ML21154A178 Final Supporting Statement 10 CFR Part 20

FINAL OMB SUPPORTING STATEMENT FOR
10 CFR PART 20
"STANDARDS FOR PROTECTION AGAINST RADIATION”
(3150-0014)
Extension
Description of the Information Collection
The general requirements for radiation protection, that are applicable to all U.S. Nuclear
Regulatory Commission (NRC) licensees, are contained in Title of the Code of Federal
Regulations (10 CFR) Part 20, “Standards for Protection Against Radiation.” The provisions of
10 CFR Part 20 apply to individuals licensed by the NRC to possess byproduct, source, or
special nuclear material. 10 CFR Part 20 also contains criteria for decommissioning of facilities
and termination of the facility license. 10 CFR Part 20 is intended to ensure that occupationally
exposed individuals and members of the public are adequately protected from the potential
hazards of exposure to radiation and/or radioactive materials (for example, by requiring
licensees to report theft or loss of licensed radioactive materials and specific incidents causing
substantial exposures to or release of radioactive material).
The recordkeeping and reporting requirements for possession of material are in Subpart L –
Records (20.2102 - 2110) and Subpart M – Reports (20.2201-2207). Recordkeeping and
reporting requirements for license termination are contained in Subpart E.
Two record retention periods appear in Part 20: 3 year retention for most survey records, and
retention for the lifetime of an active NRC license for those records of doses (or records that
provide a basis for dose estimates) received by individual workers or members of the public.
In addition, the information collection includes two online forms for requesting exemptions from
requirements for respiratory protection related to the COVID-19 Public Health Emergency
(PHE).
A.

JUSTIFICATION
The statutory authority of the NRC derives from the Atomic Energy Act of 1954
(AEA), as amended; the Energy Reorganization Act of 1974, as amended, the
Uranium Mill Tailings Radiation Control Act of 1978, as amended; the Low-Level
Radioactive Waste Policy Act of 1980; the Nuclear Waste Policy Act of 1982; and
the National Environmental Policy Act of 1969. The basic authorities from the AEA
include licensing and regulation of production, use, ownership, and distribution of
special nuclear materials, source material, and byproduct materials, and licensing
and control over the manufacture, production, possession, use, importation, or
exportation of production and utilization facilities.
Section 161b of the AEA provides that the Commission may establish such
standards as the Commission deems necessary to protect public health and safety.
Section 161o gives the Commission authority to require by rule, regulation, or
order, such reports, and the keeping of such records as may be necessary to carry
out the purposes of the AEA.

1.

Need for and Practical Utility of the Collection of Information
The information collected is used to evaluate the effectiveness of NRC
regulations and to discern any trends, problems, or special situations requiring
additional controls. The NRC uses information on worker exposures and
effluents from facilities such as nuclear power plants to analyze trends and
compare licensee performance. This information is also published in annual
reports for use by industry and other interested organizations. The NRC also
uses the information to assess applications for decommissioning and license
termination. The Description of Information Collections is listed in Appendix A.

2.

Agency Use of Information
The NRC uses the required information collection and reports to ensure that
doses to workers and members of the public do not exceed limits and are as
low as is reasonably achievable. The NRC also used the required information
collection reports to ensure that that radioactive materials are stored, handled,
and that facilities are decommissioned, in a way that will adequately protect
the health and safety of workers and the public.

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
site, by Optical Storage Media (OSM) (e.g. CD-ROM, DVD), by facsimile, or
by e-mail. It is estimated that approximately 80 percent of the 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
Some of the licensees who use byproduct, source, and special nuclear
materials are small businesses. However, since the health and safety
consequences of improper handling or use of these materials are the same for
large and small entities, it is not possible to reduce the burden on small
businesses by less frequent or less complete reporting, recordkeeping, or
accounting and control procedures.

6.

Consequences to Federal Program or Policy Activities if the Collection is Not
Conducted or is Conducted Less Frequently
Required reports are collected and evaluated on a continuing basis as events
occur. Applications for new licenses and amendments are submitted only
2

once. Information submitted in previous applications may be referenced
without being resubmitted.
The schedule for collecting the information is the minimum frequency necessary
to assure that licensees will continue to conduct programs in a manner that will
adequately protect the health and safety of the public. If the information were
not collected, it would not be possible for NRC to intervene if safety were to
decline at a licensed facility in order to ensure the continued health and safety
of the public and workers.
7.

Circumstances that Justify Variation from OMB Guidelines
Contrary to the Office of Management and Budget Guidelines (OMB) in 5 CFR
1320.6(b), the NRC requires some information to be submitted in less than
30 days:
•

10 CFR 20.1906, 20.2201, and 20.2202 contains both immediate and
24-hour reporting requirements that are necessary for NRC to provide
rapid response to incidents and to ensure public health and safety.

•

Appendix G, Section III, Paragraph (E) requires licensees to report
information in less than 30 days. This shorter notification time period is
needed so that State and local authorities can be mobilized to assist in
locating lost radioactive materials as quickly as possible to minimize
the potential hazard to members of the public.

Contrary to the Office of Management and Budget Guidelines (OMB) in 5 CFR
1320.5(d)(2), the NRC requires some records to be maintained for longer than
3 years. Records pertaining to the radiation doses and radionuclide intakes by
individual workers, to effluents released to air and water, and to the resultant
radiation exposure of members of the public must be retained for the life of the
license and transferred to the NRC upon termination of the license. This
retention period is required so that the past exposure history of any worker
can be reconstructed to allow the worker to move from licensed facility to
licensed facility and to permit the identification of trends, so that declining
licensee performance can be detected and corrected.
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 March 22,
2021 (86 FR 15273). No comments were received.
NRC also contacted four licensees by e-mail. No comments were received.

9.

Payment or Gift to Respondents
Not applicable.

