRC Regulations:

(b) .The license authorizing the use of licensed material:

(c) .0)erating and emergency procedures required by $ 34.45:

(d) 'T1e record of radiation survey instrument calibrations required by 5 34.65:

L (e)- Records of leak test results required by $ 34.67:

1 (f) Quarterly inventory records required by $ 34.69:

. (g) Utilization records required by 5 34.71:

(h)' Records of inspection and maintenance required by $ 34.73:

(1) For )ermanent installations. records of alarm system and entrance control chects required by 5 34.75.

(j) Training and certification records required by $ 34.79:

(k)' : Survey records required by 5 34.85.

. (1) Personnel monitoring records as required by $ 34.83: and L - (m) Records of receipt and transfer of sealed sources required by $ 34.63.

H 34.91 Documents and records reauired at temoorary .iobsites and use or storace ocations exceed < na 180 days.

l This new section adds the requirement that each licensee conducting operations at

- temporary jobsites or storage locations for more than 180 days shall maintain copies of the following documents and records :

i . .

, (a) The license authorizing the use of licensed material:

i (b) ~ 0perating and emergency procedures required by l 34.45.

. (c) Evidence of latest calibration of the radiation survey instruments in use o at the site required by 5 34.65.

L (d) Evidence of latest calibration of alarm ratemeters and operability checks of pocket dosimeters required by 5 34.83.

Latest survey records required by 5 34.85.

l' (e)-

(f); The shipping papers for the transportation of radioactive materials

. required by l-71.5 of this chapter: and

. (g) When operating under reciprocity pursuant to i 150.20 of this chapter. a copy of the Agreement State license authorizing use of licensed materials.

4 These are needed to ensure that workers have' the sufficient information available to safely perform radiographic operations.

34.101 Notifications.

This section.. currently at i 34.30. contains notification requirements. Sections

..34.101(a) and (b) specify requirements for notifying the NRC within 30 days of significant health and safety events and are unchanged from the current rule. A new subparagraph. -34.101(c). has been added that requires the licensee to notify the appro)riate NRC regional office in writing within 30 days prior to conducting radiograp11c operations or storing radioactive material in excess of 180 days at

- any location not listed on the license. These requirements are necessary in

e 14 order to provide the NRC with information in a timely manner to permit inspection .

'of radioactive material at these locations to. ensure that they are in compliance

with NRC safety regulations. -

Appendix A L A)pendix A would.specify the requirements to be an independent organization and tie certification program criteria all organizations must address. Appendix A does not impose new requirements on NRC's radiography licensees. Part I of this Appendix provides the requirements to be an independent certifying organization.

Parts II and III provide the requirements for the certification program and written examinations for. a certifying entity, including the Agreement States.

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

Appendix A. Part I. item 3 would require that an independent certifying organization have a certification program that is open to non members. This ensures that the independent certifying organization will uphold 10 CFR Part 4 Subpart A - Regulations Im)1ementing Title VI of the Civil Rights Act of 1964 and Title IV of the Energy reorganization Act of 1974 with respect to prohibiting discriminatory actions.

Appendix A. Part I. item 5 would require that an independent certifying ,

organization have a permanent full-time staff, a viable system for financing its -

operations, and a policy and decision making review board. This provides L information to the NRC that the organization will have.the resources to maintain an adequate program.

Appendix A. Part I. item 6 would require that an independent certifying organization have a set of written organizational by laws ud policies that provide adequate assurance of lack of conflict of interest and a system for monitoring and enforcing those by-laws and policies. The procedures are needed I to asure the independent certifying organization has a program in place for monitoring and enforcing its by laws and policies. NRC would review the program

' description to ensure that it includes this element.

. Appen' d ix A. Part I. item 9 would require that an independent certifying

. organization have written procedures describing all as)ects of its certification i~ program, maintain records of the current status of eac1 individual's certification and the administration of its certification program. The procedures are needed to ensure that the independent certifying organization has an adequate certification program. The records are needed by the certifying organization to maintain an awareness of each individual's certification, and to record its activities on the administration of its certification program. They would review the records during periodic program reviews. NRC would review the program description to ensure that it includes this element.

