Burden spreadsheet for 10 CFR Part 37

FINAL Part 37 Burden tables.xlsx

10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material

Burden spreadsheet for 10 CFR Part 37

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Overview

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


Sheet 1: SUMMARY

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



139,109.1 138,570.2 (538.9)

Sheet 2: One-time Reporting


Part 37 Final rule 2015 Renewal BURDEN CHANGE NOTES
Section Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Notes
37.21(a)(3)









0 0 0 0 0
37.41(d)









0 0 0 0 0
37.23(b)(1) in PR, 37.23(b)(2) in FR 1,400 3 4,200 0.25 1,050 1,200 3 3,600 0.25 900 (200) 0 (600) 0 (150) Initial submittal of the reviewing official(s) names for the fingerprints requirement.
37.41(a)(3) 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 Requires any licensee that has not previously implemented the Security Orders or been subject to the provisions of subpart C to provide written notification to the NRC regional office at least 90 days before aggregating radioactive material to a quantity that equals or exceeds the 0.1category 2 threshold.
TOTAL 1,400 
4,201
1,051 1,200
3,601
901





ANNUALIZED TOTAL

1,400.3
350.3

1,200.3
300.3 0 0 (200) 0 (50)


















Explanation: Decrease in burden due to one-time reporting requirements. Only new licensees and remaining Agreement State licensees, who have not yet fulfilled this requirement, are required to develop access authorization and security procedures since existing NRC licensees were previously required to fulfill this requirement.







































320108
















83700
















403808

Sheet 3: Annual Reporting


Part 37 final rule 2015 renewal BURDEN CHANGE NOTES
Section Number of Respondents Responses per Respondnt Responses Burden per Response Total Burden Hours Number of Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Number of Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Notes
37.11(a) 1,400 0 0 1 0 1,500 0 0 1 0 100 0 0 0 0 No exemption applications anticipated
37.23(b)(1), modified to 37.23(b)(2) in FR Burden included in 37.27(a)(1) Burden included in 37.27(a)(1) 0 0 0 0 0 Burden included in 37.27(a)(1)
37.23(d)









0 0 0 0 0
37.25(c) 1,400 0 0 1 0 1,500 0 0 1 0 100 0 0 0 0 Reinvestigations are conducted every 10 years. Based on the date of issuance of orders, no submission will until 2017 (next clearance period), at which time the NRC estimates it will receive 68 responses per licensee annually.
37.27 (a)(1) 1,400 3 4,200 0.25 1,050 1,500 3 4500 0.25 1125 100 0 300 0 75 Fingerprinting requirement, burden captures reviewing officials & estimated 3 new employees per licensee annually.
37.27(c) Burden included in 37.27(a)(1) Burden included in 37.27(a)(1) 0 0 0 0 0 Burden included in 37.27(a)(1)
37.41(a)(2)









0 0 0 0 0
37.43(d)(3)(ii), Burden included in 37.27(a)(1) Burden included in 37.27(a)(1) 0 0 0 0 0 Burden included in 37.27(a)(1)
37.45(a)(2)&(5) in PR, 37.45(b)(1)&(2) in FR 0 0 0 0.25 0 0 0 0 0.25 0 0 0 0 0 0 Notify regional office on LLEA none response, none estimated
37.57(a) 3 1 3 0.25 0.75 3 1 3 0.25 0.75 0 0 0 0 0 Event notification
37.57(b) 100 1 100 0.25 25 110 1 110 0.25 27.5 10 0 10 0 3 Phone call of suspicious activity
37.57(c) 3 1 3 20 60 3 1 3 20 60 0 0 0 0 0 Written follow up report for notifications within 30 days
37.77(a)&(b) 16 21.88 350 1 350 16 21.88 350.08 1 350.08 0 0 0 0 0 Advance written notification of Category 1 shipments
37.77 (c), 16 2 32 0.25 8 16 2 32 0.25 8 0 0 0 0 0 Revision notification
37.77 (d) 16 0 0 0.25 0 16 0 0 0.25 0 0 0 0 0 0 Cancel notification
37.81(a), (b), (c), (d), (e), &(f) 3 1 3 0.25 0.75 3 1 3 0.25 0.75 0 0 0 0 0 Notification of lost/missing cat 1 & 2 materials and recovery
37.81(g)&(h) 3 1 3 20 60 3 1 3 20 60 0 0 0 0 0 Written report following 37.81(a)-(f)
TOTAL

