3150-0002 Annual Burden Tables

Table 1
10 CFR Part 73 Annual Reporting Burden
Section

Description of requirement

73.5

The Commission may grant exemptions from the
requirements of the regulations in Part 73 under
specified conditions, upon the application of any
interested person or on its own initiative.

4.00

1.00

4.00

25.00

73.26(b)(3)

Prior to each shipment, licensees shall provide
information to NRC concerning the identity of the
shipper, consignee, carriers, transfer points,
modes of shipment, and security arrangements
for the shipment.
Road Shipmewnts: Calls to the movement control
center shall be made at least every half hour to
convey the status and position of the shipment. In
the event no call is received in accordance with
these requirements, the licensee or his agent shall
immediately notify the law enforcement authorities
Rail Shipmewnts: Calls to the movement control
center shall be made at least every half hour to
convey the status and position of the shipment. In
the event no call is received in accordance with
these requirements, the licensee or his agent shall
immediately notify the law enforcement authorities
Each licensee who receives a shipment of formula
quantities of SSNM shall immediately notify the
person who delivered the material to a carrier for
transport and the Director DPCP of the arrival of
the shipment at its destination. In the event such a
shipment fails to arrive at its destination at the
estimated time, or in the case of an export
shipment, the licensee who exported the
shipment, shall immediately notify Director, DPCP
and the licensee or other person who delivered
the material to a carrier for transport. The licensee
who made the physical protection arrangements
shall also immediately notify Director, DPCP of
the action being taken to trace the shipment.

0.00

0.00

0.00

20.00

Each licensee who makes arrangements for
physical protection of a shipment of formula
quantities SSNM as required by §§ 73.25 and
73.26 shall immediately conduct a trace
investigation of any shipment that is lost or
unaccounted for after the estimated arrival time
and file a report with the Commission as specified
in § 73.71.
Preplan and coordinate with the NRC to obtain
advance approval of the routes used for road and
rail shipments of spent nuclear fuel

0

0

0.00

8.00

4.00

1.00

4.00

25.00

73.26(i)(6)

73.26(k)(4)

73.27(b)

73.27(c)

73.37(b)(1)(vi)

No. of
Respondents

Responses Number of
per
Responses
Respondent

Burden
Hours per
Response

Notes

Total Annual
Burden
Hours
100.00 No change since the 2018 report.

0.00 No change since the 2018 report, because no licensees are performing

work that fall under this requirement.

0

0

0.00

1.00

0.00 No change since the 2018 report, because no licensees are performing work
that fall under this requirement. Burden hours per response has been added to
both road and rail shipments @ 1 hour each.

0

0

0.00

1.00

0.00 Put (i)(6) road and (k4) rail into 2 separate line items

0.00

0.00

0.00

1.00

0.00 No change since the 2018 report, becaue no licensees are performing

work that fall undeer this requirement.

0.00 New entry for 2021 from NSIR SMEs.

100.00 Decreased based on change in transportation

Table 1
10 CFR Part 73 Annual Reporting Burden
Description of requirement

73.38(d)

Conduct fingerprints and an FBI investigation and
criminal history records check in accordance with
Section 73.57. Conduct background
investigations before allowing an individual to act
as an armed escort or have unescorted access to
spent reactor fuel in transit. Requires the licensee
to transmit the fingerprints to the NRC.

6.00

1.00

6.00

5.25

73.46(b)(9)

Notify NRC at least 60 days in advance of a
scheduled training exercise for the security force
which is required to be observed by NRC.

2.00

1.00

2.00

1.00

2.00 There are 2 respondents and MOX has been terminated by DOE.

73.46(b)(12) & 73.46(b)(12)(i) Develop and submit to the NRC for approval
site specific, content-based, physical fitness
performance tests

0.00

0.00

0.00

8.00

0.00 This activity is complete for current CAT I licensees.

73.55(l)(7)

Requests for use of MOX fuel assemblies
containing greater than 20 weight percent PuO2
be reviewed and approved by the Commission
before receipt of MOX fuel assemblies.

0.00

0.00

0.00

8.00

0.00 MOX has been terminated by DOE.

73.55(p)(3)

Suspension of security measures reported

6.00

1.00

6.00

6.00

73.55(r)

Submission of alternative measures for
protection against radiological sabotage

1.00

1.00

1.00

8.00

73.56(d)

Background Investigation for unescorted access
to the protected area or vital area of a nuclear
power plant
Submit a fingerprint card for individuals who have
access to Safeguards Information and nuclear
power plant licensees shall fingerprint each
individual who has or will have access to
Safeguards Information or who will require
unescorted access to the nuclear power facility or
non-power reactor facility.

56.00

25.00

1400.00

0.33

91.00

427.00

38857.00

0.50

73.57(a), (b)(1), (b)(6), (d),
(d)(1), (d)(2), (g)(1), & (g)(2)

No. of
Respondents

Responses Number of
per
Responses
Respondent

Burden
Hours per
Response

Total Annual
Burden
Hours

Notes

Section

31.50 No change since the 2018 report.

6 Added this line for explicit reporting requirements that has been missed in the
past.
8.00 Pilgrim, in decommissioning stage, submitted 1 Alternative Measure in 2021.
This is the only alternative measure recognized by the NRC staff submitted in
the last 3 years.
462.00 Decreased respondents because NPPs decreased.

19428.50 No change since the 2018 report. Included NPR in the respondents total
because combined the (a) and (d) requirements to one line item.

