Burden Spreadsheet for Part 34

Part 34 Burden Tables 3102023.docx

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

Burden Spreadsheet for Part 34

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TABLE 1

ANNUAL REPORTING BURDEN OF 10 CFR PART 34



NRC LICENSEES

Section

Description

Number of Respondents

Responses per
Respondent

Total Responses/year

Burden hours/response

Total Burden hour/year

Cost at $290/hour

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

0

1

0

40

0

$0

34.27(d)

Report within 5 days results of leak testing which indicates that a source is leaking

0

1

0

4

0

$0

34.41(c)

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.

0

1

0

20

0

$0

34.101(a)&(b)

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

24

1

24

10

240

$69,600

34.101(c)

Requires notification prior to conducting radiographic operations or storing radioactive material in excess of 180 days at any location not listed on the license

0

1

0

0.5

0.0

$0

Appendix A, Part I, Item 12

Requires independent certifying organizations and/or Agreement States to exchange information about certified individuals with the Commission and the Agreement States

0

6

0

0.5

0

$0

TOTAL

 

24


24


240

$69,600



AGREEMENT STATE LICENSEES

Section

Description

Number of Respondents*

Responses
per Respondent

Total Responses/year

Burden hours/response

Total Burden hour/year

Cost at $290/hour

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

45

1

45

40

1,800

$522,000

34.27(d)

Report within 5 days results of leak testing which indicates that a source is leaking

0

1

0

4

0.00

$0

34.41(c)

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

74

1

74

20

1,480

$429,200

34.101(a)&(b)

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

28

1

28

10

280

$81,200

34.101(c)

Requires notification prior to conducting radiographic operations or storing radioactive material in excess of 180 days at any location not listed on the license

28

1

28

0.5

14

$4,060

TOTAL

 

175


175


3,574

$1,036,460







TABLE 2

ANNUAL RECORDKEEPING REQUIREMENTS OF 10 CFR PART 34



NRC LICENSEES

Section

Description

Number of
Recordkeepers

Burden
hours/ Recordkeeper

Total
hour/year

Record
Retention Period

34.25(b)&(c)

Radiation survey instrument calibration & records thereof

Included in 34.65

34.27(c)(1)&(2)

Sealed source leak testing & records thereof

Included in 34.67

34.27(e)

“S” tube leak testing & records thereof

Included in 34.67

34.29(a)&(b)

Sealed source inventories & records thereof

Included in 34.69

34.31(a)&(b)(1)&(2)&(c)

Licensee’s program for inspection and maintenance

Included in 34.73

34.42(a)

Completion of the training and testing requirements of § 34.43(a)

66

4

264

license termination

34.42(c)(1)

RSO establishes, oversees, and regularly reviews all operating, emergency, and ALARA procedures as required

66

8

528

license termination

34.42(c)(2)

RSO oversees and approves all phases of the training program for radiographic personnel

66

16

1,056

license termination

34.42(c)(3)

RSO ensures that required radiation surveys and leak tests are performed and documented in accordance with the regulations, including any corrective measures when levels of radiation exceed established limits

66

8

528

license termination

34.42(c)(4)

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

66

16

1,056

license termination

34.42(c)(5)

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

66

8

528

license termination

34.33(b)

Tests of controls and alarms at permanent radiographic installations and records thereof

Included in 34.75

34.43(f)

Records of training, examinations, refresher safety training, and semiannual inspections of job performance

Included in 34.79

34.45(a)&(b)

Program for routine operations and emergencies for employees to follow in performing safety functions & copies of procedures

Included in 34.81

34.47(b)

Read and record exposure on direct reading
dosimeters; maintain records

Included in 34.83(a)

34.47(c)

Periodic check of pocket dosimeters or electronic dosimeters for correct response to radiation; maintain records

Included in 34.83(a)

34.47(d)

Determination of exposure if an individual's pocket dosimeter goes off-scale

Included in 34.83(d)

34.47(e)

Requirements if a personnel dosimeter is lost or damaged

Included in 34.83(d)

34.47(f)

Requirement to maintain reports received from personnel dosimeter processors

Included in 34.83(c)

34.47(g)(4)

Calibrate alarm ratemeters; maintain records

Included in 34.83(b)

34.49(c)&(d)

Surveys of radiographic exposure device & records thereof

Included in 34.85

34.61

Licensee to have a copy of the license, license conditions, documents incorporated by reference, and all amendments

66

0.16

10.56

license termination

34.63

Maintain records showing receipts and transfers of sealed sources and devices using DU shielding

66

1.6

105.60

3 Years

34.65

Maintain records of calibrations of radiation survey
instruments

66

1.6

105.60

3 Years

34.67

Maintain records of leak test results

66

1.2

79.20

3 Years

34.69(a)&(b)

Maintain records of quarterly inventories of sealed sources and devices containing DU shielding & include specific information concerning such inventories

