ML20135E799

Request for OMB Review & Supporting Statements Re Occupational Radiation Exposure History.Estimated Respondent Burden Is 7,500 H

ML20135E799
Person / Time
Issue date:	09/10/1985
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0005, OMB-3150-5, NUDOCS 8509170036
Download: ML20135E799 (14)

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(Reg septemtw,1983) Request for OMB Review

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Important

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M" Read instructmObe ore completing form. Do not use the same SF 83 Send three copies of this form, the material to be rewewed, arid for t) request both ah Liecutive Order 12291 review and approval under paperwork-three copies of the supporting statement. to.

the P:perwork Reduction Act Answer all questions in Part 1. If this request is for review under E.O. Office of Information and Regulatory Affairs 12291, complete Part il and sign the regulatory certification. If this Office of Managernent and Budget request is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 3201 1320, skip Part 11, complete Part ill and sign the paperwork certification Washington, DC 20503 PART l.-Complete This Part for All Requests.

1. Department / agency and Bureau /offce ong nating request 2. A6ency code U.S. Nuclear Regulatory Comission , ERC 4

_3_ 1_ E _0

3. Name of person who can best answer QAstions regarding this request Telephone number R. E. Baker '

(301 ) 443-4579

4. Title of informaten cosiecten or runemakmg Occupational Radiation Exposure History

5. Legal Luthonti or f eftwmation costecten or ruse (cite United States Code, Pubhc law, or Esecutive Order) 42 use 2201(o) ..,

6. Af*ected pubhc (check a# thatapply) 5 0 rederaiagencies or ernpio>ees 1 O ind-dua:s or househoids 3 0 rarms s O Non profstinst.tutions 2 O stateoriocargo.ernrnents 4 5 ausinesses or other tor. profit 7 5 smaribusinesses or organizatens PART ll.-Complete This Part Only if the u ti r hv ebnder Executive Order 12291

7. Regulat on identifier Number (RIN)

____,~___ _ , or, None assigned O S. Type of submissen (check one on each category) Type of review requested Cassification Stage of development 10 Standard l'O uajor i O eroposedordraft 2 O Pending 2 O Nonmator 2 O renaiormtenmr i.-ingnorproposai 3 0 cmergency 3 0 rinai er intenm finai. mtnout enor proposai 4 0 statutoryoriudiciaideadhne

9. CF A section affected CrR

10. Does this regulation contain reporting or recordkeeping requirements that require OM8 approval under the Paperwork Reducten Act and 5 CrR 1320?

O Yes O Na

11. lf a maior rule, is there a regulatory impact analysis attached? , 1 O ves 2 O No if"No," did OMB maeve the analysis?

3 0 ves 4 O No Certification for Regulatory Submissions in subtrhtting this request for OMB review, the authonzed regulatory contact and the program official certify that the requirements of E O 12291 and any applicable potcy d.rsctsves have been compted with.

s<gnatura of program off<iai Date s+gnaturn of authorized reguatory cortact 8509170036 850910 PDR ORO E D'

• DR l2. (OMB use only)

Pee n.n e:

20. Current (most recent) oM8 control number or comment number 24. Respondents *obligationtocomply(checAthestrorisestobigetaartthatapphes) 3150-0005 1 O volunta,y

21. Requested empiration date 2 O Required to obtem or retam a benefit September 1989 3 00 Mandatory

25. Are the respondents pnmardy educational agencies or institutens or is the pnmary parpose of the coinecten related to Federal educaten pro

26. Does the agency use samphng to select respondents or does the agency recommend or prescribe the use of samphng or statetical analyses by respondents? .

. . . . . . Oves O No

{ 27. Regulatory authorrty for the mformation collecten CFR :or FR :or.other(speerfy): 42 USC 220ll0}

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' in submitting this request for oM8 approval, the agency head, the senior officia! or an authortred representative. certefes that the requirements of 5 CFR 1320. the Prreacy Act statatical standards or derectrves, and any other opphcable informaten policy directives have been comphed with l Sqnsture of program official oete s.gnatura of agency head. the senior officas or an autnoreed representative oate Patricia G. Norry bd 8 --, Y >%

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N 4

SUPPORTING STATEMENT FOR 4

NRC FORM 4 0CCUPATIONAL RADIATION EXPOSURE HISTORY

1. Description of the Information Collection NRC Form 4 is used for any individual, prior to first entry of the indi-vidual into an NRC licensee's restricted area during each employment or work assignment, who is required by the NRC licensee to disclose prior occupational dose.

Under the current OMB control number 3150-0005, NRC Form 4 has 37,200 total recordkeeping t.ours in.the current OMB inventory.