73.67(e)(3) & 73.71(b)

Notify the NRC Operations Center within 1 hour
after the discovery of the theft or attempted theft
or unlawful diversion of SNM

0.00

0.00

0.00

6.00

0.00 No notifications anticipated in the next 3 years.

73.67(e)(7)(i)

Upon request by the NRC, a shipper provide
additional information regarding a planned
shipment as the Commission considers pertinent
to the decision on whether to delay such shipment

1.00

1.00

1.00

2.00

2.00

73.67(e)(7)(ii)

The receiver, or the shipper if the receiver is not a
licensee, notify the NRC by telephone within 24
hours after the arrival of the shipment at its final
destination, or after the shipment has left the
United States as an export.

6.00

1.66

10.00

1.00

73.67(g)(3)(iii), 73.71(a), &
73.27(c)
73.70(g)

Report of lost SSNM

0.00

0.00

0.00

0.00

0

0

0.00

4.00

Information to record prior to and during shipping
of SSNM.

10.00 Increased due to transportation operations.

0.00 Moved parenthasized from "Section" column: (No notifications anticipated in the
next 3 years).
0.00 New line item added from SME for 2021. Burden hour per response estimated
@ 4.

Table 1
10 CFR Part 73 Annual Reporting Burden
Section

Description of requirement

73.71(a)(1)

Report of lost shipment of SNM or spent fuel.

73.71(b)(1)

Report of safeguards events in accordance with
Appendix G
Provides guidance for the submission of 60-day
reports required under the forgoing provisions of
Section 73.71.
Notify NRC Headquarters Operations Center
about the shipment status by telephone
Provide written advance notification to NRC of
Cat. I, Cat II and SNF shipments.
Provide 2 hr advance notification to NRC of Cat. I,
Cat II and SNF shipments.
Notify NRC of scheduled changes > 6 hrs for Cat.
I, Cat II and SNF shipments.
Licensees exporting SNM of low strategic
significance to provide advance written notification
to the NRC at least 10 days prior to shipment,
along with shipment details and itinerary, and may
notify the NRC by telephone of any changes to the
shipment details or itinerary.

73.71(d)

73.72 - Advance Notice
Telephonic
73.72(a)(1)
73.72(a)(4)
73.72(a)(5)
73.73 - Advance Notice

73.74

Requires that licensees importing SNM of low
strategic significance from a country not a party to
the Convention on the Physical Protection of
Nuclear Material must provide advance written
notification to NRC at least 10 days prior to
shipment, along with shipment details and
itinerary, and may notify the NRC by telephone of
any changes to the shipment details or itinerary.

73.77(a)(1)
73.77(a)(2)
73.77(a)(3)
73.77(d)

1 hour cyber security event notification
4 hour cyber security event notification
8 hour cyber security event notification
Follow-up written report for 73.77(a)(1), (a)(2)(i),
and (a)(2)(iii) event notifications
Provides clarification of the requirements for
reporting safeguards events.

73.71(b), Appendix G
Totals

No. of
Respondents

Responses Number of
per
Responses
Respondent

Burden
Hours per
Response

Notes

Total Annual
Burden
Hours

0.00

0.00

0.00

0.50

10.00

1.00

10.00

0.50

10.00

1.00

10.00

6.00

6.00

3.33

19.98

0.30

14.00

1.00

14.00

1.00

14.00 New line item for 2021.

14.00

1.00

14.00

1.00

14.00 New line item for 2021.

14.00

1.00

14.00

1.00

14.00 New line item for 2021.

6.00

24.00

144.00

2.00

0.00

0.00

0.00

8.00

56.00
56.00
56.00
56.00

0.50
1.00
2.00
1.00

28.00
56.00
112.00
56.00

1.00
0.50
0.50
3.00

120.00

1.00

120.00

15.00

283.00

40888.98

0.00 Added line due to the reporting requirement. Real data aquired from the NRC
Operations Center HOO, February 2021 for CY 2020.
5.00 Added line due to the reporting requirement. Real data aquired from the NRC
Operations Center HOO, February 2021 for CY 2020.
60.00 Real data aquired from the NRC Operations Center HOO, February 2021 for
CY 2020.
5.99 Changed title to "Advance Notice Telephonic."

288.00 No change since the 2018 report, because there has been no change in
transportation.

0.00 Decreased based on change in transportation No shipments of this type have
been observed or anticipated in the next 3 years.

28.00
28.00
56.00
168.00

Decreased respondents because NPPs decreased.
Decreased respondents because NPPs decreased.
Decreased respondents because NPPs decreased.
Decreased respondents because NPPs decreased.

1800.00 Increased based on changing types of licensees - FCF (7) + NPP (56) + NPR
(31) + Decom (20) + Irradiated Fuel Shipments (6)
22630.99

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

No. of
Recordkeepers

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)
Hours per
recordkeeper

Total Annual
Burden
Hours

73.20(c), 73.25(b),(c),
Establish and maintain NRC&(d); 73.26(d)(3);
approved physical protection, training
73.26(e)(1); 73.26(h)(5); & qualification and safeguards
73.26(i)(5); 73.26(j)(6);
contingency plans
73.26(k)(2); 73.37(a);
73.37(b)(2); 73.40; 73.45;
73.46(d)(3); 73.46(g)(5);
73.46(h)(1)&(3);
73.50(a)(3), 73.50(g)(1);
73.50(h);
73.51(d)(5),(6),& (10);
73.60(e); 73.67(a)&(c);
73.67(d)(11); 73.67(f)(4);
73.67(g)(3)(i); Appendix
B Section VI H.1;
Appendix C

130

16.00

2080.0

73.22(b)

169

4.00

676.0

8

1.00

8.0

Retention
period

Notes

(L, P+3, S+3) Increased based on numerous licensed sites FCFs (11), ISFSIs (80), NPRs (31), In transit (8)

73.24(b)(1)

Condition for access to Safeguards
Information
Maintain written log of the arrival at
the final destination of each
individual shipment of SSNM

73.26(c)(1)(ii)

Retain SSNM records.

