Part 34 Burden Spreadsheet

Description

TOTAL

34.101(c)

34.101(a)&(b)

34.41(c)

34.27(d)

34.13(b)-(k)

Section

An application for a specific license for the use of licensed material in
industrial radiography will be approved if the applicant meets the
specified requirements
Report within 5 days results of leak testing which indicates that a source
is leaking
A licensee may conduct lay-barge, offshore platform, or underwater
radiography only if procedures have been approved by the Commission
or by an Agreement State.
Report within 30 days of the occurrence of failures related to the source
assembly and any component critical to safe operation to properly
perform its intended function
Requires notification prior to conducting radiographic operations or
storing radioactive material in excess of 180 days at any location not
listed on the license

Description

ANNUAL REPORTING BURDEN OF 10 CFR PART 34 FOR AGREEMENT STATE LICENSEES

34.13(b)-(k)

An application for a specific license for the use of licensed material in
industrial radiography will be approved if the applicant meets the
specified requirements
Report within 5 days results of leak testing which indicates that a source
34.27(d)
is leaking
A licensee may conduct lay-barge, offshore platform, or underwater
radiography only if procedures have been approved by the Commission
34.41(c)
or by an Agreement State.
Report within 30 days of the occurrence of failures related to the source
34.101(a)&(b)
assembly and any component critical to safe operation to properly
perform its intended function
Requires notification prior to conducting radiographic operations or
34.101(c)
storing radioactive material in excess of 180 days at any location not
listed on the license
Requires independent certifying organizations and/or Agreement States
Appendix A, Part I, Item 12 to exchange information about certified individuals with the Commission
and the Agreement States
TOTAL

Section

ANNUAL REPORTING BURDEN OF 10 CFR PART 34 FOR NRC LICENSEES

1

1

1

6

13

5

5

1

1

94

224

36

1

1

1

0

36

1

58

Number of
Respondents*

37

6

5

5

13

0

8

0.5

0.5

10

20

4

40

224

36

36

94

0

58

0.5

10

20

4

40

Responses
Total
Burden
Per
Responses/yr Hrs/response
Respondent

1

0

32

1

Responses
Total
Burden
Per
Responses/yr Hrs/response
Respondent

8

Number of
Respondents

4,578.00

18

360

1,880.00

0

2,320.00

Total Burden hr/yr

635.50

3

2.5

50

260

0

320

Total Burden hr/yr

$1,268,184

$504

$100,080

$522,640

$0

$644,960

Cost at $278/hr

$176,669

$834

$695

$13,900

$72,280

$0

$88,960

Cost at $278/hr

Radiation survey instrument calibration & records
thereof
Sealed source leak testing & records thereof
“S” tube leak testing & records thereof
Sealed source inventories & records thereof

Description

34.63

34.61

34.49(c)&(d)

34.47(g)(4)

34.47(f)

34.47(e)

34.47(d)

34.47(c)

34.47(b)

34.45(a)&(b)

34.43(f)

34.33(b)

Tests of controls and alarms at permanent
radiographic installations and records thereof
Records of training, examinations, refresher safety
training, and semiannual inspections of job
performance
Program for routine operations and emergencies for
employees to follow in performing safety functions &
copies of procedures
Read and record exposure on direct reading
dosimeters; maintain records
Periodic check of pocket dosimeters or electronic
dosimeters for correct response to radiation;
maintain records
Determination of exposure if an individual's pocket
dosimeter goes off-scale
Requirements if a personnel dosimeter is lost or
damaged
Requirement to maintain reports received from
personnel dosimeter processors
Calibrate alarm ratemeters; maintain records
Surveys of radiographic exposure device & records
thereof
Licensee to have a copy of the license, license
conditions, documents incorporated by reference,
and all amendments
Maintain records showing receipts and transfers of
sealed sources and devices using DU shielding

592

1184

592

1184

592

0.16
1.6

74

118.4

11.84

Included in 34.85

Included in 34.83(b)

Included in 34.83(c)

Included in 34.83(d)

Included in 34.83(d)

Included in 34.83(a)

Included in 34.83(a)

Included in 34.81

Included in 34.79

Included in 34.75

8

74

74

RSO ensures that operations are conducted safely
and assumes control for instituting corrective actions

34.42(c)(5)

