10 CFR Part 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations

Forms and Documents

Document Name	Status
3150-0007 - Final Supporting Statement - 10 CFR Part 34.docx Supporting Statement A	2010-10-05

IC Document Collections

IC ID	Document Title	Status
33134	10 CR Part 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations	Modified

ICR Details

OMB Control No: 3150-0007	ICR Reference No: 201009-3150-002
Status: Historical Active	Previous ICR Reference No: 200708-3150-009
Agency/Subagency: NRC	Agency Tracking No:
Title: 10 CFR Part 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 01/03/2011
	Date Received in OIRA: 10/25/2010
Terms of Clearance: In accordance with 5 CFR 1320, the collection is approved for 3 years. Upon resubmission, it is suggested the agency continue to assess and where necessary update and/or correct any ratios or assumptions used in calculating estimated burden.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	01/31/2014	36 Months From Approved	12/31/2010
Responses	1,116	0	778
Time Burden (Hours)	284,868	0	199,125
Cost Burden (Dollars)	29,233	0	20,515

---

Abstract: 10 CFR Part 34 establishes radiation safety requirements for the use of radioactive material in industrial radiography. The information in the applications, reports and records is used by the NRC staff to ensure that the health and safety of the public is protected and that licensee possession and use of source and byproduct material is in compliance with license and regulatory requirements.

---

Authorizing Statute(s): PL: Pub.L. 83 - 703 68 Stat. 919 Name of Law: Atomic Energy Act
  

Citations for New Statutory Requirements: None

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 37841	06/30/2010
30-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 60146	09/29/2010
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
10 CR Part 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations

---

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	1,116	778	0	0	338	0
Annual Time Burden (Hours)	284,868	199,125	0	0	85,743	0
Annual Cost Burden (Dollars)	29,233	20,515	0	0	8,718	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The total burden increased by 85,743 from 199,125 to 284,868. The burden for NRC licensees decreased and the burden for Agreement States increased as follows: • NRC Licensees. Although the overall burden increased, the burden for NRC licensees decreased by 5,716 hours (from 43,397 to 37,681 hours). The burden decreased as a result of a decrease in the number of NRC licensees. The actual number of NRC licensees has decreased by 15, from 113 to 98 because Pennsylvania, Virginia, and New Jersey became Agreement States since the last renewal, and licensees in these states are no longer counted as NRC licensees. • Agreement State Licensees. The burden for Agreement State licensees increased by 91,459 hours (from 155,728 to 247,187 hours) due to a change in the ratio used to calculate the number of Agreement State licensees. The number of NRC licensees is known, whereas the total number of Agreement State licensees is an estimate based on NRC’s best information available from the Agreement States. NRC uses the ratio of the total of NRC licensees (subject to Part 34) to the total number Agreement State licensees to estimate the number of Agreement State respondents for each section. NRC uses this ratio approach as the total number of Agreement State licensees subject to various Part 34 Sections is not known exactly and, therefore, must be estimated. The ratio used to estimate Agreement State respondents changed from 3.6 to 6.6; therefore, the number of Agreement State licensees increased by 240, from 407 to 647. This resulted in a burden increase of 91,459 hours from 155,728 to 247,187 hours. The ratio changed because the difference in the number of NRC licensees versus Agreement States licensees has increased (three States: Pennsylvania, Virginia, and New Jersey, all of whom have a large number of material licensees, become Agreement States since the last renewal). This change affected the overall ratio used to calculate the number of Agreement State to NRC Part 34 licensees. The increase in the number of licensees is tied to a corresponding increase in the number of expected responses for various sections, resulting in an overall increase in the burden hour estimate. In the last submittal for this information collection, recordkeepers were not counted as respondents. The current submission has correctly identified all respondents, including licensees reporting information to the NRC as well as those required to retain records. As a result of this adjustment, the number of respondents has increased from 253 to 745 (647 Agreement State licensees plus 98 NRC licensees). Note that licensees reporting information are a subset of the licensees who are recordkeepers, and do not represent an additional group of licensees.

---

Annual Cost to Federal Government: $12,336

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

---

Common Form ICR:  No

---

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 10/25/2010

---