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3 NRC Form 4 is being revised to reflect requirements in revised 10 CFR I

Part 20 that the form will be used by NRC licensees, in accordance with 5 20.1104, for recording the occupational radiation exposure history of i

each individual who enters the licensee's restricted or controlled area j

and is likely to receive or actually receives an annual dose in excess of 305 of the occupational dose limits for adults ($ 20.201(a)).

{ Under the proposed revision, OMB control number 3150-0005, NRC Foru 4,

} , will request 7500 total recordkeeping hours in the OMB inventory.

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) The difference of 29,700 total recordkeeping hours is an adjustment based

( on the NRC staff's judgment that NRC licensees will need 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to pre-

{ pare each of the 30,000 forms per year rather than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to prepare each

! of 37,200 forms per year to determine prior occupational dose. Less time j is now required to complete Form 4 because of: 1. increased use of com-l puters for recordkeeping and 2. revision of chronological order of infor-nation on form so latest information can be easily added.

2. Justification In order to protect the health and safety of workers, 9 20.201 requires licensees to control within specified limits the total occupational dose 2 Enclosure 2/ Addendum 3 h

received by workers. Compliance with this requirement is demonstrated by licensees maintaining dose records on NRC Form 4, or its equivalent. The form shows each period in which the individual received occupational exposure to radiation or radioactive material and is signed by the individual receivir.g the exposure.

a. Need for the Information Collection While a licensee cannot control the dose received by a worker in prior employments, the licensee needs to know the magnitude of such dose so that additional exposure in the licensee's facility will not cause the worker's total occupational dose to exceed the limits.

Paragraphs 20.1104(a)(1) and (2) require the licensee to obtain data on prior occupational dose received during thb current calendar year and on planned special exposures and overexposures received during the lifetime of the individual. These data are to be recorded on NRC i Form 4, or its equivalent. It is essential that these records of exposure history be maintained in order for inspection and enforcement of the limits on total occupational dose.

b. Practical Utility of the Information Collection The information on the prior occupational dose of a worker would be used by the licensee to control exposure of the worker so that additional dose does not cause the total occupational dose of the worker to exceed the limits. The records would also be used by NRC inspectors to determine compliance with the dose-limiting sections of the regulations. '

c. Duplication with Other Collections of Information None.

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d. Consultations Outside the NRC During the past 36 months, members of the Part 20 revision task force have discussed the proposed revision and sought comments on the various drafts from a number of interested parties. These r

consultations have included members of the following groups:

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l 3 Enclosure 2/ Addendum 3 i

y --Licensees of various types and sizes Architects, Engineers, Contractors Power Reactors (LWR)

Research Reactors Universities Uranium Fuel Cycl,e Facilities Medical Facilities Uranium Mills Well Loggers Radiographers, and others

--Trade Organizations Edison Electric Institute: Health Physics Committees, Subcommittees, and Task Forces American Mining Congress Atomic Industrial Forum, Subcommittee on Occupational Radiation Protection and Conference on Radiation Issues Westinghouse Health Physics Staff (REM Program)

Electric Power Research Institute

--Labor Unions International Brotherhood of Electrical Workers Utility Workers Union of America

--Public Interest-Groups Natural Resources Defense Council

--Health Organizations Health Pnysics Society: National, Local Chapters, and ad-hoc Study Groups American Association of Physicists in Medicine Society of Nuclear Medicine National Council on Radiation Protection and Measurements International Commission on Radiological Protection United Nations Scientific Committee on the Effects of Atomic Radiation 4 Enclosure 2/ Addendum 3

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--Agreement States Conference of Radiation Control Program Directors

--Federal Agencies and Committees Interagency Working Group on Occupational Exposure Guidance Environmental Protection Agency Department of Energy Department of Defense Advisory Committee on Reactor Safety and Subcommittees, NRC Occupational Safety and Health Administration Department of Health and Human Services

e. Other Supporting Information

" Cost of Compliance With Occupational Exposure Revisions to 10 CFR Part 20," 12-20-82, developed by S. Cohen & Associates, Inc., under contract with NRC.

3. Description of the Information Collection

a. Number and Type of Respondents Each of the 7,500 NRC' specific licensees would be required to deter- 5

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mine the prior occupational dose received during the current calendar year for each individual who enters the licensee's restricted area and is likely to receive in a year a dose requiring provision of indi-vidual mo:1itoring devices or services pursuant to S 20.502.

b. Reasonableness of the Schedule for Collecting Information The time period for obtaining the data on prior occupational dose is not specified. However, it would be necessary for the licensee to have such data before allowing the individual worker to receive significant additional exposure, in order to ensure that the dose limits are not exceeded by the individual's total dose.

c. Method of Collecting the Information The data on dose during prior employment would be obtained pursuant to SS 20.1104(a)(1) and (2) and would be recorded on NRC Form 4, or

its equivalent.