0

1.00

0.00

3.0 New line item for 2021 from NSIR SMEs.

73.26(c)(2)
73.26(d)(3)

Retain SSNM records.
Retain a record of current management
system.
Retain a record of training and
qualification of escort personnel (initial
and requals).
Retain a record of the contingency
response plan.

0
0

1.00
2.00

0.00
0.00

3.0 New line item for 2021 from NSIR SMEs.
3.0 New line item for 2021 from NSIR SMEs.

0

4.00

0.00

3.0 New line item for 2021.

0

4.00

0.00

3.0 New line item for 2021.

73.26(d)(4)

73.26(e)(1)

A+1; A+10 All licensees have chosen to maintain documents
at the SGI level instead of SGI-M; Moved all of the
3.0 Increased because BWXT shipments of CAT II to
Belgium and NPR.

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

73.26(h)(6)

Maintain audit report program records
and documented in a report,

0

30.00

0.00

73.26(d)(4)

Requalification training records for all
individuals asssigned to act as an
escort or other security member
organization.
A numbered picture badge
identification procedure shall be used
to identify all individuals who will
have custody of a shipment.
Annual transportation security
program Review

0

40.00

0.0

0

200.00

0.0

0

5.00

0.0

73.26(g)(1)

73.26(h)(6)

Retention
period

Notes

3.0 New line item for 2021.
(E,Q,R+3) No change since the 2018 report, because there
are no licensees performing work that falls under
this requirement. No shipments of CAT I have
occurred since the 1980's.
3.0 No change since the 2018 report, because there
are no licensees performing work that falls under
this requirement. No shipments of CAT I have
occurred since the 1980's.
3.0 No change since the 2018 report, because there
are no licensees performing work that fall under
this requirement. No shipments of CAT I have
occurred since the 1980's.
S No change since the 2018 report, because there
are no licensees performing work that fall under
this requirement. No shipments of CAT I have
occurred since the 1980's.
3.0 Decreased based on change in transportation.

73.26(i)(1)

Transportation Route Plan

0

360.00

0.0

73.37(b)(2)(vi)

Retain a copy of the preplanning and
coordination activities, advance
notification, and any revision or
cancellation notice as a record

4

3.33

13.3

Maintain a written log for each spent
nuclear fuel shipment
73.37(b)(3)(v), (vi), & (vii) Maintain, revise and implement
73.37(b)(4)(iii),
written transportation physical
73.37(g)(iii)
protection and contingency and
response procedures
73.37(f)
Investigations of lost unaccounted
for after designated no-later-than
arrival time.

4

27.00

108.0

3.0 Decreased based on change in transportation

4

0.25

1.0

3.0 Decreased based on change in transportation

0

4.00

0.0

3.0 4 hours added to document the number of burden
hours for investigation.

73.37(b)(3)(iv)

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

73.38(a)(2)

Establish, implement, and maintain
its access authorization program

6

0.25

1.5

L No change since the 2018 report.

73.38(c)(2)(v)

Written confirmation from the
agency/employer that granted the
Federal security clearance or
reviewed the criminal history records
check must be provided to the
licensee.
Document individual's refusal or
unwillingness to provide information
for access authorization invesitgation

6

3.75

22.5

E+3 No change since the 2018 report.

6

3.75

22.5

E+5 No change from 2018 report. E+5 was interepreted
from (l)(1) records.

Make a record of the contents of the
telephone call and shall retain that
record, and any documents or
electronic files obtained
electronically, under paragraph (l) of
this section
procedures for protection of the
criminal history record and the
personal information from
unauthorized disclosure
Retain all fingerprint and criminal
history records received from the
FBI, or a copy if the file has been
transferred, on an individual
(including data indicating no record)

6

0.25

1.5

4

40.00

160.0

6

1.00

6.0

73.38(d)(5)(iv)(A)

73.38(d)(5)(vi)

73.38(f)(1)-(4)

73.38(f)(5)

E+5 Decreased based on change in transportation.
Interpreted from (l)(1) records.

A Added new line: Irradiated Fuel Shipments

E+5 Decreased based on change in transportation.
Interpreted from (f)(5).

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

73.38(j)

73.38(l)

73.46(b)(1)&(3)

Description of requirement

Develop, implement, and maintain
written procedures for conducting
background investigations for
persons who are applying for
unescorted access or access
authorization for spent nuclear fuel in
transit.
Retain documentation regarding the
trustworthiness and reliability of
individual employees
Security implementing procedures

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

6

40.00

240.0

6

0.25

1.5

2

80.00

160.0

73.46(b)(4),(7),(8) &
73.46(b)(11)(i)

Documentation of qualification and
requalification of Tactical Response
Team members, armed response
person, guard, or other members of
the security organization

2

33.00

66.0

73.46(b)(9)

Document the results of all training
exercises for the security force.

2

36.00

72.0

73.46(b)(10)(iii) &
73.46(b)(11)(iii)

Records of medical examination for
Tactical Response Team members,
armed response personnel, and
guards

2

150.00

300.0

Retention
period

Notes

5.0 No change from 2018 response. 5 years after the
procedure is no longer needed, 5 years after the
license is terminated. If any portion of the
procedure is supersceded, the supersceded
material is retained for 5 years. (the retentin period
is interpreded from (l)(2)).
E+5 No change since the 2018 review.

