Text

Request for OMB Review & Supporting Statement Re 10CFR20 Concerning Stds for Protection Against Radiation.Estimated Respondent Burden Is 115,210 H
	ML20137X802
Person / Time
Issue date:	12/03/1985
From:	Norry P; NRC OFFICE OF ADMINISTRATION (ADM)
To:	;
References
	OMB-3150-0014, OMB-3150-14, NUDOCS 8512100638
	Download: ML20137X802 (155)
	v • d • e

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l 5"*'"*" 8 3 (Re. feve rrnter juM) Request for DMB Reuleh [7__ o-Imp;rtant N Read instructions before completing form, Do not use the same SF 83 Send three copies of this forro, tre rnatetta! to be cerewed. ,md tw to reque4 both an Eaecutive Order 12291 review and approva! uncer paperwork--three copies of the sungorting stata ment, to the Paperwork Reduction Act Answer all questions in Part 1. If this request is for review under E.O. Of fice of Information and Regulatory Attwrs -

12291, complete Part ll and sign the regulatory certification. If this Office of Management and Budget request is for approval under the Paperwork Reduction Act and 5 CFR Attention: Dochet Library, Room 3201 1320, sWp Part 11, complete Part til and sign the paperwark certification. Washington, DC 20503 PART l.-Complete This Part for All Requests.

1. Department / agency and Bureau /of fice originating renuest -

2.M @ E ~ '~~~

U.S. Nuclear Regulatory Commission 31 5 0

3. N;ms of person who can best answer questions regarding this request l

~ 'adh'oEe~riun. Lee R. E. Baker 1301 3427-4579 4.1stle of information conection or rulemaking 10 CFR 20, Standards For Protection Against Radiation

5. Legal Luthority f or information collection or rule (cate United StJfes code, euenc tow. or necut,ve order) 42 2201(o)

USC . or

6. Affected public(check allthatapply) 5 Feder alagencies or employees 1 O indiviouaisorhousenoids 3 0 rarms e O non prof tinstitut.ons 2 O stateoriocaigovernments 4 0 Businesses orother for-profit 7 K] smaribus.nesses o, organizations PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Reguttion Identifier Number (RIN)

, _ _ ~ _ __ _ __. , or. None assigned O

8. Type of submissson (check one on each category) Type of review requested Classitiestion Stage of development 10 5tandard 1 Major 1 O eroposedordraft 2 O pending 2 E Nonmajor 2 O rinaiorinterimfinai,withpriorproposal 3 I Emergency 3 0 rinaiorintenrn vnai.without pnor proposai 4 O siaiutoryorjudiciaideaanne

9. CFR section affected CFR

10. Does this regulation contain reporting or recordkeeping requirements that require OMB approval under the Paperwork Reduction Act and 5 CFR 1320?

- O ves O no

11. If a mIgor rule, rs there a regulatory impact analysis attached? 1 O ves h O fa if"No, did OMB waive the analysis?

30ves 4 0 no Certification for Regulatory Submissions ~

ln submitting this request for OMB review, the authorized regulatory contact and the program offlClal certify that the requiremer:ts of E o.12291 and any apphcable pobey crectives have been comphed with S:;rutura ct program official Date Sgnature of authorized regulatory contact .

8512100638 851203 03.,

PDR ORG EUSOMB PDR

12. <0Me use on.y)

Previous ec,tions ensonete 83 108 standard Form 83 (M *s h i, h5M 754000 634 4034 hex'M W W s CFR 1320 ano t o 1231

7 PART lil>-Complete This Part Only if the Esquest is for Approval of o Collection (

of Information Under the P:n. .d Reduction Act and 5 CFR 1320. A l

13. Abstract-o scribe needs, uses and affected public in 50 words or less

" Nuclear radiation monitoring, radiation safety, package, theft, loss, nuclear material" Th2 NRC is' proposing a major revision of 10 CFR 20 which provides the-requirements for th2 protection of individuals who are exposed, both within and-outsfde of the workplace, to ionizing radiation from routine activities which are licensed the the NRC.

14. Type of information collection (check only one)

In Iermation cokoctione not contained in rules 10 Regularstbmission 2 O Emergencysubmission(certificationattached)

Inifornention conectione containee he rvene 3 O Eaisting regulatson (no cherve proposed) 6 Final or interim final without prior NPRM 7. Enter date of expected or actual Federal 4 O Notice cf proposed rulemaking(NPRM) A O Regular submission Register publication at this stage of rulemalung 5 O rinal, NPRM was previously published aO Emergencysubmission(certificationattached) (month, day, peer): December 1985

15. Type of review requested (check only one) 10 Newcollection 4 O Reinstatementatapre u.iyapprovedcasi.ctionforwhichapprovai 2@ Revsionof acurrentlyapprovedcollection has expired 3 O Extersson of the expiration date of a currently approved collection 5 O Eaisting collectson in use without an OMS controi number without any change in the substance or in the method of collection

16. Agency report form number (s)(onclude standard /optsonal form number (s)) 22. Purpone of information collection (check as manyas apply)

NA 1 O Appiecation for benefits 2 O Program evaluation

17. Annual reportmg or disclosure burden 3 General purpose statistics 1 Numberof respondents . 4 L '.] Regulatory or compliance 2 Number of responses per respondent. 5 O Program piarning or management 3 Total annual responses (hne 1 times line 2) 6 0 Research 4 Hours per response . 7 O Audit 5 Total hours (line 3 times line 4) l

18. Annuai recordkeepmg burden 23. Frequency of recordheepmg or reportmg(check a# that appfy) 1 Number of recordkeepers . .

I b Recordkeepmg 2 Annual hours per recordkeeper. #eporthw 3 Total recordkeeping hours (hne 1 times hne 2) .

2 @ onoccasion 4 Recordkeeping retention penod years a O weekly

19. Tot:1 annual burden 4 O Monthly 1 Requested (fine 17 5 plus line 18-3) . 115,210 5 @ que,,e,,,

21n current oMB inventory ..

6 0 s.mi-annuairy 3 Difference (fine f less hoe 2) . . 7 $ Annually

_ Espionstion ofd#ference 8 O sienniairy 4 Program change . . . . .. . 9 0 other(dence,b ):

5 Adiustment .

20. Current (most recent) oMB control number or comment number 24. Respondents

obligatson to comply (check the strotwest obigetion that applies) 3150-0014 i o voionta,y

21. Requested expiration date 2 O Required to obtain or retain a benefit <

October 1988 3 00 uandatory

25. Are the respondents primanly educational age.9eies or institutions or is the pnmary purpose of the collection related to Federal education programst O vos G No

26. Does the agency use sampling to select respondents or does the agency recommend or prescribe the use of sampling or statistical analysis by respondents? . . . . . O yes d No

27. Regulat authonty f r he information collection CFR :or FR ;or.other(specify):

Paperwork Certification in submitting this request for oMB approval, the agency head, the senior official or an authonzed representative, certifies that the requirements of 5 CFR 1320. the Pnv:cy Act, statistical standards or directives, and any other applicable information policy directives have been comphed with.

Sgnatureof programofficiat Date Signa re of Age c head. the senior official or an authonzed representative Date

' Of e of d ni ra n <- L7 12/3/85 u cm iu4 o - 4s 3-m

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OMB SUPPORTING STATEMENT FOR J,

10 CFR PART 20 - STANDARDS FOR PROTECTION AGAINST RADIATION Description of the Information Collection FM

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The NRC is proposing a major revision of its regulation 10 CFR Part 20,

" Standards for Protection Against Radiation," to provide the requirements for

, the protection of individuals who are exposed, both within and outside of the workplace, to ionizing radiation from routine activities (normal operations) which are licensed by the NRC.

The reporting requirements necessary to implement the proposed major revision are summarized in Table 1. Most of the proposed reporting requirements would not be changed in intent or substance from the present'10 CFR Part 20. New

-;t g reporting requirements would be proposed for planned special exposures and

.for a reference level of effective dos'e eodivalent to members of the public.

> For the purposes of SF-83, the annual reporting or disclosure burden would be:

Number of respondents 7,500 4

Number of responses per respondent 42.2 Total. annual responses 316,163

, Hours.per response 1 Total hours 31,632 c

1The recordkeeping requirements necessary to implement the proposed major revision are summarized in Table 2. Most of the proposed recordkeeping requirements would'not be changed in intent or substance from the present 10

~CFR Part 20. A new recordkeepfng requirement is that all licensees must incorporate "as low as reasonably achievable" considerations into their radi_ation protection programs. .A recordkeeping requirement not previously quantified is the long-standing requirement that all if,censees ensure that each container of license 6 material bears a durable, clearly visible label.

For the_ purposes of SF-83, the annual recordkeeping burden would be:

' Number of recordkeepers 7,500 Annual hours per recordkeeper 45.8 Total recordkeeping hours 343,230 The requested total annual burden would be 374,862 hours0.00998 days 0.239 hours 0.00143 weeks 3.27991e-4 months .

+ In the current OMB inventory under OMB centrol number 3150-0014, NRC has 115,210 hours0.00243 days 0.0583 hours 3.472222e-4 weeks 7.9905e-5 months . g

((4 ,

The difference of 259,652 hours0.00755 days 0.181 hours 0.00108 weeks 2.48086e-4 months is composed of 169,093 hours0.00108 days 0.0258 hours 1.537698e-4 weeks 3.53865e-5 months of program ,

-change for new reporting'and recordkeeping requirement's and 90,559 hours0.00647 days 0.155 hours 9.242725e-4 weeks 2.126995e-4 months of adjustment to reflect recent improved NRC staff judgments of estimated burdens on respondents.

Sepa' rate justifications foN the several reporting and recordkeeping requirements in revised 10 CFR Part 20'are set out below.

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ANNUAL RECORDKEEPING BURDEN i

1 i

Table 2. Annual Recordkeeping Burden Annual Burden per Proposed Section Recordkeepers Recordkeeper (Hrs) Annual Burden (Hrs)

(No.) ,

20.102 (a)(1) 7500 2.7 20,300 20.102(a)(4) 0 0 0 (See $20.1102) 20.202(a) 0 0 0 (See NRC Form 5) 20.202(b) 0 0 0 (See NRC Form 5) 20.204(a) 0 0 0 (See NRC Form 5) 20.204(c) 0 0 0 (See NRC Form 5) 20.204(d) 0 0 0 (See NRC Form 5) 20.204(h)(2) 0 0 0 (See NRC Form 5) 20.206(b) 0 0 0 (See t20.1105) 20.P.06(d) 0 0 0 (See 120.1104(a)(2))

20.206(g) 0 0 0 (See 520.1105) 20.206(h) 0 0 0 (See 520.1105) 20.501(a) 0 0 0 (See %20.1103) 20.502(a) 0 0 0 (See NRC Form 5) 20.502(b) 0 0 0 (See NRC Form 5) 20.<602(a)(3) 32 4 128 20.703(a)(2)(ii) '

0 0 0 (See 120.1103) 20.703 (2)(iv) 5 40 16.7

. 200 20.904 7500 125,000 '

20.904 (4) 100 1 100 20.905(d) 1200 1 1200 20.1005(c) . 0 0 0(See$20.llU8) 20.1102 7500 2 15,000 "

20.1103 7500 10 ~ 75,000 20.1104(a)(1) 7500 1.32 9'900 20.1104(a)(2) 70 5 20.1104(b) 0 0 .'350O (See NRC form 4) 20.1105 5 10 50

. 400 1 48,00 20.1108 4000 12 48,000 343,230 l

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SUPPORTING STATEMENT FOR -

10 CFR 20.102(a)(1)

AS LOW AS IS REASONABLY ACHIEVABLE LEVELS OF EXPOSURE

1. -Justification Paragraph 20.102(a) states that each licensee shall' ensure that the. dose to individuals receiving occupational dose and to members of the public I is as low as is reasonably achievable (ALARA) and does not exceed the appropriate limits. This requirement is responsive to long-standing recommendations of the National Council on Radiation Protection,-the

-International Commission on Radiological Protection, and guidance for Federal' regulatory' agencies'in Report No. 1 of the Federal Radiation-Council.

a. Need for the Information Collection

, The NRC believes that it is necessary for the licensee to include in the radiation protection program formal provisions for ALARA in order to achieve (1) a consistent level of-implementation of ALARA and (2) an inspectable and enforceable regulatory requirement for licensees.

b. Practical Utility of the Information Collection The ALARA provisions in the radiation protection program are used

.by employees of the licensee to guide the day-by-day conduct of radiation protection aspects of the licensee's activities.

c. Duplication With Other Collections of Information None.