8

74

16

16

74

74

8

74

296

Included in 34.73

Included in 34.67
Included in 34.67
Included in 34.69

4

34.42(c)(4)

Total Hr/Yr

Included in 34.65

Burden Hrs Per
Recordkeeper

74

Number of
Recordkeepers

RSO ensures that personnel monitoring devices are
calibrated and used properly, that records are kept of
the monitoring results, and that timely notifications
are made as required by § 20.2203 of this chapter

34.27(c)(1)&(2)
34.27(e)
34.29(a)&(b)
34.31(a)&(b)(1)&
Licensee’s program for inspection and maintenance
(2)&(c)
Completion of the training and testing requirements
34.42(a)
of § 34.43(a)
RSO establishes, oversees, and regularly reviews all
34.42(c)(1)
operating, emergency, and ALARA procedures as
required
RSO oversees and approves all phases of the
34.42(c)(2)
training program for radiographic personnel
RSO ensures that required radiation surveys and
34.42(c)(3)
leak tests are performed and documented in
accordance with the

34.25(b)&(c)

Section

ANNUAL RECORDKEEPING REQUIREMENTS OF 10 CFR PART 34 FOR NRC LICENSEES

3 Years

license
termination

license
termination

license
termination

license
termination

license
termination

license
termination

license
termination

Record
Retention
Period

Maintain records of calibrations of radiation survey
instruments
Maintain records of leak test results
Maintain records of quarterly inventories of sealed
sources and devices containing DU shielding &
include specific information concerning such
inventories
Maintain utilization logs for each sealed radioactive
source & records thereof
Maintain records of equipment problems and
maintenance
Maintain records of alarm system and entrance
control device tests at permanent radiographic
installations
Maintain records of training of radiographers and
radiographers' assistants in accordance with §
34.43(f)
Retain records of current operating and emergency
procedures specified in § 34.45
Maintain exposure records for direct reading
dosimeters
Maintain records for alarm ratemeter calibrations
Maintain records for reports from personnel
dosimeter processor & for estimates of exposures
resulting from off- scale or lost or damaged
dosimeters
Maintain record of last survey of each radiographic
exposure device on each day used prior to placing
device in storage
Maintain each record in a legible form
Maintain copies of records sufficient to demonstrate
compliance at field stations and temporary job sites
120
0
5

74
74
74

3

2.5

74

122.5

74
74

0.08

5

74
74

48.2

27

36

12

74

74

2

74

1.6
1.2

74
74

370

0

8880

222

185

9065

5.92

370

578.4

1998

2664

148

88.8

118.4

3 Years

life of program
license
termination

3 Years

3 Years

3 Years

3 Years

license
termination

3 Years

3 Years

3 Years

3 Years

3 Years

3 Years

ICO procedures for proctoring examinations

ICO written procedures describing its certification
program
ICO procedures to ensure due process with respect
to administration of certification program

ICO written by laws and policies

Appendix A, Part CP includes procedures for denying an application,
revoking, suspending, and reinstating a certificate
II, item 4
CP includes procedures for renewing certifications;
Appendix A, Part renewals without examination require evidence of
II, item 6
recent full-time employment and annual refresher
training

Appendix A, Part CP includes procedures to ensure that all
II, item 3
examination questions are protected from disclosure

ICO description of procedures for choosing
Appendix A, Part
examination sites and for providing an appropriate
I, item 13
examination environment
CP required to provide documentation demonstrating
Appendix A, Part that radiography applicants have received training
II, item 2
and are capable of independently working as a
radiographer

Appendix A, Part
I, item 6
Appendix A, Part
I, item 9
Appendix A, Part
I, item 10
Appendix A, Part
I, item 11

10

10

1

1

10

38

1

1

10

1

10

10

1
1

70

10

1

1

10

10

10

38

10

10

10

70

10

life of program

life of program

life of program

life of program

life of program

life of program

life of program

life of program

life of program

Note: 34.87 requires the licensee to maintain all records in a legible form (including electronic storage media). This requirement does not impose additional burden beyond the burden included in other recordkeeping requirements.