Appendix A. Part I item 10 would' require that an independent certifying

. organization have procedures to ensure that certified individuals are provided due process with respect to the administration of its certification program.

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

15 Appendix A. Part I. item 11 would require that an independent certifying organization have procedures to ensure that the individuals proctoring each examination are not employed 'by the same company or corporation (or a wholly-owned subsidiary of such company or corporation) as any of the examinees. The procedures are needed to help ensure fairness in the examination process. NRC would review the prograli description to ensure that it includes this element.

Appendix A. Part I, item 12 would require that independent certifying organizations and/or Agreement States exchange information about certified individuals with the Commission and the Agreement States and allow periodic review of their certification programa and related records. The exchange of information and periodic review are to ensure that all individuals' certifications are current and valid. NRC would review the program description to ensure that it includes this element.

Appendix A. Part 1. item 13 would require that an independent certifying organization provide a description to the Commission of its procedures for choosing examination sites and for providing an appropriate examination environment. The procedures are needed to ensure that the independent certifying organization provide for appropriate examination sites and environments. NRC would review the program description to ensure that it includes this element.

Appendix A. Part II item 2 would require that a certification 3rogram must .

require applicants for certification to provide documentation t1at demonstrates that the applicant has: (a) received training in the topics set forth in Appendix A to this part: (b) satisfactorily completed a minimum period of on the job training: and (c) received verification by an Agreement State or a NRC licensee that the applicant has demonstrated the capability of independently working as a radiographer. Submission of this documentation to the certifying organization is necessary for the certifying organization to verify an applicant's training and to determine that the applicant meets certain certification criteria. NRC would review the program description to ensure that it includes this element.

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

Appendix A. Part II, item 4 would require that a certification program must include procedures whereby an application or certification would be considered null and void if the applicant or certified individual is archibited from acting as a radiographer by a regulatory agency at the time of macing the application.

The procedures are needed to ensure that the certification program include provisions for automatically denying certification to an individual if the individual has been prohibited from acting as a radiographer by the NRC or an Agreement State. NRC would review the program description to ensure that it includes this element.

Appendix A, Part II. item 6 would require that a certification program must include procedures for renewing the certifications and, if the procedures allow renewals without examination, require evidence of recent active full time employment and annual refresher training. The procedures are intended to ensure l

l

g 16 that the certification program include provisions for certification renewal. NRC would review the program description to ensure that it includes this element.

Appendix A. Part II. item 7 would recuire that a certification program must include procedures whereby an indivicual's certification may be revoked, suspended, or restricted for willful or significant failure to comply with his or her employer's operating or emergency procedures, or the Commission's or a l Agreement State's regulations. The procedures are intended to ensure that the 1 certification program include provisions for revoking, suspending, or restricting an individual's certification in the event of a willful or significant failure to ,

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

Appendix A. Part II. item 8 would require that a certification program must provide for automatic suspension of an individual's certification, based on Commission or Agreement State action prohibiting the individual from acting as a radiographer. This requirement is intended to ensure that the certification 1 program include a provision for automatic suspension that would prohibit an i individual from acting as a radiographer. NRC would review the program  :

description to ensure that it includes this element.

Appendix A. Part II. item 9 would require that a certification program must provide for sanctions imposed against certified individuals that are at least as severe as any action taken by the Commission or an Agreement State. This

• requirement is intended to ensure that the certification program include a provision to impose sanctions against certified indiv! duals, and would uphold the proposed 10 CFR Part 34. Subpart H Violations. NRC would review the program description to ensure that it includes this element.

2. Reduction of Burden throuah Information Technoloav There are no legal obstacles to reducing the burden associated with this information collection. The revision to 10 CFR Part 34.87 permits licensees to retain records in electronic format. Reports must still be submitted in writing, since these reports require the signature of a responsible official.

3. Effort to Identify Duplication ,

The Information Requirements Control Automated System (IRCAS) was searched and no duplication was found.

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

- 5. Effort to Reduce Small Business Burden Many NRC radiography licensees are su.all businesses. Efforts have been made to keep the requirements for information to a minimum. However, since the ,

consequences of mishandling a radiography source are likely to be the same for  ;

large and small entities, it is not possible to further reduce the burden on small businesses by less frequent or less complete recordkeeping or reporting.

l

. j b.