2 Enclosure 2/ Addendum 2

^

b ; - ~% ~

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 con-sultations have included members of the following groups:

--Licensees of various types and sizes

~

Architects, Engineers, Contractors Power Reactors (LWR)

Research Reactors !

' Universities i Uranium Fuel Cycle Facilities Medical Facilities

. Uranium Mills

. Well Loggers Radiographers, and others -

s

--Trade Organizations Edison Electric Institute: Health Physics Committees, Subcommittees, 4

and Task Forces American Mining Congress Atomic Industrial Forum, Subcommittee on Occupational Radiation Protection and Conference on Radiation Issues

' West!.1ghouse Health Physics Staff (REM Program) t Electric Power Research Institute Labor Unions

, International Brotherhood of Electrical Workers

! Utility Workers . Union of America Public Interest Groups Natural Resources Defense Council i

3 Enclosure 2/ Addendum 2 rv - e w. ,w , <.m.+ w. - e.--. , -p. , ,- ,-e,-- - -~---a , m - , - g n- -<m- .,, e, .--- -,a- ---

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--Health Organizations Health Physics Society: National, Local Chapters, and ad-hoc g 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

--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 Succorting 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.

2. Description of the Information Collection

a. Number and Type of Resoondents The requirement in S 20.102(a)(1) applies to all NRC specific

. licensees. However, certain types of licensees, such as medical licensees, are already required to include ALARA provisions in their 4 Enclosure 2/ Addendum 2

i radiation protection programs by conditions or technical specifica-tions in their licenses. The regulation will, therefore, be a new requirement for about 5,500 licensees (7,500 total licensees - 2,000 licensees already with ALARA provisions).

b. Reasonableness of the Schedule for Collecting Information Licensees would be expected to have developed ALARA provisions for the guidance of workers in their facilities before beginni'ng opera-tions. For those licensees already operating without formal ALARA provisions being required by their license, such provisions would be expected to be in place when the revision of Part 20 becomes effec-tive. It is planned to make the revision effective within five full calendar years following publication as a final rule so that licen-sees can meet new or modified requirements.

c. Method of Collecting the Information Licensees will be required to. develop a radiation protection program, including ALARA provisions, for use within their operations. Para-graph 20.102(a)(1) does not require the submittal of the program or the ALARA provisions for NRC review.

d. Record Retention Period Recordkeeping aspects pursuant to S 20.102(a)(4) are treated separately (see S 20.1102).

e. Reporting Period Licensees would be required to develop the radiation protection program, including ALARA provisions, but are not required to submit the program for NRC review.

5 Enclosure 2/ Addendum 2

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f. Copies Recuired to be Submitted None. l

g. Format of Information to be Maintained or Submitted The format of the radiation protection program, including ALARA provi-sions, has-not been specified in the regulation. The programs will

. vary in complexity commensurate with the complexity of the activities-conducted by the licensee. Guidance on the contant of the radiaton protection programs and ALARA provisions has been provided in Divi-sion 8 Regulatory Guides.

3. Estimate of Burden

a. Estimated Hours Recuired to Respond to the Collection

It is estimated that about 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , as an average, will be required by each of 5,500 licensees not currently required to have ALARA provisions to develop ALARA provisions for inclusion in their radia-tion protection programs, or about 44,000 hours0 days 0 hours 0 weeks 0 months . -An additional 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per year, as an average, is estimated for updating or modi -

fying the program provisions. The first year the 2,000 licensees who already have ALARA provisions in place will have to update their pro-visions. -After the first year, all 7,500 licensees will have to spend an average of one hour / year updating their ALARA provisions.

1 Number of recordkeepers..................... 7,500 2 Annual hours per re'cordkeeper............... 2.7 3 _ Total recordkeeping hours................... 20,300

b. Estimated Cost Required to Respond to the Collection The first year cost for the development of radiation protection programs including ALARA provisions is estimated at $2.2 million 6 Enclosure 2/ Addendum 2

e 4 (5,500 licensees x 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months x $50/ hour). The annual updating is estimated at $375,000 (7,500 licensees x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months x $50/ hour).

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

d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government NRC cost is incurred by inspectors reviewing the radiation protection program and ALARA provisions. The NRC inspectors presently review the licensee's radiation protection programs as part of their inspection.

The added requirement is estimated to require, on the average, 1 addi-tional hour during each inspection, taken as once every 3 years. The estimated cost is $125,000 per year (7,500 licensees x 1/3 hour per year x $50/ hour).

7 Enclosure 2/ Addendum 2

d SUPPORTING STATEMENT FOR '

. 10 CFR 20.602(a)(3) and (b)

ADMINISTRATIVE AND ALTERNATIVE CONTROLS FOR ACCESS TO VERY HIGH RADIATION AREAS

1. Justification e.

h Very high radiation areas, by definition, offer the real.and immediate

/ danger of lethal. exposures. Section 20.602 requires primary controls, i

secondary controls, and administrative controls but also in*/ites the licensee to propose alternative methods of control. The multi-layers of

. controls are required to make the probability of inadvertent exposures extremely unlikely. The alternative opti,on is a recognition that control L

of a specific application might. benefit by a unique control method. In any event, clearly specified procedures and records are vital to ensure understanding of the control system.

~

- $ 20.602'a)(3) rcquires that the licensee institute administrative controls.

in addition to those required in S 20.601 to ensure that there is control l of access to very high radiation areas.

$ 20.602(b) provides that a licensee may apply to the Commission for approval of alternative methods for controlling access to very high radia-tion areas.

a. Need for the Information Collection Information describing the administrative controls is necessary to ensure that all workers will follow approved procedures in working in or about very high radiation areas. ' Descriptions of alternative systems are needed in order to fully understand the proposed alter-

- natives.

8 Enclosure 2/ Addendum 2 y--a * --'-r- - -

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b. Practical Utility of the Information Collection It is essential that the licensee who opts to use an alternative

method to control access to a very high radiation area provide a full and detailed description of this method to the Commission in order that health and safety is not compromised. The information will be used by NRC licensing staff to make a judgement on the adequacy of the' alternative to avoid lethal exposures. This information will be used by NRC inspectors and others to ensure that such controls are in

-place and operative and thus avoid inadvertent exposures of workers to very high dose rates which could cause lethal doses in short periods of time.

c. Duplication with Other Collections of Information None.

l

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. Thesa consulta--

tions have included representatives of the following groups:

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

Research Reactors

Universities Uranium Fuel Cycle Facilities-Medical Facilities Uranium Mills Well Loggers

. Radiographers, and others 9 Enclosure 2/ Addendum 2

--Trade Organizations Edison Electric Institute: Health Physics Committees, Subcommittees, and Task Forces American Mining Congress Atomic Industrial Forum, Subcommittee on Occupational Radiation Protection and Coaference 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 Physics Society: National, Local Chapters, and ad-hoc Study Groups American Association of Physicists in Medi. cine 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

--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 l Advisory Committee on Reactor Safety and Subcommittees, NRC 10 Enclosure 2/ Addendum 2

Occupational Safety and Health Administration Department of Health and Human Services

e. Other Supporting Information None.

2. Description of the Information Collection

a. Number and Type of Respondents 5 20.602(a)(3)--The proposed change in administrative controls would require approximately 85 licensees including reactor operators, irradiators, high level waste facilities to institute administrative controls in the first year and approximately 5 licensees among the same categories each year thereafter.

5 20.602(b)--The proposed change in alternative methods would affect mostly reactor licensees. Approximately 100 licensees would be affected by this new requirement the first year and 5 licensees per

~

year thereafter.

b. Reasonableness of the Schedule for Collecting Information The information must be submitted with the application so that the adequacy of the radiation protection program to prevent overexposures can be evaluated.

c. Method of Collecting the Information The application for a license is the only source of information on administrative [520.602(a)(3)] and alternative [9 20.602(b)] controls to a proposed activity.

11 Enclosure 2/ Addendum 2

1 I

d. Record Retention Period i Administrative procedures and plant design information are routinely maintained by all facilities and should be retained for the lifetime of the facility.

e. Reporting Period Information is submitted as part of the application for license.

f. Copies Required to be Submitted -

One copy is required to be_ filed with NRC.

g. Format of Information to be Maintained or Submitted Not specified.

3. Estimate of Burden .

a. Estimated Hours Required to Resoond to the Collection S 20.602(a)(3)--The time required to supply information about the administrative controls is approximated at 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per licensee for a total time estimate of 340 hours0.00394 days 0.0944 hours 5.621693e-4 weeks 1.2937e-4 months among 85 licensees in the first year and about 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months each year _among 5 licensees annually thereafter.

1 Number of recordkeepers........................ 32 2 Annual hours per recordkeeper.................. 4 l

3 Total recordkeeping hours...................... 128 9 20.602(b)--An estimate of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per license applicant is projected.

Therefore, the time burden would be approximately 400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months for 100 licensees for preparing the information concerning altern"ative methods the first year and 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months for 5 licensees per year thereafter.

12 Enclosure 2/Addendem 2

. . . - .. _ - .-- = . . - _ - - _

. .- .. . - = -_

-g a S 20.602(b) i 1 Number of respondents.......................... 37 2 Number of responses per respondent............. 1

- 3 Total annual responses......................... 37

- 4 Hours per response............................. 4

. - 5 Total hours.................................... 148

b. - Estimated Cost Required to Respond to the Collection

, 9 20.602(a)(3)--The rate used to determine the cost of complying with the administrative control information requirement is $50 per hour

- of staff. time. This yields a cost of $17,000 in the first year and about $1,000 each year thereafter.

S' 20.602(b)--At $50 per hour of staff time, applying for alternative control methods would cost'each of the 100 licensees $200 the first year. The projected first year cost is $20,000. The annual cost 4 would be $1,000 after the first year.

c. ~ Source of Burden Data and Method for Estimating the Burdon s

- The burden estimates were obtained from a review of the kind of -

- activities licensed by NRC and consideration of the amount of time estimated to be required by licensees to describe administrative and alternative controls.

, 'd . -Reasonableness of Burden Estimates The estimates by NRC staff are believed to be realistic or even con-servative, e.g., an overestimate of the total costs. No firm basis for the cost projection exists.

4. -

Estimate of the Cost to the Federal Government l . 5 20.602(a)(3)--Cost to the NRC will be incurred during the evaluation of

, - the administrative controls and during onsite inspections. The cost of 13 Enclosure 2/ Addendum 2 e - , ,--,, - - - - - . -

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the evaluation would be (85 applications x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months x $50/ hour) about $4,250 the first year, and (5 applications x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months x $50/ hour) about $250 each year thereafter. The cost of the inspections would apply to all of the licensees having such administrative controls and would cost about (260 licensees x 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months / inspection every 3 years x $50) $2,200/ year. The total cost would be about $6,500 the first year, and about $2,500/ year thereafter.

S 20.602(b)--The cost incurred by NRC to review the licensee's alternatives is estimated at 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per licensee initially for a time burden of 400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months the first year. At $50 per staff hour for review, this would cost

$20,000 in the first year. Thereafter, 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months of inspection time would be expended by NRC to review alternatives submitted annually by approxi-mately 5 licensees. This yields a monetary commitment of $1,000 annually based on $50 per hour for 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months .

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l 14 Enclosure 2/ Addendum-2

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SUPPORTING STATEMENT FOR 10 CFR 20.703 (a)(2)(iv), (a)(3), (a)(5) and (b)

RESPIRATORY PROTECTION PROGRAM a

1. Justification

.Section 20.703 sets forth requirements applicable to the protection of workers against the intake of radioactive material, particularly applicable to-the use'of respiratory protection equipment. Included are (1) require-ments for written procedures regarding selection, fitting, issuance, main-tenance, and. testing of respirators; supervisic, and training of personnel; and recordkeeping ($ 20.703(a)(2)(iv)); (2) requirements for issuance of a written'policystatementonrespiratorusage($'50.703(a)(3));(3) require-ments for specific approval before u' sing respiratory protection equipment

. that has not been tested or certified by NIOSH/MSHA, has not had certifica-tion extended by NIOSH/MSHA, or'is not on an existing schedule for testing or certification ($ 20.703(a)(5); and (4) requirements for prior authort-zation before assigning respiratory _ protection factors in excess of those specified in Appendix A of Part 20 (S 20.703(b)).

a. Need for the Information Collection S 20.703(a)(2)(iv) Written procedures are needed to establish the licensee's use of reapiratory protection equipment.