34.89(a)&(b)

34.87

34.85

34.83(c)&(d)

34.83(b)

34.83(a)

34.81

34.79(a)&(b)

34.75

34.73(a)&(b)

34.71(a)&(b)

34.69(a)&(b)

34.67

34.65

120

1
74

50

1

533

RSO ensures that personnel monitoring devices are
calibrated and used properly, that records are kept of
the monitoring results, and that timely notifications
are made as required by § 20.2203 of this chapter

34.47(d)

34.47(c)

34.47(b)

34.45(a)&(b)

34.43(f)

34.42(c)(5)

Program for routine operations and emergencies for
employees to follow in performing safety functions &
copies of
Read and record exposure on direct reading
dosimeters; maintain records
Periodic check of pocket dosimeters or electronic
dosimeters for correct response to radiation;
maintain records
Determination of exposure if an individual's pocket
dosimeter goes off-scale

533

8

533

RSO ensures that operations are conducted safely
and assumes control for instituting corrective actions
Records of training, examinations, refresher safety
training, and semiannual inspections of job
performance

16

533

34.42(c)(4)

8

533

4264

8528

Included in 34.83(d)

Included in 34.83(a)

Included in 34.83(a)

Included in 34.81

Included in 34.79

8

16

4264

8528

4264

2132

Included in 34.75

Included in 34.73

Included in 34.69

Included in 34.67

4

“S” tube leak testing & records thereof

34.27(e)

Included in 34.67

533

Sealed source leak testing & records thereof

34.27(c)(1)&(2)

Total Hr/Yr

29.611.76

120

50

Included in 34.65

Number of
Burden Hrs Per
Recordkeepers Recordkeeper

34.29(a)&(b)
Sealed source inventories & records thereof
34.31(a)&(b)(1)&
(2)&(c)
Licensee’s program for inspection and maintenance
Tests of controls and alarms at permanent
34.33(b)
radiographic installations and records thereof
Completion of the training and testing requirements
34.42(a)
of § 34.43(a)
RSO establishes, oversees, and regularly reviews all
operating, emergency, and ALARA procedures as
34.42(c)(1)
required by 10 CFR part 20 of this chapter
RSO oversees and approves all phases of the
34.42(c)(2)
training program for radiographic personnel
RSO ensures that required radiation surveys and
leak tests are performed and documented in
34.42(c)(3)
accordance with

Radiation survey instrument calibration & records
thereof

Description

34.25(b)&(c)

Section

ANNUAL RECORDKEEPING BURDEN OF 10 CFR PART 34 FOR AGREEMENT STATE LICENSEES

CP provides timely response to inquiries from
Appendix A, Part
members of the public about an individual's
II, item 7
certification status
Written examinations have test items drawn from a
Appendix A, Part
question bank containing psychometrically valid
III, item 3
questions based on the material in § 34.43(g)
TOTAL

license
termination

license
termination

license
termination

license
termination
license
termination

license
termination

Record
Retention
Period

life of program

life of program

Requirements if a personnel dosimeter is lost or
damaged
Requirement to maintain reports received from
personnel dosimeter processors
Included in 34.83(c)

Included in 34.83(d)

CP includes procedures to ensure that all
examination questions are protected from disclosure
CP includes procedures for denying an application,
revoking, suspending, and reinstating a certificate
CP includes procedures for renewing certifications;
renewals without examination require evidence of
Appendix A, Part recent full-time employment and annual refresher
II, item 6
training

