Burden spreadsheet for 10 CFR Part 37

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Overview

SUMMARY
One-time Reporting
Annual Reporting
One-time 3rd Party
Annual 3rd Party
One-time recordkeeping
Annual recordkeeping
2015 renewal summary

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Sheet 1: SUMMARY

Annual or One-Time	Information Collection Type	Requirement	Final Rule Burden	2015 Renewal Burden	Burden change
One-time	Reporting	37.21(a)(3)	0.0	0	0
One-time	Reporting	37.41(d)	0.0	0	0
One-time	Reporting	37.23(b)(1) in PR, 37.23(b)(2) in FR	350.0	300	-50.0
One-time	Reporting	37.41(a)(3)	0	0.3	0.0
Annual	Reporting	37.11(a)	0	0	0
Annual	Reporting	37.23(b)(1), modified to 37.23(b)(2) in FR	0	0	0
Annual	Reporting	37.23(d)	0	0	0
Annual	Reporting	37.25(c)	0	0	0
Annual	Reporting	37.27 (a)(1)	1050	1125	75
Annual	Reporting	37.27(c)	0	0	0
Annual	Reporting	37.41(a)(2)	0	0	0
Annual	Reporting	37.43(d)(3)(ii),	0	0	0
Annual	Reporting	37.45(a)(2)&(5) in PR, 37.45(b)(1)&(2) in FR	0	0	0
Annual	Reporting	37.57(a)	0.75	0.75	0
Annual	Reporting	37.57(b)	25	27.5	2.5
Annual	Reporting	37.57(c)	60	60	0
Annual	Reporting	37.77(a)&(b)	350	350.08	0.079999999999984
Annual	Reporting	37.77 (c),	8	8	0
Annual	Reporting	37.77 (d)	0	0	0
Annual	Reporting	37.81(a), (b), (c), (d), (e), &(f)	0.75	0.75	0
Annual	Reporting	37.81(g)&(h)	60	60	0
One-time	3rd Party Disclosure	37.43(c)	933.333333333333	800.0	-133.3
One-time	3rd Party Disclosure	37.45 (a)(b)	0	66.6666666666667	66.6666666666667
Annual	3rd Party Disclosure	37.11(c)(4)	0	0	0
Annual	3rd Party Disclosure	37.23(c)	0	0	0
Annual	3rd Party Disclosure	37.23(d)	16800	18000	1200
Annual	3rd Party Disclosure	37.23(g)(1)	0	0	0
Annual	3rd Party Disclosure	37.27(a)(2)	420	450	30
Annual	3rd Party Disclosure	37.43(c)	1400	1500	100
Annual	3rd Party Disclosure	37.45(a)(1)&(2)	4200	4500	300
Annual	3rd Party Disclosure	37.45(b)(1) & (2)	0	0	0
Annual	3rd Party Disclosure	37.49(d)	0	0	0
Annual	3rd Party Disclosure	37.57(a)	0.75	0.75	0
Annual	3rd Party Disclosure	37.57(b)	100	110	10
Annual	3rd Party Disclosure	37.75(a)(1)	175	175.04	0.039999999999992
Annual	3rd Party Disclosure	37.75(a)(2)	875	875	0
Annual	3rd Party Disclosure	37.75(b)	15000	19875	4875
Annual	3rd Party Disclosure	37.75(c)	0	0	0
Annual	3rd Party Disclosure	37.75(c)	2,400	3180	780
Annual	3rd Party Disclosure	37.75(d)	48	52.8	4.8
Annual	3rd Party Disclosure	37.77(a)&(b)	1400	1400.32	0.319999999999936
Annual	3rd Party Disclosure	37.77 (c),	8	8	0
Annual	3rd Party Disclosure	37.77 (d)	0	0	0
Annual	3rd Party Disclosure	37.79(b)(1)(iii) in PR, 37.79(b)(1)(ii) in FR	0	0	0
Annual	3rd Party Disclosure	37.81(a),(c)&(e)	0	0	0
One-time	Recordkeeping	37.23(h)(2)	23333.3333333333	20000.0	-3333.3
One-time	Recordkeeping	37.43(b)	46666.6666666667	40000.0	-6666.7
Annual	Recordkeeping	37.23(e)(3) in PR, 37.23(e)(5) in FR	1400	1,500	100
Annual	Recordkeeping	37.23(f)	0	0	0
Annual	Recordkeeping	37.23(g)(1)	0	375	375
Annual	Recordkeeping	37.23(h)(1)	3150	3,375	225
Annual	Recordkeeping	37.23(h)(2)	700	750	50
Annual	Recordkeeping	37.23(h)(3)	0	0	0
Annual	Recordkeeping	37.25(a)(2)	0	0	0
Annual	Recordkeeping	37.25(a)(10)(i) in PR, 37.25(a)(7) in FR	0	0	0
Annual	Recordkeeping	37.25(b) in PR, 37.25(b)(2) in FR	0	0	0
Annual	Recordkeeping	37.29(l-m) in PR, 37.29(a)(12)&(13) and 37.29(b) in FR	0	0	0
Annual	Recordkeeping	37.31(a)	1050	1,125	75
Annual	Recordkeeping	37.31(e)	1050	1,125	75
Annual	Recordkeeping	37.33(b)&(c)	2100	2,250	150
Annual	Recordkeeping	37.43(a)(4)	4620	4,950	330
Annual	Recordkeeping	37.43(b)(3)	350	375	25
Annual	Recordkeeping	37.43(c)(4)	4200	4,500	300
Annual	Recordkeeping	37.43(d)(5) in PR, 37.43(d)(5) & (6) in FR	0	0	0
Annual	Recordkeeping	37.43(d)(7)(i) in PR, 37.43(d)(8)(i) and (ii) in FR	0	0	0
Annual	Recordkeeping	37.43(d)(7)(ii) in PR, 37.43(d)(8)(i) and (ii) in FR	350	375	25
Annual	Recordkeeping	37.45(a)(2)	0	0	0
Annual	Recordkeeping	37.45(b)(3)	0	0	0
Annual	Recordkeeping	37.45(c)	1400	1,500	100
Annual	Recordkeeping	37.51(b)	350	375	25
Annual	Recordkeeping	37.55(c)	2100	2,250	150
Annual	Recordkeeping	37.71(c) in PR, 37.71(a)-(d) in FR	300	398	97.5
Annual	Recordkeeping	37.75(a)(3), (b), & (e)	312	410	97.5
Annual	Recordkeeping	37.77(e)	0.16	0	0
Annual	Recordkeeping	37.79(c) in PR, 37.79(a)(1)(iii) &(v) in FR	12	12	0
Annual	Recordkeeping	37.79(b)(1)(i)	0	0	0
			139,109.1	138,570.2	(538.9)