3

10. Confidentiality of Information
Confidential and proprietary information is protected in accordance with NRC
regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
No sensitive information is requested under these regulations.
11. Justification for Sensitive Questions
No sensitive information is requested under these regulations.
12. Estimated Burden and Burden Hour Cost
NRC Licensees
The burden for NRC licensees to respond to the collection is shown in Tables
1, 3, and 5. The total burden for NRC licensees is 91,665 hours (5,899 hours
for reporting + 342 hours for third-party disclosures + 85,724 hours for
recordkeeping) at a cost of $25,658,235 (91,965 hours x $279/hour).
An estimated 3,000 NRC licensees respond to the 10 CFR Part 20 information
collections. These are licensees who are directly regulated by the NRC and
includes materials and reactor licensees.
Agreement State Licensees
Section 274 of the AEA 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 AEA. Licensees
operating in these “Agreement States” are referred to in this supporting
statement as “Agreement State Licensees.”
The NRC has established compatibility requirements for Agreement States to
implement their own regulations in a manner consistent with NRC regulations.
The number of NRC licensees is known, whereas the total number of
Agreement State licensees is an estimate based on NRC’s best information
available from the Agreement States. NRC uses the ratio of the total of NRC
licensees (subject to 10 CFR Part 20) to the total number Agreement State
licensees to estimate the number of Agreement State respondents for each
section. NRC uses this ratio approach as the total number of Agreement
State licensees subject to various 10 CFR Part 20 Sections. The current ratio,
based on the number and size of NRC regulated states to Agreement States,
is approximately 1:7.4 (NRC licensees: Agreement State licensees).
The burden for Agreement State licensees to respond to the collection is
shown in Tables 2, 4, and 6. The total burden for Agreement State licensees
is 677,431 hours (40,542 hours reporting + 2,531 hours third-party disclosure
+ 634,358 hours recordkeeping) at a cost of $189,003,249 (677,431 x

$279/hour).
Total
The total burden for the collection is 769,396 hours (91,665 hours for NRC
licensee respondents and 677,431 hours for Agreement State licensee
respondents), at a total cost of $214,661,205 (769,395 hours x $279/hour).
See Tables 7 and 8.
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 basis
of this 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
The 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 percent of the
recordkeeping burden cost. Therefore, the records storage cost is estimated
to be $80,361 (85,724 NRC recordkeeping hours + 634,358 Agreement State
recordkeeping hours x 0.0004 x $279/hour).
14. Estimated Annualized Cost to the Federal Government
The estimated annualized cost to the Federal Government is $2,525,787 (see
Table 9). This cost is calculated using 9,053 total annual hours at a labor rate
of $279/hour to review reports submitted by NRC licensees. Note that costs
do not include costs to review Agreement State licensee actions, as this is a
responsibility that has been discontinued by the NRC and assumed by the
Agreement States as detailed in Section 12, “Estimated Industry Burden and
Burden Hour Cost.”
The NRC costs associated with this collection are recovered through license
fees assessed to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.
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 Change in Burden or Cost
The overall NRC licensee and Agreement State licensee burden has
increased by 128,500 hours from 640,896 hours to 769,396 hours. This
includes an increase of 420 hours of NRC licensee reporting burden only
(from 5,479 hours to 5,899 hours) and an increase of 128,200 hours of
Agreement State licensee overall burden (from 549,231 hours to 677,431
hours).

5

The increase in NRC licensee reporting burden is due to the NRC receiving an
increased number of exemptions due to the COVID-19 PHE and the two NRC
online forms, “Part 20 Respirator Protection Exemption Request for NonPower Reactors/RTR” and “Part 20 Respirator Protection Exemption Request
for Power Reactors” which are for requesting exemptions from requirements
for respirator protections related to the COVID-19 PHE. The burden per
exemption request increased from 20 to 80 hours. The estimate of the
number of burden hours for NRC licensee recordkeeping and third-party
disclosure has remained the same.
The burden attributed to Agreement State licensees increased for reporting
burden by 7,668 hours from 32,874 hours to 40,542 hours. Recordkeeping
burden for Agreement State licensees increased by 120,053 hours from
514,305 hours to 634,358 hours. The burden attributed to Agreement State
licensee third-party disclosures increased by 479 hours (from 2,052 hours to
2,531 hours). These changes are due to the ratio used to estimate Agreement
State respondents changing from 6.0 to 7.4 (therefore increasing the number
of estimated Agreement State respondents and recordkeepers). The ratio
changed because the difference in the number of current NRC licensees
versus Agreement States licensees has increased.
In addition, the hourly fee rate increased from $263 to $279.
16. Publication for Statistical Use
This information will not be published 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
There are no exceptions.
B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not used in this collection of information.

TABLE 1
REPORTING BURDEN FOR NRC LICENSEES

SECTION

20.1101(d)
20.1202
20.1203
20.1204
20.1206
20.1208
20.1301(d)

20.1302(c)
20.1403(a),(c),
(d),(e)(1)
20.1403(e)(2)
20.1404
20.1406
20.1601(c)
20.1703(b)
20.1705(a)&(b)
20.1906(d)
20.2002
20.2004
20.2006
20.2201(a)
20.2201(b)

DESCRIPTION

Radiation protection
programs
Calculation of doses
Calculation of doses
from airborne
material
Determinations of
internal exposure
Planned special
exposures
Dose limits for an
embryo/fetus
Application for
higher dose to
member of the
public
Request to adjust
effluent values
Criteria for license
termination (residual
radioactivity - lower)
Criteria for license
termination (residual
radioactivity - higher)
Alternate criteria for
license termination
Minimization of
contamination
Alternative methods
for access control
Alternate respiratory
protection
equipment
Application for use
of higher protection
factors
Package receipt
(NRC notification)
Applications for
alternate disposal
procedures
Treatment or
disposal by
incineration
Low-level waste
disposal
Telephone reports
for loss of material
Written reports for
loss of material

NO. OF
RESPONDENTS

RESPONSES
PER
RESPONDENT

TOTAL
RESPONSES

ANNUAL
BURDEN PER
RESPONDENT
(HRS)

TOTAL
ANNUAL
BURDEN
(HRS)

NOTES

see § 20.2203
see § 20.2206
see § 20.2206
see § 20.2206
see § 20.2204
see § 20.2206
0

0

0

4

0

2

1

2

10

20

3

1

3

23

69

1

1

1

10

10

0

0

0

20

0

10

1

10

20

200

10

1

10

8

80

15

1

15

40

600

15

1

15

40

600

14

1

14

3

42

20

1

20

20

400

None
expected

Burden included under 10 CFR 50 (OMB clearance no. 3150-0011)
Burden included under NRC Forms 540-542 (OMB clearance nos. 3150-0164, 31500166, 3150-0165)
30.3