$ 20.703(a)(3) The written policy statement is needed to establish certain administrative aspects of the program such as: the routine, nonroutine, and emergency use of respirators; the use of process engineering controls, instead of respirators; and the periods of respirator use and relief from respirator use.

$ 20.703(a)(5)--The requirement permitting use of only respiratory protection devices that have been tested or certified by NIOSH/MSHA 15 Enclosure 2/ Addendum 2

or specifically approved by the NRC staff is needed to ensure pro-tection of the worker.

5 20.703(b)--The requirement for prior approval before assigning respiratory protection factors higher than those already specified in Appendix A of Part 20 is needed to ensure protection of the worker. .

b. Practical Utility of the Information Collection S 20.703(a)(2)(iv)--The written procedures will be used by the licensee's staff in the daily conduct of the respiratory protection program and by the NRC inspectors in reviewing the licensee's program.

S 20.703(a)(3)--The written policy statement will be used by the licensee's staff in making decisions about the conduct of the respira-tory protection program and by the NRC inspectors.

S 20.703(a)(5)--The information on alternative respiratory protection devices that the licensee wishes to use will be evaluated by the NRC staff in order to ensure protection of workers prior to use of those devices.

S 20.703(b)--The data on specific respiratory protection devices, sub-mitted in support of an application to use higher protection factors, will be evaluated by the NRC staff prior to the use of the higher protection factors in order to ensure protection of workers against the intake of radioactive material.

c. Duolication with Other Collections of Information None.

16 Enclosure 2/ Addendum 2

d. Consultations Outside the NRC During the past 36 months, members of the Part 20 revisio task force have discussed the proposed revision and sought comments on the various drafts from a number of interested parties. These consulta-tions have included representatives of the following groups:

4

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

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

--Trade Organizations Edison Electric Instit'ute: 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) l Electric Power Research Institute

--Labor Unions International Brotherhood of Electrical Workers Utility Workers Union of America i --Public Interest Groups Natural Resources Defense Council 17 Enclosure 2/ Addendum 2 I

t 6

~

e- , - . , ~ - - , - - ,w-.- - - - - - .~ ,- ---.. . . . , - ,~,--,--,.-,wr , ,, -n.,-,~m- w - - , . . , , .,.

r--

--Health Organizations Health Physics 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

--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 Succorting Information The requirements in S 20.703 are not new in the revision of Part 20 t

and have been the subject of prior rulemaking procedures associated with the existing S 20.103.

! 2. Description of the Information Collection f

a. Number and Type of Resoondents l

The requirements in S 20.703 will apply to about 175 large licensecs,

{ , such as power reactors, uranium mills and fuel processors, and some l lcrge suppliers of radioactive materials, whose operations might l

l 18 Enclosure 2/ Addendum 2

involve significant airborne concentrations of radionuclides. It is estimated that there may be 5 licensees per year responding to SS 20.703(a)(2)(iv) and 20.703(a)(3). We have estimated one applica-tion / year from one of these licensees for the provisions of SS 20.703(a)(5) and 20.703(b).

-b. Reasonableness of the Schedule for Collecting Information The written procedures and policy statement need to be established before use of respiratory protection, as required, to ensure the safety of the worker. Evaluations of alternative respiratory protec-tion devices, and the protection factors to be assigned to respira-tory protection devices, also need to be performed and established before use in order to protect the worker.

c. Method of Collecting the Information The information involved in each of the four requirements included in this justification is available only from the applicant-licensee.

The licensee must establish the procedures and policies so they are applicable to the licensee's operations. The licensee must submit supporting documentation for requests to use alternative devices or to claim protection factors other than established factors.

d. Record Retention Period

$20.703(a)(2)(iv)--The licensee shall maintain the written procedures required by this section for the lifetime of the license.

e. Reportina Period In all four requirements under this report justification, the only specification of time is that the matters are to be established

. prior to use of the respiratory protection equipment.

19 Enclosure 2/ Addendum 2

f. Copies Required to be Submitted Copies of the written procedures and policy statements should be made available to all of the workers in the licensee's facility that are involved in the respiratory protection program. A_ copy is also to be maintained for inspection. One copy of the application required pursuant to SS 20.703(a)(5) and 20.703(b) is to be filed with the NRC.

_ g. Format of Information to be Maintained or Submitted The format-of the written procedures, policy statements and applica-tions is not specified.

3. Estimate of Burden

.'e s -

.a. Estimated Hours Required to Respond to the Collection 5 20.703(a)(2)(iv)--Th'e time required to develop the written proce-dures is estimated at 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months for each of 5 licensees per year, or 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months / year.

1, Number of recordkeepers................... 5 2 Annual hours per recordkeeper............. 40 3 Total recordkeeping hours................. 200

$ 20.703(a)(3)--The time required to develop and issue the policy statement is estimated at 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for each of.5 licensees per year, or 40_ hours / year.

5 20.703(a)(5)--The time required for one licensee to file the informa-tion is estimated at 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months . Of this, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are technical-staff time and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months are clerical time.

5 20.703(b)--The time required by one licensee to file an application for higher protection factors is estimated at 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months . Of this, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are technical staff time and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months are clerical time.

l 20 Enclosure 2/ Addendum 2 l i

l

_J

$ 20.703 (a)(3) (a)(5) (b) 1 Number ~of respondents................ 5 1 1

~

2 Number of responses-per respondent... 1 1 1 3 Total annual responses............... 5 1 1 4 Hours per response................... 8 28 28 5' Total hours.......................... 40 28 28 The total burden of these provisions is 296 hours0.00343 days 0.0822 hours 4.89418e-4 weeks 1.12628e-4 months / year.

b. Estimated Cost Recuired to Resoond to the Collection I

The estimated annual costs are:

$ 20.703(a)(2)(iv) $10,000 (5 licensees x 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months x $50/ hour)

$ 20.703(a)(3) $ 2,000 (5 licensees x 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months x $50/ hour)

$ 20.703(a)(5) $ 1,280 (1 licensee x 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months x $50/ hour +

q 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months x $20/ hour)

5 20.703(b) $ 1,280 (1 licensee x 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months x $50/ hour +

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months x $20/ hour)

Total $14,560 I

i'

c. Source of Burden Oata and Method for' Estimating the 8urden The burden data and estimates are judgements of NRC staff based on experience gained as licensees and as regulators.

d. Reasonableness of Burden Estimates The estimates of burden are thought to be reasonable. No alternative information is available.

' 4. Estimate of the Cost to the Federal Government 4

Cost is incurred by the NRC inspectors reviewing the written procedures and policy statements (SS 20.703(a)(2)(iv) and 20.703(a)(3)), and the NRC 21 -

Enclosure 2/ Addendum 2 4

....-.---,_,.y. . , .,_n.- , , ~ . , _ , , ,_,,4.m.4., - , . . - . -,_..,._,,,4~7 _,.....,,3- ,.r--- . , . . , -4.. , e,

Itcensing staff evaluating the applications for use of alternative respiratory protection devices and use of higher protection factors (SS 20.703(a)(5) and 20.703(b)). These annual costs are estimated as:

S 20.703(a)(2)(iv) $10,000 (5 licensees x 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months x $50/ hour)

-S 20.703(a)(3)- $ 1,250 (5 licensees x 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months x $50/ hour)

S 20.703(a)(5) $ 1,000 (1 licensee x 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months x $50/ hour)

S 20.703(b)- $ 1,000 (1 licensee x 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months x $50/ hour)

Total $13,250 22 Enclosure 2/ Addendum 2

i SUPPORTING STATEMENT FOR 10 CFR 20.904(a) and 20.904(c)(4)

LABELING OF CONTAINERS OF LICENSED MATERIAL AND EXCEPTIONS i'

s

. 5 20.904(a) requires that the licensee ensure that each container of licensed material bears a durable, clearly visible label identifying the radionuclide(s),

the estimate of the quantity of radioactivity, and the date for which the activ-ity is estimated. Exceptions to this statement are provided for in 5 20.904(c).

5 20.904(c)(4) provides that a licensee is not required to label containers if 3

it'is not practical to do so, and if such contents are identified to the appropriate individual by a readily available written record which is retained as long asLthe containers are in use for the purpose indicated on the record.

T l

1. Justification

$ 20.904(a)--In order to avoid or minimize exposures, it is necessary.that the worker know what r,adiation source he is using or handling. One way

.of doing this is by labeling the containers.

5 20.904(c)(4)--In some instances, it is impractical to label some con-l, ~ tainers. In such cases, a record containing certain information that '

4 otherwise would appear on a label can be placed in a readily available i

record.

j l

a. Need for the Information Collection In order to be adequately informed of the potential radiological hazard associated with licensed material in a container, there is a need for each container of licensed material to bear a durable,

[ clearly visible label identifying the radionuclide(s), the estimate I

~

of the quantity of radioactivity, and the date for which the activ-

[ .ity is estimated. The label shall bear the radiation symbol and the i

23 Enclosure 2/ Addendum 2

.. . .- . _. - -- - - . - _ - - _ ~ _ -

-words "CAHTION, RADIOACTIVE MATERIAL" or "0 ANGER, RADIOACTIVE MATE-RI AL. 'I It shculd also' provide sufficient information to permit indi-viduals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposures.

The licensee should ' include appropriate information such as radiation

, -levels, kinds of materials, and mass enrichment. +

In cases where the labeling is impractical ($ 20.904(c)(4)), records must identify the'radionuclide(s) in the container (s), the estimate of the quantity of radioactivity, and the date for which the activity is estimated. The records should also provide sufficient information to permit individuals handling or using the container, or working in the vicinity of the containers, to take precautions to avoid or minimize exposures. The records should include appropriate informa-tion such as radiation levels, kinds of material, and mass enrichment.

b. Practical Utility of the Information Collection l

It is essential that.the containers of radioactive material be properly' labeled (S 20.904(a)) in order to ensure recognition and proper use of the material, thus avoiding accidental exposures.

When it is impractical to label containers in accordance with 5 20.904(a), or if'the labels on the containers would not be helpful to the worker, e.g., such as containers stored under water, the appropriate information in a readily accassible -location will pro-vide an acceptable alternative to direct labeling of the container.

e i c. Duplication with Other Collections of Information None.

1 l

d. Consultations Outside the NRC

!=

l -

l During the past 36 months, members of the Part 20 revision task l force have discussed the proposed revision and sought comments on l-t L 24 Enclosure 2/ Addendum 2 L

E t the various drafts from a number of interested parties. These consultations have included representatives of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle Facilities

, Medical Facilities Uranium Mills Well Loggers Radiographers, and others 4

--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 Physics Society: National, Local Clapters, and ad-hoc Study Groups

. American Association of Physicists in Medicine Society of Nuclear Medicine 25 Enclosure 2/ Addendum 2 s

National Council on Radiation Protection and Measurements International Commission on Radiological Protection United Nations Scientific Committee on the Effects of Atomic i Radiation .

--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 Subccmmittees, NRC Occupational Safety and Health Administration Department of Health and Human Services O. .0ther Supporting Information None. ,

i i

2. 09scription of the Information Collection

a. Number and Tyoe of Respondents 8 20.904(a)--This proposed provision would apply to all 7,500 HRC licensees. Licensees are assumed to use an average of 1,000 labels per year. Thus, it is estimated that approximately 7,500,000 labels c

will be provided and placed on containers by all licensees.

4

$ 20.904(c)(4)--Approximately 100 licensees, including power reac-tors, irradiators and others who might use high level sources, are i

anticipated to use this alternate method in lieu of labeling.

26 Enclosure 2/ Addendum 2 l

_,'[ , - _. _,. _ _ _ _

-m , , - - , -

i

b. Reasonablenass of the Schedule for Collecting Information This information on the content of containers of radioactive material must be available when the material comes into the licensee's posses-sion. This timing is necessary and reasonable to protect the health ,

and safety of workers.

c. Method of Collecting the Information The information required by SS 20.904(a) and 20.904(c)(4) is avail-able from the licensee's normal technical and administrative sources.

No collection method is specified by the regulation.

d. Record Retention Period

/ 9 20.904(a)--The licensee is required to maintain a label on the con-

<s tainer of rad'oactive i material as long as necessary to ensure recog-nition and proper use of the radioactive material, i.e. for the life-time of the container and its radioactive contents.

I S 20.904'c)(4)--The

( written record is retained as long as the con-tainers are in use for the' purpose indicated on the record.

e. Reporting Period

. .i l k' Not applicable.

f. Copies Required to be Submitted Not applicable.

g. Forma't-of Information to be Maintained or Submitted Not specified.