17-

6. . Consequences of Less Freauent Collection

. Applications are only required to be submitted for the initial license, for amendments. and for renewal.every 5 years. The application >rocess requires that applicants and licensees perform a comprehensive review of t1eir entire radiation safety program to assure that all activities will be or are being conducted safely and in accordance with NRC regulations. Requests for certification

program approval proposed in 5 34 43(a)(2) need to be submitted only once.

Requests for certification )rogram changes would be submitted on an "as needed" basis. The submission of t1e required information is essential to NRC's determination of whether the applicant has procedures that are adequate to protect the public health and safety and meet regulatory requirements. The ,

review and submission of the information required for the application is o essential to NRC's determination of whether .the applicant has training, experience, equipment, facilities and procedures for the use of byproduct

' material that are adequate to protect the public health and safety. Other reporting and recordkeeping requirements are occasioned by specified events such as leak tests.-instrument calibrations, and inventories of licensed material.

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

7. Circumstances Which Justify Variation from OMB Guidelines ,

Section 34.27(d) varies from OMB guidelines in requiring that licensees report within 5 days of the leak testing any result which would indicate that a source is leaking. This requirement for a report in less than 30 days is necessary - .

because a leaking source could present a radiological hazard to workers and the j public, and NRC must be notified )romptly in order to be able to assess whether  ;

corrective actions initiated by t1e licensee are adequate.

Section 34.81 varies from OMB guidelines in requiring that licensees retain a  ;

~ copy of current operating and emergency procedures as a record until the Commission terminates the license. _It is necessary that these procedures be retained longer that 3 years because the information is used by the licensee and its employees throughout the period of licensed activity to guide the handling and use of radioactive material in normal and emergency situations. '

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

1Section 34.83(d) varies from OMB guidelines by requiring that licensees maintain records of estimates of exposures as a result of off scale pocket dosimeters or  !

lost or damaged film badges or TLDs until the Commission terminates the license.

This information may be needed to reconstruct a worker's dose history in the  ;

event they lose their-records. and to permit a planned special exposure.  ;

8. Consultations Outsidetthe NRC 4

American Society for Nondestructive Testing. Inc. (ASNT) was consulted concerning the certification program development and information collection requirements.

The requirements included in the revised rule were extensively discussed in a  ;

public workshop held in Dallas. Texas in November 1992 and comments obtained in

l 18 that workshop were included in developing the proposed rule. The revised rule will be published in the Federal !Lecister for public comment.

l

9. Confidentiality of Information None, except for proprietary information.

10. Justification for Sensitive Ouestions There are no questions regarding sensitive issues.

11. Estimated Annualized Cost to the Federal Government I

The estimated annual cost of professional staff effort devoted to application review is included in OMB Clearance 3150 0120. NRC Form 313. Staff estimates of reporting burden for 10 CFR Part 34 submittals are included as Table 1 and total $98,208.  !

Staff estimates that based on inspection time and frequency of inspections, it expends 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of inspection effort per licensee annually for a cost of $211.200 (8 hrs. X 200 NRC licensees X $132). Total cost to the government for the revised a 10 CFR Part 34 is therefore $309,408. Costs are fully recovered through fee  !

assessments to NRC licensees pursuant to 10 CFR Parts 170 and 171.

12. Estimate of Burden ,

See Tables 2. 3 and 4. Total 10 CFR Part 34 burden for recordkeeping and reporting i is estimated to be 65.815 hours0.00943 days <br />0.226 hours <br />0.00135 weeks <br />3.101075e-4 months <br />. Total cost for licensees is estimated at

$8.687.580 ($132 X 65.815 hrs). In addition, there is an increase in burden for NRC Form 313 of-14 hours each for 700 licensees, or an increase of 9.900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> and a cost of $1.306.800 ($132 X 9.900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />).