1

30.3

3

90.9

30.3

1

30.3

3

90.9

7

20.2201(d)
20.2202(a)
20.2202(b)
20.2203(a)&(b)
20.2204
20.2205
20.2206
20.2207(a),
(b), (c), (d),
(e), (f)
20.2207 (g)
20.2207(h)
20.2301
NRC Online
Form
NRC Online
Form

App G

Additional
information reports
Immediate
notification of
incidents
24-hr notification of
incidents
Reportable event
notification
Planned special
exposure reports
Reports to
individuals (dose
limits exceeded)
Individual reports
National source
tracking reports
Correction &
reconciliation
Initial inventory
report
Exemption
applications
Respirator
Protection
Exemption Request
for Power Reactors
Respirator
Protection
Exemption Request
for Non-Power
Reactors/RTR
Requirements for
low-level waste
transfers

5.3

1

5.3

3

15.9

10

1

10

1

10

38

1

38

40

1,520

20

1

20

6

120

5

1

5

5

25

Burden included in 20.2203(a) except for doses to individuals (see Table 3)
Burden included under NRC Forms 4 and 5 (OMB clearance 3150-0005 & 3150-0006)
Burden included in OMB clearance for NRC Form 748 (OMB clearance 3150-0202)

1,425

1
1,425
One-time report completed

1

1,425

80

1

80

5

400

40

1

40

2

80

20

1

20

2

40

3

1

3

20

60

TOTAL
1,425

1,797

8

5,899

TABLE 2
REPORTING BURDEN FOR AGREEMENT STATE LICENSEES

SECTION

20.1101(d)
20.1202
20.1203
20.1204
20.1206
20.1208
20.1301(d)
20.1302(c)
20.1403(a),(c),
(d),(e)(1)
20.1403(e)(2)
20.1404
20.1406
20.1601(c)
20.1703(b)
20.1705(a)&(b)
20.1906(d)
20.2002
20.2004
20.2006
20.2201(a)
20.2201(b)
20.2201(d)
20.2202(a)
20.2202(b)
20.2203(a)&(b)

DESCRIPTION

Radiation protection
programs
Calculation of doses
Calculation of doses from
airborne material
Determinations of internal
exposure
Planned special exposure
Dose limits for an
embryo/fetus
Application for higher dose
to member of the public
Request to adjust effluent
values
Criteria for license
termination (residual
radioactivity - lower)
Criteria for license
termination (residual
radioactivity - higher)
Alternate criteria for
license termination
Minimization of
contamination
Alternative methods for
access control
Alternate respiratory
protection equipment
Application for use of
higher protection factors
Package receipt (NRC
notification)
Applications for alternate
disposal procedures
Treatment or disposal by
incineration
Low-level waste disposal
Telephone reports for loss
of material
Written reports for loss of
material
Additional information
reports
Immediate notification of
incidents
24-hr notification of
incidents
Reportable event
notification

NO. OF
RESPONDENTS

RESPONSES
PER
RESPONDENT

TOTAL
RESPONSES

ANNUAL
BURDEN PER
RESPONDENT
(HRS)

TOTAL
ANNUAL
BURDEN
(HRS)

NOTES

see § 20.2203
see § 20.2206
see § 20.2206
see § 20.2206
see § 20.2204
see § 20.2206
0

0

0

4

0

1

15

10

148

1

22

23

511

1

7.4

10

74

0

0

20

0

1

74

20

1,480

74

1

74

8

592

111

1

111

40

4,440

111

1

111

40

4,440

104

1

104

3

311

None
expected

15
22
7.4
0
74

148
1
148
20
2,960
Burden included under 10 CFR 50 (OMB clearance no. 3150-0011)
Burden included under NRC Forms 540-542 (OMB clearance nos. 3150-0164, 31500166, 3150-0165)
224

1

224

3

673

224

1

224

3

673

39

1

39

3

118

74

1

74

1

74

281

1

281

40

11,248

148

1

148

6

888

9

20.2204
20.2205

Planned special exposure
reports
Reports to individuals
(dose limits exceeded)

20.2206

Individual reports

20.2207(a),
(b), (c), (d),
(e), (f)
20.2207 (g)

National source tracking
reports

20.2207(h)
20.2301

Initial inventory report
Exemption applications

App G

Requirements for low-level
waste transfers

37
1
37
5
185
Burden included in 20.2203(a) except for doses to individuals (see Table 4)
Burden included under NRC Forms 4 and 5 (OMB clearance 3150-0005 & 3150-0006)
Burden included in OMB clearance for NRC Form 748 (OMB clearance 3150-0202)

Correction & reconciliation
10,545

1
10,545
One-time report completed

1

10,545

148

1

148

5

740

22

1

22

20

444

TOTAL
10,545

12,409

10

40,542

TABLE 3
THIRD PARTY DISCLOSURE BURDEN FOR NRC LICENSEES

SECTION
20.1901(b)&(c)
20.1904
20.1906(d)
20.2006(b)
20.2205
Appendix G,
Section III,
Paragraphs (A)(D)
TOTAL

DESCRIPTION
Caution signs
Labeling containers
Carrier notification
Low-level waste
disposal
Reports to
individuals (dose
limits exceeded)
Requirements for
low-level waste
transfers

NO. OF
RESPONDENTS

RESPONSES
PER
RESPONDENT

TOTAL
RESPONSES

ANNUAL
BURDEN PER
RESPONDENT
(HRS)

TOTAL
ANNUAL
BURDEN
(HRS)

750
750
14

1
1
1

750
750
14

0.1
0.1
3

75
75
42

NOTES

Burden included under NRC Forms 540-542 (OMB clearance nos. 3150-0164, 3150-0166,
3150-0165)
25

1

25

6

150

Burden for Sections I and II included under NRC Forms 540-542 (OMB clearance nos. 31500164, 3150-0166, 3150-0165)
750
1,539
342

11

TABLE 4
THIRD PARTY DISCLOSURE BURDEN FOR AGREEMENT STATE LICENSEES

SECTION

20.1901(b)&(c)
20.1904
20.1906(d)
20.2006(b)
20.2205
Appendix G,
Section III,
Paragraphs
(A)-(D)
TOTAL

DESCRIPTION

Caution signs
Labeling
containers
Carrier
notification
Low-level waste
disposal
Reports to
individuals (dose
limits exceeded)
Requirements
for low-level
waste transfers

NO. OF
RESPONDENTS

RESPONSES
PER
RESPONDENT

TOTAL
RESPONSES

ANNUAL
BURDEN PER
RESPONDENT
(HRS)