27 Enclosure 2/ Addendum 2 i

3. Estimate of Burden

a. Estimated Hours Reouired to Respond to the Cellection 5 20.904(a)--An estimate of 1 minute per label or 125,000 hours0 days 0 hours 0 weeks 0 months of licensee time per year is projected for the direct labeling re, qui rement.

.$ 20.904(c)(4)--An estimate of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per year for each of the 100 affected licensees or 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months of licensee time per year is projected when the exception to direct labeling is used.

S 20.904(a) S 20.904(c)(4) 1 Number of recordkeepers.............. 7,500 100 2 Annual hours per recordkeeper........ 16.7 *1 3 Total recordkeeping hours............ 125,000 , 100

-b. Estimated Cost Required to Respond to the Collection S 20.904(a)--At $20 per hour of clerical time, the annual cost is

$2,500,000.

-5 20.904(c)(4)--At $50 per~ hour of staff time, the annual cost would be $5,000.

c. Source of Burden,0ata and Method for Estimating the Burden The burden estimates were obtained from a review of 'the kind of activ-ities licensed by NRC and the' amount of time required by licensees to

_ perform this information collection and judgement on the part of the NRC staff.~

. d. -Reasonableness of Burden Estimates The estimates of burden are thought to be reasonable. No alternative information is available.

28 Enclosure 2/ Addendum 2

. 6

4. Estimate of the Cost to the Federal Government e

5 20.904(a)--The cost incurred by NRC would be that associated with the inspector's time and is estimated to be 1,450 hours0.00521 days 0.125 hours 7.440476e-4 weeks 1.71225e-4 months annually. This yields an annual cost of $72,500.

{

$ 20.904(c)(4)--The cost incurred by NRC would be that associated with the inspector reviewing the licensee's written record. This is estimated to require a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months annually. At $50 per, hour of inspector time, the monetary burden is estimated at $500 annually.

29 Enclosure 2/ Addendum 2 i

l

d SUPPORTING STATEMENT FOR 10 CFR 20.1102 RECORDS CF RADIATION PROTECTION PROGRAM, INCLUDING ALARA PROVISIONS

1. Justification

~

Paragraph 20.102(a) states that each licensee shall ensure that the dose

.to individuals receiving occupational dose and to members of the public is low as is reasonably achievable (ALARA) and does not exceed the appropriate limits. This requirement is responsive to long-standing recommendations of the National Council on Radiation Protection, the International Commission on Radiological Protection, and guidance for Federal; regulatory agencies in Report No.1 of the Federal Radiation

-Council,

a. Need for-the Information Collection 4

In order to assess the level of implementation of the licensee's

. radiation protection program, including provisions for maintain-ing radiation exosures ALARA, and to achieve an inspectable and c ;

, enforceable regulatory requirement for ifcensees, it is necessary I

that the licensee maintain records of the radiation protection program, including ALARA provisions, pursuant to S 20.1102.

F .-

b. Practical Utility of the Information Collection The records of the licensee's radiation protection program and ALARA progrm features will permit the NRC inspectors to check the com-pliance of the licensee with 9 20.102 and the implementation of the licensee's radiation protection program and ALARA provisions. This review would be one part of the routine periodic inspections, vary-

ing in frequency from that in power reactors with resident inspec-

. tors, to once in several years, as for certain gauges and measuring 30 Enclosure 2/ Addendum 2

. t devices, depending upon the potential for radiological protection

problems. The records will also be used by the licensee to control daily operations within the radiation protection program and to review the relative effectiveness of past efforts on ALARA.

c. Duplication with Other Collections of Information None.

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 con-sultations have included members of the following groups:

--Licensees of various types and sizes Architects, Engineers, Contractors ~

Power Reactors (LWR)

Research Reactors Universities Uranium Fuel Cycle 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 31 Enclosure 2/ Addendum 2

I .'

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

--Public Interest Groups Natural Resources Defense Council

--Health Organizations Health Physics 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.

--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 Depa,rtment of Health and Human Services

e. Other Suoporting 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.

32 Enclosure 2/ Addendum 2 w + , w

i

s. t~

2. Description of the Information Collection

a. Number and Type of Respondents This recordkeeping requirement applies to all 7,500 NRC specific licensees, including those who are already required, by license condition or technical specification, to have incorporated ALARA provisions into their radiation protection programs.

b. Reasonableness of the Schedule for Collecting Information The regulation does not specify any frequency for examination and verification of program features or for entry. The frequency will

. vary with the degree of complexity and potential for radiological protection problems in the program.

c. Method of Collecting the Information The licensee is the only source of the information on the implementa-tion of the licensee's radiation protection program, including ALARA".

provisions. The NRC staff is unaware of any alternative method for collecting information that will permit inspection and enforcement of the regulation.

d. -Record Retention period I

The licensee would be required to retain the records for two years

or until completion of the first inspection of the radiation protec-tion aspects of the licensee's program, whichever is longer.

It may be necessary for the licensee to retain records for more than two years if there has not been a first inspection within that time. - Such retention is necessary in order for the NRC to inspect

, the ALARA program and ensure that the program is protecting the public health and safety.

33 Enclosure 2/ Addendum 2-

r 4 .

e. Reporting Period This information collection item does not involve reports.

f. Copies Required to be Submitted -

None.

g. Format of Information to be Maintained or Submitted .

The format for records of the radiation protection program and ALARA actions has not been specified in the regulation. It is expected i that the records will be written notation of the licensee's radiation protection program, including ALARA provisions, and examination and verification of program features and actions taken by the licensee.

e .-

3. Estimate of Burden

a. Estimated Hours Reouired to Respond to the Collection '

The-time required to maintain records of thel licensee's implementa-tion of the radiation protection program and the ALARA provisions '

will vary, depending upon_the size and complexity _of the licensee's program. It is estimated that, on the average, 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of clerical time will be required per licensee per year, or 15,000 hours0 days 0 hours 0 weeks 0 months / year (7,500 licensees x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months / year per licensee).

1 Number of recordkeepers..................... 7,500 2 Annual hours per recordkeeper............... 2 3 Total recordkeeping hours................... 15,000

b. Estimated Cost Required to Respond to the Collection

. The estimated cost is $300,000 (15,000 hour0 days 0 hours 0 weeks 0 months / year x $20/ hour).

34 Enclosure 2/ Addendum 2 c --. -.,y- - -- ~ - 7p-- - __ - - -

c ,

-. s

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

d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government NRC cost is incurred by the inspector's review of the records of the licensee's implementation of the radiation protection program, including ALARA provisions. NRC inspectors presently review a licensee's radiation protection program as part of the . routine inspection. Review of the addi-tional records is estimated to require, on the average, 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months during each inspection, taken as once every three years. The estimated cost is

$187,500 (7,500 licensees x 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months / inspection x 1 inspection /

3 years x $50/ hour).

35 Enclosure 2/ Addendum 2

a .

SUPPORTING STATEMENT FOR

, 10 CFR 20.1103 RECOROS OF SURVEYS

1. Justification Each licensee is required to maintain records showing the results of surveys and calibrations required by SS 20.501, 20.703(a)(2)(ii) and 20.905(b).

Section 20.501 requires licensees to make surveys that are necessary for compliance with the Part 20 regulations and that are reasonable to evaluate the extent of radiation levels that could be present and the potential for intake of radioactive materials by individuals. Pursuant to S 20.703(a)(2)(ii), licensees' respiratory programs must include surveys and bioassays, as appropriate, to evaluate actual intakes of' radioactive materials. Section 20.905(b) requires licensees, upon receipt of a package containing, radioactive materials, to monitor the external surfaces of the

-package for radioactive contamination and radiation levels. Records are necessary so that the NRC inspectors or others may verify that such surveys required for adequate radiation protection have been made.

a. Need for the Information Collection.

The records of the surveys and calibrations are a practical way for.

the inspectors and the licensee's health physics personnel to estab-lish that the surveys and calibrations were accomplished and to review the results obtained, the methods used, the dates, and other necessary information.

b. Practical Utility of the Information Collection Surveys provide the bases for radiation exposure information needed by the licensee to implement the radiation protection program, 36 Enclosure 2/ Addendum 2

a;*

generally, and to evaluate the doses received by workers and the public, specifically.

c. Duplication with Other Collections of Information None.

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 consultations have included members of the following groups:

--Licensees of various types and sizes Architects, Engi,ne,ers, Contractors Power Reactors (LWR)

Research Reactors Universities '

Uranium Fuel Cycle 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 37 Enclosure 2/ Addendum 2

--Public Interest' Groups Natural Resources Defense Council

--Health Organizations Health Physics 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

--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 Succorting 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.

2. Descriotion of the Information Collection

a. Number and Tyoe of Rescondents This proposed change would involve all 7,500 NRC licensees.

38 Enclosure 2/ Addendum 2

b. -Reasonableness of the Schedule for Collecting Information The licensee must collect and retain the recora. of surveys and cali-brations whenever such data become available in order to evaluate current health physics practices.

c. Method of Collecting the Information No particular method of collection of information is specified in S 20.1103.

d. Record Retention Period ,

1 The licensee is required to retain records required by SS 20.501 and 20.905(b) for two years after the record is made or until completion of the first inspection of the radiation protection aspects of the licensee's program, whichever is longer. It may be necessary'for the licensee to retain records for more than two years if there has not been a first inspection within that time. Such retention is necessary in order for the NRC to inspect the program and ensure that the program is protecting the public health and safety.

Records of surveys and bioassays required by $20.703(a)(2)(ii) shall be retained, pursuant to $20.1103(b), until the Commission terminates the pertinent license.

e. Reporting Period The information collection item does not involve reports.

f. Copies Required to be Submitted None.

g. -Format of Information to be Maintained or Submitted The format of the record is not specified in the regulation.

39 Enclosure 2/ Addendum 2

3. Estimate of Burden

, a. Estimated Hours RaGuirad to Respond to the Collection Approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per year per licensee are estimated to be required to prepare these records, for a total of 75,000 hours0 days 0 hours 0 weeks 0 months per year for the'7,500 licensees.

1 Number of recordkeepers..................... 7,500 2 Annual hours per Pecordkeeper............... 10 3 Total recordkeeping hours................... 75,000

b. Estimated Cost Reouired to Resoond to the Collection

At $20 per hour of clerical time, each licensee would expend $200/

year for an annual cost of $1,500,000 among the 7,500 licensees.

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

d. Reasonableness of Burden Estimates

~The estimates are comparable to estimates of burden under S 20.401(b) of the existing Part 20.

4. Estimate of the Cost to the Federal Government The time expended by the inspectors to inspect survey records is estimated to be 5,000 hours0 days 0 hours 0 weeks 0 months per year. At $50 per hour for staff cost, this repre-sents an annual cost of $250,000.

1

4 40 Enclosure 2/ Addendum 2

. - - , - a.. . -. - _ _ . , .

SUPPORTING STATEMENT FOR

. 10 CFR 20.1104(a)(1), (a)(2) and (b)

DETERMINATION OF PRIOR OCCUPATIONAL DOSE

1. Justification In order to protect the health and safety of workers, S 20.201 requires

' licensees to control the total occupational dose received by workers within

specified limits.~ Compliance is demonstrated through records, which are required in SS 20.1104 (a)(1), (a)(2) and (b).

a. Need for the Information Collection i

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. This need is emphasized in the case of short-term (transient) workers and workers with multiple employments (" moonlighters").

Paragraph 20.1104(a)(1) requires the licensee to determine the total dose received by a worker during the current calendar year, including dose from previous employments.

Paragraph 20.1104(a)(2) requires a licensee who proposes to condoct a planned special exposure to determine the status of the workers within the annual and lifetime constraints on planned special exposures.

(See $ 20.206(d).)

. Paragraph 20.1104(b) requires the licensee to record the prior occupa-

tional dose information on NRC Form 4. as revised. Justification for

NRC Form 4 is presented separately.

41 Enclosure 2/ Addendum 2

- . = . _ , - __ _-

(

'b. Practical Utility of the Information Collection The information on the prior occupational dose of a worker would be used by a licensee to control exposure of the worker such that addi-tional dose does not cause the total dose to the worker to exceed the limits.

c. Duplication with Other Collections of Information None. '

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 consulta-tions'have included members of the following groups:

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

Research Reactors Universities

. Uranium Fuel Cycle 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 42 Enclosure 2/ Addendum 2

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 Physics 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 Mations Scientific Committee on the Effects of Atomic j -Radie ton

--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 43 Enclosure 2/ Addendum 2

e. Other Sucoorting 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.