L + 2 years for Increased due to personal NRC staff observation
superceded at a CAT I site.
records
Q/R+3 MOX doesn't do this yet

3.0 MOX doesn't do this yet. (73.46(b)(9), refers to
Section (i)(2)(ii), which is no longer in the
regulation. The intent of (b)(9) is to refer to (i)(2).
Therefore administrative rule change will be
processed in CY2021 to change reference of
(i)(2)(ii) in (b)(9) to (i)(2)). Changed Hours per
recordkeeper from 1 to 3, due to 3 exercises being
documented per year.
3.0 Increased due to annual requirement for medical
certification for approximately 150 security staff.

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

73.46(b)(12)(ii)

Annual medical examination
including a determination and written
certification by a licensed physician

2

0.00

0.0

73.46(d)(10)

Records of containers that are
containers of contaminated wastes
must be drum scanned and tamper
sealed
Verify and certify the content of each
shipping container through the
witnessing of gross weight
measurements and nondestructive
assay, and through the inspection of
tamper seal integrity and associated
seal records

2

63.75

127.5

3.0 Same as last renewal period.

2

42.50

85.0

3.0 Same as last renewal period.

Maintain a log of individuals escorted
in the protected area (include name,
date, time, purpose of visit and
employment affiliation, citizenship,
and name of the individual to be
visited).
Annual security program review at
Category I fuel cycle facilities
Establish and document response
arrangements that have been made
with local law enforcement
authorities.
Documentation of qualification and
requalification of armed response
person, guard, or other members of
the security organization

2

51.00

102.0

3.0 Same as last renewal period.

2

40.00

80.0

3.0 Same as last renewal period.

3

0.50

1.5

0

0.64

0.0

73.46(d)(11)

73.46(d)(13)

73.46(g)(6)
73.46(h)(2)

73.50(a)(4)

3.0 Decreased due to assumptions that licensees
exercise 73.46(b)(10)(iii) and 73.46(b)(11)(iii).

L+3 years for No of recordkeepers are only 2 because BWXT
supersceded and NFS (both CAT I sites).
Q/R+3 No licensees performing work that fall under this
requirement

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

73.50(c)(5)

73.50(g)(2)

73.51(d)(12)

73.54(b)(1); 73.54(e) &
(f); 73.55(b)(8);
73.55(c)(6);
75.55(b)(7);
73.55(c)(1)&(3);
73.55(e)(1)&(2);
73.55(e)(8)(iv);
73.55(k)(5)&(6);
73.55(l)(3); 73.55(n)(1);
73.55(o)
73.55(b)(6); 73.55(c)(4);

Description of requirement

Maintain a log of individuals escorted
in the protected area (include name,
date, time, purpose of visit and
employment affiliation, citizenship,
and name of the individual to be
visited).
Establish and document response
arrangements that have been made
with local law enforcement
authorities.
Physical protection program review
must include an evaluation of the
effectiveness of the physical
protection system and a verification
of the liaison established with the
designated response force or LLEA.

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

0

1.60

0.0

3.0 No changes since the 2018 report, because there
are no licensees performing work that fall under
this requirement.

0

0.02

0.0

L No changes since the 2018 report, because there
are no licensees performing work that fall under
this requirement.

80

8.00

640.0

3.0 Increased to updated number of specific-licensed
ISFSIs. The retention requirement is in
73.51(d)(13)

Establish and maintain a cyber
security plan

56

80.00

4480.0

Physical Security Plan

56

80.00

4480.0

Training and Qualification Plan

56

80.00

4480.0

L+3 years for
superceded
records
L+3 years for
superceded
records

Decreased recordkeepers because NPPs decreased
and increased hours per recordkeepers due to the
magnitude of the work.
Decreased recordkeepers because NPPs decreased.

L+3 years for Decreased recordkeepers because NPPs decreased.
superceded
records

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

73.55(b)(11)& 73.58(b)

73.55(c)(5)

73.55(c)(7); 73.55(f);
73.55(k)(8); 73.55(l)(3);
73.55(n)(1), 73.56(l);
73.56(m)(4)
73.55(g)(6)(i)(B)

73.55(g)(6)(ii)(C)

73.55(g)(6)(iii)

Description of requirement

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

Assess and manage the potential for
adverse effects on safety and
security, including the site
emergency plan, before
implementing changes to plant
configurations, facility conditions, or
security
Safeguards Contingency Plan

56

96.00

5376.0

3.0 Decreased recordkeepers because NPPs decreased.

56

40.00

2240.0

Security implementing procedures

56

40.00

2240.0

L+3 years for Decreased recordkeepers because NPPs decreased.
superceded
records
L+3 years for Decreased recordkeepers because NPPs decreased.
superceded
records

Maintain a record, to include name
and affiliation, of all individuals to
whom access control devices have
been issued
Maintain a record, to include the
name and areas to which unescorted
access is granted, of all individuals to
whom photo identification badges
have been issued

56

48.00

2688.0

Annually Decreased recordkeepers because NPPs decreased.