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Sheet 2: One-time Reporting

	Part 37 Final rule					2015 Renewal					BURDEN CHANGE					NOTES
Section	Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Notes
37.21(a)(3)											0	0	0	0	0
37.41(d)											0	0	0	0	0
37.23(b)(1) in PR, 37.23(b)(2) in FR	1,400	3	4,200	0.25	1,050	1,200	3	3,600	0.25	900	(200)	0	(600)	0	(150)	Initial submittal of the reviewing official(s) names for the fingerprints requirement.
37.41(a)(3)	1	1	1	1	1	1	1	1	1	1	0	0	0	0	0	Requires any licensee that has not previously implemented the Security Orders or been subject to the provisions of subpart C to provide written notification to the NRC regional office at least 90 days before aggregating radioactive material to a quantity that equals or exceeds the 0.1category 2 threshold.
TOTAL	1,400		4,201		1,051	1,200		3,601		901
ANNUALIZED TOTAL			1,400.3		350.3			1,200.3		300.3	0	0	(200)	0	(50)
	Explanation: Decrease in burden due to one-time reporting requirements. Only new licensees and remaining Agreement State licensees, who have not yet fulfilled this requirement, are required to develop access authorization and security procedures since existing NRC licensees were previously required to fulfill this requirement.
																320108
																83700
																403808

