Part 19- Final Supportung Statement -ML20357A054

FINAL SUPPORTING STATEMENT FOR
10 CFR PART 19
"NOTICES, INSTRUCTIONS, AND REPORTS TO WORKERS: INSPECTION
AND INVESTIGATIONS" (3150-0044)
--REVISION
DESCRIPTION OF THE INFORMATION COLLECTION
This information collection is primarily addressing the licensee third-party disclosure
requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 19. Less than 12
percent of the burden for this clearance is associated with recordkeeping and reporting
requirements. 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
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 entity’s 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.”

2

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 work place.”
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 individual’s 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

3

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."
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.

4

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. For the most recent fiscal year, approximately 684 small entity adjustments
were granted by the NRC in regard to licensing fees.

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.

8.

Consultations Outside the NRC
Opportunity for public comment on the information collection requirements for this
clearance package was published in the Federal Register on November 4, 2020 (85
FR 70202). The NRC received one comment on the information collection
requirements.
Comment 1: The commenter made statements about a former United States
president.
Response: The NRC considers this comment to be out-of-scope and it is not related
to the questions asked in the request for comments posted in the Federal Register on
November 4, 2020 (85 FR 70202).
Seven NRC licensees were contacted by e-mail as part of the public consultation
process. Feedback on this information was requested. No responses or comments
were received in responses to these consultations.

5

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 NRClicensed 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 3,000 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 NRC’s 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 135,747.3 hours (0.5 hours reporting + 3,000
hours annual recordkeeping + 1,881 hours one-time recordkeeping + 130,865.8 hours
third-party disclosures) at a cost of $37,873,505 (135,747.3 hours x $279/hour).
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 NRC’s 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 NRC’s Web site at
https://scp.nrc.gov/rulemaking.html.

6

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 16,500 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 1:5.9 (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 443,913.3 hours (3 hours
reporting + 16,500 hours annual recordkeeping + 11,097.9 hours one-time
recordkeeping + 416,312.4 hours third-party disclosures) at a cost of $123,851,819
(443,913.3 x $279/hour). The following table is a summary of the burden:

Reporting
Recordkeeping
Third-party disclosures
One-time
recordkeeping burden
TOTAL

NRC Licensees
Hours
Responses
0.5
1.0
3,000.0
3,000.0
130,865.8
363,201.8
1,881.0
135,747.3

366,202.8

Total Burden for Part 19
Agreement State
Hours
Responses
3.0
6.0
16,500.0
16,500.0
416,312.4 1,516,526.3
11,097.9
443,913.3

1,533,032.3

TOTAL
Hours
Responses
3.5
7.0
19,500.0
19,500.0
547,178.3
1,879,728.1
12,978.9
579,660.7

1,899,235.1

Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

The $279 hourly rate used in the burden estimates is based on the Nuclear Regulatory
Commission’s fee for hourly rates as noted in 10 CFR 170.20 “Average cost per
professional staff-hour.” For more information on the hourly rate, see the Revision of Fee
Schedules; Fee Recovery for Fiscal Year 2020 (85 FR 37250, June 19, 2020).
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 $3,624.65 (32,478.9 hours x 0.0004 x
$279/hr).

14.

Estimated Annualized Cost to the Federal Government
There is no cost to the Federal government except for those that involve requests by

7

workers for inspections. Approximately one worker requests an inspection each year
pursuant to 10 CFR 19.16. Each request takes an average of 3 hours to resolve. Thus,
the estimated annual cost to the Federal government is $837 (1 report/year x 3
hours/report x $279/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 increased from 320,968.9 hours to 579,660.7 hours
and the respondents decreased from 20,300 to 19,500 (3,000 NRC licensees +
16,500 AS licensees). Responses increased from 1,401,163.0 responses to
1,899,235.1. In this submission, the NRC staff identified third-party disclosure
requirements in 19.11 for posting notices to workers. The burden for these
requirements was not captured in the last submission of this information
collection. The omission has been corrected in the current submission. The
inclusion of these requirements has increased the overall total by 275,700
hours and 609,500 responses.
The current submission does not represent any changes in the requirements for
licensees.
The following table is a summary of the change in burden from the 2017
renewal to the current request:

Reporting
Recordkeeping
Third-party disclosures
One-time burden
TOTAL

Burden Change from 2017 to Current Request
2017 Renewal
Current Request
Burden Change
Hours
Responses
Hours
Responses
Hours
Responses
3.5
7.0
3.5
7.0
20,300.0
20,300.0
19,500.0
19,500.0
(800.0)
(800.0)
287,498.4
1,380,856.0
547,178.3 1,879,728.1
259,679.9
498,872.1
13,167.0
12,978.9
(188.1)
320,968.9
1,401,163.0
579,660.7 1,899,235.1
258,691.8
498,072.1

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 51,447.3 hours to 135,747.3
hours, an increase of 84,300 hours. This increase is attributed to an increase in thirdparty disclosures, as previously discussed.
The estimated number of NRC licensee responses changed from 251,702.8
responses (1 reporting response + 3,000 recordkeepers + 248,701.8 third-party
disclosure responses) to 366,202.8 responses (1 reporting response + 3,000

8

recordkeepers + 363,201.8 third-party disclosure responses), an increase of 114,500
responses. This increase is attributed to an increase in third-party disclosures, as
previously discussed.
Agreement State Licensees
The burden estimate for Agreement State licensees changed from 269,521 hours to
443,913.3 hours, an increase of 174,392.3 hours. This increase is attributed to an
increase in third-party disclosures, as previously discussed.
The estimated number of Agreement State licensee responses changed from
1,149,460.2 responses (6 reporting response + 17,300 recordkeepers + 1,132,154.2
third-party disclosure responses) to 1,533,032.3 responses (6 reporting response +
16,500 recordkeepers + 1,516,526.3 third-party disclosure responses), an increase of
383,572.1 responses. This increase is attributed to an increase in third-party
disclosures, as previously discussed.
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.

18.

Exceptions to the Certification Statement
Not applicable.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL
METHODS
Not applicable.

Section
19.16(a)
Total

Table 1: NRC Licensee Annual Reporting Burden
Responses per
Total
Burden Hours
Total Burden Cost at $279/hr
Respondents
Respondent
Responses
per Response
1
1.0
1.0
0.5
0.5 $
140
1
1.0
0.5 $
140

Table 2: NRC Licensee One-Time Recordkeeping
Total
Annual
Cost at
Number of
Hours per
Section
$279/hr
Recordkeepers Recordkeeper Burden
Hours
19.12 (Training
99
19.0 1,881.0 $ 524,799
materials)

9

Table 3: NRC Licensee Annual Recordkeeping
Number of
Hours per
Total Annual
Cost at
Section
Recordkeepers Recordkeeper Burden Hours
$279/hr
19.12 (Training materials)
3,000
1.0
3,000.0 $
837,000
Total
3,000
3,000.0 $
837,000

10

Section

19.11(a)

19.11(b)

19.11(d)
19.11(e)
19.11(g)
19.12
19.13(b)

19.13(b)

19.13(c)

19.13(c)

19.13(d)

19.13(e)

19.13(e)

19.13(e)

19.13(e)

19.13(e)
Total

Description
Posting applicable
documents (most
licensees)
Posting applicable
documents (subset
of applicants and
licensees)
Alternate posting
instructions
Posting NRC Form 3
Timeframe for
posting applicable
documents
Worker instructions
Annual worker dose
report (monitored
reportable workers)
Annual worker dose
report (monitored
nonreportable
workers)
Former worker dose
report on demand
(commercial
transient)
Former worker dose
report on demand
(other transient)
Copies of reports
under 20.2202,
20.2203, 20.2204,
and 20.2206 given to
worker
Terminating worker
dose report
(commercial
transient)
Terminating worker
dose report (other
licensee transient
workers)
Terminating worker
dose report
(commercial
terminating)
Terminating worker
dose report (other
terminating)
Terminating worker
dose report
(nonreportable
terminating workers)

Table 4: NRC Licensee Third-Party Disclosures
Responses
Burden
Total
Respondents
per
Hours per
Responses
Respondent
Response