56

48.00

2688.0

3.0 Decreased recordkeepers because NPPs decreased.

Access authorization program
personnel shall be issued passwords
and combinations to perform their
assigned duties

56

165.00

9240.0

3.0 Decreased recordkeepers because NPPs decreased.

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

73.55(g)(7)(i)(C)

Maintain a visitor control register in
which all visitors shall register their
name, date, time, purpose of visit,
employment affiliation, citizenship,
and name of the individual to be
visited before being escorted into
any protected or vital area

56

90.00

5040.0

3.0 Decreased recordkeepers because NPPs decreased.

73.55(i)(4)(ii)(H)

Maintain a record of all alarm
annunciations, the cause of each
alarm, and the disposition of each
alarm
Document and maintain current
agreements with applicable law
enforcement agencies to include
estimated response times and
capabilities.
Security program reviews.

56

48.00

2688.0

3.0 Decreased recordkeepers because NPPs decreased.

56

10.00

560.0

3.0 Decreased recordkeepers because NPPs decreased.

56

1380.00

77280.0

3.0 Decreased recordkeepers because NPPs decreased.

6

1.00

6.0

3.0 Decreased recordkeepers because NPPs decreased.

56

0.25

14.0

L Decreased recordkeepers because NPPs decreased.

73.55(k)(9)

73.55(b)(10); 73.55(m);
73.55(q)(4)
73.55(p)(1)&(3)

73.55(q)(3)

The suspension of security
measures must be reported and
documented in accordance with the
provisions of § 73.71
If a contracted security force is used
to implement the onsite physical
protection program, the licensee’s
written agreement with the contractor
must be retained by the licensee as a
record for the duration of the contract

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

73.56(a)(4)

73.56(d)
73.56(e)

73.56(f)
73.56(i)

73.56(j)

73.56(k)

Description of requirement

Licensees and applicants shall certify
individuals' unescorted access
authorization and are responsible to
maintain, deny, terminate, or
withdraw unescorted access
authorization
Backgroung investigation - multiple
parts
Psychological assessment to assist
in verifying trustworthiness and
reliability
Behavioral observation training and
testing
Annual Supervisory Review to assist
in verifying trustworthiness and
reliability
List of individuals who are authorized
to have unescorted access to
specific nuclear power plant vital
areas during non-emergency
conditions
Trustworthiness and reliability of
background screeners and access
authorization program personnel

No. of
Recordkeepers

Hours per
recordkeeper

0

8.00

Total Annual
Burden
Hours
0.0

Retention
period

Notes

A This is the initial requirement which has been completed
by all current licensees.

56

1837.50

102900.0

A+5 Decreased recordkeepers because NPPs decreased.

56

245.00

13720.0

A+5 Decreased recordkeepers because NPPs decreased.

56

24.00

1344.0

3.0 Decreased recordkeepers because NPPs decreased.

56

1455.00

81480.0

A Decreased recordkeepers because NPPs decreased.

56

24.00

1344.0

A Decreased recordkeepers because NPPs decreased.

56

40.00

2240.0

L Decreased recordkeepers because NPPs decreased.

73.56(m)

Establish and maintain a system of
files and procedures to ensure
personal information is not disclosed
to unauthorized persons

56

24.00

1344.0

L Decreased recordkeepers because NPPs decreased.

73.56(m)(1)

Signed consent from the subject
individual that authorizes the
disclosure of any information
collected

56

3.00

168.0

3.0 Decreased recordkeepers because NPPs decreased.

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

73.56(n)(1),(2), &(6)

73.57(e)(1)

73.57(f)

73.67(e)(3)(iv)

73.70(a)

73.70(b)

Description of requirement

Access Authorization Program Audits
Prior to any final adverse
determination, the licensee shall
make available to the individual the
contents of records obtained from
the FBI for the purpose of assuring
correct and complete information.
Confirmation of receipt by the
individual of this notification must be
maintained.
Procedures for protection of the
criminal history record and the
personal information from
unauthorized disclosure

Establish and maintain written
response procedures for dealing with
threats of thefts or thefts of this
material.
Record of currently designated
authorized individuals

Names, addresses, and badge
numbers of all individuals authorized
to have access to vital equipment or
special nuclear material, and the vital
areas and material access areas to
which authorization is granted

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

56

88.50

4956.0

3.0 Decreased recordkeepers because NPPs decreased.

5

0.25

1.3

114

40.00

4560.0

A Overall decrease because hours changed to
match maintenance of procedures of other
requirements. Initial development is complete for
all current licensees so removed that burden.
Recoerdkeepers updated - NPPs sites (56), NPRs
(31), FCFs (7); Decom (20)

6

40.00

240.0

L+3 and Added Roman numeral (iv) in the section number.
superceded +3 Changed P+3 to L+3 and superceded +3

65

7.00

455.0

65

7.00

E+1

L+3 and Changed from P+3 to L+3 and superceded+3
superceded +3 Decreased due to updated numbers of licensees
that fall into this category (this is assuming that the
numbers that addup are greater than 67) - NPP
sites (56) and FCFs (7)
455.0
PER+3 and Increased due to updated numbers of licensees
superceded+3 that fall into this category (this is assuming that the
numbers that add up are greater than 67) - NPP
sites (56) and FCFs (7)

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

73.70(d)

Log indicating name, badge number,
time of entry, and time of exit of all
individuals granted access to a vital
area except those individuals
entering or exiting the reactor control
room

63

50.00

3150.0

PER+3 Decreased due to updated numbers of licensees
that fall into this category - NPPs (56) and FCFs
(7)

73.70(e)

Documentation of all routine security
tours and inspections, and of all
tests, inspections, and maintenance
performed on physical barriers,
intrusion alarms, communications
equipment, and other security related
equipment used pursuant to the
requirements of this part

63

60.00

3780.0

PER+3 Decreased due to updated numbers of licensees
that fall into this category - NPPs (56) and FCFs
(7)

73.70(f)

A record at each onsite alarm
annunciation location of each alarm,
false alarm, alarm check, and tamper
indication that identifies the type of
alarm, location, alarm circuit, date,
and time.

