ML23240A362

OMB 3150-0044, 10 CFR Part 19, Draft Supporting Statement

ML23240A362
Person / Time
Issue date:	10/17/2023
From:	NRC/OCIO
To:
References
OMB 3150-0044
Download: ML23240A362 (15)

Text

DRAFT SUPPORTING STATEMENT FOR 10 CFR PART 19 "NOTICES, INSTRUCTIONS, AND REPORTS TO WORKERS: INSPECTION AND INVESTIGATIONS" (3150-0044)

EXTENSION DESCRIPTION OF THE INFORMATION COLLECTION Licensees are required to post information regarding this regulation, their license, applicable notices of violation, and the role of the U.S. Nuclear Regulatory Commission (NRC). Licensees are also required to instruct workers on matters related to radiological working conditions. This instruction ranges from a tour of the workplace pointing out hazards to a 1-week intensive course on radiation protection involving the preparation of training material. Workers need to be educated about health risks from occupational exposure to radioactive materials or radiation, precautions or procedures to minimize exposure, worker responsibility to report promptly to the Commission any licensee conditions which may lead to or cause a violation of Commission regulations, and the individual radiation exposure reports which are available to them. The licensee is required to control radiation doses to individuals in restricted areas so that, with the exception of planned special exposures under 10 CFR 20.1206, no one receives an annual dose which exceeds the limits established by 10 CFR 20.1201. The annual limit shall be the more limiting of the total effective dose equivalent being equal to 5 rems or the sum of the deep-dose equivalent and the committed dose equivalent to any individual organ or tissue other than the lens of the eye being equal to 50 rems. The annual limit to the lens of the eye is 15 rems, and 50 rems to the skin, or to any extremity.

The individual should be informed of the radiation dose he or she receives because: (a) that information is needed by both a new employer and the individual when the employee changes jobs in the nuclear industry; (b) the individual needs to know the radiation dose received as a result of an accident or incident (if this dose is in excess of the 10 CFR Part 20 limits) so that he or she can seek counseling about future work involving radiation, medical attention, or both, as desired; and (c) since long-term exposure to radiation may be an adverse health factor, the individual needs to know whether the accumulated dose is being controlled within the NRC limits.

Pursuant to 10 CFR 19.16, a worker may notify the Commission about radiological working conditions he believes are in violation of the Atomic Energy Act, the regulations, or license, and the worker may request an inspection. Upon receipt of such notice, the Commission must determine whether the complaint meets certain requirements specified in 10 CFR Part 19, and either request an inspection or determine that an inspection is not warranted and so notify the complainant in writing.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information For specific information collection requirements, see Description of Requirements.

2. Agency Use of the Information With the exception of 10 CFR 19.12 and 19.16, Part 19 information collections are not provided to the Commission; notices, instructions, and reports required by Part 19 are provided by NRC licensees to individuals participating in licensed activities. Some information collections may require an annual report to the NRC. As stated above, notices received pursuant to 10 CFR 19.16 must be reviewed by the Commission to determine whether the complaint meets certain requirements specified in 10 CFR Part

19. The Commission will then either request an inspection or determine that an inspection is not warranted and so notify the complainant in writing.

3. Reduction of Burden Through Information Technology The NRC has issued Guidance for Electronic Submissions to the NRC which provides direction for the electronic transmission and submittal of documents to the NRC.

Electronic transmission and submittal of documents can be accomplished via the following avenues: the Electronic Information Exchange (EIE) process, which is available from the NRC's Electronic Submittals Web page, by Optical Storage Media (OSM) (e.g. CD-ROM, DVD), by facsimile or by e-mail. It is estimated that approximately 25 percent of the potential responses are filed electronically.

4. Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.

5. Effort to Reduce Small Business Burden There is no feasible way of reducing the burden on small businesses while still accomplishing the objective of informing individuals of their exposure to radiation.

However, the burden is small and should have no significant impact on operating costs.

6. Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently If the information collection were not conducted, workers would not be aware of their total radiation dose.

7. Circumstances which Justify Variation from OMB Guidelines This action does not vary from OMB guidelines.

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8. Consultations Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package has been published in the Federal Register.

9. Payment or Gift to Respondents Not applicable.

10. Confidentiality of the Information Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17 (a) and 10 CFR 2.390 (b). However, no information normally considered confidential or proprietary is requested.

11. Justification for Sensitive Questions Not applicable.

12. Estimated Industry Burden and Burden Hour Cost The regulations in 10 CFR Part 19 establish requirements for notices, instructions, and reports by licensees and regulated entities to individuals participating in NRC-licensed and regulated activities. As such, the majority of the requirements under this Part represent third-party disclosure notifications, in which the licensees are providing information to workers about the dose received. In this renewal, third-party disclosure notifications have been captured as such in the burden tables.

NRC Licensees A total of 2,200 NRC licensees respond to the Part 19 information collections. These are licensees in states who are directly regulated by the NRC and includes materials licensees (dockets 30, 40, 70, and 72) and reactor licensees. The number of NRC licensees is expected to remain at or near the current number over the coming 3 years.

Data on the number of workers receiving third-party notifications from these licensees was obtained from the NRCs Radiation Exposure Information and Reporting System.

The burden for NRC licensees to respond to the collection is shown in Tables 1-4.

The total burden for NRC licensees is 111,653.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> reporting + 2,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> annual recordkeeping + 646 hours0.00748 days <br />0.179 hours <br />0.00107 weeks <br />2.45803e-4 months <br /> one-time recordkeeping + 108,806.9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> third-party disclosures) at a cost of $32,379,486 (111,653.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> x $290/hour).

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Agreement State Licensees Section 274 of the Atomic Energy Act of 1954, as amended, provides a statutory basis under which NRC discontinues and the Agreement State assumes portions of its regulatory authority to license and regulate byproduct materials (radioisotopes); source materials (uranium and thorium); and certain quantities of special nuclear materials. The mechanism for the transfer of NRCs authority to a State is an agreement signed by the Governor of the State and the Chairman of the Commission, in accordance with section 274b of the Act. Licensees operating in these Agreement States are referred to in this supporting statement as Agreement State Licensees. A map of Agreement States and non-Agreement States is located on NRCs Web site at https://scp.nrc.gov/rulemaking.html.

The NRC has established compatibility requirements for Agreement States to implement their own regulations in a manner consistent with NRC regulations. Annually, the Agreement States provide the NRC with an estimate of the total number of licensees within their states. The total number of Agreement State licensees is based on the annual estimate provided by the Agreement States. For this renewal, the NRC used an estimate of 16,000 Agreement State licensees, based on the most recent reporting by Agreement States to the NRC. The number of Agreement licensees is expected to remain at or near the current number over the coming 3 years.

However, the number of Agreement State licensees subject to each individual section within Part 19 is not known, and must be estimated. NRC uses the ratio of the total of NRC licensees (subject to Part 19) to the total number Agreement State licensees to estimate the number of Agreement State respondents for each section. The current ratio, is 1:7.3 (NRC licensees: Agreement State licensees)

The burden for Agreement State licensees to respond to the collection is shown in Tables 5-8. The total burden for Agreement State licensees is 443,246 hours0.00285 days <br />0.0683 hours <br />4.06746e-4 weeks <br />9.3603e-5 months <br /> (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> reporting + 16,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> annual recordkeeping + 4,712 hours0.00824 days <br />0.198 hours <br />0.00118 weeks <br />2.70916e-4 months <br /> one-time recordkeeping +

412,531 hours0.00615 days <br />0.148 hours <br />8.779762e-4 weeks <br />2.020455e-4 months <br /> third-party disclosures) at a cost of $128,541,340 (443,246 x $290/hour).