TOTAL
ANNUAL
BURDEN
(HRS)

5,550

1

5,550

0.1

555

5,550

1

5,550

0.1

555

104

1

104

3

311

NOTES

Burden included under NRC Forms 540-542 (OMB clearance nos. 3150-0164, 3150-0166,
3150-0165)
185

1

185

6

1110

Burden for Sections I and II included under NRC Forms 540-542 (OMB clearance nos. 31500164, 3150-0166, 3150-0165)
11,389

11,389

12

2,531

TABLE 5
RECORDKEEPING BURDEN FOR NRC LICENSEES

SECTION

20.1101(a)
20.1202
20.1203
20.1204
20.1206
20.1208
20.1403(d)

DESCRIPTION

NO. OF
RECORDKEEPERS

Radiation protection
programs
Calculation of doses
Calculation of doses
from airborne material
Determination of internal
exposure
Planned special
exposures
Dose limits for an
embryo/fetus
Decommissioning Plan
or License Termination
Plan

BURDEN
PER
RECORDKEEPER
(HRS)

see § 20.2106
see § 20.2105
see § 20.2106
3

20

100

80

20.1901
20.1905(e)

Caution signs
Exempt containers

750
600

0.1
0.2

20.1906(e)
20.2005(c)
20.2006

Opening packages
Specific waste disposal
Low-level waste
disposal

1,803

1

20.2102(a)&(b)

Program records

3,003

4

20.2103(a)&(b)

Survey records

3,003

8

20.2104
20.2105

Prior dose records
Planned special
exposure records
Records of dose

0

3

20.2107(a)
20.2108(a)
20.2110
20.2207(a),
(b), (c), (d), (e)
App. G

60

RULT1

see § 20.2103
see § 20.2103
8,000
RULT1

75
120

LOC2

1,803
see § 20.2108
Burden included under Forms 540-542 (OMB clearance nos. 3150-0164, 31500166, 3150-0165)

Declaration of
pregnancy
Dose limit (members of
the public)
Waste disposal records
Form of records
National source tracking
reports
Requirements for lowlevel waste transfers

TOTAL

12,012

(a)(1)=RULT,
(a)(2)=3 yrs
24,024
(a)=3 yrs,
(b)=RULT
see § 20.2106
0
RULT

none expected

Burden included under NRC Forms 4 & 5 (OMB clearance nos. 3150-0005 &
3150-0006)
150
1
150
RULT
3,000

5

15,000

RULT

8
24,000
RULT
3,000
No additional burden (included in 20.2102 through 20.2108)
Burden included in OMB clearance for NRC Form 748 (3150-0202)
3

160

3,003

480

85,724

1 RULT
2 LOC

NOTES

see § 20.2106
see § 20.2106

Surveys & monitoring
Intake evaluation
Written procedures on
respiratory protection
equipment

20.2106

RECORD
RETENTION

see § 20.2102

20.1501
20.1703(c)(2)
20.1703(c)(4)

20.2106

TOTAL
ANNUAL
BURDEN
(HRS)

= Retained until license termination
= Life of container

13

RECORDKEEPING BURDEN FOR AGREEMENT STATE LICENSEES

SECTION

DESCRIPTION

20.1101(a)

Radiation protection
programs

20.1202
20.1203

Calculation of doses
Calculation of doses
from airborne material
Determination of internal
exposure
Planned special
exposures
Dose limits for an
embryo/fetus
Decommissioning Plan
or License Termination
Plan

20.1204
20.1206
20.1208
20.1403(d)

20.1501
20.1703(c)(2)
20.1703(c)(4)

Surveys & monitoring
Intake evaluation
Written procedures on
respiratory protection
equipment

20.1901

Caution signs

20.1905(e)

Exempt containers

20.1906(e)

Opening packages

20.2005(c)
20.2006

Specific waste disposal
Low-level waste
disposal

20.2102(a)&(b)

Program records

NO. OF
RECORDKEEPERS

BURDEN
PER
RECORDKEEPER

TOTAL
RECORD
ANNUAL
RETENTION
BURDEN
(HRS)
(HRS)
see § 20.2102

NOTES

see § 20.2106
see § 20.2106
see § 20.2106
see § 20.2105
see § 20.2106
22.2

RULT1

20
444
see § 20.2103
see § 20.2103

RULT1

80
740

5,550

59,200

0.1
0.2

4,440

555
LOC2
888

1
13,342

13,342
see § 20.2108
Burden included under Forms 540-542 (OMB clearance nos. 3150-0164, 31500166, 3150-0165)
22,222
4

20.2103(a)&(b)

Survey records

20.2104
20.2105

Prior dose records
Planned special
exposure records
Records of dose

22,222
8

20.2106
(records of
dose)

1
2

20.2106
(declaration of
pregnancy)

Declaration of
pregnancy

20.2107(a)
20.2108(a)

Dose limit (members of
the public)
Waste disposal records

20.211

Form of records

0

3

(a)(1)=RULT,
(a)(2)=3 yrs
(a)=3 yrs,
177,778
(b)=RULT
see § 20.2106
0
RULT
88,889

none expected

Burden included under NRC Forms 4 & 5 (OMB clearance nos. 3150-0005 &
3150-0006)
1
1,110

RULT
1,110

5
22,200

RULT
111,000

8
RULT
22,200
177,600
No additional burden (included in 20.2102 through 20.2108)

RULT = Retained until license termination
LOC = Life of container

14

20.2207(a),
(b), (c), (d), (e)
App. G

TOTAL

National source tracking
reports
Requirements for lowlevel waste transfers

Burden included in OMB clearance for NRC Form 748 (3150-0202)
22.2

160
3,552

22,222
634,358

15

TABLE 7 BURDEN SUMMARY
Hours
5,899
342
85,724
40,542
2,531
634,358
769,396

NRC Licensee Reporting
NRC Licensee 3rd Party Disclosure
NRC Licensee Recordkeeping
Agreement State Reporting
Agreement State 3rd Party Disclosure
Agreement State Recordkeeping
TOTAL

Responses
1,797
1,539
3,003
12,409
11,389
22,222
52,359

TABLE 8
TOTALS FOR NRC LICENSEES AND AGREEMENT STATE LICENSEES
Hours
91,965
677,431
769,396

NRC Licensees Total
Agreement State Licensees Total
TOTAL

Responses
6,339
46,020
52,359

Total Number of recordkeepers:

25,225 (3,003 NRC licensee recordkeepers +
22,222 Agreement State licensee
recordkeepers)

Number of respondents:

25,225 (3,003
NRC licensees +
22,222
Agreement State
licensees)

16

TABLE 9
ANNUALIZED COST TO THE FEDERAL GOVERNMENT
(NRC Staff Burdens Associated with 10 CFR Part 20)
SECTION

TOTAL HOURS

NOTES

20.1101

0

see § 20.2102

20.1202

0

see § 20.2106

20.1203

0

see § 20.2106

20.1204

0

see § 20.2106

20.1206

0

see § 20.2106

20.1208

0

see § 20.2106

20.1301(d)

0

none expected

20.1302(c)

4

20.1403(a-e)

60

20.1404

0

20.1406

200

20.1501

0

20.1601(c)

8

20.1703(b)

300

20.1703(c)(2)

0

20.1703(c)(4)

200

20.1705(a)&(b)

300

20.1904

50

20.1905(e)

9

20.1906(d)

6

20.1906(e)

9

20.2002

150

20.2004

0

Burden included in OMB Clearance for Part 50
(OMB clearance no. 3150-0011)

20.2005(c)

0

see § 20.2108

20.2006

0

Burden included in OMB clearance for NRC
Forms 540-542 (OMB clearance nos. 3150-0164,
3150-0166, 3150-0166)

see § 20.2103

see § 20.2103

17

SECTION

TOTAL HOURS

20.2102(a)

2250

20.2103(a)

3000

20.2103(b)

0

see §20.2103(a)

20.2104

0

see § 20.2106

20.2105

0

none expected

0

Burden included in OMB Clearance for NRC Forms
4 and 5 (OMB clearance nos. 3150-0005, 31500006)

0

none expected

20.2106
(records of dose)
20.2106
(declaration of pregnancy)

NOTES

20.2107(a)

7

20.2107(b)

0

20.2108(a)

510

20.2108(b)

0

see §20.2108(a)

20.2110

0

format requirement only

20.2201(a)

91

20.2201(b)

91

20.2201(d)

5

20.2202(a)

60

20.2202(b)

117

20.2203(a)

320

20.2203(b)

0

20.2204

100

20.2206(b)&c)

0

Burden included in OMB Clearance for NRC Forms
4 and 5 (OMB clearance nos. 3150-0005, 31500006)

20.2207(a), (b), (c), (d), (e), (g)

0

Burden included in OMB clearance for NRC Form
748

20.2207(h)

0

One-time report completed

20.2301

400

NRC Online Form:
Respirator Protection
Exemption Request for
Power reactors

800

NRC Online Form:
Respirator Protection

400

18

see §20.2107(a)

see § 20.2203(a)

Exemption Request for
Non-Power Reactors/RTR
App G
TOTAL

6
9,073

19

For Sections I and II, Burden included in OMB
Clearance for NRC Forms 540-542 (OMB
clearance nos. 3150-0164, 3150-0166, 3150-0165)

Appendix A: Description of Information Collections for 10 CFR Part 20
10 CFR 20.1003 defines a declared pregnant woman as a woman who has voluntarily informed
the licensee in writing that she is pregnant. Licensees are required to maintain records of doses
to the embryo/fetus and the declared pregnant woman in 10 CFR 20.2106. Licensees are also
required by 10 CFR 20.2106(e) to keep the declaration on file, although it may be maintained
separately from the dose records.
10 CFR 20.1101 requires licensees to develop, document and implement radiation protection
programs; establish radiation protection procedures; and perform program reviews periodically.
This is necessary to ensure the health and safety of the workers and the general public. The
burden for recordkeeping requirements is contained in 10 CFR 20.2102.
10 CFR 20.1201 and 20.1202 set limits for occupational exposures. The recordkeeping
requirements for this section are contained in 10 CFR 20.2106. Dose limits are necessary to
ensure the health and safety of the workers. The reporting requirements for this section are
contained in 10 CFR 20.2206. Both requirements are covered under the OMB clearance for
NRC Forms 4 and 5 (3150-0005 and 3150-0006, respectively).
10 CFR 20.1203 requires licensees to determine dose from airborne radioactive material. This
is necessary to ensure compliance with dose limits. The recordkeeping and reporting
requirements for this section are contained in 10 CFR 20.2106 and 20.2206 respectively and
are covered under a separate OMB clearance for NRC Forms 4 and 5 (OMB 3150-0005 and
3150-0006).
10 CFR 20.1204 requires licensees to make measurements as needed to assess internal
exposures of occupationally exposed individuals. The recordkeeping and reporting
requirements for this section are contained in 10 CFR 20.2106 and 20.2206 respectively and
are covered under a separate OMB clearance for NRC Forms 4 and 5 (OMB 3150-0005 and
3150-0006).
10 CFR 20.1206 sets limits for planned special exposures. This is necessary to ensure the
health and safety of workers. The recordkeeping and reporting requirements for this section are
contained in 10 CFR 20.2105 and 20.2204 respectively.
10 CFR 20.1208 sets limits for doses to an embryo/fetus of a declared pregnant worker. This is
necessary to protect the health and safety of the embryo/fetus.
10 CFR 20.1301(d) allows licensees to apply to the Commission to increase the dose limit for
the general public from 0.1 rem/year to up to 0.5 rem/year. This is needed to ensure that a
temporary deviation from the established dose limits adequately protects the health and safety
of workers and the public.
10 CFR 20.1302(c) allows licensees to apply to the Commission for permission to use alternate
effluent release concentration limits based on actual physical and chemical characteristics of the
effluent released. This is needed to ensure that if alternate values are used by licensees, then
the values are adequate to protect the health and safety of the public.
10 CFR 20.1403(a)-(c) and (e)(1) require that, if restrictions on future use of the site are
proposed, the information that the licensee must provide is as follows: (1) further reductions in
20