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Sheet 3: Annual Reporting

	Part 37 final rule					2015 renewal					BURDEN CHANGE					NOTES
Section	Number of Respondents	Responses per Respondnt	Responses	Burden per Response	Total Burden Hours	Number of Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Number of Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Notes
37.11(a)	1,400	0	0	1	0	1,500	0	0	1	0	100	0	0	0	0	No exemption applications anticipated
37.23(b)(1), modified to 37.23(b)(2) in FR	Burden included in 37.27(a)(1)					Burden included in 37.27(a)(1)					0	0	0	0	0	Burden included in 37.27(a)(1)
37.23(d)											0	0	0	0	0
37.25(c)	1,400	0	0	1	0	1,500	0	0	1	0	100	0	0	0	0	Reinvestigations are conducted every 10 years. Based on the date of issuance of orders, no submission will until 2017 (next clearance period), at which time the NRC estimates it will receive 68 responses per licensee annually.
37.27 (a)(1)	1,400	3	4,200	0.25	1,050	1,500	3	4500	0.25	1125	100	0	300	0	75	Fingerprinting requirement, burden captures reviewing officials & estimated 3 new employees per licensee annually.
37.27(c)	Burden included in 37.27(a)(1)					Burden included in 37.27(a)(1)					0	0	0	0	0	Burden included in 37.27(a)(1)
37.41(a)(2)											0	0	0	0	0
37.43(d)(3)(ii),	Burden included in 37.27(a)(1)					Burden included in 37.27(a)(1)					0	0	0	0	0	Burden included in 37.27(a)(1)
37.45(a)(2)&(5) in PR, 37.45(b)(1)&(2) in FR	0	0	0	0.25	0	0	0	0	0.25	0	0	0	0	0	0	Notify regional office on LLEA none response, none estimated
37.57(a)	3	1	3	0.25	0.75	3	1	3	0.25	0.75	0	0	0	0	0	Event notification
37.57(b)	100	1	100	0.25	25	110	1	110	0.25	27.5	10	0	10	0	3	Phone call of suspicious activity
37.57(c)	3	1	3	20	60	3	1	3	20	60	0	0	0	0	0	Written follow up report for notifications within 30 days
37.77(a)&(b)	16	21.88	350	1	350	16	21.88	350.08	1	350.08	0	0	0	0	0	Advance written notification of Category 1 shipments
37.77 (c),	16	2	32	0.25	8	16	2	32	0.25	8	0	0	0	0	0	Revision notification
37.77 (d)	16	0	0	0.25	0	16	0	0	0.25	0	0	0	0	0	0	Cancel notification
37.81(a), (b), (c), (d), (e), &(f)	3	1	3	0.25	0.75	3	1	3	0.25	0.75	0	0	0	0	0	Notification of lost/missing cat 1 & 2 materials and recovery
37.81(g)&(h)	3	1	3	20	60	3	1	3	20	60	0	0	0	0	0	Written report following 37.81(a)-(f)
TOTAL			4,694		1,554.50			5,004.1		1,632.1			310		78

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Sheet 4: One-time 3rd Party

	Part 37 final rule					2015 Renewal					BURDEN CHANGE					NOTES
Section	Number of Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Number of Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Number of Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Notes
37.43(c)	1,400	1	1,400	2	2,800	1,200	1	1,200	2	2,400	-200	0	-200	0	-400	Training
37.45 (a)(b)	1,400	0	0	20	0	10	1	10	20	200	-1,390	1	10	0	200	Initial preparation and coordination with LLEA on security plan, this was already done under Orders (action complete). Remaining respondents account for new licensees who did not receive Orders.
TOTAL	1,400		1,400		2,800	1,200	0	1,210		2,600	-200	0	-190	0	-200
ANNUALIZED TOTAL			466.7		933.3			403.3		866.7			-63.3		-66.7
	Explanation: Burden change is due to one-time third-party notification requirements. New licensees, and remaining Agreement State licensees, who have not yet fulfilled this requirement, are required to develop access authorization and security procedures since existing NRC licensees were previously required to fulfill this requirement.