66

2

132

3 Years

34.71(a)&(b)

Maintain utilization logs for each sealed radioactive source & records thereof

66

36

2,376

3 Years

34.73(a)&(b)

Maintain records of equipment problems and maintenance

66

27

1,782

3 Years

34.75

Maintain records of alarm system and entrance control device tests at permanent radiographic installations

11

48.2

530.20

3 Years

34.79(a)&(b)

Maintain records of training of radiographers and radiographers' assistants in accordance with §34.43(f)

66

5

330

3 Years

34.81

Retain records of current operating and emergency procedures specified in § 34.45

66

0.08

5.28

license termination

34.83(a)

Maintain exposure records for direct reading dosimeters

66

122.5

8,085

3 Years

34.83(b)

Maintain records for alarm ratemeter calibrations

66

2.5

165

3 Years

34.83(c)&(d)

Maintain records for reports from personnel dosimeter processor & for estimates of exposures resulting from off- scale or lost or damaged dosimeters

66

3

198

3 Years

34.85

Maintain record of last survey of each radiographic exposure device on each day used prior to placing device in storage

66

120

7,920

3 Years

34.87

Maintain each record in a legible form

66

0

0

life of program

34.89(a)&(b)

Maintain copies of records sufficient to demonstrate compliance at field stations and temporary job sites

66

5

330

license termination

Note: Section 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.

Appendix A, Part I, item 6

ICO written by laws and policies

1

10

10

life of program

Appendix A, Part I, item 9

ICO written procedures describing its certification program

1

70

70

life of program

Appendix A, Part I, item 10

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

1

10

10

life of program

Appendix A, Part I, item 11

ICO procedures for proctoring examinations

1

10

10

life of program

Appendix A, Part I, item 13

ICO description of procedures for choosing
examination sites and for providing an appropriate examination environment

1

10

10

life of program

Appendix A, Part II, item 2

CP required to provide documentation demonstrating that radiography applicants have received training and are capable of independently working as a radiographer

1

38

38

life of program

Appendix A, Part II, item 3

CP includes procedures to ensure that all examination questions are protected from disclosure

1

10

10

life of program

Appendix A, Part II, item 4

CP includes procedures for denying an application, revoking, suspending, and reinstating a certificate

1

10

10

life of program

Appendix A, Part II, item 6

CP includes procedures for renewing certifications; renewals without examination require evidence of recent full-time employment and annual refresher training

1

10

10

life of program

Appendix A, Part II, item 7

CP provides timely response to inquiries from members of the public about an individual's
certification status

1

50

50

life of program

Appendix A, Part III, item 3

Written examinations have test items drawn from a question bank containing psychometrically valid questions based on the material in § 34.43(g)

1

120

120

life of program

TOTAL

 

66

 

26,462.44

 



AGREEMENT STATE LICENSEES

Section

Description

Number of Recordkeepers

Burden
hours/ Recordkeeper

Total
hour/year

Record
Retention Period

34.25(b)&(c)

Radiation survey instrument calibration & records thereof

Included in 34.65

34.27(c)(1)&(2)

Sealed source leak testing & records thereof

Included in 34.67

34.27(e)

“S” tube leak testing & records thereof

Included in 34.67

34.29(a)&(b)

Sealed source inventories & records thereof

Included in 34.69

34.31(a)&(b)(1)&
(2)&(c)

Licensee’s program for inspection and maintenance

Included in 34.73

34.33(b)

Tests of controls and alarms at permanent radiographic installations and records thereof

Included in 34.75

34.42(a)

Completion of the training and testing requirements of

§ 34.43(a)

482

4

1,928

license
termination

34.42(c)(1)

RSO establishes, oversees, and regularly reviews all
operating, emergency, and ALARA procedures as required by 10 CFR part 20 of this chapter

482

8

3,856

license termination

34.42(c)(2)

RSO oversees and approves all phases of the training program for radiographic personnel

482

16

7,712

license
termination

34.42(c)(3)

RSO ensures that required radiation surveys and leak tests are performed and documented in accordance with the regulations, including any corrective measures when levels of radiation exceed established limits.

482

8

3,856

license termination

34.42(c)(4)

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.