4,694
1,554.50

5,004.1
1,632.1

310
78

Sheet 4: One-time 3rd Party


Part 37 final rule 2015 Renewal BURDEN CHANGE NOTES
Section Number of Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Number of Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Number of Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Notes
37.43(c) 1,400 1 1,400 2 2,800 1,200 1 1,200 2 2,400 -200 0 -200 0 -400 Training
37.45 (a)(b) 1,400 0 0 20 0 10 1 10 20 200 -1,390 1 10 0 200 Initial preparation and coordination with LLEA on security plan, this was already done under Orders (action complete). Remaining respondents account for new licensees who did not receive Orders.
TOTAL 1,400
1,400
2,800 1,200 0 1,210
2,600 -200 0 -190 0 -200
ANNUALIZED TOTAL

466.7
933.3

403.3
866.7

-63.3
-66.7


















Explanation: Burden change is due to one-time third-party notification requirements. New licensees, and remaining Agreement State licensees, who have not yet fulfilled this requirement, are required to develop access authorization and security procedures since existing NRC licensees were previously required to fulfill this requirement.







Sheet 5: Annual 3rd Party


Part 37 final rule 2015 renewal BURDEN CHANGE NOTES
Section Rspndnts Rsps. Per Respndt Responses Burden per Response Total Burden Hours Rspndnts Rsps. Per Respndt Responses Burden per Response Total Burden Hours Number of Respondents Responses per Respondent Responses Burden per Response Total Burden Hours Notes
37.11(c)(4) Burden captured in 37.57(a) Burden captured in 37.57(a) 0 0 0 0 0 Burden captured in 37.57(a)
37.23(c) Burden captured in 37.27(a)(2) Burden captured in 37.27(a)(2) 0 0 0 0 0 Burden captured in 37.27(a)(2)
37.23(d) 4,200 1 4,200 4 16,800 4,500 1 4,500 4 18,000 300 0 300 0 1,200 Employees providing personal history information
37.23(g)(1) 0 0 0 1 0 0 0 1 0 0 0 0 0 0 Notification of employees that they have the right to correct and complete information. No responses anticipated
37.27(a)(2) 1,400 3 4,200 0.1 420 1,500 3 4,500 0.1 450 100 0 300 0 30 Notify each individual how their fingerprints will be used.
37.43(c) 1,400 1 1,400 1 1,400 1,500 1 1,500 1 1,500 100 0 100 0 100 Training
37.45(a)(1)&(2), (d) 1,400 1 1,400 3 4,200 1,500 1 1,500 3 4,500 100 0 100 0 300 Annual LLEA coordination
37.45(b)(1) & (2)