residual radioactivity necessary to release the site for unrestricted use would result in net public
or environmental harm or were not being made because the residual levels associated with
restricted conditions are as low as is reasonably achievable (ALARA); (2) adequate provisions
for legally enforceable institutional controls that provide reasonable assurance that the total
effective dose equivalent (TEDE) from residual radioactivity distinguishable from background to
the average member of the critical group will not exceed 25 mrem per year; (3) provisions have
been made for sufficient financial assurance to enable an independent third party to assume
and carry out responsibilities for any necessary control and maintenance of the site; and (4)
residual radioactivity at the site has been reduced so that if the institutional controls were no
longer in effect, there is reasonable assurance that the TEDE from residual radioactivity
distinguishable from background to the average member of the critical group is as low as
reasonably achievable and would not exceed 100 mrem per year.
10 CFR 20.1403(d) requires that a decommissioning plan or License Termination Plan (LTP) be
submitted to the Commission by the licensee indicating the licensee’s intent to decommission in
accordance with 10 CFR Parts 30.36(d), 40.42(d), 50.82(a) and (b), 70.38(d), or 72.54, and
specifying that the licensee intends to decommission by restricting use of the site, and that the
decommissioning plan or LTP document how the advice of individuals or institutions in the
community who may be affected by the decommissioning has been sought and incorporated, as
appropriate, following analysis of that advice. In seeking advice on issues associated with
restricted use, licensees are required to provide for participation by a broad cross section of
community interests who may be affected by the decommissioning, provide an opportunity for
comprehensive, collective discussion on the issues by the participants represented, and prepare
a publicly available summary of the results of all such discussions, including a description of the
individual viewpoints of the participants on the issues and the extent of agreement and
disagreement among the participants on the issues.
10 CFR 20.1403(e)(2) requires that, as an option to the 100 mrem per year level, a level of
500 mrem/year may be allowed if the licensee demonstrates that further reductions in residual
radioactivity necessary to comply with the 100 mrem/year value are not technically achievable,
would be prohibitively expensive, or would result in net public or environmental harm, that
provisions exist for durable institutional controls, and that there is sufficient financial assurance
to enable a responsible government entity, or independent third party, both to carry out periodic
rechecks of the site no less frequently than every 5 years and to assume and carry out
responsibilities for any necessary control and maintenance of those controls.
10 CFR 20.1404 requires that, if the licensee proposes to use alternate criteria, the information
the license must provide is as follows: (1) an analysis of possible sources of exposure that
provides assurance that public health and safety would continue to be protected, and that it is
unlikely that the dose from all man-made sources combined, other than medical, would be more
than the 1 mSv/year (100 mrem/year) limit of Subpart D of 10 CFR Part 20; (2) an indication that
restrictions on site use according to the provisions of 10 CFR 20.1403 have been employed to
the extent practical to minimize exposures at the site; (3) doses have been reduced to ALARA
levels; and (4) a decommissioning plan or LTP has been submitted indicating the licensee's
intent to decommission in accordance with 10 CFR Parts 30.36(d), 40.42(d), 50.82(a) and (b),
70.38(d), or 72.54, and specifying that the licensee proposes to decommission by use of
alternate criteria, and documenting in the decommissioning plan or LTP how the advice of
individuals and institutions in the community who may be affected by the decommissioning has
been sought and incorporated, as appropriate, following analysis of that advice.

21

10 CFR 20.1406 requires applicants for licenses to describe in the application how facility
design and procedures for operation will minimize contamination of the facility and the
environment, facilitate eventual decommissioning, and minimize the generation of radioactive
waste.
10 CFR 20.1501 requires licensees to conduct surveys and to monitor radiological conditions.
These are necessary to ensure that the licensee is aware of all the radiological conditions that
could contribute to dose in order to comply with dose limits. The recordkeeping requirements
for this section are contained in 10 CFR 20.2103.
10 CFR 20.1601(c) allows licensees to apply to the Commission for approval of alternate methods
for controlling access to high radiation areas. This is needed to ensure that any proposed
deviation from established mechanisms adequately protects the health and safety of workers and
the public.
10 CFR 20.1703(b) allows licensees to submit an application to the Commission for permission
to use respiratory protection equipment that has not been tested or certified for use by the
National Institute for Occupational Safety and Health. Records of this application and its
approval are required to ensure that licensee practices are in compliance with regulations.
10 CFR 20.1703(c)(2) requires licensees to perform surveys and bioassay as needed to
evaluate actual intakes. The recordkeeping requirement for this paragraph is contained in
10 CFR 20.2103. These records are needed so that NRC can ensure, through inspection, that
the licensee is adequately protecting the health and safety of workers.
10 CFR 20.1703(c)(4) requires licensees to have written procedures regarding the proper issue
and use of respiratory protection equipment. This is needed to ensure, through inspection, that
these devices are used consistent with the goal to maintain occupational doses ALARA and in a
safe manner.
10 CFR 20.1705(a) and (b) requires licensees to submit an application to the Commission
before using assigned protection factors higher than those in Appendix A to 10 CFR Part 20 for
the purpose of calculating exposures. Records of this application and its approval are required
to ensure that respiratory protective equipment is being used in a manner that will protect the
health and safety of workers.
10 CFR 20.1901(b) and (c) allows licensees to label sources, source holders, or device
components containing sources of licensed materials and to provide additional information, as
appropriate, to make individuals aware of potential radiation exposures and to minimize
exposures.
10 CFR 20.1904 requires that labels used to identify radioactive material containers use
specified formats and wording. This is needed to minimize potential doses or releases of
radioactive material due to worker confusion.
10 CFR 20.1905(e) requires that licensees maintain records of radioactive material containers
that cannot be labeled in accordance with this Part due to special circumstances for the life of
the container. This is necessary to ensure that radioactive material is properly monitored at all
times.
22