2. Description of the Information Collection

a. Number and Type of Respondents S 20.1104(a)(1)--Each of the 7,500 NRC specific licensees would be required to determine the prior occupational dose 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 individual monitoring devices or services pursuant to S 20.502.

S 20.1104(a)(2)--This requirement would apply only to those license s who intend to conduct planned special exposures. While the NRC staff believes that such exposures might not be made because they are to be used only when justifiable in exceptional situations, for purposes of this report justification we have assumed that 5 power reactor licensees will conduct planned special exposures each year.

S 20.1104(b)--This paragraph' requires each of the 7,500 NRC licensees and any licensees conducting planned special exposures to record the data on prior occupational dose received by workers on NRC Form 4.

b. Reasonableness of the Schedule for Collecting Information s 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.

44 Enclosure 2/ Addendum 2

c. Method of Collecting the Information

-Paragraph 20.1104(d) specifies that the licensee shall attempt to obtain records of prior occupational dose by telephone, telegram, electronic media, or letter, and shall request follow-up written verification of dose data received via telephone, telegram, or elec-tronic media. The licensee may accept an up-to-date NRC Form 4 signed by the individual and countersigned by an appropriate offi-cial of the most recent employe.- for work involving radiation expo-sure, or of the current employer, if the individual is not employed by the licensee.

d. Record Retention Period Pursuant to S 20.1104(c), the licensee shall retain records used in preparing NRC Form 4 for two years after the record is made or_until completion of the first inspection of the radiation protection aspects of the licensee's program, whichever is longer. It may be necessary for the licensee to retain records for'more than two years if there has not been a first inspection within that time. Such retention is necessary in order for the NRC to inspect the program and ensure that the program is protecting the health and safety of workers.

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

f. Copies Required to be Submitted None.

g. Format of Information to be Maintained or Submitted

~

The information on prior occupational dose is to be obtained in writ-ing, either directly or as verification of information initially pro-vided by telephone, telegram, or electronic media. No further format is specified.

45 Enclosure 2/ Addendum 2

3. Estimate of Burden

a. Estimated Hours Reouired to Resoond to the Collection S 20.1104(a)(1)--NRC licensees monitor about 300,000 individuals each year. If we assume a 10% annual turnover in this population, data on prior occupational dose would be sought for about 30,000 workers each year. Many ~ of these will present up-to-date NRC Form 4s, particularly those involved in nuclear power plants which experience a large part of short-term work. Further, a number of reactor licensees are devel-oping interacting computer programs to facilitate the exchange of this, and other, data. Therefore, we estimate an average of 0.33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months per worker, or a total of 9,900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months / year (30,000 workers x 0.33 hour3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months ) for all 7,500 licensees. The number of hours /recordkeeper per year will vary according to the number of monitored workers /recordkeeper and the turnover rate of workers employed by the licensee. Therefore ,-

the burden could range from 0-100 hours /recordkeeper per year. A point estimate of 1.32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months /recordkeeper per year is used for cal-culational purposes only.

S 20.1104(a)(2)--It has been estimated that 5 reactor licensees might conduct planned special exposures each year, requiring data on about 10 workers for each such exposure. However, it is likely' that all 70 reactor licensees will choose to obtain the planned special exposure data on key individuals in anticipation of a need to conduct such exposures. Therefore, we estimate a burden of 350 hours0.00405 days 0.0972 hours 5.787037e-4 weeks 1.33175e-4 months / year (70 licensees x 10 individuals / year x 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months / individual).

S20.1104(b)--The' burden for this recordkeeping requirement is included under the estimated burden for NRC Form 4.

S20.1104(a)(1) S20.1104(a)(2)

. 1 Number of recordkeepers.............. 7,500 70 2 Annual hours per recordkeeper........ 1.32 5 3 Total recordkeeping hours............ 9,903 350 46 Enclosure 2/ Addendum 2

b. Estimated Cost Reouired to Resoond to the Collection S 20.1104(a)(1)--The cost of this requirement is estimated to be abcut

$198,000/ year _(9,900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months x $20/nour).

S 20.1104(a)(2)--The cost of this requirement is estimated to be about

+

$7,000/ year (350 hours0.00405 days 0.0972 hours 5.787037e-4 weeks 1.33175e-4 months x $20/ hour).

l 4

The total cost would approach $205,000/ year. .

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

-d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government NRC cost is incurred by inspectors reviewing the records maintained by

the licensees.

S 20.1104(a)(1)--It is estimated that 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months is spent, on the average, '

reviewing the data on prior occupational dose at each of the 7,500 licensees' offices during routine inspections, which are an average of once every 3 years. The estimated cost is (7,500 licensees x 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months /

inspection x 1 inspection /3 years x $50/ hour) about $62,000/ year.

S 20.1104(a)(2)--It is estimated that 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months would be spent at each of the 5 reactor licensees who might conduct a planned special exposure each year reviewing the data on prior planned special exposures and overexpo-

. sures received during the lifetimes of the workers involved. The esti-mated cost is about $125/ year (5 licensees x 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months / licensee / year x

$50/ hour). The total cost is estimated to be about $62,125/ year.

47 Enclosure 2/ Addendum 2

SUPPORTING STATEMENT FOR 10 CFR 20.1105 RECORDS OF PLANNED SPECIAL EXPOSURES

1. Justification Section 20.206 provides for planned special exposures under which a licensee may allow an adult worker to receive doses above the basic dose

. limits, but within specific annual and lifetime constraints. Sec-tion 20.206(g) requires licensees to maintain certain records for planned special exposures in accordance with $20.1105. These planned special ex-posures are to be authorized only in exceptional situations, when alterna-tives which might avoid the higher exposures are unavailable or impractical.

The planned special exposure provision would provide some of the flexibil-ity in the management of occupational exposures necessary-to accomplish tasks in high radiation areas that was previously provided under the 5(N-18) dose-averaging formula, which has been deleted from the proposed revision. The planned special exposure provision implements a somewhat less restrictive recommendation in Publication 26 of the International Commission on Radiological Protection.

a. Need for the Information Collection The NRC, while recognizing the potential need for some doses above the basic dose limits in order to accomplish certain tasks in high radiation areas, would impose a number of constraints on the use of the planned special exposure provision. In order to monitor the use of the planned special exposure provision and to inspect and enforce the regulatory constraints, it is considered necessary to require the records specified in S 20.1105. These records must describe the special exposure pursuant to $20.206, the name of the management official who authorized the planned special exposure and a copy of the signed authorization, what actions were necessary, why the actions 48 Enclosure 2/ Addendum 2

e were necessary, how doses were maintained ALARA, what individual and collective doses were expected to result, and the doses actually received in the planned special. exposure.

b. Practical Utility of the Information Collection The information to be recorded pursuant to S 20.1105 would be used by NRC inspectors to monitor the use of the planned special exposure provision and to . inspect and enforce the regulatory constraints.

It is expected that these records would be reviewed as soon as an inspection could be conveniently scheduled following report of the conduct of a planned special exposure pursuant to S 20.1204.

c. Duolication with Other Collections of Information None. .

+

d. Consultations Outside the NRC Ouring 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 consulta-tions have included members of the following groups:

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

Research Reactors ,

Universities Uranium Fuel Cycle Facilities Medical Facilities Uranium Mills Well Loggers

. Radiographers, and others 49 Enclosure 2/ Addendum 2

--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 Radiat'.on 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 Physics 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

--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 50 Enclosure 2/ Addendum 2 Y 1

Occupational' Safety and Health Administration Department of Health and Human Services

e. Other Suoportino 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.

2. Description of the Information Collection

a. Number and Type of Resoondents The provision for planned special exposures is available to all NRC specific licensees, and, if used, the recordkeeping requirements in S 20.1105 would apply. Practically, only licensees having very ....

large sources, such as power reactors, are likely to encounter cir-cumstances justifying planned special exposures. Since the planned special exposures are to be considered necessary only in exceptional situations, the NRC staff believes that the provision for planned special exposures may not be used. However, for purposes of this recordkeeping justification, we are assuming that 5 reactor licensees may conduct planned special exposures each year.

b. Reasonableness of the Schedule for Collecting Information i

It is the intent of S 20.206 to require-licensee management to docu-

. ment the decision to conduct activities which utilize the planned special exposure provision before the exposure is carried out. Such a decision is to be reached following evaluation of the circumstances involved, what and why actions are necessary, the potential doses to workers, and how the doses are to be maintained ALARA. These items should be recorded under $20.1105(a) at the time the decision is made

. to conduct a planned special exposure event.

l

, 51 Enclosure 2/ Addendum 2

The doses actually received would be recorded under S20.1105(a) after the planned special exposure event pursuant to SS 20.206(h),

20.1105(a)(6) and 20.1106.

c. Method of Collecting the Information The licensee is the only source of the information on the circum-stances of the planned special exposure. The NRC staff is unaware of any alternative method for collecting information that will permit inspection and enforcement of the regulation.

d. Record Retention period Under $20.1105(b), the licensee is to retain records of all planned special exposures until the NRC terminates each pertinent license

~

requiring these records. This retention period is consistent with other dose record retention periods and is considered necessary for long term evaluation (or possible re-evaluation) of occupational exposures.

e. Recorting Period This recordkeeping justification does not involve any reports,

f. Cooies Required to be Submitted None.

g. Format of Information to be Maintained or Submitted While the information to be included is specified in SS 20.206 and 20.1105, the format of that information is not specified in the regulation.

52 Enclosure 2/ Addendum 2

3. Estimate of Burden

a. Estimated Hours Reouired to Respond to the Collection It is estimated that five licensees will conduct a planned special

. exposure per year. It is further estimated that docdmentation of the

, evaluations made by the licensees, the authorizations of the planned special exposures pursuant to S20.206(b), and the doses expected and actually received will involve 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per planned special event, or a total of 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months / year.

1 Number of recordkeepers..................... 5 2 Annual hours per recordkeeper............... 10 3 Total recordkeeping hours................... 50 I b. Estimated Cost Required to Respond to the Collection The estimated cost is'(50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months / year x $50/ hour) $2,500/ year.

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

d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by i S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government .

NRC cost is incurred by inspectors reviewing the records of the licensee's conduct of a planned special exposure. The review is estimated to require

. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per planned special exposure for a cost of $500/ year (5 planned special exposure events / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months / event x $50/ hour).

53 Enclosure 2/ Addendum 2

!?

\

4 SUPPORTING STATEMENT FOR 10 CFR 20.1107 0

RECORDS OF RELEASE OF RADI0 ACTIVE MATERIAL IN EFFLUENTS

1. Justification F 4-Section 20.301 establishes a limit for individual meabers of the public on the total radiation dose from all sources and operations, except natural s background and medical diagnosis and therapy (as a patient). This total dose includes dose from sources outside of the body and the committed effective dose equivalent (50 year calculation) received from radioactive o

material taken into the body. Section 20.303 establishes a reference level applicable to the contribution of dose from one licensee's opera--

tions so that the total dose to members of the public from all sources will be within the dose limits. These constraints on dose to the public are believed necessary to achieve an acceptable level of risk to the health and safety of the public.

a. Need for the Information Collection Information required pursuant to S 20.1107 on the identity and'quan-Etity of radionuclides released by a licensee in effluents to unre-stricted areas is needed in order to permit assessment of the committed effective dose equivalent to the public that might result from the intake of the, radionuclides. The information on releases and on external radiation dose would te obtained from survey data recorded pursuant to S 20.1103.

b, practical Utility of the Information Collection The records on releases in effluents would be used by the licensee for day-by-day program control, in the assessment of operation of effluent treatment equipment, and in the assessment of dose within S4 Enclosure 2/ Addendum 2

- ~ _ , . ._ _. . ._ ,_ _ - , . _ _ .

.1 the annual limit and the reference level applicable to members of the public. The records would be reviewed by the NRC inspectors to

' determine compliance with the annual limit and reference level.

c. Duplication with Other Collections of Information None.