0
0 0 0 0 0 0
37.49(d) 0 0 0  0.1 0 0 0 0 0.1 0 0 0 0 0 0 Request armed response from LLEA- burden in 37.45(a)(10). none anticipated
37.57(a) 3 1 3 0.25 0.75 3 1 3 0.25 1 0 0 0 0 0 Event notification
37.57(b) 100 1 100 1 100 110 1 110 1 110 10 0 10 0 10 Notify ops center with 4 hrs of suspicious activity
37.75(a)(1) 16 21.88 350 0.5 175 16 21.88 350 0.5 175 0 0 0 0 0 Pre-planning and coordination of Category 1 shipping with receiving licensee
37.75(a)(2) 16 218.75 3,500 0.25 875 16 218.75 3,500 0.25 875 0 0 0 0 0 Pre-planning and coordination with States thru which shipment passes of Category 1 Shipments
37.75(b) 400 75 30,000 0.5 15,000 530 75 39,750 0.5 19,875 130 0 9,750 0 4,875 Pre-planning and coordination of Category 2 shipping with receiving licensee
37.75(c) 400 75 30,000 0.08 2,400 530 75 39,750 0.08 3,180 130 0 9,750 0 780 Notification of shipping licensee upon receipt on Category 2 shipments
37.75(d) 100 3 300 0.16 48 110 3 330 0.16 53 10 0 30 0 5 Change in arrival time
37.77(a)&(b) 16 21.88 350 4 1,400 16 21.88 350 4 1,400 0 0 0 0 0 Advance written notification to the states of Category 1 shipments
37.77 (c), 16 2 32 0.25 8 16 2 32 0.25 8 0 0 0 0 0 Revision notification to state
37.77 (d) 16 0 0 0.25 0 16 0 0 0.25 0 0 0 0 0 0 Cancel notification to state
37.79(b)(1)(iii) in PR, 37.79(b)(1)(ii) in FR 0 0 0 0.03 0 0 0 0 0.03 0 0 0 0 0 0 Periodic reports to communication center
37.81(a),(c)&(e) 0 0 0 0.25 0 0 0 0 0.25 0 0 0 0 0 0 Category 1, zero estimated
TOTAL

75,835
42,826.75

96,175.16
50,126.91

20,340.16
7,300.16

Sheet 6: One-time recordkeeping


Part 37 final rule 2015 Renewal BURDEN CHANGE NOTES
Section Number of Recordkeepers Burden per Recordkeeper Total Annual Burden Hours Number of Recordkeepers Burden per Recordkeeper Total Annual Burden Hours Number of Recordkeepers Burden per Recordkeeper Total Annual Burden Hours Notes Retention Period
37.23(h)(2) 1,400 50 70,000 1,200 50 60,000 -200 0 -10,000 One time burden to develop access authorization procedures 3 yrs after procedure no longer need, or license termination
37.43(b) 1,400 100 140,000 1,200 100 120,000 -200 0 -20,000 One time burden to develop security procedures 3 yrs after procedure is not longer needed, or 3 yrs after procedure is superceded
TOTAL 1,400
210,000 1,200
180,000 -200 0 -30,000

ANNUALIZED TOTAL 1,400
70,000 1,200
60,000 -200 0 -10,000














Explanation: Decrease in burden due to one-time record keeping requirements. Only new licensees and remaining Agreement State licensees, who have not yet fulfilled this requirement, are required to develop access authorization and security procedures since existing NRC licensees were previously required to fulfill this requirement.