The following table is a summary of the burden:

Total Burden for Part 19 NRC Licensees Agreement State TOTAL Hours Responses Hours Responses Hours Responses Reporting 0.5 1.0 3.0 6.0 3.5 7.0 Recordkeeping 2,200.0 2,200.0 16,000.0 16,000.0 18,200.0 18,200.0 Third-party disclosures 108,806.9 301,798.08 412,531 1,569,376.8 521,337.9 1,871,174.88 One-time recordkeeping burden 646 - 4,712 - 5,358.0 -

TOTAL 111,653.4 303,999.08 433,246.0 1,585,382.8 544,899.4 1,889,381.88 Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

The $290 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20, Average cost per professional staff-hour. For more information on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2022 (87 FR 37214, Jun. 22, 2022).

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13. Estimate of Other Additional Costs NRC has determined that the records storage cost is roughly proportional to the recordkeeping burden cost. Based on a typical clearance, the records storage cost has been determined to be equal to 0.0004 times the recordkeeping burden cost. Therefore, the records storage cost for this clearance is $2,732.728 (23,558 hours0.00646 days <br />0.155 hours <br />9.22619e-4 weeks <br />2.12319e-4 months <br /> x 0.0004 x

$290/hr).

14. Estimated Annualized Cost to the Federal Government There is no cost to the Federal government except for those that involve requests by workers for inspections. Approximately one worker requests an inspection each year pursuant to 10 CFR 19.16. The estimated annual cost to the Federal government is $145 (1 NRC report/year x 0.5 hrs per response x $290) and for Agreement States, $1,058 (1 report/year x 7.3 x 0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s/report x $290/hour).

The staff has developed estimates of annualized costs to the Federal Government related to the conduct of this collection of information. These estimates are based on staff experience and subject matter expertise and include the burden needed to review, analyze, and process the collected information and any relevant operational expenses.

15. Reasons for Changes in Burden or Cost Total The total burden estimate decreased from 579,661 hours0.00765 days <br />0.184 hours <br />0.00109 weeks <br />2.515105e-4 months <br /> to 544,899 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.420695e-4 months <br /> and the respondents decreased from 19,500 to 18,200 (2,200 NRC licensees +

16,000 AS licensees). Responses decreased from 1,899,235 responses to 1,889,382. The total number of responses and hours decreased as a result of the decrease in total NRC licensees from 3,000 to 2,200. The one-time recordkeeping burden has decreased from 1,881 hours0.0102 days <br />0.245 hours <br />0.00146 weeks <br />3.352205e-4 months <br /> to 646 hours0.00748 days <br />0.179 hours <br />0.00107 weeks <br />2.45803e-4 months <br /> due to the NRC staff identifying that previous collections incorrectly reported the total number of one-time recordkeeping burden for the three-year period as annual burden. This submission corrects that error and reports the annualized one-time recordkeeping burden. However, the ratio change between NRC licensees and Agreement States has risen from 5.9 to 7.3, resulting in an increase in the burden for Agreement States.

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The following table is a summary of the change in burden from the 2020 renewal to the current request:

Burden Change from 2020 to Current Request 2021 Renewal Current Request Burden Change Hours Responses Hours Responses Hours Responses Reporting 3.5 7.0 3.5 7.0 - -

Recordkeeping 19,500.0 19,500.0 18,200.0 18,200.0 (1,300.0) (1,300.0)

Third-party disclosures 547,178.3 1,879,728.1 521,337.9 1,871,174.88 (25,840.4) (8,553.22)

One-time burden 12,978.9 - 5,358.0 - (7,620.9) -

TOTAL 579,660.7 1,899,235.1 544,899.4 1,889,381.88 (34,761.30) 146.78 Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

NRC Licensees The burden estimate for NRC licensees changed from 135,747.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to 111,653.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, a decrease of 24,093.90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />. This decrease is attributed to a decrease in One-time recordkeeping burden, and total number of NRC licensees as previously discussed.