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 consulta-tions have included members of the following groups:

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

Research Reactors-

' Universities

' Uranium Fuel C)tte acilities Medical Fa<1tq9r Uranium Mills Well' Loggers Radiographers, and others

--Trade Organizations Edison Electric Institute: Health Physics Committees, Subcommittees, and Task Forces American Mining Congress iAtomic Industrial Forum, Subcommittee on Occupational Radiation 5

Protection and. Conference on Radiation Issues

. Westinghouse Health Physics-Staff (REM Program) k Electric. Power Research. Institute

'3 ,

55 Enclosure 2/ Addendum 2 .

I

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

--Public Interest Groups Natural Resources Defense Council

--Health Organizations Health Physics 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 Ur.ited Nations Scientific Committee on the Effects of Atomic Radiation g,

--Agreement States

, Conference of Radiation Cont.cl Program Directors

--Federal Agencies and Committees a

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 Succortina Information None.

56 Enclosure 2/ Addendum 2

o: s

2. Description of the Information Collection

a. Number and Type of Respondents This requirement would involve about 4,000 licensees, both small and large, who use radioactive material in forms other than sealed sources and devices.

b. Reasonableness =of the Schedule for Collecting Information Section 20.1107 does not specify a schedule for collecting informa-

tion on the release of radioactive material in effluents to unre-stricted areas.

c. Method of Collectino the Information The licensee will use survey data recorded pursuant to S 20.1103 to obtain information on the identity and quantity of radionuclides released in effluents to unrestricted areas.

d. Record Retention Period Paragraph 20.1107(b) states that the licensee shall retain the records until the Commission terminates each pertinent license requiring the record. These records may be required at any future time for the licensee to document the contribution of dose to individual members of the public from his operations so that the total dose to members of the public from all sources will be within the dose limits. These constraints on dose to the public are necessary to achieve an accept-able level of risk to the health and safety of the public.

e. Recorting Period This information collection item does not involve reports.

f. Cooies Reouired to be Submitted None.

57 Enclosure 2/ Addendum 2

g. Format of Information to be Maintained or Submitted The format o'f the records is not specified in the regulation.

3. Estimate of Burden

a. Estimated Hours Required to Resoond to the Collection It is estimated that about 4,000 licensees would spend an average of about 48,000 hours0 days 0 hours 0 weeks 0 months / year (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months / year per licensee x 4,000 licensees) maintaining the required records. '

1 Number of recordkeepers..................... 4,000 2 Annual hours per recordkeeper............... 12 3 Total recordkeeping hours................... 48,000

b. Estimated Cost Recuired to Respond to the Collection The estimated cost is $960,000/ year (4,000 licensees x 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months / year x $20/ hour).

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

d. Reasonableness of Burden Estimates The estimates are thought to be reasonable, but no direct supporting data are available.

4. Estimate of the Cost to the Federal Government

. NRC cost is incurred during review of the records by NRC inspectors. The cost is estimated to be about $70,000/ year (4,000 licensees x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months /

inspection per licensee every 3 years x $50/ hour).

58 Enclosure 2/ Addendum 2

SUPPORTING STATEMENT FOR

, 10 CFR 20.1108 RECORDS OF WASTE DISPOSAL

1. Justification Sections 20.1001, 20.1002, 20.1003, 20.1004, and 20.1005 specify methods for disposal, or for obtaining specific license authorization of alterna-tive disposal methods. Sections 30.51, 40.61, and 70.51 require records of waste disposal, among others. However, because the specification of methods and constraints on those methods are stated in Part 20, it is considered appropriate to restate the requirement for records of waste 5tsposal in S 20.1108.

a. Need for the.Information Collection Records of waste disposal are needed to permit routine in'spection for compliance with the provisions of the sections in Part 20 related to waste disposal, to permit inspection against the constraints on kinds and quantities of licensed material in the possession of the licensee at any given time, and to permit assessment of the kinds and quantities of radioactive material disposed of by various methods and the potential dose to people,

b. Practical Utility of the Information Collection .

The information will be used by. inspectors to determine compliance with NRC regulations during routine inspections. Such information might also be used to assess dose to members of the public.

59 Enclosure 2/ Addendum 2

c. Duolication with Other Collections of Information Each of the licensing Parts 30, 40 and 70 require maintenance of records of disposal. One set of records is all that is required to meet the requirements in Part 20 and the licensing Parts.

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 consulta-tions have included members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle 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 60 Enclosure 2/ Addendum 2

^

--Public. Interest Groups Natural Resources Defense Council- -

--Health Organizations Health Physics 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 c

--Agreement States

_ Conference of Radiation Control Program Directors

--Federal' Agencies and Committees Interagency. Working Group on_0ccupational 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 None.

t

, 2. Description of the Information Collection

a. Number and Type'of Resoondents

. The requirement for disposal records applies to all 7,500 NRC licensees.

However, licensees using only sealed sources and devices are unlikely to dispose of such sources. It is more probable that they will transfer 61 Enclosure 2/ Addendum 2

the sources to another authorized recipient, perhaps by return to the initial supplier. For purposes of this justification, we have assumed disposal records will be maintained annually by about 4,000 licensees.

b. Reasonableness of the Schedule for Collecting Information There is no schedule of time for the disposal records. However, they should.be generated at the time of disposal for practical reasons.

c. . Method of Collecting the Information The records are generated by the licensee at the time of disposal while the kinds and approximate quantities of r'dioactive a material

' involved in a'given operation are known.

d. Record Retention Period Paragraph 20.1108(b) states that the licensee shall retain.the records until'the Commission terminates each pertinent license requiring the record. -These records may be required at any future time for the licensee to document the contribution of dose to individual members of the public from his operations so that the total dose to members of the public from all sources will be within the_ dose limits. These constraints on dose to the.public are necessary to' achieve an accept-able level .of risk to the health and safety of the public.

e. Reporting Period

'Not' applicable.

f. -Copies Required to be Submitted Only one copy of disposal records is needed.

g. Format of Information to be Maintained or Submitted The format of the records is not specified.

62 Enclosure 2/ Addendum 2

.9 b ,

3. Estimate of Burden

a. Estimated Hours Recuired to Respond to the Collection It is estimated that each of the 4,000 licensees will, on the aver-age, use 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months annually in the maintenance of disposal records.

The total burden would approach 48,000 hours0 days 0 hours 0 weeks 0 months / year (4,000 licens- .

ees x 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months / year per licensee).

1 Number of recordkeepers..................... 4,000 2 Annual hours per recordkeeper............... 12 3 Total recordkeeping hours................... 48,000

b. Estimated Cost Reouired to Resoond to the Collection The cost is estimated to be about $960,000/ year (48,000 hours0 days 0 hours 0 weeks 0 months /

year x $20/ hour).

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

d. Reasonableness of Burden Estimates We believe that the estimates are reasonable, but no direct support-ing data are available.

4. Estimate of the Cost to the Federal Government NRC cost is incurred during the inspection of the disposal records. The cost is estimated to be about $70,000/ year (4,000 licensees x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months /

,< inspection every 3 years x $50/ hour).

63 Enclosure 2/ Addendum 2

0 D s e

w g O

9 ANNUAL REPORTING BURDEN

Table 1. Annual Reporting Burden Responses per Annual Annual Burden Annual Proposed Respondents Respondent Responses per Response Burden Section (No.) (No.) (No.) (Hrs.) (Hrs.) -

20.205(b (5) 50 228 11,400 0.25 2850 20.205 (6) 50 228 11,400 0.5 5700

'20.206 5 1 5 2 10

20.206 (See520.1204) - - - -

20.206 5 1 5 2 10 20.303 1 1 1 8 8 20.601 8 1 8 2 16 20.602 b 37 1 37 4 148 20.703 a (3) 5 1 5 8 40 20.703(a(5) 1 1 1 28 28 20.703(b i 1 1 28 28 20.905(c 25 1 25 5 125 20.1002(a) 25 1 25 33 825 20.1006f b) & (c) (See App. F) - - - -

20.1006(d) .(See App. F) .

20.1201(a) 30 1 30 10 minutes 5 20.1201 b) 30 1 30 3 90 20.1201 5 1 5 3 15 20.1202 10 1 10 1 10 20.1202 . 40 1 40 1 40 20.1203 (1) 40 1 40 6 240 20.1203 (2) S 1 5 6 30 20.1203 (3) 10 1 10 6 60 20.1203 (4) 5 1 5 6 30 20.1203 (5) 5 l 5 6 30 20.1203(c 5 1 5 6 30 20.1204- 5 1 5 1 5 20.1205 40 1 40 4 160 20.1206 450 352 158,500 2.75 minutes 7265 20.1207 450 289 130,000 3.85 minutes 8334 App. F, Sec. I & II 2250 2 4500 1 4500 App. F, Sec. III 25 1 25 40 1000 31,G32

SUPPORTING STATEMENT FOR 10 CFR 20.205(b)(5) and (6)

FURTHER PROVISIONS - INTERNAL EXPOSURE INVOLVING RADIONUCLIDES

- WITH VERY LONG EFFECTIVE HALF-LIVES

1. Justification Section 20.205 provides an exception for licensees -to control the exposure of workers to certain very long effective half-lived radionuclides on the basis of effective dose equivalent received during a given calendar year rather than on the basis of committed effecti"e dose equivalent (that is,

.the total dose that would be received by the individual during the 50 years ,

following the intake),_as is required for the control of all other radio- -

nuclide intakes. The exception itself is considered warranted because of very. practical problems of measurement of the radionuclides covered by the exception at permissible occupational exposure levels,

a. Need for the Information Collection Under the exception in S 20.205, the annual effective dose equiva-lent would be used as the basis for controlling the exposure of the worker. This annual effective dose equivalent would not reflect the additional ~ dose to which the worker would be committed in subsequent years, without any further intake of radionuclides. If the worker is to be fully aware of the total risk to which he may be subjected, it is necessary that the licensee inform the worker of the best estimates of both the annual and the committed portions of the dose.

This would be provided pursuant to S 20.205(b)(5).

~

(Paragraph 20.205(b)(5) also reminds the licensee that the estimated annual and committed doses are to be recorded ($ 20.1106 and NRC 64 Enclosure 2/ Addendum 2

Form 5); reported to the individual; and sent to subsequent employers as part of the worker's occupational radiation exposure history . ,

(S 20.1104 and NRC Form 4.)

The difference between annual effective dose equivalent and committed effective dose equivalent will vary from one radionuclide to another and is dependent upon the physical and chemical form of the radio-nuclide. Further, the concentrations of certain radionuclides in the air or in bioassay samples at or below permissible. annual limits of intake might be difficult to measure with sufficient accuracy to permit projection of the committad effective dose equivalent to be used to demonstrate compliance with the regulations. If'the worker is to understand the estimates of dose and the associated risk, the pertinent information and instruction need to be provided to the i worker. This instruction would be provided pursuant to S 20.205(b)(6) and 5 19.12 of.10 CFR Part 19.

~

4

b. -Practical Utility'of the Information Collection

.The information on annual and committed effective dose equivalent

.; . estimates and the significance and the uncertainty of the estimates

are required to be provided to the worker so Glat the worker may know the magnitude of the exposure and understand the estimated doses and the associated risk. .The instruction wuuld be provided I

prior to entry into a licensee's restricted area and periodically reviewed and updated. The information on dose would be provided annually.

I

c. Duplication with Other Collections of Information There is no duplication. However, note the interaction with SS 20.1104 and 20.1106 and with NRC Forms 4 and 5, discussed in 1.a.

of this supporting statement.

ll 65 Enclosure 2/ Addendum 2 i

. . _ _ _ . . . _ _ _ , _ . _ _ _ . . _ _ _ . _ _ , _ . . _ . . . . _ . - . . _ _ ,.. ,_ _. .,_... ,.___ . .,__ ,.,_..., m., , . , , . _ . ,

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 consulta-tions have included members of the following groups:

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

Research Reactors

Universities Uranium Fuel Cycle 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 66 Enclosure 2/ Addendum 2

.: .s

--Health Organizations Health Physics 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

--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 None.

2. Description of the Information Collection

a. Number and Type of Respondents The provisions of 59 20.205(b)(5) and (6) would involve approximately 50 licensees who are operators of uranium mills, fuel fabrication and scrap recovery facilities, UF conversion facilities, and uranium

. processing and reprocessing facilities.

