ML20136E445

Request for OMB Review & Supporting Statement Re 10CFR19, Notices,Instructions & Repts to Workers,Insps. Estimated Respondent Burden Is 91,339 H

ML20136E445
Person / Time
Issue date:	12/08/1985
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0044, OMB-3150-44, NUDOCS 8601070022
Download: ML20136E445 (8)

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Request for GMB Review

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Important i,

Read enstructror s t fore completing form. Do not use the same Sr 83 Serid three copies of this form, the material to be reviewed, and for j

to request both an Executive Order 12291 review anct approval under paperwork---three copies of the st;pporting statement. to.

-the Paperwork Reduction Act.

Ansur all questeons in Part 1. If inis request is for review uncer E.O.

Office of Infor'mation and Regulatory Affairs 12291, complete Part il and si8n the regu'atory certificat.on it this Office of Management and Hudget recuest is for approval under the Paperwork Reduction A<.t and 5 CFR Attention: Docket Library. Room 3201

? 1320. skip Part it, comclete Part til and sign the paperwor k certif <ation.

Washington. DC 20503 PART 1.-Complete This Part for All Requests.

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1. Department / agency and tjureau/cf fice origir.ating re quest

2. A enty code 6

L U.S. Nuclear Regulatory Comission 3 1 5 0 7

). Nrtne of person aho can best ansmet Guestions regarding tms recuest Telephone number Jack R. Metzger

< 301 3 492-4947

4. I lle of intcrmatsor) collection or sufemahng l-10 CFR.19 - Notices, Instructions, and Reports to Workers; Inspections

5. Legal authonty f ar enfortnation r_o:lection or rule (cate Unsted States Cere. Publ*c le*. of becutsve Ordrr) 42 usc 2201(o)

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6. Alfectec putlic (cSece allthatap@)

5 C fede alagenciesof errpioyees r

1 h indev. duals or houserio.d.

3 C rarrns 6 G Non orce.tinst.iui.ons i

j 2 O State or low governrnents 4 E] Busir esses or otrier for prott 1 3 Small businesses or organitations PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulation Idanti er Non-t'er (RIN) f

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Qce et submewoon ((hn s cc e en t ach catepwy)

Type of revieev requested Clusificatioru Stage at deselopenent

C Stanord l'

1 C Maior 1 C F9erwe cor cut 2 C Pendeg 2 C ter maine 2 L ? nreier

< n i r + ~in ;> n v<<*nai 3 0 t rnerien<<

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3 C f;rw' or tras orn te A 6 t%t pr.or g.%posa!

4 C Statutory er tudioal deadline l

9. CF R setten a Hec ted r

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10. Dru this re guw.cn c ontain te r+rt.ry o4 rewrdm p.or. tro -m*,a

.+qu re OMB as unsai unt'er the Paperwor> Reduct.on Act ard 5 Cf'N 13201 O ies C t.a

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II. it a ma;ct rule, rt there a recWtrq enpact anain s ettaccai 1 C yes 2 O re It %c," d.r3 OMt1Ja.se tr,c anaps' 3 C Yes 4 C No i

' Cartification for Regulatory Submissions l.

In submitterig this request for OMU review. tt.e autherdett repeater, w te t.wr' 9 t t er reism c'tw ias cc tity t*a t+ e tv qu"eme+ts ett O ID91 arid ar.y aN, math r

poN V deret tv5 have rA er r empl-ed wth hEdie r ' rey ram ot'eru

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$~r.... r e.-.-........,,of a 2thenref tr e Wro y r or L.(t

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l ; PAST IJl.-Compi;ta This Part Cnly if the Cequ=t is for Appr;vil cf c Collection cf Inform tirn Under th7 Paperwork Reduction Act rnd 5 CFR 1320.

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13. Abstract-Oncode rtreds uses and affected public m 50 aords or less l

" Radiation safety, nuclear radiation monitoring, individuals, doces" The information in reports required by Section 19.13 of 10 CFR 19 is used by both individual radiation workers and NRC licensees to assure that radiation doses to individuals are maintained within established limits.