The estimated number of NRC licensee responses changed from 366,202.8 responses (1 reporting response + 3,000 recordkeepers + 363,201.8 third-party disclosure responses) to 303,999 responses (1 reporting response + 2,200 recordkeepers + 301,798 third-party disclosure responses), a decrease of 62,203.8 responses. This decrease is attributed to a decrease in total number of NRC licensees and one-time recordkeeping burden, as previously discussed.

Agreement State Licensees The burden estimate for Agreement State licensees changed from 443,913.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to 443,246 hours0.00285 days <br />0.0683 hours <br />4.06746e-4 weeks <br />9.3603e-5 months <br />, a decrease of 667.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. This decrease is attributed to the decrease in one-time recordkeeping burden in third-party disclosures, as previously discussed.

The estimated number of Agreement State licensee responses changed from 1,533,032.3 responses (6 reporting response + 16,500 recordkeepers + 1,516,526.3 third-party disclosure responses), to 1,585,382.8 responses (6 reporting response +

16,000 recordkeepers + 1,569,376.8 third-party disclosure responses), an increase of 52,350.5 responses. This increase is attributed to change in radio for calculating the Agreement State licensees.

16. Publication for Statistical Use NRC does not publish this information for statistical use.

17. Reason for Not Displaying the Expiration 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.

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18. Exceptions to the Certification Statement Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Not applicable.

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DESCRIPTION OF REQUIREMENTS Information Collections Requirements in 10 CFR Part 19 as follows:

10 CFR 19.11 requires NRC licensees and applicants for NRC licenses to post notices for workers and describes how this information must be made available to workers. These requirements are described more specifically below.

10 CFR 19.11(a) states - Each licensee (except for a holder of an early site permit under subpart A of part 52 of this chapter, or a holder of a manufacturing license under subpart F of part 52 of this chapter) shall post current copies of the following documents: (1) The regulations in this part and in part 20 of this chapter; (2) The license, license conditions, or documents incorporated into a license by reference, and amendments thereto; (3) The operating procedures applicable to licensed activities; (4) Any notice of violation involving radiological working conditions, proposed imposition of civil penalty, or order issued pursuant to subpart B of part 2 of this chapter, and any response from the licensee.

10 CFR 19.11(b) states - Each applicant for and holder of a standard design approval under subpart E of part 52 of this chapter, each applicant for an early site permit under subpart A of part 52 of this chapter, each applicant for a standard design certification under subpart B of part 52 of this chapter, and each applicant for and holder of a manufacturing license under subpart F of part 52 of this chapter shall post: (1) The regulations in this part; (2) The operating procedures applicable to the activities regulated by the NRC which are being conducted by the applicant or holder; and (3) Any notice of violation, proposed imposition of civil penalty, or order issued under subpart B of part 2 of this chapter, and any response from the applicant or holder.

10 CFR 19.11(d) provides an alternative to posting most documents from the manner specified in 10 CFR 19.11 (a) and (b) - If posting of a document specified in paragraphs (a)(1), (2) or (3), or (b)(1) or (2) of this section is not practicable, the licensee or regulated entity may post a notice which describes the document and states where it may be examined.

10 CFR 19.11(e)(1) states - Each licensee, each applicant for a specific license, each applicant for or holder of a standard design approval under subpart E of part 52 of this chapter, each applicant for an early site permit under subpart A of part 52 of this chapter, and each applicant for a standard design certification under subpart B of part 52 of this chapter shall prominently post NRC Form 3, "Notice to Employees," dated August 1997.

Later versions of NRC Form 3 that supersede the August 1997 version shall replace the previously posted version within 30 days of receiving the revised NRC Form 3 from the Commission.

10 CFR 19.11(g) tells applicants for and holders of NRC licenses the timeframe in which documents described by 10 CFR 19.11 (a)(4) or (b)(3) must be posted - Commission documents posted under paragraphs (a)(4) or (b)(3) of this section shall be posted within 2 working days after receipt of the documents from the Commission; the licensee's or regulated entitys response, if any, shall be posted within 2 working days after dispatch by the licensee or regulated entity. These documents shall remain posted for a minimum of 5 working days or until action correcting the violation has been completed, whichever is later.