67 Enclosure 2/ Addendum 2

l

)

I

b. Reasonableness of the Schedule for Collecting Information' -

l l

l Information on annual and collective effective dose equivalents is i to be reported to the individual annually. This schedule reflects consideration of other data which the licensees will be required to I

collect and maintain to demonstrate compliance with annual dose '

limits. The annual limits, in turn, reflect recommendations of the ;

. International Commission on Radiological Protection.

l-Workers are to be instructed prior to entry into a licensee's restricted area, pursuant to $ 19.12, 10 CFR Part 19, so that the L individual will be aware of the significance of the doses he might receive, as well as all of the other instructions necessary to pro-tact the worker.

c. Method of Collecting the Information l

L Paragraph 20.205(b)(5) does not specify how the estimates'of annual L and committed effective dose equivalents are to be provided to the worker. Further, 9 20.205(b)(6) does not specify the method or detail the content of the instruction to be provided. Section 19.12 of 10 CFR Part 19-states that the instructions shall be commensurate !

with potential radiological' health protection problems in the ;

restricted area.

l

d. Record Retention Period l The record retention referenced in S 20.205(b)(5) is covered in l 5 20.1106 and NRC Form 5 and is stated as lifetime retention. '

i

e. Reportino Period Paragraph 20.205(b)(5) requires that the dose information be provided

to the worker annually. Instruction to be provided pursuant to

.5 20.206(b)(6) is not specified. However, 8 19.12 of 10 CFR Part 19 ,

1 requires the more general instruction, of which this would be a part, '.

l l 68 Enclosure 2/ Addendum 2 l

l

y .

to be provided prior to entry into the licensee's restricted area.

f. Copies Required to be Submitted One copy of the worker's annual dose would be provided to the worker.

The instruction provided pursuant to 5 20.205(b)(6) may include printed material appropriate to the licensee's operations.

g.- Format of Information to be Maintained or Submitted The format of the, report of dose to the worker is not specified.

The format of the instruction to be provided to the individual worker is not specified.

3. Estimate of Burden .,.,

a. Estimated Hours Required to Respond to the Collection The burden of $20.205(b)(5) on each licensee will depend on the number

-of workers whose exposures are being controlled under the exception in S 20.205. It is estimated that about 50 licensees will control exposures of a total of about 11,400 workers in this way. Discussion (see 1.d. of this supporting statement) indicates that licensees are likely to develop their own form, requiring only the addition of worker identification, period covered, and the dose data. This is estimated to require about 0.25 hour2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months for each of the 11,400 workers, or about 2,850 hours0.00984 days 0.236 hours 0.00141 weeks 3.23425e-4 months per year for the 50 licensees. Since there is a wide range (0 to >100) in the number of affected workers per licensee, a point estimate of 228 responses per respondent is used for calcula-tional purposes only.

The instruction of the worker pursuant to S 20.205(b)(6), including initial and periodic updating, might require 0.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months per worker, or 5,700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months per year.

69 Enclosure 2/ Addendum 2

S 20.205(b)(5) S 20.205(b)(6) 1 Number of respondents..................... 50 50 2 Number of responses per respondent........ 228 228 3 Total annual responses.................... 11,400 11,400 4 Hours per response........................ 0.25 0.50 5 Total hours............................... 2,850 5,700 P

b. Estimated Cost Required to Respond to the Collection Preparation of the (form) dose estimates for workers would be performed by clerical staff for a cost of about $57,000 annually ($20/ hour x 2,850 hours0.00984 days 0.236 hours 0.00141 weeks 3.23425e-4 months / year).

Instruction wauld cost about $285,000 annually ($50/ hour x 5,700 hours0.0081 days 0.194 hours 0.00116 weeks 2.6635e-4 months /

year).

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

d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government Cost is incurred by NRC inspectors verifying that the dose estimates and instruction have been provided to workers by the licensees. This inspec-tion effort might involve 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per year for each of the 50 licensees controlling exposures under the exception in S 20.205. The cost is esti-mated to be $2,500 per year ($50/ hour x 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months / year).

70 Enclosure 2/ Addendum 2

F e

4 0 SUPPORTING STATEMENT FOR 10 CFR 20.206(c) and (h)

INSTRUCTIONS FOR PLANNED SPECIAL EXPOSURES 1

1. Justification Section 20.206 provides for planned special exposures under which a licensee may allow an adult worker to receive doses above the basic dose limits, but within specific annual and lifetime constraints. These planned special exposures are to be authorized only in exceptional situations, when alternatives which might avoid the higher exposure are unavailable or impractical. The planned special exposure provision would provide some of the flexibility in the management of some occupational exposures necessary to accomplish tasks in.high radiation areas that was previously provided under the 5(N-18) dose-averaging formula, which has been deleted in the proposed revision. The planned special exposure provision implements a somewhat less restrictive recommendation in Publication 26 of the Inter-national Commission on Radiological Protection,

a. Need for the Information Collection S 20.206(c)--In order to ensure adequate radiation protection is pro-vided, among other things, it is considered necessary that the indi-viduals involved in planned special exposures be informed of the purpose of the operation and the estimated doses and special radia-tion or other conditions involved in performing the task, and be instructed in the measures to keep the doses and all risks as low as is reasonably achievable.

S 20.206(h)--The NRC believes that the individuals involved in a planned special exposure should be informed in a timely manner of the radiation doses received.

71 Enclosure 2/ Addendum 2

T O 6 l

f j b. Practical Utility of the Information Collection S 20.206(c)--Pravisions for the information and instruction allow l workers to evaluate the need for the planned special exposure and to participate in planning the actions involved, for which workers could have unique perspective. The estimated radiation dose information would enable the workers involved to consider the effectiveness of the protective measures to be used during the planned special expo-sure event, to assess the potential degree of risk associated with the event, and to be aware of their projected status within the annual and lifetime exposure constraints on planned special exposures.

S 20.206(h)--Information on the radiation doses received, as different from projected doses, would enable the workers to assess in a timely manner the degree of risk actually associated with the event, and to be aware of their status within the annual and lifetime exposure con-straints on planned special exposures.

c. Duplication with Other Collections of Information None,

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 consulta-tions have included members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle Facilities 72 Enclosure 2/ Addendum 2 m )

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 Physics 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

--Agreement States Conference of Radiation Control Program Directors l

73 Enclosure 2/ Addendum 2

, ,_ _. . ..- -_ . __ _ _ . _ _ - _ . . . ~ _ . ._. .-. _ . - _ . . _ . .

. o

--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 l Department of Health and. Human Services j , e. Other Supporting Information 1

None.

L

2. Descriotion of the Information Collection i I

a. .NumberandTyde'ofRespondents While the provisions for planned special exposures are available to all NRC specific licensees,. only licensees having very large sources, l such'as power reactors, are likely to encounter circumstances justi-fying planned special exposures. Since the planned special exposures

are to be used only in exceptional situations, the NRC staff believes-

that the provisions for planned special exposures might not be used.

However, for the purposes of this reporting justification, we are assuming that 5 reactor licensees will each conduct one planned l special exposure each year, subject to this reporting requirement.

b. Reasonableness of the Schedule for Collectino Information S 20.206(c)--It is considered reasonable and necessary that instruc- ;

tion be provided to the worker $ involved before.the planned special !

exposure, i

I l

[

74 Enclosure 2/ Addendum 2 ,

!. .. .. . _ - . . _ _ . . _ _ _ . _ _ _ _ . _ . , . . . _ _ . ~ _ . _ _ _ _ . _ . . - - _ . . _ _ _ - . _ _ _ -

1

.O O S 20.206(h)--Provision of the information on doses actually received by the workers within 15 days after determination of the doses is reasonable because it recognizes practical problems in processing dosimeters and preparing the written notices, while providing reason-ably early_ dose information to the workers.

c. Method of Collecting the Information S 20.206(c)--The licensee verbally provides the information stated in S 20.'206(c) to the individual workers involved. The NRC staff is unaware of any alternative method for providing the information that will be less burdensome on the licensee than verbal communication with the involved individuals. '

S 20.206(h)--The licensee records the dose and provides written infor-mation on the doses received during the planned special exposure to the individual workers involved. (The recordkeeping portion of this provision is justified under S 20.1105.)

d. Record Retention Period No record is required under the portions of S 20.206(c) and (h) justi-fled in this supporting statement. (The recordkeeping portion of this provision is justified under 6 20.1105.)

e. Reporting Period S 20.206(c)--The verbal provision to the involved individuals of the purpose, estimated dose, and "As low As Is Reasonably Achievable" measures with respect to a planned special exposure must be prior to the planned special exposure.

S 20.206(h)--The information on doses received during the planned special exposure is to be provided within 15 days after determina-tion of the dose.

75 Enclosure 2/ Addendum 2

f. Copies Required to be Submitted S 20.206(c)--None. The information is provided verbally.

S 20.206(h)--One copy of the report of the dose received during the planned special exposure is to be provided to each individual involved.

g. Format of Information to be Maintained or Submitted The format of the information to be provided pursuant to SS 20.206(c)

, and 20.206(h) is not specified.

3. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection S 20.206(c)--The time required to indicate the provisions stated in S 20.206(c) will vary depending on the complexity of the licensee's particular situation. It is estimated that it will require approxi-mately 2 staff-hours for each of five licensees to comply with the collection requirement. This gives an overall licensee time estimate of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months per year.

S 20.206(h)--It is estimated that each licensee would commit 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to the preparation of a form letter to the individual worker involved in a planned special exposure, and another hour addressing the letter and entering the individual worker's doses, for a total ,

commitment of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months / year (5 licensees / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months / licensee).

5 20.206(c) $ 20.206(h) 1 Number of respondents................ 5 5

' ~

2' Number of responses per respondent... 1 1 3 Total annual responses............... 5 5

! 4 Hours per response................... 2 2 5 Total hours.......................... 10 10 76 Enclosure 2/ Addendum 2

b. Estimated Cost Required to Respond to the Collection 8 20.206(c)--The estimated annual cost is $500 (10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months / year x $ 50/

hour).

S 20.206(h)--The estimated annual cost is $500 (10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months / year x $50/

hour).

The total cost under this report justification is $1,000/ year.

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

d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government 5 20.206(c) The primary cost to NRC will be the time required by the inspection staff during onsite visits to licensee facilities to. verify that verbal instructions-were given. Assuming $50 per hour for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months with each licensee involved, the annual cost will be $250 for 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months of inspection time.

$ 20.206(h) It is estimated that NRC inspectors would spend about I hour at each of the licensee's facilities verifying that written notices of the doses received during a planned special exposure were provided to the workers involved. This is estimated to cost $250 (5 licensees x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months x

$50/ hour).

The total cost under this report justification would be $500.

77 Enclosure 2/ Addendum 2

-. . . .. . . - .- . . - .. ..~ ~ . .. . . . . -

c- . .

i l

SUPPORTING STATEMENT FOR 10 CFR 20.303(c) fl PRIOR AUTHORIZATION TO EXCEED THE REFERENCE LEVEL i

l~

1.- Justification Annual dose-limits in S 20.301 apply to actual doses that are received by; ;

I individuals in the public. However, for a variety of complex reasons, it~

might be inipractical to determine precisely an annual dose. Therefore, it might be desirable for a licensee to establish compliance with the

-dose limits in a practical manner by using site-specific parameters and reasonable assumptions to demonstrate that the doses are not likely to i

exceed a-fraction of the limits. For this purpose, reference levels are l

,, established. Operations that result in conditions at or below these reference levels will ensure that no individual member of the public will l be subject to doses that exceed the annual dose limits in S 20.301.

a. Need for the Information Collection i

i If a licensee has a clear need to routinely or periodically operate ;

in excess of the reference level, the NRC needs to be aware of such a large contribution to public dose and to verify that the licensee's program assesses the doses properly and controls the doses within the l

0.5-rem annual limit, and that the licensee is maintaining public exposures as low as is reasonably achievable (ALARA). Since the l 0.5-rem annual limit also includes dose contributions from radiation j

sources other than those of the licensee, the evaluation must extend

~

beyond the licensed facility. Supporting information to justify j operations which might result in doses in excess o'f the reference

{ 1evel would be included in an application for specific-license author-ity:to routinely or periodically exceed the reference level. The

! 78 Enclosure 2/ Addendum 2 I

L_

supporting information to be included in the application is given in S 20.303(c).

b. Practical Utility of the Information Collection '

The licensee will send the information to NRC's licensing staff. In turn, the staff will evaluate the information to make a determination of the necessity to routinely or periodically exceed the reference level before granting specific authorization for the operation.

c. Duplication with Other Collections of Information None."

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 consultations have included representatives of the following groups:

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

Research Reactors Universities

-Uranium Fuel Cycle Facilities Medical Facilities s -

Uranium Mills -

Well Loggers Radiographers, and others

--Trade Organizations Edison Electric Institute: Health Physics Committees, Subcomm.ittees, and Task Forces American Mining Congress 79 Enclosure 2/ Addendum 2

. 0 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 Physics 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

--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 None.