10 CFR 20.1906(d) requires licensees to notify the carrier and the NRC Operations Center upon
receipt of a radioactive material package which is damaged, contaminated, or where radiation
levels exceed limits. This is needed so that NRC can, through inspection, ensure that shipment
procedures and practices are adequate to protect the health and safety of workers and the
public.
10 CFR 20.1906(e) requires licensees to develop, maintain and retain written procedures
regarding radioactive material shipment. This is needed to ensure that the packages containing
radioactive material will be opened in a manner consistent with the protection of the health and
safety of the public and workers.
10 CFR 20.2002 allows licensees to apply to the Commission for approval of procedures not
otherwise allowed in this Part regarding the disposal of licensed material. The application must
include: (a) a description of the waste, (b) an environmental analysis, (c) the nature and
location(s) of other potentially affected facilities, and (d) analyses and procedures to ensure that
doses are ALARA. This is needed to ensure that licensed material is handled in a manner that
will adequately protect the health and safety of the public and workers.
10 CFR 20.2004 requires Part 50 licensees who incinerate waste oils onsite to report any
changes or additions to the information supplied under 10 CFR 50.34 and 50.34 a, and to follow
the procedures of 10 CFR 50.59 with respect to such changes. This is needed so that NRC can
ensure that radioactive effluents associated with incineration of waste oils conform to the
requirements of Appendix I to 10 CFR Part 50.
10 CFR 20.2005(c) requires licensees to maintain records of waste disposal. The
recordkeeping requirement for this section is contained in 10 CFR 20.2108. This is needed to
allow NRC to ensure, through inspection, that waste disposal is in accordance with NRC
regulations.
10 CFR 20.2006(a) requires that licensees establish a manifest tracking system to control
transfers of low-level radioactive waste intended for disposal at a land disposal facility so that
NRC can inspect to ensure that adequate control of this material exists as specified in Appendix
G to 10 CFR Part 20.
10 CFR 20.2006(b) requires that licensees use NRC's Uniform Low-level Radioactive Waste
Manifest and transfer this information to the intended consignee, as specified in Section I of
Appendix G to 10 CFR Part 20.
10 CFR 20.2006(c) requires a certification by the waste generator, processor, or collector as
specified in Section II of Appendix G to 10 CFR Part 20.
The information in 10 CFR 20.2006 (a)-(c) is needed to control shipments and disposal of lowlevel waste (LLW) to ensure public health and safety and to protect the environment. The
specific requirements are discussed in more detail in Appendix G to 10 CFR Part 20.
These reporting requirements are covered under the clearances for NRC Forms 540, 541, and
542 (OMB Clearance numbers 3150-0164, 3150-0166, and 3150-0165).

23

10 CFR 20.2102(a) requires licensees to maintain records of the radiation protection program,
including ALARA provisions and program reviews. This is needed so that NRC can ensure,
through inspection, that the health and safety of workers and the public is adequately protected.
10 CFR 20.2102(b) requires licensees to retain records of radiation protection programs until
the Commission terminates the license. This is needed so that workers will have ready access
to radiation protection programs and procedures as long as the facility is in operation. This
paragraph further requires that licensees retain records of radiation protection program reviews
for 3 years. This is needed so that adequate records will exist at the time of inspection to
determine if the radiation protection program adequately protects the health and safety of
workers and the public.
10 CFR 20.2103(a) requires licensees to maintain records showing the results of surveys and
calibrations required by this Part. These records will be maintained for 3 years after the records
are created. This is needed to ensure, through inspection, that surveys required for adequate
radiation protection have been made.
10 CFR 20.2103(b) requires licensees to maintain records that form the basis of dose
estimates, results of air sampling surveys, and bioassays required under the Radiation
Protection Standard and results of measurements and calculations used to evaluate radioactive
effluents released to the environment be maintained for as long as the facility is licensed by
NRC. This is needed to ensure that adequate records exist at the time of routine inspection to
support an assertion that adequate radiation surveys have been performed and to ensure that
adequate records exist to reconstruct a worker’s dose estimate at any time during the period in
which the facility is licensed by NRC.
10 CFR 20.2104 requires licensees to attempt to obtain records of prior occupational exposures
prior to authorizing entry into restricted or controlled areas by individuals for whom personnel
radiation monitoring is required. This recordkeeping requirement is covered in a separate OMB
clearance for NRC Form 4 (OMB clearance number 3150-0005).
10 CFR 20.2105 requires licensees to maintain records of planned special exposures until the
Commission terminates the license since they form the basis for assessing dose to an
individual.
10 CFR 20.2106 requires licensees to record and maintain the results of individual monitoring
until the Commission terminates the license. This recordkeeping requirement is covered in a
separate OMB clearance for NRC Form 5 (OMB clearance number 3150-0006).
10 CFR 20.2107(a) requires licensees to maintain records of compliance with does limit for
individuals of the public. This is needed to permit assessment of the dose to the public that
might result from these radionuclide releases in order to confirm compliance with dose limits.
10 CFR 20.2107(b) requires that the records required in 10 CFR 20.2107(a) be maintained until
the license is terminated by the Commission as they form the basis for estimating dose.
10 CFR 20.2108(a) requires licensee to maintain records of waste disposal to permit (1) routine
inspection for compliance with the provisions of the sections in 10 CFR Part 20 related to waste
disposal, (2) inspection against constraints on the kinds and quantities of licensed material in
24

the possession of the licensee at any given time, and (3) assessment of the kinds and quantities
of radioactive material disposed of by various methods and the potential dose to the public.
10 CFR 20.2108(b) requires that the waste disposal records be retained until the termination of
the license by the Commission.
10 CFR 20.2110 establishes the quality, format and retention of records required by this Part.
There is no additional recordkeeping or reporting requirements associated with 10 CFR
20.2110. This establishes a common format to minimize confusion for workers moving from
licensee to licensee in the course of their employment and to facilitate inspection.
10 CFR 20.2201(a) requires licensees to report any theft or loss of licensed material by
telephone immediately or in writing within 30 days, dependent upon the potential risk to the
health and safety of the public associated with the missing radioactive material. This is needed
so that prompt corrective action can be taken.
10 CFR 20.2201(b) requires licensees to follow-up telephone reports with written reports of the
incident within 30 days of the telephone report. This is needed to ensure that the proper followup actions were taken by the licensee.
10 CFR 20.2201(d) requires the licensees to report any additional information relevant to the
loss of radioactive material, discovered subsequent to the written report, be submitted within 30
days of discovery. This is needed to ensure that the actions were taken to protect the health
and safety of workers and the public are based on complete information regarding the event.
10 CFR 20.2202(a) requires that the licensee immediately notify the NRC upon becoming aware
of specific incidents causing substantial exposures to or release of licensed material. This is
needed so that the NRC can identify possible generic problems and notify other licensees.
10 CFR 20.2202(b) requires that the licensee notify the NRC within 24 hours upon becoming
aware of specific incidents involving licensed material. This is needed to allow early evaluation
of the incident by NRC to ensure that appropriate action can be taken to protect against further
hazard to life or property.
10 CFR 20.2203(a) establishes that, in addition to the notification required by 10 CFR 20.2202,
each licensee is required to submit a written report within 30 days after learning of specific
incidents involving doses or concentrations of radioactive materials in excess of limits. This is
needed to ensure that there are appropriate follow-up actions to avoid a recurrence.
10 CFR 20.2203(b) contains the requirements for the content of reports required by 10 CFR
20.2203(a).
10 CFR 20.2204 requires licensees to submit a written report to the NRC within 30 days after a
planned special exposure. This is needed to ensure that the use of planned special exposures
is in accordance with requirements.
10 CFR 20.2205 establishes that when a licensee is required, pursuant to 10 CFR 20.2203 or
20.2204 to report to the Commission any exposure of an identified occupational exposed
individual, the licensee must also provide a copy of the report submitted to the Commission to
the individual at the same time.