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!4. Type of infnr.naton collection (c*cc4 onir orre)

Informat*on collec tio% not contained in rules l

1 C pan 0r sua n:ss on 2 O tmergency suomission(cert f,cationattachedi informattoor c oilsctions contained in rules 3 b Enteng re gulanon (no change fstoposed) 6 Fmal or intarem fmat without pnor NDRM

7. Enter date of espected or actual Federal 4 O Notice of proc,osed rutemaking(NPRM)

A O Reguiar subm,ss.on Register publication at this stage of rulemaking 5 O final, NP7M was pr.e+uusly pubbshed B O Emargency submission (certificarronattached)

(mor ~ day, year):

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I5. Type of revese sequested (check anty one) t O me,,c3ivect,on 4 O Reinstatement of a previous y approved coiiection for wnicn app ovai 2 b Reesioq of J Cu' rent'y aDproved Col ection h e pired 3 0 Estens.on of the espiration date of a currentry approved conect<,n 5 O E isting coii ction in use witnout an oms contro number etnoga3 change in the substance or it the m?thod of couection It. Agenc o re.,oit w number (s)(soctvde standard l optional furon nurnDer(s))

22. Purpose of information cealet bon (check as manyas apply) t p

1 O Appucation for benefits

17. Annual reptq or d scmure nede" 2

Program evaluation 3 C General purpose statistics 4800 1 tLmer of reumdents 41] Reguatoryorcomphance 2 tuncer o responses p e +..omuent.

5' Program plannmg or management l

r 6 O Research 3 T st9 anraual responses (Wr I rimes t ne 2)

• I 7 O Aud t 4 Hws per responve S

l 5 Totat houQne 3 times I.ne 4) l

18. Annu 1recordheeping burden

23. Frequency of recordkeeping or reporting (check all that apply) i NA I Number of recordaeepers 1

Recordkeeping 2 Annual hours per recordkeeper.

8ePortins 3 Total recor@eeping hours (hne i times 6ce 2) 2 O onoccasion 4 hecurdkeeping retention penod years 3

Weekly

19. Iotal annual burden 4 O Montnir 9l'000

$ 0 @arterty i R:nuested (hne 17 5 plus Irne 18-3).

77,800 6 0 sem. annuan, 2 in current OMO mventory

+13,539 7 g 3nn,33, 3 D,tference t ine 11ess Ime 2)

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Esplanation of difference 8 0 B ennially 4 Precam chinge 9 ] other(descerbe) 5 AJus m.rt.

+13,539~

20. Current ( nost recent) OMS controf number or comment number

24. Respondents' obbgation to comply (chec4 the strongestobtegation thatapptres) r 3150-0044 1 O voiuntary

21. Recuested esairit.on date 2 O Required to obtain or eeta,n a benefit 11/88 3 K) u,nd,o,,

25. t.re the respondents pnmaniy educational agencies or institutes or is the pnmary purpose of the collection related to Federal education programs?

ves @ No

26. Does the agency use samphng to select respondents or does the agency recommend or presenbe the use of samphng or statistical analysis by responderr.e

. O ves G no

! 21MigQtor utnonty f r heinformation collection CfR

or rt

or,of her (specify).

e Paperworlt C'e~rtilNation in submitting this request for oMB approval, the agency head the senior official or an authonted representative certifies that the requirements of 5 CFR 1320 the Pnvacy Ad. stat.stic al standards or directives, and any other appbcabie information pohcy directives have been comohed with.

I signMure of proicam official Date I

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l signaturaof nencthead the senw afric

, author zed rapresentative oate Patricia G. Norry y4

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SUPPORTING STATEMENT FOR SECTION 19.13 of 10 CFR PART 19,

" NOTICES, INSTRUCTIONS, AND REPORTS TO WORKERS: INSPECTIONS" Description of the Information Collection 10 CFR Part 19, Section 19.13 " Notifications and Reports to Individcais,"

requires NRC licensees to give written reports of exposure to radiation as described in the following subsections from that regulation.

19.13(a) " Radiation exposure data for an individual, and the results of any measur6ments, analyses, and calculations of radioactive material deposited or retained in the body of an individual, shall be reported to the individual...

Each notification and report shall be in writing; include appropriate identi-fying data such as the name of the licensee, the name of the individual, and the individual's social security number; include the individual's exposure information; and contain the following statement:

This report is furnished to you under the provisions of the Nuclear Regula-tory Commission regulation 10 CFR Part 19.

You should preserve this report for further reference."

S19.13(b) "At the request of any worker, each licensee shall advise such worker annually of the worker's exposure to radiation or radioactive material as shown in records maintained by the licensee pursuant to S20.401(a) and (c)."

l S19.13(c) "At the request of a worker formerly engaged in licensed activities controlled by the licensee, each licensee shall furnish to the worker a report of the worker's exposure to radiation or radioactive material.