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10 CFR 19.12 requires NRC licensees to give reports to workers as follows: "All individuals who in the course of employment are likely to receive in a year an occupational dose in excess of 100 mrem (1 mSv) shall be (1) kept informed of the storage, transfer, or use of radiation and/or radioactive material; (2) instructed in the health protection problems associated with exposure to radiation and/or radioactive material, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed; (3) instructed in, and required to observe, to the extent within the worker's control, the applicable provisions of Commission regulations and licenses for the protection of personnel from exposure to radiation and/or radioactive material; (4) instructed of their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and licenses or unnecessary exposure to radiation and/or radioactive material; (5) instructed in the appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation and/or radioactive material; and (6) advised as to the radiation exposure reports which workers may request pursuant to § 19.13. The extent of these instructions shall be commensurate with potential radiological health protection problems present in the workplace.

10 CFR 19.13 - "Notifications and Reports to Individuals," requires NRC licensees to give written reports of exposure to radiation as described in the following subsections from that regulation. The records of exposure to radiation referenced by 10 CFR 19.13 are maintained in accordance with the requirements of 10 CFR Part 20.

10 CFR 19.13(a) - Radiation exposure data for an individual, and the results of any measurements, analyses, and calculations of radioactive material deposited or retained in the body of an individual, shall be reported to the individual as specified in this section.

The information reported shall include data and results obtained pursuant to Commission regulations, orders or license conditions, as shown in records maintained by the licensee pursuant to Commission regulations. Each notification and report shall: be in writing; include appropriate identifying data such as the name of the licensee, the name of the individual, the individual's social security number; include the individual's exposure information; and contain the following statement:

This report is furnished to you under the provisions of the Nuclear Regulatory Commission regulation 10 CFR Part 19. You should preserve this report for further reference."

10 CFR 19.13(b) - "Each licensee shall make dose information available to workers as shown in records maintained by the licensee under the provisions of 10 CFR 20.2106. The licensee shall provide an annual report to each individual monitored under 10 CFR 20.1502 of the dose received in that monitoring year if: (1) The individuals occupational dose exceeds 1 mSv (100 mrem) TEDE or 1 mSv (100 mrem) to any individual organ or tissue; (2) The individual requests his or her annual dose report.

10 CFR 19.13(c)(1)(i), (ii) and (2) - "At the request of a worker formerly engaged in licensed activities controlled by the licensee, each licensee shall furnish to the worker a report of the worker's exposure to radiation and/or to radioactive material: (i) as shown in records maintained by the licensee pursuant to § 20.2106 for each year the worker was required to be monitored under the provisions of § 20.1502; and (ii) for each year the 9

worker was required to be monitored under the monitoring requirements in effect prior to January 1, 1994. (2) This report must be furnished within 30 days from the time the request is made or within 30 days after the exposure of the individual has been determined by the licensee, whichever is later. This report must cover the period of time that the worker's activities involved exposure to radiation from radioactive material licensed by the Commission and must include the dates and locations of licensed activities in which the worker participated during this period."

10 CFR 19.13(d) - "When a licensee is required pursuant to §§ 20.2202, 20.2203 or 20.2204 of this chapter to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also provide the individual a report on his or her exposure data included in the report to the Commission. This report must be transmitted at a time not no later than the transmittal to the Commission."

10 CFR 19.13(e) - "At the request of a worker who is terminating employment with the licensee that involved exposure to radiation or radioactive materials, during the current calendar quarter or the current year, each licensee shall provide at termination to each worker, or to the worker's designee, a written report regarding the radiation dose received by that worker from operations of the licensee during the current year or fraction thereof. If the most recent individual monitoring results are not available at that time, a written estimate of the dose must be provided together with a clear indication that this is an estimate."