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d. Record Retention Period.

The records on NRC Form 4, or its equivalent, are to be retained

until the Commission terminates each pertinent license. requiring this record.,

e. Reportina Period This justification does not involve a reporting requirement.

f. Copies Required to be Submitted

The licensee is required to keep one copy of the NRC Form 4, or its ,

,, equivalent, for each individual for whom provision of individual monitoring devices or services is required pursuant to $ 20.502.

g. Format of Information to be Maintained or Submitted The format of the information to be maintained is established by NRC Form 4.

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4. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection

[ NRC Form 4, or its equivalent, must be completed by all 7500 licensees for all individuals requiring provision of individual monitoring devices or services pursuant to $ 20.502. Approximately 300,000

{ individuals are monitored and, by allowing a 10% annual turnover in

] the workforce, there would be 30,000 NRC Form 4s, or equivalents,

required per year. It is estimated that about 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of clerical time would be used to prepare the form, or its equivalent, using the

. data obtained pursuant to $$ 20.1104(a)(1) and (2), or about 7,500 I hours / year (30,000 forms x 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> / form).

1 Number of recordkeepers. . . . . . . . . . . . . . . . . . . 7,500 2 Annual hours per recordkeeper............. I  !

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3 Total recordkeeping hours................. 7,500  !

l b. Estimated Cost Required to Respond to the Collection ,

The cost of this requirement is estimated to be about $150,000 6 Enclosure 2/ Addendum 3

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>s (7,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> x $20/ hour).

An additional 5%, or $7,500, is allowed for the cost of maintaining the records. The total cost would be

$157,500/ year.

c. Source of Burden Data and Method for Estimating the Burden The burden data and estimates are judgments of NRC staff based on experience gained as licensees and as regulators.

d. Reasonableness of Burden Estimates Theestimatesofoverallburdenarecomparablet3thosedevelopedby 1

S. Cohen & Associates, Inc., under contract with the NRC.

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5. Estimate of the Cost to the Federal Government NRC cost is incurred by the inspectors review of the information on NRC Form 4, or its equivalent, and records maintained by licensees and by the cost of printing the NRC Form 4. An average of 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of inspection time per year is spent reviewing such records at each of about 70 reactor sites. An average of 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of inspection time per 3 years is spent 4

reviewing such records of about 7,475 materials licensees. <Therefore, the total inspection cost would be abouti$36,500/ year'(70 x 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> / year +

7,475 x 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> every 3 years = 730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br /> / year x $50/ hour). Federal printing costs forif.he forms would be about.$1,500/ year. The total cost to the Federal government would be about $38,000/ year.

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[7590-01]

1 3 APPENDIX G REVISED NRC FORM 4 OCCUPATIONAL RADIATION EXPOSURE HISTORY Revised NRC Form 4 is appended for the convenience of those who may wish to comment on the proposed regulations. It is not a part of the regulations. However, the Commission does solicit comments on its content.

If the proposed regulations are adopted and codified in Title 10 of the Code of Federal Regulations, the form will be used by licensees, in accord-ance with S 20.1104, for recording the occupational radiation exposure history of each individual who enters the licensee's restricted or control-led area and is likely to receive or actually receives an annual dose in excess of 30% of the limits in S 20.201(a).

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Enclosure 1 1

FORM NRC-4 OCdUPATIONALRADIATIONEXPOSUREHISTORY 1 NAME (Print - Lost, First, Middle) 2. SOCIAL SECURITY NO. 3. DATE OF BIRTH 4. MAIS, ADDRESS, & LICENSE f OF LICENSEE SUl9tATION OF DOSE EQUIVALENT

5. 5. 7. 8. 9. 10. 11. 12. 13. 14.

Previous employments involving Dates of Periods Lens of Skin Extree- Whole Over Planned Record, radiation exposure - list nasc employment of Eye ities Body Exposures Special Estimate, and address of employer (from - To: Exposure Exposures or Assumed (ress) (rees) (rees) (rees) (rees) (rees) (R.E. or A) i i n.

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I 15. 16. 17. 18. 19. 20.

I Total Total Total Total Total Tots!

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4 im 21. Remarks 15 r

1. M T 22. CERTIFICATION: I certify that the exposure history listed in Columns 5, 6, and 7 is correct and complete to the 8 g best of my knowledge and belief. c3 Employee Signature Date O

23. COUNTER I certify that the esposure history and the information on dose is correct and complete to the j CERTIFICATION: best of my knowlege and belief.