Such report shall be furnished within 30 days from the time the request is made, or withia 30 days after the exposure of the individual has been determined by the licensee, whichever is later; shall cover within the period of time specified in the request, each calendar quarter in which the worker's activities involved exposure to radiation from radioactive materials licensed by the Commission; and shall include the dates and locations of licensed activities in which the worker participated during this period."

S19.13(d) "When a licensee is required pursuant to S20.405 or S20.408 of this chapter to report to the Commission any exposure of an individual to radiation or radioactive material the licensee shall also provide the individual a report on his exposure data included therein.

Such report shall be transmitted at a time not later than the transmittal to the Commission."

(These are reports of radiation exposure in excess of NRC limits.)

S19.13(e) "At the request of a worker who is terminating employment in a given calendar quarter with the licensee in work involving radiation dose, or a worker who, while employed by another person, is terminating assignment to work l

involving radiation dose in the licensee's facility in that calendar quarter, each licensee shall provide to such worker, or to worker's designee, at termination, a written report regarding the radiation dose received by that j

worker from operations of the licensee during that specifically identified calendar quarter or fraction thereof, or provide a written estimate of that dose if the finally determined personnel monitoring results are not available at the time.

Estimated dose shall be clearly indicated as such."

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1.

Need for the Collection of Information The licensee is required to control radiation duses *.o individuals in restricted areas so that, 01th one exception, no one receives an accumulated dose during a quarter that exceeds the limits established by 10 CFR 20.101(a).

These r7diation drse limits are 1.25 rems to the whole body, 18.75 rems to the extremitf y and 7.5 rems to the skies of the wnoie body.

Section 20.101(b) perr.!ts s whole bo(y radiation dose per quarter not to exceed 3 rems provided that tha planned Auditional dose plus the lifetime accumulated dose does not exceed L (N-18), where "N" is the individual's age in years.

The individual should be informed of the radiation dose he or she receives because (3) that inforectich is needed by both a new employer and the individual when the employee ch.nggs jobs in the nuclear industry; (b) radiation dose information from post employers is needed when the individual is not changing jobs in order to Tetermine wnether additional exposure can be peamitted up to 3 rems per quarter baC 1 on the lifetime accumulated dose and the individual's age; (c) the individual needs to know the radiation dose received as a result of an accident or incident so that he or she can seek cpunseling aboint future work involving radiation or medical attention or both, as desi rad; and (d) since long term exposure to radiation may be an adverse health factor, the individual needs to know whether the accumulated dose is ueing controlled within NRC limits.

2.

Agency Use of Informa* ion Section 19.13 does not require the reporting office to send information to the NRC.

4 3.

Reduction of Burden Through Information Technology Not Applicable.

4.

Effort to Identify Duplication There is no duplication.

5. Effort to Use Similar Information There is no source for the required information other than licensees.

Licensees are required to mair,tain this information by the provisions of $20.401(a),10 CFR Part 20.

6. Effort to Reduce Small Dusiness Burden There is no feasible way of reducing the b den on small businesses while still accomplishing the objective of informing individuals of their exposure to radiation.

However, the burden is small and should have no significant impact on operating costs.

7. Consequences of Less Frequent Collection Workers would not be aware of their total radiction dose.

8. Circumstances Which Justify variation From OMB Guidelines No variation. >

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9. Consultations Outside the NRC There have been no additional outside consultations since the original consul-tations were held at the time the requirement was being considered for adoption.

10. Confidentiality of Information Not Applicable.

11. Justification for Sensitive Questions Not applicable

12. Estimated Annual Cost to the Federal Government There is no additional cost to the Federal Government.

13. Estimate of Burden Section 19.13(b) Annual Reports to Current Employees Approximately 4,800 licensees. monitor the radiation exposure to their workers.

The total population thus monitored is about 308,000 individuals. These data are based on reports which licensees have provided the NRC in compliance with the reporting requirement of 10 CFR 20.407(a).

Assuming that:

(1) each worker requests an annual report of his radiation exposure, and (2) each report takes 10 minutes of preparation time, the total compliance burden of S19.13(b) on the population of 4,800 licensees is estimated to be 51,333 man-hours per year.

(308,000 reports / year X 10 minutes / report = 51,333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br /> / year.)