482

16

,7712

license termination

34.42(c)(5)

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

482

8

3,856

license termination

34.43(f)

Records of training, examinations, refresher safety training, and semiannual inspections of job performance

Included in 34.79

34.45(a)&(b)

Program for routine operations and emergencies for
employees to follow in performing safety functions & copies of procedures

Included in 34.81

34.47(b)

Read and record exposure on direct reading dosimeters; maintain records

Included in 34.83(a)

34.47(c)

Periodic check of pocket dosimeters or electronic dosimeters for correct response to radiation; maintain records

Included in 34.83(a)

34.47(d)

Determination of exposure if an individual's pocket dosimeter goes off-scale

Included in 34.83(d)

34.47(e)

Requirements if a personnel dosimeter is lost or damaged

Included in 34.83(d)

34.47(f)

Requirement to maintain reports received from personnel dosimeter processors

Included in 34.83(c)

34.47(g)(4)

Calibrate alarm ratemeters; maintain records

Included in 34.83(b)

34.49(c)&(d)

Surveys of radiographic exposure device & records
thereof

Included in 34.85

34.61

Licensee to have a copy of the license, license conditions, documents incorporated by reference, and all amendments

482

0.16

77.12

license termination

34.63

Maintain records showing receipts and transfers of sealed sources and devices using DU shielding

482

1.6

771.20

3 Years

34.65

Maintain records of calibrations of radiation survey instruments

482

1.6

771.20

3 Years

34.67

Maintain records of leak test results

482

1.2

578.40

3 Years

34.69(a)&(b)

Maintain records of quarterly inventories of sealed sources and devices containing DU shielding & include specific

482

2

964.00

3 Years

34.71(a)&(b)

Maintain utilization logs for each sealed radioactive source

482

36

17,352

3 Years

34.73(a)&(b)

Maintain records of equipment problems and maintenance

482

27

13,014

3 Years

34.75

Maintain records of alarm system and entrance
control device tests at permanent radiographic installations

77

48.2

3,711.40

3 Years

34.79(a)&(b)

Maintain records of training of radiographers and radiographers' assistants in accordance with § 34.43(f)

482

5

2,410

3 Years

34.81

Retain records of current operating and emergency procedures specified in § 34.45

482

0.08

38.56

license termination

34.83(a)

Maintain exposure records for direct reading dosimeters

482

122.5

59,045

3 Years

34.83(b)

Maintain records for alarm ratemeter calibrations

482

2.5

1,205

3 Years

34.83(c)&(d)

Maintain records for reports from personnel dosimeter processor & for estimates of exposures resulting from off-scale or lost or damaged dosimeters

482

3.2

1,542.40

3 Years

34.85

Maintain record of last survey of each radiographic exposure device on each day used prior to placing device

482

120

57,840

3 Years

34.87

Maintain each record in a legible form

482

0

0

life of program

34.89(a)&(b)

Maintain copies of records sufficient to demonstrate compliance at field stations and temporary job sites

482

5.4

2,602.80

license termination

Note: Section 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

Appendix A, Part II, item 2

CP required to provide documentation demonstrating that radiography applicants have received training and are capable of independently working as a radiographer

8

14

112

life of program

Appendix A, Part II, item 3

CP includes procedures to ensure that all examination questions are protected from disclosure

8

10

80

life of program

Appendix A, Part II, item 4

CP includes procedures for denying an application, revoking, suspending, and reinstating a certificate

8

10

80

life of program

Appendix A, Part II, item 6

CP includes procedures for renewing certifications; renewals without examination require evidence of recent full-time employment and annual refresher training

8

10

80

life of program

Appendix A, Part II, item 7

CP provides timely response to inquiries from members of the public about an individual's certification status

8

25

200

life of program

Appendix A, Part III, item 3

Written examinations have test items drawn from a question bank containing psychometrically valid questions based on the material in § 34.43(g)

1

120

120

life of program

TOTAL

 

482

 

191,515.08

 





TABLE 3

ANNUAL THIRD-PARTY DISCLOSURE REQUIREMENTS OF 10 CFR PART 34



NRC LICENSEES

Section

Description

Number of
Respondents

Responses
per
Respondent

Total
Responses/year

Burden
hours/response

Total Burden
hour/year

Cost at $290/hour

34.20(b)(1)

Labels on radiographic exposure devices

66

1

66

0.4

26.4

$7,656

34.35(a)

Requires durable, legible, and clearly visible label on source
changer or container that indicates whom to notify

66

1

66

0.8

52.80

$15,312

34.35(b)

Requires appropriate packaging, labeling, and shipping papers for transport of licensed material

66

1

66

36

2,376

$689,040

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

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

66

1

66

2.5

165

$47,850

TOTAL


66

 

264

 

2,620.20

$759,858







AGREEMENT STATE LICENSEES

Section

Description

Number of
Respondents

Responses per
Respondent

Total Responses/year

Burden
hours/response

Total Burden hour/year

Cost at $290/hour

34.20(b)(1)

Labels on radiographic exposure devices

482

1

482

0.4

192.80

$55,912

34.35(a)

Requires durable, legible, and clearly visible label on source changer or the storage container that is securely attached

482

1

482

0.8

385.60

$111,824

34.35(b)

Requires appropriate packaging, labeling, and shipping papers for transport of licensed material

482

1

482

36

17,3524

$5,032,080

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

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

482

1

482

2.5

1,2054

$349,450

TOTAL


482


1,928.00


19,135.40

$5,549,266



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