25

10 CFR 20.2206(b) and (c) require licensees to report the results of individual monitoring
annually to NRC on NRC Form 5 or equivalent electronic media. These requirements are
covered under a separate OMB clearance for NRC Form 5 (OMB clearance number 31500006).
10 CFR 20.2207 requires licensees who manufacture, transfer, receive, disassemble, or
dispose of a nationally tracked source complete and submit a National Source Tracking
Transition Report as specified in paragraphs (a) through (e) of this section. Paragraph (f) of this
section specifies the timing requirements for the report, and the methods of submitting the
report. These requirements are included in the clearance package for NRC Form 748 (OMB
clearance number 3150-0202).
10 CFR 20.2207(g) requires licensees to correct errors in previously filed reports or file any
missed transaction reports within 5 business days of the discovery. The section also requires
licenses to reconcile and verify the inventory of nationally tracked sources possessed by the
licensee against the licensee’s data in the National Source Tracking System (NSTS) on an
annual basis. This verification is necessary to maintain the accuracy and reliability of the
system over time. The burden to correct errors and file missed transaction reports is included in
the clearance package for NRC Form 748 (OMB clearance number 3150-0202). The burden to
conduct an annual reconciliation with the NSTS database is included in this clearance package
for 10 CFR Part 20.
10 CFR 20.2207(h) required licensees to report their initial inventory of Category 1 and
Category 2 nationally tracked sources to the NSTS by January 31, 2009. The initial inventory
report included the source information such as make, model, serial number, radionuclides,
source strength, and date for which the source strength is reported. The report also included
the licensee name, address, and license number along with the name of the individual that
prepares the report. This information is needed to ensure accountability of nationally tracked
sources. This is a one-time collection that has been completed.
10 CFR 20.2301 allows licensees to apply to the Commission for exemption from this rule.
Appendix G, Section I requires that waste generators, collectors, and processors of LLW
intended for ultimate disposal at a licensed low-level radioactive waste facility to prepare a
manifest on NRC Forms 540, 541, and 542, as appropriate. The justification for the information
collection requirements in these forms are covered in separate OMB clearances for NRC Forms
540, 541, and 542 (OMB clearance numbers 3150-0164, 3150-0166, and 3150-0165).
This section specifies the specific data to meet NRC manifest requirements (i.e., shipper, date,
total radioactivity, container identification and description, physical and chemical description of
the waste, chelating agents, classification of the waste, radiation levels, etc.). This information
is electronically submitted to the NRC (discussed in 10 CFR 61.80(l)), to enhance the ability of
the NRC and State regulatory agencies to control and safely regulate disposal of LLW. Without
this information the ability for the licensee and the regulatory agencies to assess the site's
performance would be severely impacted and thus the regulatory agency responsibility to
protect public health and safety and the environment could not be adequately accomplished.
Appendix G, Section II requires that all generators, processors, and collectors certify by signing
and dating the shipment manifest, that the shipment is properly classified, described, packaged,
marked, and labeled to meet Department of Transportation, NRC, and State requirements. This
26

is necessary to ensure that the proper company official verifies that appropriate requirements
have been met prior to shipment.
Appendix G, Section III, Paragraphs (A)-(D) provides the specific manifesting procedures for
generators, processors, collectors, and the land disposal facility operators during shipment and
receipt of the LLW. This includes classification of and labeling of the LLW, conducting a quality
assurance program to assure compliance with §§ 61.55 and 61.56, requirement to use the NRC
Uniform Low- Level Radioactive Waste Manifest, requirements to provide the intended
consignee the manifest information and acknowledgment of its receipt and procedures in the
event acknowledgment is not received, and storage of manifest data. These procedures are
necessary to ensure that LLW is tracked from generator shipment to ultimate disposal and that
no LLW is unaccounted for. A quality assurance program is necessary to ensure companies
are properly following the procedures. The receipt acknowledgment is necessary to ensure
investigations are undertaken when LLW is not where it is supposed to be. The storage of the
manifest information is necessary to conduct audits and in the event that any discrepancies or
other problems needed to be investigated.
Sections A.5 (generators), B.3 (collectors), and C.6 (processors) authorize that the manifest data
may be transmitted electronically instead of by hard copy. This is a voluntary option designed to
allow the manifest system to work more effectively and efficiently.
Appendix G, Section III, Paragraph (E) requires investigations and reporting to NRC when LLW
has not been accounted for. This information is needed to identify and locate missing LLW and
to identify improper procedures.
NRC Online Forms, “Respirator Protection Exemption for Non-Power Reactors” and “Respirator
Protection Exemption for Power Reactors.” The NRC requires licensees to meet the medical
evaluation frequency and fit-testing frequency requirements specified in 10 CFR
20.1703(c)(5)(iii) and 10 CFR 20.1703(c)(6). Guidance for meeting these requirements can be
found in Regulatory Guide 8.15, Acceptable Programs for Respiratory Protection. Requiring the
licensed facilities to comply with the specific requirements in 10 CFR 20.1703(c)(5)(iii) and 10
CFR 20.1703(c)(6) may result in a licensee requiring personnel to take actions that are contrary
with the practices recommended by the Centers for Disease Control and Prevention (CDC) to
limit the spread of Coronavirus Disease 2019 (COVID-19). To facilitate and streamline
licensees’ requests for exemptions to these requirements, this information collection includes
two online forms to submit the required information for a specific exemption request. One form
is for power reactor licensees and the second is for research and test reactor (RTR) and nonpower reactor licensees to submit their exemption requests. The use of these online forms is
restricted to exemptions requests resulting from the impact of the COVID-19 PHE. Burden only
addresses the burden to complete and submit the online forms.

27