13. Reasons for Chance in Burden i

The change in burden is due to the revision of 10 CFR Part 34 in its entirety and additional information to be submitted on NRC Form 313, cleared under 0MB Clearance l number 3150 0120. j i

14. Publication for Statistical Use None.

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

l l

i l

TABLE 1 ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT FOR REVIEW 0F REPORTS ASSOCIATED WITH THE REVISED 10 CFR PART 34 SECTION NUMBER OF STAFF FEDERAL GOVER M ENT COST RESPONSES HOURS / RESPONSE AT $132/HR l 34.27(d) 2 1 264 34.43(a)(2) 20 1 2.640 34.101(a and b) 5 4 2.640 34.101(c) 700 1 92.400 l Appendix A. Part 1 1 132

1. Item 12 Appendix A. Part 1 1 132 i

I I. Item 13 TOTAL 729 9 98,208

?

I 19 l

l l

L L.

TABLE 2 INFORMATION COLLECTION BURDENS ASSOCIATED WITH RECORDKEEPING REQUIREMENTS OF liiE REVISED 10 CFR PART 34 i

l SECTION LIC HRS / TOTAL COST AT REC. RET. NOTES AFFECTED LIC BURDEN $132/HR 34.20(b)(1) 700 1 700 92.400 3 Yrs Labels 34.20(b)(2) 700 See OMB Clearance No. 3150-0008 34.20(f) 700 1 700 92.400 3 Yrs- New.

labels 34.25(c) 700 0 3 Yrs see 6 34.65 34.27(b)(2) 700 0 3 Yrs see 5 34.67 34.27(b)(3) '350 1 350 46.200 UST 1

.34.27(c). 350 3 1.050 138.600 3 Yrs 34.27(f) 350 3 1.050 138.600 3 Yrs 34.29(b) 700 0 see 5 34.69 34.31(a) 700 0 see I S 34.73 34.31(b) 700 0 see 5 34.73 34.33(b) 175 0 see

$ 34.75 34.35(a)(2) 700 2 1.400 184.800 3 Yrs 34.42 700 0 see 6 34.13(g) 34.43(a)(3) 700. 1 700 92.400 some new l 34.43(b)(1) 700 1 700 92.400 some new  ;

l n ,

l 2 Until source is transferred.

l 20

TABLE 2 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH THE RECORDKEEPING REQUIREMENTS OF E E REVISED 10 CFR PART 34 SECTION LIC HRS / TOTAL COST AT REC. NOTES AFFECTED LIC BURDEN $132/HR RET.

34.43(e) 700 0 0 see S 34.79 new 34.45(b) 700 0 RULT 8

see S 34.81 34.47(b) 700 0 3 Yrs see S 34.83(a) 34.47(c) 700 0 3 Yrs see S 34.83(a) 34.47(d) 35 0 RULT' New. see S 34.83(d) 2 34.47(e) 35 0 RULT New, see S 34.83(d) 34.47(f) 700 0 RULT 2

see S 34.83(c) 34.47(g)(5) 700 0 3 Yrs New. see S 34.83(b) 34.49(f) 700 0 3 Yrs see S 34.85 2

34.61 700 1 700 92.400 RULT New 34.63 700 1 700 92.400 3 Yrs 34.65 700 1 700 92.400 3 Yrs 34.67 700 2 1.400 184.800 3 Yrs 34.69 700 2 1.400 184.800 3 Yrs l

34.71(a, b) 700 50 35.000 4.620.000 3 Yrs some info new 34.73(a.b) 700 2 1.400 184.800 3 Yrs some new info 1

.eet.,n _ 4, >4 cense 4s 1e _ . tee.

21 l

l i

i l

I l

L________-._____-__-______ _ _ _ _ . - - - )

TABLE 2 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH THE RECORDKEEPING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION LIC HRS / TOTAL COST AT REC. RET. NOTES AFFECTED LIC BURDEN $132/HR 34.75 175 3 525 69,300 3 Yrs some new info 34.79(a, b) 700 6 4.200 554.400 3 Yrs 34.81 700 2 1.400 184.800 RULT* l 34.83(a) 700 4 2.800 369.600 3 Yrs some new 34.83(b) 700 2 1.400 184.800 3 Yrs some new i

34.83(c) 700 See OMB Clearance No. 3150-0014 34.83(d) 35 2 70 9.240 RULT l

some new 34.85 700 1 700 92.400 3 Yrs some new  :

34.87 700 0 Format i only 34.89 175 3 525 69.300 3 Yrs  !