63

700.00

44100.0

PER+3 Increased due to updated numbers of licensees
that fall into this category - NPPs (56) and FCFs
(7)

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Description of requirement

73.70(g)

Shipments of special nuclear
material subject to the requirements
of this part, including names of
carriers, major roads to be used,
flight numbers in the case of air
shipments, dates and expected times
of departure and arrival of
shipments, vertification of
communication equipment on board
the transfer vehicle, names of
individuals who are to communicate
with the transport vehicle, container
seal descriptions and identification,
and any other information to confirm
the means utilized to comply with §§
73.25, 73.26, and 73.27.

73.70(h)

73.71(c)

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

Retention
period

Notes

0

4.00

0.0

3.0 No licensees performing work that fall under this
requirement.

Procedures for controlling access to
protected areas and for controlling
access to keys for locks used to
protect special nuclear material.

63

40.00

2520.0

L and Decreased due to updated numbers of licensees
superceded +3 that fall into this category - NPPs (56) and FCFs
(7)

Maintain a current log and record the
safeguards events described in
paragraphs II(a) and (b) of appendix
G

94

450.00

42300.0

3.0 Decreased recordkeepers due to updated
numbers of licensees that fall into this category NPPs (56), NPRs (31), FCFs (7);
Decreased hours based on discussion with
previous security officers: 7-10 hours per week is
a conservative average for how much time is spent
maintaing the log for 73.71(c) Safeguards Events.
The average comes out to about 450.

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

73.77(b)

73.77(d)(12)

Appendix B Section VI
B.4.a.1.

Description of requirement

24 hour cyber security recordable
event
Maintain a copy of the written
security follow-up report of a cyber
security event notifiation
Obtain and retain a written
certification from the licensed
physician that no medical conditions
were disclosed by the medical
examination that would preclude the
individual’s ability to participate in the
physical fitness tests

No. of
Recordkeepers

Total Annual
Burden
Hours

Retention
period

Notes

56

4.50

252.0

56

4.50

252.0

56

8.00

448.0

PER Decreased recordkeepers because NPPs decreased.

40.00

2240.0

3.0 Decreased recordkeepers because NPPs decreased.

Appendix B Section VI
B.4.b.4.

Physical fitness qualification of each
armed member of the security
organization must be documented by
a qualified training instructor and
attested to by a security supervisor

56

Appendix B Section VI
C.2.(b).

On-the-job training must be
documented by a qualified training
instructor and attested to by a
security supervisor (Hours per
recordkeeper is based on a min of 40
hours of OJT)
Performance Evaluation Program
Documentation

56

Appendix B Section VI
C.3.g; Appendix B,
Section VI.C.3.h;
Appendix B, Section
VI.C.3.i; Appendix B,
Section VI.C.3.m;

Hours per
recordkeeper

Numberof recordkeepers decreased due to decrease in
NPPs.
PER+3 or L Decreased recordkeepers because NPPs decreased.

Retention is in VI. H.3.

13.33

746.5

3.0 Decreased recordkeepers because NPPs decreased.
Increased hours per per recordkeepers. Calculations for
Hours per recordkeeper are calculated considering 6
new hires every 3 years @ 6.67 hours per
documentation (6*6.67=40\3=13.33

56

40.00

2240.0

3.0 Decreased recordkeepers because NPPs decreased.

Retention Period Column Key:
"A" = Annual // "E" = Term of Employment // "L" =
Life of License // "P" = Physical Protection Plan
(PPP) // "PER" = Period Requiring Record // "Q" =
Qualification // "R" = Requalification // "S" =
Safeguards Contingency Plan (SCP) // "+" = The
added number of years for retention after the
record is made (e.g., P+3 years, S+3 years, A+1
year)

Table 2
10 CFR Part 73 Annual Recordkeeping Burden

Section

Appendix B Section VI
E.1.(b).

Appendix B Section VI
F.1.b; Appendix B
Section VI F.5.a
Totals

Description of requirement

Each armed member of the security
organization shall be trained and
qualified by a certified firearms
instructor for the use and
maintenance of each assigned
weapon
Results of weapons qualification and
requalification must be documented
and retained as a record

No. of
Recordkeepers

Hours per
recordkeeper

Total Annual
Burden
Hours

56

12.50

700.0

56

96.00

5376.0

210

451787.6

Retention
period

Notes

3.0 Decreased recordkeepers because NPPs decreased.

3.0

Description of requirement

73.22(d) and (f)

Marking Safeguards Information and
Preparing document for external
transmission
Marking SGI-M and Preparing document
for external transmission

169

31

0

0.0

0

0.0

Inform local law enforcement agencies of
abnormal presence or activity of persons
or vehicles
the personnel in the remote location shall
request assistance from the law
enforcement authorities, notify the
shipment movement control center and
initiate the appropriate contingency plans.

0

0

0.0

0.25

0.0

0

1

0.0

4

0.0

73.26(i)(6) and (k)(4) - (No
notifications anticipated in the next 3
years)

In the event that no communication is
received from the shipment or escort
personnel at a designated call-in time, the
licensee must notify law enforcement
authorities immediately and initiate
appropriate contingency plans. Applies to
both road and rail shipments.