Sheet 7: Annual recordkeeping


Part 37 final rule 2015 renewal BURDEN CHANGE NOTES
Section Number of Recordkeepers Burden per Recordkeeper Total Annual Burden Hours Number of Recordkeepers Burden per Recordkeeper Total Annual Burden Hours Number of Recordkeepers Burden per Recordkeeper Total Annual Burden Hours Notes Retention Period
37.23(e)(3) in PR, 37.23(e)(5) in FR 1,400 1 1,400 1,500 1 1,500 100 0 100 List of persons approved access 3 years from the date the individual no longer requires unescorted access
37.23(f) Burden included in 37.23(h)(2) Burden included in 37.23(h)(2) 0 0 0 Burden included in 37.23(h)(2)
37.23(g)(1) 0 0.25 0 1,500 0.25 375 1,500 0 375 Notification records 1 year
37.23(h)(1) 1,400 2.25 3150 1,500 2.25 3375 100 0 225 Record of procedure and trustworthiness 3 years from the date the individual no longer requires unescorted access
37.23(h)(2) 1,400 0.5 700 1,500 0.5 750 100 0 50 Current procedures for conducting background investigations 3 yrs after procedure no longer need, or license termination
37.23(h)(3) Burden included in 37.23(e)(5) Burden included in 37.23(e)(5) 0 0 0 Burden included in 37.23(e)(5)
37.25(a)(2) Burden included in 37.23(h)(1) Burden included in 37.23(h)(1) 0 1 0 Burden included in 37.23(h)(1)
37.25(a)(10)(i) in PR, 37.25(a)(7) in FR Burden included in 37.23(h)(1) Burden included in 37.23(h)(1) 0 0 0 Burden included in 37.23(h)(1)
37.25(b) in PR, 37.25(b)(2) in FR Burden included in 37.23(h)(1) Burden included in 37.23(h)(1) 0 0 0 Burden included in 37.23(h)(1)
37.29(l-m) in PR, 37.29(a)(12)&(13) and 37.29(b) in FR Burden included in 37.23(h)(1) Burden included in 37.23(h)(1) 0 2 0 Burden included in 37.23(h)(1)
37.31(a) 1,400 0.75 1,050 1,500 0.75 1,125 100 0 75 Written procedures for protection of the record 3 yrs from date no longer requires access
37.31(e) 1,400 0.75 1,050 1,500 0.75 1,125 100 0 75 Fingerprint and criminal history records 3 yrs from date no longer requires access
37.33(b)&(c) 1,400 1.5 2,100 1,500 1.5 2,250 100 0 150 Document results of program review – 3 years 3 years
37.43(a)(4) 1,400 3.3 4,620 1,500 3.3 4,950 100 0 330 Security plan 3 yrs after plan is superseded or until license termination
37.43(b)(3) 1,400 0.25 350 1,500 0.25 375 100 0 25 Security plan implementing procedures 3 years after the record is superseded.
37.43(c)(4) 1,400 3 4,200 1,500 3 4,500 100 0 300 Training records for security plan 3 years
37.43(d)(5) in PR, 37.43(d)(5) & (6) in FR Burden included in 37.43(d)(8) Burden included in 37.43(d)(8) 0 0 0 Burden included in 37.43(d)(8)
37.43(d)(7)(i) in PR, 37.43(d)(8)(i) and (ii) in FR Information protection procedures - included in 37.43(b)(3) Information protection procedures - included in 37.43(b)(3) 0 0 0 Information protection procedures - included in 37.43(b)(3)
37.43(d)(7)(ii) in PR, 37.43(d)(8)(i) and (ii) in FR 1,400 0.25 350 1,500 0.25 375 0 0 25 List of trust worthy person 3 years
37.45(a)(2)





0 0 0

37.45(b)(3)





0 0 0

37.45(c) 1,400 1 1400 1,500 1 1500 100 0 100 Records of coordination with LLEA 3 years
37.51(b) 1,400 0.25 350 1,500 0.25 375 100 0 25 Records of maintenance and testing 3 years
37.55(c) 1,400 1.5 2100 1,500 1.5 2250 100 0 150 Records of security plan review 3 years
37.71(c) in PR, 37.71(a)-(d) in FR 400 0.75 300 MasterImage: Cat 2 licensees shipping. 530 0.75 397.5 130 0 98 Copy of document verification before transfer 3 years
37.75(a)(3), (b), & (e) 416 0.75 312 MasterImage: (Cat 2) 530 Radiographers + (Cat 1) 15 M&D + 1 Irradiator/yr) =646 546 0.75 409.5 130 0 98 Copy of preplanning info for shipments 3 years
37.77(e) 16 0.01 0.16 16 0.01 0.16 0 0 0 Copy of advance notification, revision, cancellation notices 3 years
37.79(c) in PR, 37.79(a)(1)(iii) &(v) in FR 16 0.75 12 16 0.75 12 0 0 0 Written procedures for road shipment of category 1 material 3 years
37.79(b)(1)(i) 0 0.75 0 0 0.75 0 0 0 0 Procedures for rail shipments 3 years
TOTAL

23,444.2

25,644.2 0 0 2,200


Sheet 8: 2015 renewal summary

2015 Renewal Summary: Part 37 Totals

Hours Responses
Reporting 1,932.4 6,204.4
Recordkeeping 85,644.2 1,200.0
Third-Party Disclosure 50,993.6 96,578.5
Total 138,570.2 103,982.9






Respondents

Final Rule 2015 renewal
Agreement State Licensees 1,100 1,200
NRC Licensees 300 300
Individuals making personal history disclosures under 37.23(d) 4,200 4,500
Total 5,600 6,000
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