34.91 525 3 1.575 207.900 3 Yrs New Appendix A, 1 life of See Part I, item program Appendix 3 A, Part I, Item 9 Appendix A, 1 life of See Part I, item program Appendix 5 A, Part I, Item 9 Appendix A. 1 10 10 1.320 life of Part I, item program ,

6 Appendix A, 1 40 40 5.280 life of Part I, item program

9 -

2 Retain until license is terminated.

22

TABLE 2 (cont'd)

INFORMATION COLLECTION BURDENS ASSOCIATED WITH THE REu)RDKEEPING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION LIC HRS / TOTAL COST AT REC. RET. NOTES AFFECTED LIC BURDEN $132/HR Appendix A. 1 10 10 1.320 life of Part I, item program 10 Appendix A, 1 10 10 1,320 life of Part I. item ., program 11 1-Appendix A. l' 10 10 1.320 11fe of Part I, item program 13 Appendix A, 3,000 1 3,000 3 % ,000 Part II, ites 2  !

Appendix A,- -1 10 10 1.320 life of  ;

, Part II, program i item 3 '

Appendix A', .1 10 10 1,320 life of Part II, program

item 4 Appendix A. 1 10 10 1,320 life of t Part II. program j item 6

! Appendix A. 1 10 10 1,320 life of Part-II, program item 7 Appendix A, 1 10 10 1,320 life of Part II, program item 8 Appendix A. I 10 10 1,320 life of Part II, program item 9-l TOTALS N/A 64.285 8.485.620 N/A N/A

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TABLE 3 INFORMATION COLLECTION BURDENS ASSOCIATED WITH REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 34 SECTION- NUMBER OF HOURS /- TOTAL COST AT REP. NOTES RESPONSES RESPONSE BURDEN $132/HR RET.

34.27(d) 20 2 40 5.280 34.43(a)( 2 10 20 2.640 2) 34.101 5 10 50 6.600 (a and b) 34.101- 700 2 1.400 184.800 New (c)

Appendix 1 10 10 1.320 life of 5rtI.

item 12 ppendix 1g 10 10 1.320 life of P5rtI.

item 13 TOTAL- 729 1.530 201. % 0 i

24 L _ - - _ - _ _ - _ _ _ _ _ _ _ - - _ _ _ _ - - _. - _- -

TABLE 4 INFORMATION COLLECTION BURDENS ASSOCIATED WITH  ;

REPORTING REQUIREMENTS OF THE REVISED 10 CFR PART 34  !

THAT ARE COVERED BY OPE CLEARANCE NO. 3150 0120 SECTION LICENSEES HOURS / TOTAL COST AT REP. NOTES AFFECTED LICENSEE BURDEN $132/HR RET.

34.11 700 RULT 2

See OMB  !

Clearance No. 3150-l 0120 34.13(b) 700 1 700 92.400 RULT 2

Increase  ;

over OMB Clearance No. 3150-0120 34.13(c) 700 1 700 92.400 RULT 2

Increats over 0MB Clearance No. 3150-0120 34.13(d)- 700 RULT 2

See OMB Clearance No. 3150- .

0120 '

34.13(e) 700 RULT 2

See OMB Clearance No. 3150-0120 34.13(f) 700 RULT 2

See OMB Clearance No. 3150-0120  ;

34.13(g) 700 1 700 92.400 RULT 2

Increase '

over 0MB  :

Clearance No. 3150-0120 2

Retain until license is terminated.

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• 1 TABLE 4 (cont'd)

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

THAT ARE COVERED BY OMB CLEARANCE NO. 3150-0120 SECTION LICENSEES HOURS / TOTAL COST AT REP. NOTES AFFECTED LICENSEE BURDEN $132/HR RET.

34.13(h) 700 1 700 92.400 RULT Increase over 0MB Clearance No. 3150-0120  ;

34.13(i) 700 10 7.000 924.000 RULT 8

Increase over 0MB Clearance No. 3150- 1 0120 1 1

34.13(j) 100 1 100 13.200 Increase l over OMB l Clearance No. 3150-0120 ,

_ TOTAL N/A 9.900 1.306.800

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