Appendix A, Part
II, item 3
Appendix A, Part
II, item 4

10
10

10

9
9

9

90

90

90

life of program

life of program

life of program

Calibrate alarm ratemeters; maintain records
Included in 34.83(b)
Surveys of radiographic exposure device & records
34.49(c)&(d)
thereof
Included in 34.85
Licensee to have a copy of the license, license
conditions, documents incorporated by reference,
license
34.61
and all amendments
533
0.16
85.28
termination
Maintain records showing receipts and transfers of
34.63
sealed sources and devices using DU shielding
533
1.6
852.8
3 Years
Maintain records of calibrations of radiation survey
34.65
instruments
533
1.6
852.8
3 Years
34.67
Maintain records of leak test results
533
1.2
639.6
3 Years
Maintain records of quarterly inventories of sealed
sources and devices containing DU shielding &
34.69(a)&(b)
include specific
533
2
1066
3 Years
Maintain utilization logs for each sealed radioactive
34.71(a)&(b)
source
533
36
19188
3 Years
Maintain records of equipment problems and
34.73(a)&(b)
maintenance
533
27
14391
3 Years
Maintain records of alarm system and entrance
control device tests at permanent radiographic
34.75
installations
86
48.2
4164.5
3 Years
Maintain records of training of radiographers and
radiographers' assistants in accordance with §
34.79(a)&(b)
34.43(f)
533
5
2665
3 Years
Retain records of current operating and emergency
license
34.81
procedures specified in § 34.45
533
0.08
42.64
termination
Maintain exposure records for direct reading
34.83(a)
dosimeters
533
122.5
65292.5
3 Years
34.83(b)
Maintain records for alarm ratemeter calibrations
533
2.5
1332.5
3 Years
Maintain records for reports from personnel
dosimeter processor & for estimates of exposures
resulting from off533
3.2
1705.6
3 Years
34.83(c)&(d)
Maintain record of last survey of each radiographic
exposure device on each day used prior to placing
device
533
120
63960
3 Years
34.85
34.87
Maintain each record in a legible form
533
0
0
life of program
Maintain copies of records sufficient to demonstrate
license
34.89(a)&(b)
compliance at field stations and temporary job sites
533
5.4
2878
termination
Note: 34.87 requires the licensee to maintain all records in a legible form (including electronic storage media). This requirement does not impose additional burden
beyond the burden included in other recordkeeping requirements
CP required to provide documentation demonstrating
that radiography applicants have received training
Appendix A, Part and are capable of independently working as a
radiographer
9
14
126
life of program
II, item 2

34.47(g)(4)

34.47(f)

34.47(e)

CP provides timely response to inquiries from
Appendix A, Part members of the public about an individual's
II, item 7
certification status
Written examinations have test items drawn from a
Appendix A, Part question bank containing psychometrically valid
III, item 3
questions based on the material in § 34.43(g)
TOTAL
25

120

9

1
533

120
211837.22

225

life of program

life of program

Labels on radiographic exposure devices
Requires durable, legible, and clearly visible label on source
changer or container that indicates whom to notify
Requires appropriate packaging, labeling, and shipping
papers for transport of licensed material
Requires the licensee to provide radiographers and
assistants with copies of pertinent sections of NRC and DOT
regulations, the NRC license, and operating and emergency
procedures

Description

74

74

74

74

Number of
Respondents
74

1

1

1

Responses
Per
1

TOTAL

34.43(b)(1)&(c)(1)

34.35(b)

34.35(a)

34.20(b)(1)

Section

Requires the licensee to provide radiographers and
assistants with copies of pertinent sections of NRC and DOT

Labels on radiographic exposure devices
Requires durable, legible, and clearly visible label on source
changer or container that
Requires appropriate packaging, labeling, and shipping
papers for transport of licensed

1
1

533
533

533

1

1

533

533

Responses Per
Respondent

Number of
Respondents

ANNUAL THIRD PARTY DISCLOSURE BURDEN OF 10 CFR PART 34 FOR AGREEMENT STATE LICENSEES

TOTAL

34.43(b)(1)&(c)(1)

34.35(b)

34.35(a)

34.20(b)(1)

Section

ANNUAL THIRD PARTY DISCLOSURE REQUIREMENTS OF 10 CFR PART 34 FOR NRC LICENSEES

2,132.00

533

533

533

533

Total Responses/yr

296

74

74

74

Total
Responses/yr
74

2.5

36

0.8

0.4

Burden
Hrs/response

2.5

36

0.8

Burden
Hrs/response
0.4

21,160.10

1,332.50

19,188.00

426.4

213.2

Total Burden hr/yr

2,937.80

185

2,664.00

59.2

29.6

Total Burden hr/yr

$5,882,508

$370,435

$5,334,264

$118,539

$59,270

Cost at $278/hr

$816,708

$51,430

$740,592

$16,458

$8,229

Cost at $278/hr

Reporting
Recordkeeping
Third-Party Disclosure
TOTAL

TOTAL BURDEN FOR 10 CFR 34
Agreement State
NRC Licensees
TOTAL
Licensees
635.50
4,578.00
5,213.50
29,611.76
211,837.22
241,448.98
2,937.80
21,160.10
24,097.90
33,185.06
237,575.32
270,760.38
$1,449,353.00
$67,122,816.44
$6,699,216.20
$75,271,385.64

Cost @$278/hr