0.00

0.00

0.00

1.00

0.00

73.27(a)(1)

notify the consignee of the time of
departure of the shipment
written certification from the licensee who
is to take delivery of the shipment
notify the consignee of the arrival of the
shipment
notify the person who delivered the
material to a carrier for transport of the
arrival of the shipment
Preplan and coordinate shipment
itineraries with the reciever. Must obtain
approval from the NRC for the routes to
be used.

0

0

0.0

1

0.0

73.37(b)(1)(v)

Arrange with local law enforcement for
response for route used.

73.37(b)(1)(iv)

Preplan and coordinate shipment
information no later than 2 weeks prior to
the shipment or prior to the first shipment
of a series of shipments with the
governor of a State
Advanced notification of shipment. Notify
the NRC and State(s) prior to the
shipment of SNF within or through a
State. notify the Tribal official or Tribal
official’s designee of each participating
Tribe referenced in 10 CFR 71.97(c)(3)
prior to the transport of spent fuel within
or across the Tribal reservation.

73.23(d) and (f)
73.26(e)(2)

73.26(f)(2)

No. of
Respondents

Table 3
10 CFR Part 73, Annual Third Party Disclosure Burden
Responses
Responses
Burden per
Total burden hours
per
response
respondent
5
845.0
1
845.0

Section

Notes
Decreased due to changing types of licensees. Most
licensees have chosen to maintain documents at the
SGI level instead of SGI-M; Moved majority of the
SGI-M numbers to SGI.
No licensees performing work that fall under this
requirement.
0
No licensees performing work that fall under this
requirement.

0

73.27(a)(2)
73.27(a)(3)
73.27(b)

73.37(b)(1)(ii)&(vi)

No licensees performing work that fall under this
requirement.

This reports to 3rd party
and NRC… should it be
in both? Does one take
precedence? Does it
even matter since the
amount is 0?

0
0

0

0.0

1

0.0

0

0

0.0

0.5

0.0

0

0

0.0

0.5

0.0

4

20

80.0

1

80.0

4

20

80.0

1

80.0

0
0

No licensees performing work that fall under this
requirement.
No licensees performing work that fall under this
requirement.
No licensees performing work that fall under this
requirement.
No licensees performing work that fall under this
requirement.

0
Decreased based on change in transportation.

80
Added line because the line immediately above this
had a description of requirement that included the
required coordination with local law enforcement.
80

73.37(b)(2)(i-iii)

73.37(b)(2)(iv)

73.37(b)(2)(v)

73.37(f)

Revision notice. Licensee shall notify by
telephone a responsible individual in the
office of the governor of any schedule
change that differs by more than 6 hour
Each licensee who cancels a shipment
for which advance notification has been
sent shall send a cancellation notice to:
the governor or to the governor's
designee of each State previously
notified, each Tribal official or the Tribal
official's designee previously notified and
the NRC
Investigations of lost unaccounted for
after designated no-later-than arrival
time.

Decreased based on change in" transportation.
4

6

24.0

3

72

Decreased based on change in transportation.

4

6

24.0

1

24

4

15

60.0

0.25

15

Decreased based on change in transportation.

4

5

0

20.0

0.00

6.6

Removed "and", added a "::, and added "and the
NRC to the description of requirement for clarity.

0.0

Added line that was deleted from last review.
Estimated burden hours to 4.

0.33

0.0

4.0

Section

Description of requirement

73.38(d)(1)

Licensees shall not initiate any element of
a background investigation without the
informed and signed consent of the
subject individual.
Any individual who is required to have a
background investigation under this
section shall disclose the personal history
information that is required by the
licensee's access authorization program
for the reviewing official to make a
determination of the individual's
trustworthiness and reliability.

73.38(d)(2)

73.38(i)

73.46(h)(4)(iii)(B) (Emergency
notification - never used)

73.50(g)(3)(iii)(B) (Emergency
notification - never used)

73.55(g)(7)(i)(C)

73.55(k)(8)(iii)

73.55(p)(1)

73.56(d)

73.56(e)

73.56(f)

Any individual who has applied for or is
maintaining access authorization shall
promptly report any legal action(s) taken
by a law enforcement authority or court of
law that could result in incarceration or a
court order or that requires a court
appearance. The licensee shall inform
the individual of this obligation, in writing,
prior to granting unescorted access or
certifying access authorization
Upon detection of abnormal presence or
activity of persons or vehicles within an
isolation zone, a protected area, a
material access area, or a vital area,
licensee shall inform local law
enforcement agencies of the threat and
request assistance
Upon detection of abnormal presence or
activity of persons or vehicles within an
isolation zone, a protected area, a
material access area, or a vital area,
licensee shall inform local law
enforcement agencies of the threat and
request assistance
Maintain a visitor control register before
being escorted into any protected or vital
area
Upon receipt of an alarm or other
indication of a threat, the licensee shall
notify law enforcement agencies.
The suspension of security measures
must be reported and documented in
accordance with the provisions of § 73.71
Licensees, applicants, and contractors or
vendors shall not initiate any element of a
background investigation without the
informed and signed consent of the
subject individual.
ensure that a psychological assessment
has been completed before the individual
is granted unescorted access or certified
unescorted access authorization.
each person subject to the behavior
observation program to report any
concerns arising from behavioral
observation.

No. of
Respondents

4

Table 3
10 CFR Part 73, Annual Third Party Disclosure Burden
Responses
Responses
Burden per
Total burden hours
per
response
respondent
4.0
2.0
1

Decreased based on change in transportation.

0.5
4.0

4

Notes

1

2.0

Decreased based on change in transportation.