Total
Burden
Hours

Cost at
$279/hr

2,950

10.0

29,500.0

1.00

29,500.00

$8,230,500

50

500.0

25,000.0

2.00

50,000.00

$13,950,000

0.08

4,800.00

$1,339,200

see 19.11(a) & (b)
3,000.0

20.0

60,000.0

see 19.11(a) & (b)
3,000

1.0

3,000.0

8.00

24,000.00

$6,696,000

180

650.0

117,000.0

0.08

9,360.00

$2,611,440

3,000

16.0

48,000.0

0.08

3,840.00

$1,071,360

100

78.14

7,814.0

0.17

1,328.38

$370,618

80

0.76

60.8

1.50

91.20

$25,445

1

1.0

1.0

0.17

0.17

$47

100

520.9

52,090.0

0.08

4,167.20

$1,162,649

80

5.0

400.0

0.08

32.00

$8,928

100

120.0

12,000.0

0.083

996.00

$277,884

80

19.6

1,568.0

0.33

517.44

$144,366

2,820

2.4

6,768.0

0.33

2,233.44

$623,130

3,000

363,201.8

11

130,865.83 $ 36,511,567

Table 5: Agreement State Annual Reporting Burden
Responses per
Total
Burden Hours
Total Burden
Respondents
Cost at $279/hr
Respondent
Responses
per Response
Hours
6
1.0
6.0
0.5
3.0 $
837
6
6.0
3.0 $
837

Section
19.16(a)
Total

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
584
19.0 11,097.9 $ 3,096,314
materials)

Table 7: Agreement State Licensee Annual Recordkeeping
Section
19.12 (Training materials)
Total

Number of
Hours per
Total Annual
Recordkeepers Recordkeeper Burden Hours
16,500
16,500

1.0

13

16,500.0 $
16,500.0 $

Cost at
$279/hr
4,603,500
4,603,500

Section

19.11(a)

19.11(b)

19.11(d)
19.11(e)
19.11(g)
19.12
19.13(b)

19.13(b)

19.13(c)

19.13(d)

19.13(e)

19.13(e)

19.13(e)

Total

Table 8: Agreement State Licensee Third-Party Disclosures
Responses
Burden
Total
Total
Description
Respondents
per
Hours per
Burden
Responses
Respondent
Response
Hours
Posting applicable
documents (most
16,500
10.0
165,000.0
1.00 165,000.00
licensees)
Posting applicable
documents (subset
0
500.0
0.0
2.0
0.0
of applicants and
licensees)
Alternate posting
see 19.11(a) & (b)
instructions
Posting NRC Form
16,500
20.0
330,000.0
0.08
26,400.00
3
Timeframe for
see 19.11(a) & (b)
posting applicable
documents
Worker instructions
16,500
1.0
16,500.0
8.00
132,000.0
Annual worker dose
report (monitored
1,062
650.0 690,300.0
0.08
55,224.0
reportable workers)
Annual worker dose
report (monitored
16,500
16.0 264,000.0
0.08
21,120.0
nonreportable
workers)
Former worker
dose report on
472
0.76
358.7
1.50
538.1
demand (other
transient)
Copies of reports
under 20.2202,
20.2203, 20.2204,
6
1.0
6.0
0.17
1.0
and 20.2206 given
to worker
Terminating worker
dose report (other
472
5.0
2,360.0
0.08
188.8
licensee transient
workers)
Terminating worker
dose report (other
472
20.2
9,534.4
0.33
3,146.4
terminating)
Terminating worker
dose report
(nonreportable
16,028
2.4
38,467.2
0.33
12,694.2
terminating
workers)
16,500
1,516,526.3
416,312.4

14

Cost at
$279/hr
$46,035,000

$0

$7,365,600

$36,828,000
$15,407,496

$5,892,480

$150,124

$285

$52,675

$877,832

$3,541,675

$62,750,567

Reporting
Recordkeeping
Third-party disclosures
One-time
recordkeeping burden
TOTAL

Table 9: Total Burden for Part 19
NRC Licensees
Agreement State
TOTAL
Hours
Responses
Hours
Responses
Hours
Responses
0.5
1.0
3.0
6.0
3.5
7.0
3,000.0
3,000.0
16,500.0
16,500.0
19,500.0
19,500.0
130,865.8
363,201.8
416,312.4 1,516,526.3
547,178.3
1,879,728.1
1,881.0
135,747.3

366,202.8

11,097.9
443,913.3

1,533,032.3

12,978.9
579,660.7

1,899,235.1

Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

Reporting
Recordkeeping
Third-party disclosures
One-time burden
TOTAL

Table 10: Burden Change from 2017 to Current Request
2017 Renewal
Current Request
Burden Change
Hours
Responses
Hours
Responses
Hours
Responses
3.5
7.0
3.5
7.0
20,300.0
20,300.0
19,500.0
19,500.0
(800.0)
(800.0)
287,498.4
1,380,856.0
547,178.3 1,879,728.1
259,679.9
498,872.1
13,167.0
12,978.9
(188.1)
320,968.9
1,401,163.0
579,660.7 1,899,235.1
258,691.8
498,072.1

Note: The one-time recordkeepers are also annual recordkeepers, and therefore are not counted twice in the responses total.

15