10 CFR 19.16(a) - "Any worker or representative of workers who believes that a violation of the [Atomic Energy] Act, the regulations in this chapter, or license conditions exists or has occurred in license activities with regard to radiological working conditions in which the worker is engaged, may request an inspection by giving notice of the alleged violation to the Administrator of the appropriate Commission Regional Office, or to Commission inspectors. Any such notice shall be in writing, shall set forth the specific grounds for the notice, and shall be signed by the worker or representative of workers.

A copy shall be provided the licensee by the Regional Office Administrator or the inspector no later than at the time of inspection except that, upon the request of the worker giving such notice, his name and the name of individuals referred to therein shall not appear in such copy or on any record published, released or made available by the Commission, except for good cause shown."

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Table 1: NRC Licensee Annual Reporting Burden Responses per Total Burden Hours Section Respondents Total Burden Cost at $290/hr Respondent Responses per Response 19.16(a) 1 1.0 1.0 0.5 0.5 $ 145 Total 1 1.0 0.5 $ 145 Table 2: NRC Licensee One-Time Recordkeeping Total Number of Hours per Annual Cost at Section Recordkeepers Recordkeeper Burden $290/hr Hours 19.12 (Training 34 19.0 646.0 $ 187,340 materials)

Table 3: NRC Licensee Annual Recordkeeping Number of Hours per Total Annual Cost at Section Recordkeepers Recordkeeper Burden Hours $290/hr 19.12 (Training materials) 2,200 1.0 2,200.0 $ 638,000 Total 2,200 2,200.0 $ 638,000 11

Table 4: NRC Licensee Third-Party Disclosures Responses Burden Total Total Cost at Section Description Respondents per Hours per Burden Responses $290/hr Respondent Response Hours Posting applicable 19.11(a) documents (most 2,153 10.0 21,530.0 1.00 21,530.00 $6,243,700 licensees)

Posting applicable documents (subset 19.11(b) 47 500.0 23,500.0 2.00 47,000.00 $13,630,000 of applicants and licensees)

Alternate posting 19.11(d) see 19.11(a) & (b) instructions 19.11(e) Posting NRC Form 3 2,200 20.0 44,000.0 0.08 3,520.00 $1,020,800 Timeframe for 19.11(g) posting applicable see 19.11(a) & (b) documents 19.12 Worker instructions 2,200 1.0 2,200.0 8.00 17,600.00 $5,104,000 Annual worker dose 19.13(b) report (monitored 161 650.0 104,650.0 0.08 8,372.00 $2,427,880 reportable workers)

Annual worker dose report (monitored 19.13(b) 2,200 16.0 35,200.0 0.08 2,816.00 $816,640 nonreportable workers)

Former worker dose report on demand 19.13(c) 89 78.14 6,954.46 0.17 1,182.26 $342,855 (commercial transient)

Former worker dose 19.13(c) report on demand 72 0.76 54.72 1.50 82.08 $23,803 (other transient)

Copies of reports under 20.2202, 19.13(d) 20.2203, 20.2204, 1 1.0 1.0 0.17 0.17 $47 and 20.2206 given to worker Terminating worker dose report 19.13(e) 89 520.9 46,360.10 0.08 3,708.81 $1,075,555 (commercial transient)

Terminating worker dose report (other 19.13(e) 72 5.0 360.0 0.08 28.80 $8,352 licensee transient workers)

Terminating worker dose report 19.13(e) 89 120.0 10,680.0 0.083 886.44 $257,068 (commercial terminating)

Terminating worker 19.13(e) dose report (other 72 19.6 1,411.2 0.33 465.7 $135,053 terminating)

Terminating worker dose report 19.13(e) 2,039 2.4 4,893.6 0.33 1,614.88 $468,315 (nonreportable terminating workers)