Employer $lanature Date

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(7590-01]

INSTRUCTIONS FOR PREPARATION OF NRC FORM 4 A separate copy of this form, or a clear and legible recora containing all of the information required on this form, must be prepared by each licensee of the NRC for each individual who enters the licensee's restricted area under circumstances that might result in the individual receiving a dose requiring provision of individual monitoring devices or services under 5 20.502 of " Standards for Protection Against Radiation,"

10 CFR Part 20. The requirement for completion of this form is stated in S 20.1104.

The licensee shall make a reasonable effort to obtain: a record of all names an'd addresses of previous employers during employment periods involving radiation exposure; reports of the individual's previously accumulated occupational dose for each period of employment during the current calendar year; and, prior to permitting an individual to parti-cipate in a planned special exposure, all planned special exposures and overexposures received during the lifetime of the individual. The licensee may accept an up-to-date NRC, Form 4 signed by the individual and countersigned by an appropriate official of the most recent employer or by the individual's current employer, if the individual is not employed by the licensee.

The licensee shall use the dose information to control further exposure of the individual within the limits specified in SS 20.201, 20.205, 20.206, and 20.207.

Listed below by item are instructions and additional information pertinent to completing this form:

Item 1. Self-explanatory.

Item 2. Self explanatory, except that if the individual has no social security number the word "None" shall be inserted.

Item 3. Self-explanatory.

Item 4. Self explanatory.

288 Enclosure 1 e

[7590-01]

Item 5. List the name and address of each previous employer for all previous work involving occupational exposure to radiation. Start with the first employer and work fcrward in chronological order to the most recent employer. For periods of self employment, insert the words "Self employed."

Item 6. Give the dates of each employment listed in Item 5.

Item 7. List the periods during which occupational exposure to radiation occurred.

Item 8. Enter the dose equivalent to the lens of the eye. The entries shall be for each period of employment during the current calendar year only. The dose entered for the lens of the eye is the eye dose equivalent, unless the licensee evaluates the dose to the lens through whatever shielding is present, or unless the eyes are protected with shields having a tissue equivalent thickness of at least 700 mg/cm2 . In the latter case, the dose entered for the lens of the eye is the deep dose equivalent. Do not include the dose received during planned special exposures.

Items 9 Enter the dose equivalent to the skin and extremities, respectively, and 10. The entries shall be for each period of employment during the current calendar year only. The dose to the skin and extremities is the shallow dose equivalent, and shall be averaged over 10 cm 2 in the region of highest exposure. Do not include the dose received during planned special exposures.

Item 11. Enter the sum of the (whole-body, external) deep dose equivalent and the committed effective dose equivalent for each period of employment during the current calendar year. (The licensee may assess deep dose equivalent through a tissue equivalent absorber of 300 mg/cm2 as for eye dose equivalent.) The licensee shall use the data obtained frem the records of previous occupational exposures of the individual or, in the absence of records, in accordance with the provisions in S 20.1104. The licensee may 289 Enclosure 1

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[7590-01) i use written estimates of dose provided to an individual at termination of employment pursuant to S 19.13(e) until the finally determined personnel monitoring data are available.

The licensee shall include dose received as a result of over-exposures, accidents, and emergencies, but shall not include dose received during planned special exposures.

Item 12. Enter that portion of the summation of dose equivalent for each body part that has exceeded the annual limit for that body part in any year during the lifetime of the individual.

Item 13. Enter the summation of dose equivalent received during planned special exposures. Separate entries shall be made for whole body (WB), lens of eye (Eye), skin (Skin), and extremities (Ext).

Note that the provisions for planned special exposures do not apply to the intake of radionuclides.

Item 14.

i Enter whether the data on doses were obtained from records (enter "R"), estimates of dose (enter "E") provided at termina-tion of very recent employment in the absence of the finally determined dose, or assumed (enter "A") in the absence of

. records in accordance with S 20.1104.

Item 15. Self explanatory.

Item 16. Self explanatory.

Item 17. Self explanatory.

Item 18. Self explanatory.

Item 19. Self explanatory.

Item 20. Self explanatory.

290 Enclosure 1

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[7590-01]

Item 21. This space should be used to record any unusual or limiting information about the data recorded on the form. This should include data on intake of radionuclides prior to (effective date); particularly the kinds or quantities of radionuclides listed in Table 3. S 20.205. It could include notation of contribution to dose from multiple employments during a period, or dose received by the individual as a patient during medical diagnosis and therapy.

Item 22. The employee must certify that the information in Items 5, 6, and 7 is accurate and complete to the best of the individual's knowledge. The date is th'e date of the individual's signature.

• Item 23. This certification may be used to implement the provision for acceptance of an up-to-date NRC Form 4 when countersigned by an appropriate official of the most recent or current employer (see S 20.1104(d)).

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1 291 Enclosure 1