0.0

Totlal burden hours remains the same as the 2018
review.

Totlal burden hours remains the same as the 2018
review.

0.5

0.0

4

0

0.5

2

0

0.0

0.25

0.0

0

0

0.0

0.25

0.0

56

1320.3

73,937.0

0.1

7,393.7

56

1

56.0

0.25

14.0

5

2

10.0

0.5

5.0

56

16.2

907.0

6.75

6,122.3

56

2.5

140.0

2.25

315.0

56

10

560.0

0.1

56.0

0
No licensee falls under this information.

0

7,394

14

Decreased due to fewer NPPs than in 2018. Decreased
respondents because NPPs decreased. Changed No. of
respondents from 60 to 56.
Decreased due to fewer NPPs than in 2018. Decreased
respondents because NPPs decreased. Changed No. of
respondednts from 60 to 56.
This is a weather influenced suspencion.

5
Decreased respondents because NPPs decreased.

6,122
Decreased respondents because NPPs decreased.

315
Decreased respondents because NPPs decreased.

56

Section
73.56(g)

73.56(m)(2)

73.57(b)(3)

73.57(e)

Description of requirement

Any individual who has applied for or is
maintaining unescorted access shall
promptly report any legal action(s) taken
by a law enforcement authority or court of
law that could result in incarceration or a
court order or that requires a court
appearance. The licensee shall inform
the individual of this obligation, in writing,
prior to granting unescorted access or
certifying access authorization

No. of
Respondents
56

Table 3
10 CFR Part 73, Annual Third Party Disclosure Burden
Responses
Responses
Burden per
Total burden hours
per
response
respondent
17.8
997.0
0.1
99.7

Decreased respondents because NPPs decreased.

100
56

1

56.0

0.5

28.0

licensee shall notify each affected
individual that the fingerprints will be used
to secure a review of his/her criminal
history record, and inform the individual
of proper procedures for revising the
record or including explanation in the
record
licensee shall make available to the
individual the contents of records
obtained from the FBI for the purpose of
assuring correct and complete
information

120

50

6,000.0

0.5

3,000.0

120

50

6,000.0

0.5

3,000.0

Where potential conflicts are identified,
the licensee shall communicate them to
appropriate licensee personnel and take
compensatory and/or mitigative actions to
maintain safety and security under
applicable Commission regulations,

56

12

672.0

1

672.0

10

18.5

185.0

2

370.0

0

0

0.0

0.5

0.0

All information pertaining to a denial or
unfavorable termination of the individual's
unescorted access or unescorted access
authorization shall be promptly provided,
upon receipt of a written request by the
subject individual or his or her designated
representative as designated in writing.

Notes

Decreased respondents because NPPs decreased.

28
Increased due to updated numbers of licensees that
fall into this category - NPPs (56), NPRs (31), FCFs
(7); Decom (20); Irradiated Fuel Shipments ( 6)

3,000
Increased due to updated numbers of licensees that
fall into this category - NPPs (56), NPRs (31), FCFs
(7); Decom (20); Irradiated Fuel Shipments ( 6)

3,000
73.58(d)

73.67(e)(1)(i)

73.67(e)(6)(ii)

73.67(g)(1) and(2)

Provide advance notification to the
receiver of any planned shipments
specifying the mode of transport,
estimated time of arrival, location of the
nuclear material transfer point, name of
carrier and transport identification
Notify the exporter who delivered the
material to a carrier for transport of the
arrival of such material
Provide advance notification to the
receiver of any planned shipments
specifying the mode of transport,
estimated time of arrival, location of the
nuclear material transfer point, name of
carrier and transport identification; Notify
the shipper of receipt of the material

Decreased respondents because NPPs decreased.

672
No change since 2018.

370
No import of CAT II licensees.
0
21.0

6

3.5

4

84.0

Decreased based on change in transportation.

84

Section
73.67(g)(3)(ii)

73.67(g)(5)(ii)

TOTAL

Description of requirement

Make arrangements to be notified
immediately of the arrival of the shipment
at its destination, or of any such shipment
that is lost or unaccounted for after the
estimated time of arrival at its destination
Notify the person who delivered the
material to a carrier for transport of the
arrival of such material

No. of
Respondents
6

6

Table 3
10 CFR Part 73, Annual Third Party Disclosure Burden
Responses
Responses
Burden per
Total burden hours
per
response
respondent
21.0
1
21.0

3.5
1.75

Notes
Decreased based on change in transportation.

21
11.0

1

11.0

Decreased based on change in transportation.
21,341

89,869.0

21,473.3

$5,954,139.00

Reporting
Recordkeeping
Third Party Disclosure
Total

2021 BURDEN TOTALS
Responses
Hours
Cost at $263/hr
40,889.0
22,631.0 $ 5,951,951
210.0
451,787.6 $ 118,820,126
89,869.0
21,473.3 $ 5,647,465
130,968.0
495,891.8 $ 130,419,542

Recordkeeping costs
Fingerprint submission
Total other costs

$
$
$

50,419
502,550
552,969

Costs to the government

$

1,183,500

Reporting
Recordkeeping
Third Party Disclosure
Total

BURDEN CHANGE
Current burden in ROCIS
2021 estimates
Change
Hours
Responses
Hours
Responses
Hours
Responses
22,591
40,819
22,631
40,889
40
70
475,852
210
451,788
210
(24,064)
42,963
136,957
21,473
89,869
(21,490)
(47,088)
541,406
177,986
495,892
130,968
(45,514)
(47,018)