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Sheet 5: Annual 3rd Party

	Part 37 final rule					2015 renewal					BURDEN CHANGE					NOTES
Section	Rspndnts	Rsps. Per Respndt	Responses	Burden per Response	Total Burden Hours	Rspndnts	Rsps. Per Respndt	Responses	Burden per Response	Total Burden Hours	Number of Respondents	Responses per Respondent	Responses	Burden per Response	Total Burden Hours	Notes
37.11(c)(4)	Burden captured in 37.57(a)					Burden captured in 37.57(a)					0	0	0	0	0	Burden captured in 37.57(a)
37.23(c)	Burden captured in 37.27(a)(2)					Burden captured in 37.27(a)(2)					0	0	0	0	0	Burden captured in 37.27(a)(2)
37.23(d)	4,200	1	4,200	4	16,800	4,500	1	4,500	4	18,000	300	0	300	0	1,200	Employees providing personal history information
37.23(g)(1)	0	0	0	1	0	0	0	0	1	0	0	0	0	0	0	Notification of employees that they have the right to correct and complete information. No responses anticipated
37.27(a)(2)	1,400	3	4,200	0.1	420	1,500	3	4,500	0.1	450	100	0	300	0	30	Notify each individual how their fingerprints will be used.
37.43(c)	1,400	1	1,400	1	1,400	1,500	1	1,500	1	1,500	100	0	100	0	100	Training
37.45(a)(1)&(2), (d)	1,400	1	1,400	3	4,200	1,500	1	1,500	3	4,500	100	0	100	0	300	Annual LLEA coordination
37.45(b)(1) & (2)								0		0	0	0	0	0	0
37.49(d)	0	0	0	0.1	0	0	0	0	0.1	0	0	0	0	0	0	Request armed response from LLEA- burden in 37.45(a)(10). none anticipated
37.57(a)	3	1	3	0.25	0.75	3	1	3	0.25	1	0	0	0	0	0	Event notification
37.57(b)	100	1	100	1	100	110	1	110	1	110	10	0	10	0	10	Notify ops center with 4 hrs of suspicious activity
37.75(a)(1)	16	21.88	350	0.5	175	16	21.88	350	0.5	175	0	0	0	0	0	Pre-planning and coordination of Category 1 shipping with receiving licensee
37.75(a)(2)	16	218.75	3,500	0.25	875	16	218.75	3,500	0.25	875	0	0	0	0	0	Pre-planning and coordination with States thru which shipment passes of Category 1 Shipments
37.75(b)	400	75	30,000	0.5	15,000	530	75	39,750	0.5	19,875	130	0	9,750	0	4,875	Pre-planning and coordination of Category 2 shipping with receiving licensee
37.75(c)	400	75	30,000	0.08	2,400	530	75	39,750	0.08	3,180	130	0	9,750	0	780	Notification of shipping licensee upon receipt on Category 2 shipments
37.75(d)	100	3	300	0.16	48	110	3	330	0.16	53	10	0	30	0	5	Change in arrival time
37.77(a)&(b)	16	21.88	350	4	1,400	16	21.88	350	4	1,400	0	0	0	0	0	Advance written notification to the states of Category 1 shipments
37.77 (c),	16	2	32	0.25	8	16	2	32	0.25	8	0	0	0	0	0	Revision notification to state
37.77 (d)	16	0	0	0.25	0	16	0	0	0.25	0	0	0	0	0	0	Cancel notification to state
37.79(b)(1)(iii) in PR, 37.79(b)(1)(ii) in FR	0	0	0	0.03	0	0	0	0	0.03	0	0	0	0	0	0	Periodic reports to communication center
37.81(a),(c)&(e)	0	0	0	0.25	0	0	0	0	0.25	0	0	0	0	0	0	Category 1, zero estimated
TOTAL			75,835		42,826.75			96,175.16		50,126.91			20,340.16		7,300.16

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Sheet 6: One-time recordkeeping

	Part 37 final rule			2015 Renewal			BURDEN CHANGE			NOTES
Section	Number of Recordkeepers	Burden per Recordkeeper	Total Annual Burden Hours	Number of Recordkeepers	Burden per Recordkeeper	Total Annual Burden Hours	Number of Recordkeepers	Burden per Recordkeeper	Total Annual Burden Hours	Notes	Retention Period
37.23(h)(2)	1,400	50	70,000	1,200	50	60,000	-200	0	-10,000	One time burden to develop access authorization procedures	3 yrs after procedure no longer need, or license termination
37.43(b)	1,400	100	140,000	1,200	100	120,000	-200	0	-20,000	One time burden to develop security procedures	3 yrs after procedure is not longer needed, or 3 yrs after procedure is superceded
TOTAL	1,400		210,000	1,200		180,000	-200	0	-30,000
ANNUALIZED TOTAL	1,400		70,000	1,200		60,000	-200	0	-10,000
	Explanation: Decrease in burden due to one-time record keeping requirements. Only new licensees and remaining Agreement State licensees, who have not yet fulfilled this requirement, are required to develop access authorization and security procedures since existing NRC licensees were previously required to fulfill this requirement.

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Sheet 7: Annual recordkeeping