Section 19.13(c) Reports to Former Employees Based on reports to the NRC of radiation doses that terminating employees have received, it is estimated that approximately 500 licensees are affected by the requirement to provide a report to former employees of the total dose received while in the employment of the licensee.

Since about 120,000 reports of individual terminations are made to the NRC each year, that is the maximum number of reports that could be requested by the affected former employees.

However, the number of individuals involved (as contrasted with reports) is around 53,000.

This indicates that there is a fairly large transient group that changes employers more than once per year.

Assuming that 50% of 120,000 terminations involve individuals who request a report of the radiation dose they received during their entire period of employment at that licensee's facility, the total burden is 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> / year (120,000 reports / year X 0.5 X 10 minutes - hour / report = 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> / year).

E minutes Section 19.13(d) Reports to Overexposed and Terminating Employees Section 20.405 of 10 CFR 20 requires licensees to report to the NRC any incident involving a radiation dose that exceeds NRC limits.

Section 20.408 of that regulation requires that the licensee report the radiation dose received during the period of employment at the time an employee terminates his/her employment..

In ecch of the two sets of circumstances define above, the licensee must also report the same information to the affected employee.

The 920.405 requirement affects a total population of approximately 4,800 licensees, the number providing radiation monitoring of their workers.

The number of individuals overexposed has ranged durina the years of record from about 15 to 50. Assuming that: (1) an average of 36 overexposures reports per year and (2) that each report takes 10 minutes to prepare, the total compliance burden of bl9.13(d) (for $20.405 reports) on the population of 4,800 licensees is estimated to be 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per year.

(36 reports / year X 10 minutes / report =

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.)

The 920.403 requirement affects about 500 licensees per year. This report is the same as required by fl9.13(c), the difference being that the $19.13(d) report is furnished automatically while the 919.13(c) report is furnished at the request of the terminating employee.

As the reports are similar, the same assumptions used for 619.13(c) are used for 919.13(d), and the total compliance burden of 619.13(d) on the pop (ulation of 500 licensees affected is estimated to be 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year.

120,000 reports 3 10 minutes / report = 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.)

Section 19.13(c) Report to Terminating Employee of Last Quarter's Radiation Dose With the exception of radiation exposure received during incidents, the reports described previously deal with the total radiation dose received during either a year or the period of employment at a single licensee's facility. However, since the radiation dose is controlled by a quarterly limit, it is desirable that a terminating employee receive a report of the dose received to date during the fraction of a quarter in which he/she has been employed by the licensne.

If that report indicates the limit has not been reached for the quarter, the individual can continue receiving radiation exposure during work activities during the rest of the qu6 Mer with the new employer.

As these reports involve the same assumptions used for 919.13(c) and 19.13(d),

the total compliance burden of $19.13(e) in the population of 500 affected licensees is estimated to be 10,000 man-hours per year (assuming 50% of employees will request report.)

(60,000 reports X 10 minutes / report = 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.)

14. Reasons for Change in Burden This supporting statement for extension of requirements in 10 CFR 19.13 contains an increase in the burden on licensees as a result of an increase in the number of individuals employed by licensees who receive exposure to radiation.

These affected individuals have increased from an estimated 787,000 in 1982 to a current estimate of about 308,000. By the rationale and estimates presented previously in this statement, the increased employment indicates an increase in the number of reports to individualr. from 467,000 in 1982 to a current estimate of 548,000.

The associated burden on licensees has correspondingly increased from 77,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in 1982 to about 91,300 in 1985. (See attached table for computatf or of 1985 burden.)

• While the total number of licensees has not changed appreciably,' there has been an increase in the number of operating nuclear power plants and a decrease in the number of fuel cycle facilities. Because there are many more workers monitored for radiation exposure at nuclear power plants, the net effect is an increase in the number of reports that licensees must prepare.

15. Publication for Statistical Use Not applicable.

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Attachment BURDEN TABLE RESPONSES PER TOTAL BURDEN PER SECTION RESPONDENTS RESPONDENT RESPONSES

RESPONSE

TOTAL BURDEN 19.13(b) 4,800 64.2 308,000 10 min.

51,333 19.13(c) 500 120 60,000 10 min.

10,000 19.13(d) 4,800 2.5 120,000 10 min.

20,000 i

500

.07 36 10 min.

6 19.13(e) 500 120 60,000 10 min'.

10,000 l-l Totals 4,000 114.2 548,036 10 min.

91,339 l

• Burden hours X $60.00/ hour l

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