Total 2,200 301,798.08 108,806.9 $ 31,554,068 12

Table 5: Agreement State Annual Reporting Burden Responses per Total Burden Hours Total Burden Section Respondents Cost at $290/hr Respondent Responses per Response Hours 19.16(a) 7 1.0 7.0 0.5 3.5 $ 1,015 Total 7 7.0 3.5 $ 1,015 Table 6: Agreement State Licensee One-Time Recordkeeping Total Number of Hours per Annual Cost at Section Recordkeepers Recordkeeper Burden $279/hr Hours 19.12 (Training 248 19.0 4,712 $ 1,366,480 materials)

Table 7: Agreement State Licensee Annual Recordkeeping Number of Hours per Total Annual Cost at Section Recordkeepers Recordkeeper Burden Hours $279/hr 19.12 (Training materials) 16,000 1.0 16,000.0 $ 4,640,000 Total 16,000 16,000.0 $ 4,640,000 13

Table 8: Agreement State Licensee Third-Party Disclosures Responses Burden Total Total Cost at Section Description Respondents per Hours per Burden Responses $290/hr Respondent Response Hours Posting applicable 19.11(a) documents (most 16,000 10.0 160,000.0 1.00 160,000.00 $46,400,000 licensees)

Posting applicable documents (subset 19.11(b) 0 500.0 0.0 2.0 0.0 $0 of applicants and licensees)

Alternate posting 19.11(d) see 19.11(a) & (b) instructions Posting NRC Form 19.11(e) 16,000 20.0 320,000.0 0.08 25,600.00 $7,424,000 3

Timeframe for 19.11(g) posting applicable see 19.11(a) & (b) documents 19.12 Worker instructions 16,000 1.0 16,000.0 8.00 128,000.0 $37,120,000 Annual worker dose 19.13(b) report (monitored 1,175 650.0 763,750.0 0.08 61,100.0 $17,719,000 reportable workers)

Annual worker dose report (monitored 19.13(b) 16,000 16.0 256,000.0 0.08 20,480.0 $5,939,200 nonreportable workers)

Former worker dose report on 19.13(c) 526 0.76 399.76 1.50 599.64 $173,896 demand (other transient)

Copies of reports under 20.2202, 19.13(d) 20.2203, 20.2204, 7 1.0 7.0 0.17 1.2 $348 and 20.2206 given to worker Terminating worker dose report (other 19.13(e) 650 5.0 3,250.0 0.08 260 $75,400 licensee transient workers)

Terminating worker 19.13(e) dose report (other 650 20.2 13,130 0.33 4,332.9 $1,256,541 terminating)

Terminating worker dose report 19.13(e) (nonreportable 15,350 2.4 36,840 0.33 12,157.2 $3,525,588 terminating workers)

Total 16,000 1,569,376.8 412,531 $119,633,973 14

Table 9: Total Burden for Part 19 NRC Licensees Agreement State TOTAL Hours Responses Hours Responses Hours Responses Reporting 0.5 1.0 3.0 6.0 3.5 7.0 Recordkeeping 2,200.0 2,200.0 16,000.0 16,000.0 18,200.0 18,200.0 Third-party disclosures 108,806.9 301,798.08 412,531 1,569,376.8 521,337.9 1,871,174.88 One-time recordkeeping burden 646 - 4,712 - 5,358.0 -

TOTAL 111,653.4 303,999.08 433,246.0 1,585,382.8 544,899.4 1,889,381.88 Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

Table 10: Burden Change from 2020 to Current Request 2020 Renewal Current Request Burden Change Hours Responses Hours Responses Hours Responses Reporting 3.5 7.0 3.5 7.0 - -

Recordkeeping 19,500.0 19,500.0 18,200.0 18,200.0 (1,300.0) (1,300.0)

Third-party disclosures 547,178.3 1,879,728.1 521,337.9 1,871,174.88 (25,840.4) (8,553.22)

One-time burden 12,978.9 - 5,358.0 - (7,620.9) -

TOTAL 579,660.7 1,899,235.1 544,899.4 1,889,381.88 (34,761.30) 146.78 Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

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