	Part 37 final rule			2015 renewal			BURDEN CHANGE			NOTES
Section	Number of Recordkeepers	Burden per Recordkeeper	Total Annual Burden Hours	Number of Recordkeepers	Burden per Recordkeeper	Total Annual Burden Hours	Number of Recordkeepers	Burden per Recordkeeper	Total Annual Burden Hours	Notes	Retention Period
37.23(e)(3) in PR, 37.23(e)(5) in FR	1,400	1	1,400	1,500	1	1,500	100	0	100	List of persons approved access	3 years from the date the individual no longer requires unescorted access
37.23(f)	Burden included in 37.23(h)(2)			Burden included in 37.23(h)(2)			0	0	0	Burden included in 37.23(h)(2)
37.23(g)(1)	0	0.25	0	1,500	0.25	375	1,500	0	375	Notification records	1 year
37.23(h)(1)	1,400	2.25	3150	1,500	2.25	3375	100	0	225	Record of procedure and trustworthiness	3 years from the date the individual no longer requires unescorted access
37.23(h)(2)	1,400	0.5	700	1,500	0.5	750	100	0	50	Current procedures for conducting background investigations	3 yrs after procedure no longer need, or license termination
37.23(h)(3)	Burden included in 37.23(e)(5)			Burden included in 37.23(e)(5)			0	0	0	Burden included in 37.23(e)(5)
37.25(a)(2)	Burden included in 37.23(h)(1)			Burden included in 37.23(h)(1)			0	1	0	Burden included in 37.23(h)(1)
37.25(a)(10)(i) in PR, 37.25(a)(7) in FR	Burden included in 37.23(h)(1)			Burden included in 37.23(h)(1)			0	0	0	Burden included in 37.23(h)(1)
37.25(b) in PR, 37.25(b)(2) in FR	Burden included in 37.23(h)(1)			Burden included in 37.23(h)(1)			0	0	0	Burden included in 37.23(h)(1)
37.29(l-m) in PR, 37.29(a)(12)&(13) and 37.29(b) in FR	Burden included in 37.23(h)(1)			Burden included in 37.23(h)(1)			0	2	0	Burden included in 37.23(h)(1)
37.31(a)	1,400	0.75	1,050	1,500	0.75	1,125	100	0	75	Written procedures for protection of the record	3 yrs from date no longer requires access
37.31(e)	1,400	0.75	1,050	1,500	0.75	1,125	100	0	75	Fingerprint and criminal history records	3 yrs from date no longer requires access
37.33(b)&(c)	1,400	1.5	2,100	1,500	1.5	2,250	100	0	150	Document results of program review – 3 years	3 years
37.43(a)(4)	1,400	3.3	4,620	1,500	3.3	4,950	100	0	330	Security plan	3 yrs after plan is superseded or until license termination
37.43(b)(3)	1,400	0.25	350	1,500	0.25	375	100	0	25	Security plan implementing procedures	3 years after the record is superseded.
37.43(c)(4)	1,400	3	4,200	1,500	3	4,500	100	0	300	Training records for security plan	3 years
37.43(d)(5) in PR, 37.43(d)(5) & (6) in FR	Burden included in 37.43(d)(8)			Burden included in 37.43(d)(8)			0	0	0	Burden included in 37.43(d)(8)
37.43(d)(7)(i) in PR, 37.43(d)(8)(i) and (ii) in FR	Information protection procedures - included in 37.43(b)(3)			Information protection procedures - included in 37.43(b)(3)			0	0	0	Information protection procedures - included in 37.43(b)(3)
37.43(d)(7)(ii) in PR, 37.43(d)(8)(i) and (ii) in FR	1,400	0.25	350	1,500	0.25	375	0	0	25	List of trust worthy person	3 years
37.45(a)(2)							0	0	0
37.45(b)(3)							0	0	0
37.45(c)	1,400	1	1400	1,500	1	1500	100	0	100	Records of coordination with LLEA	3 years
37.51(b)	1,400	0.25	350	1,500	0.25	375	100	0	25	Records of maintenance and testing	3 years
37.55(c)	1,400	1.5	2100	1,500	1.5	2250	100	0	150	Records of security plan review	3 years
37.71(c) in PR, 37.71(a)-(d) in FR	400	0.75	300	MasterImage: Cat 2 licensees shipping. 530	0.75	397.5	130	0	98	Copy of document verification before transfer	3 years
37.75(a)(3), (b), & (e)	416	0.75	312	MasterImage: (Cat 2) 530 Radiographers + (Cat 1) 15 M&D + 1 Irradiator/yr) =646 546	0.75	409.5	130	0	98	Copy of preplanning info for shipments	3 years
37.77(e)	16	0.01	0.16	16	0.01	0.16	0	0	0	Copy of advance notification, revision, cancellation notices	3 years
37.79(c) in PR, 37.79(a)(1)(iii) &(v) in FR	16	0.75	12	16	0.75	12	0	0	0	Written procedures for road shipment of category 1 material	3 years
37.79(b)(1)(i)	0	0.75	0	0	0.75	0	0	0	0	Procedures for rail shipments	3 years
TOTAL			23,444.2			25,644.2	0	0	2,200

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Sheet 8: 2015 renewal summary

2015 Renewal Summary: Part 37 Totals
	Hours	Responses
Reporting	1,932.4	6,204.4
Recordkeeping	85,644.2	1,200.0
Third-Party Disclosure	50,993.6	96,578.5
Total	138,570.2	103,982.9
Respondents
	Final Rule	2015 renewal
Agreement State Licensees	1,100	1,200
NRC Licensees	300	300
Individuals making personal history disclosures under 37.23(d)	4,200	4,500
Total	5,600	6,000