80 Enclosure 2/ Addendum 2 4 *

. n f

~

2. Description of the Information Collection

a. Number and Type of Respondents Only one application to operate in excess of the reference level is anticipated per year. Such an application might be expected from a large licensee, such as a reactor licensen who is experiencing unusually high fuel leakage but, for economic reasons, desires to continue operation.

'hl{

b. Reasonableness of the Schedule for Collecting Information 1

Prior approval for routinely or periodically exceeding the reference level is considered necessary in order to ensure the health and safety of individuals in the public who might otherwise be unneces-sarily exposed.

i

) c. Met $odofCollectingtheInformation y>, <

The information is to be provided in an application filed by a

' licensee or license applicant. The licensee is the only source of such information regarding operations which could potentially exceed ther'efer$ncelevel.

d.

Record Retention Period The licensee is not required to maintain any records.

e. Reporting Period L

No parfod is noted. However, the licensee will send the information to NRC prior to the time for which the necessity exists for carrying Tout-the' operation, f I

3 ,

81- Enclosure 2/ Addendum 2

\

f.' Copies Required to be Submitted One application for authorization is sent to NRC's licensing staff.

g. Format of Information to be Maintained or Submitted The format of the application is not specified in the regulation.

3. Estimate of Burden

a. . Estimated Hours Required to Respond to the Collection It is estimated that eight hours of technical staff time will be required for one licensee to prepare the application.

1 Number of respondents....................... 1 2 Number of-responses per respondent.......... 1 3 Total annual responses...................... 1 4 Hours per response.......................... 8 5 To tal ho u r s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

b. Estimated Cost Reouired to Resoond to the Collection At $50 per hour of staff time, $400 per year would be expended to prepare the one application expected annually.

c. _ Source of Burden Data and Method for-Estimating the Burden The burden data were obtained from a projection of what it would most.

likely cost in time and monetary effort far a licensee to prepare '

such an application.

d. Reasonableness of Burden Estimates The estimates of burden are thought to be reasonable estimates by staff. No alternative source of information or estimates of burden exists.

82 Enclosure 2/ Addendum 2

t

4. Estimate of the Cost to~the Federal' Government At 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of staff time per year to review the application, $400 (8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months /

year x $50/ hour) would be estimated as the yearly cost to the government.

't h

t i'

F 83 Enclosure 2/ Addendum 2

SUPPORTING STATEMENT FOR 10 CFR 20.601(b)

ALTERNATIVE METHODS FOR CONTROLLING ACCESS TO HIGH RADIATION AREAS

1. Justification Section 20.601 requires licensees to establish controls on access to high radiation areas so that individuals who enter such areas will be aware of the high radiation levels present and be monitored, instructed, and otherwise protected.

a. Need for the Information Collection Section 20.601 sets forth several methods for controlling access to

, _high radiation areas that are acceptable to the NRC. However, there can be circumstances and situations where alternative methods of con-trol might be equally effective and less burdensome on the licensee.

Paragraph 20.601(b) provides for approval of such alternative

, controls,

b. Practical Utility of the Information Collection The licensee who opts to use an alternative method to control access to high radiation areas must provide a full and detailed description of the alternative method to the Commission in order that health and safety features can be evaluated. Specific approval must be obtained prior to implementing control methods other than those snecified in S 20.601(a).

NRC inspectors will review the licensee's program for compliance with the control measures proposed and approved.

84 Enclosure 2/ Addendum 2

~

c. Duolication with Other Collections of Information None.

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 consultations have included representatives of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle 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 S:

--Labor Unions International Brotherhood of Electrical Workers Utility Workers Union of America 85 Enclosure 2/ Addendum 2

--Public Interest Groups Natural Resources Defense Council

--Health Organizations Health Physics 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 t

United Nations Scientific Committee on the Effects of Atomic Radiation

--Agreement States Conference of Radiation Control Program Directors 1 --Federal Agencies and Committees '

a Interagency Working Group on Occupational Exposure Guidance -

Environmental Protection Agency Department of Energy

_ Department of Defense b

Advisory. Committee on Reactor Safety and Subcommittees, NRC Occupational' Safety and Health Administration Department of. Health and Human-Services

e. Other Supporting Information None. -

- 2. Description of the Information Collection >

- a. Number and Tyne of Resoondents The provision for alternative methods of control is available to all

'NRC licensees who have high radiation areas. It is estimated that 86 Enclosure 2/ Addendum 2 y3 + .c,, ,--s- ----- - - --- --<--r-- -e r,ie-- - -

about 8 licensees each year will each file one application for such alternative control measures,

b. Reasonableness of the Schedule for Collecting Information Prior approval of alternative control measures is considered necessary in order to ensure the health and safety of individuals who might otherwise enter the high radiation area-and be unnecessarily exposed,

c. Method of Collecting the Information The applicant for license is the only source of information regarding a proposed alternative method for control. The information must be incorporated into the license in order to make the program inspectable and enforceable.

, d. Record Retention Period This report justification does not involve a recordkeeping requirement.

e. Reoorting Period The information on an alternative control measure for high radiation areas must be filed for specific license approval prior to use of

-the alternative control measure.

f. Copies Required to be Submitted One copy is to be filed with NRC.

g. Format of Information to be Maintained or Submitted No format is specified for the presentation of the alternative control method.

l l 87 Enclosure 2/ Addendum 2 L

3. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection It is estimated that 8 applicants annually will spend about 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months preparing the submission of alternative control methods for a total of-16 hours / year.

1 Number of respondents....................... 8 2 Number of responses per respondent.......... 1 3 Total annual responses...................... 8 4 Hours per response.......................... 2 5 Total hours................................. 16

b. . Estimated Cost Reouired to Resoond to the Collection .,

The estimated cost is $800/ year (16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months x $50/ hour).

c. Source of Burden Data and Method for Estimating the Burden

-The burden data and estimates are judgements of NRC staff based on experience gained as licensees and as regulators.

d. Reasonableness of Burden Estimates

.The estimates are comparable to estimates of burden experienced

.under 5 20.203(c)(5) of the existing Part 20.

4. Estimate of the Cost to the Federal Government The cost incurred by NRC to evaluate the applicant's alternative method of control of access to high radiation areas is estimated at 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months /

' application for-a burden of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months / year and a cost of $400/ year.

88 Enclosure 2/ Addendum 2

't.

SUPPORTING STATEMENT FOR 10 CFR 20.905(c)

NOTIFICATION REGARDING RADI0 ACTIVE CONTAMINATION ON OR EXCESS RADIATION LEVELS IN THE VICINITY OF PACKAGES AND 10 CFR 20.905(d)

ESTABLISHING AND' MAINTAINING PROCEDURES FOR OPENING PACKAGES S 20.905(c) requires the licensee to immediately' notify the final delivery carrier and the appropriate NRC regional office if packages, other -than those transported by exclusive use vehicle, have removable radioactive contamination on.the external surface in excess of 0.01 microcuries per 100 square centi-

~

meters or radiation levels in excess of 0.01 rem /hr at 1 m from the external surface.

.5 20.905(d) requires the licensee to establish' records and maintain procedures for safely opening packages containing radioactive material.

1. Justification S.20.905(c)--If removable contamination or radiation levels in excess of-the limits outlined in the proposed S 20.905(c) is detected, there must be immediate notification by the licensee of the final delivery carrier and the appropriate NRC regional office in order to avoid further spread of.the contamination and-to take any actions that may be necessary or

. practical to reduce exposures from the contamination.

~ S 20.905(d)--The licensee must establish and maintain written procedures for safely opening packages in which radioactive material is received in order to ensure the health and safety of those involved in handling and transporting packages containing radioactive material.

1 1

89 Enclosure 2/ Addendum 2

a. Need for the Information Collection S 20.905(c)'--If, during shipment, a package is damaged such that radioactive material leaks out or an excessive radiation level exists, the carrier might need to take prompt action to avoid con-

.tamination and exposure of the person (s) involved, the contamination

~

of vehicles and other shipments, and to take action to reduce or eliminate the contamination.

5 20.905(d)--Procedures for safely opening packages are necessary to avoid exposure of those involved in receiving and opening packages containing radioactive materials.

-b. Practical Utility of the Information Collection

'SL20.905(c)--The report will allow the carrier to take any correc-tive action that is necessary and practical to limit spread of-the contamination and exposure of people. The report to the NRC will tpermit NRC to assess the adequacy of the corrective actions taken, and to coordinate actions in other parts of the country, if such is necessary. All of these actions must be taken promptly.

.6 20.905(d)--The procedures will be used by the licensee's employees

'to ensure safety during the opening of packages. The-procedures will be. reviewed-by NRC inspectors to verify compliance.

c. Duplication'with Other Collections of Information None.

d. Consultations Outside the NRC JDuring 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 consulta-tions have included representatives of the following groups:

90 Enclosure 2/ Addendum 2

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

Research Reactors

-Universities Uranium Fuel Cycle 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 Physics 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 91- Enclosure 2/ Addendum 2

--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 Succorting Information None.

2. Description of the Information Collection e

a. Number and Tyne of Rescondents 6 20.905(c)--This proposed change would involve approximately 25 of the (mostly raterial) licensees who receive transport packages con-taining radioactive material each year.

S 20.905(d)--This proposed change would involve approximately 6,000 (mostly material) licensees, but the procedures would be reviewed

~ and updated about once every 5 years so that only 1,200 would be considered each year.

b. Reasonableness of the Schedule for Collecting Information S 20.905(c)--The reports to carriers and NRC must be made very promptly.in order to limit the spread of contamination and the expo-sure of people.

92 Enclosure 2/ Addendum 2

, I

s S 20.905(d)--In order to avoid potential exposure and release of radioactive material, procedures for the opening of packages need to be developed before workers open packages of radioactive material.

c. Method of Collecting the Information S 20.905(c)--Each licensee shall immediately notify the final delivery carrier of a package having' contamination or excess radiation levels.

In addition, NRC must be notified by telephone and telegram, mailgram or facsimile.

S 20.905(d)--Each licensee shall prepare the procedures to be used to open the kinds of packages to be received in the licenses' e unique facilities.

d. Record Retention Period 3

The licensea is required by SS 20.905(d)(3) to maintain the procedures for opening packages as long as they are appropriate for use.

e. Recorting Period When an incident occurs, the licensee must immediately notify the appropriate carrier and NRC individuals. No report is required for 8 20.905(d).

f. Copies Required to be Submitted A report of a contamination incident is required, but this need not be a hard copy written report.

~

g. Format of Information to be Maintained or Submitted Not specified.

93 Enclosure 2/ Addendum 2

3. Estimate of Burden

a. Estimated Hours Reouired to Respond to the Collection 9

~

S 20.905(c)--An estimate of 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months might be needed for each of the 25 licensees to report a contaminated shipment. A total of 125 hours0.00145 days 0.0347 hours 2.066799e-4 weeks 4.75625e-5 months /

year is thus projected.

1 Number of respondents....................... 25 2 Number of responses per respondent.......... 1 3 Total annual responses...................... 25 4 Hours per response.......................... 5 5 Total hours................................. 125 9 20.905(d)--It is estimated that 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per year per licensee will be required to record the procedures. This is a total time commitment of 1,200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months annually among all licensees.

1 Number of recordkeepers..................... 1,200 2 Annual hours per recorokeeper............... 1 3 Total recordkeeping hours................... 1,200

b. Estimated Cost Reouired to Respond to the Collection

$ 20.905(c)--At $50 per hour of staff time, each licensee would expend approximately $250 for an annual amount of $6,250 among the 25 licensees.

S 20.905(d)--At $50 per hour of staff time, each licensee would expend

$50 annually (5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months /5 years). This yields a total cost commitment of $60,000/ year ($50/ hour x 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months /5 years x 1,200 licensees).

94 Enclosure 2/ Addendum 2

c. Source of Burden Data and Method for Estimating the Burden The burden estimates were obtained from a review of the kind of activ-ities licensed by the NRC and consideration of the amount of time

. required by licensees to establish and maintain such procedures.

d. Reasonableness of Burden Estimates No supporting data are available to judge the reasonableness of the estimates.

4. Estimate of the Cost to the Federal Government L S 20.905(c)--The time needed by NRC to review the report required in this section is estimated to be a total of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months annually. At $50 per hour of review time, this is $300 annually.

$ 20.905(d)--Assuming that 6,000.11censees have to develop the procedures and an irispector takes approximately 10 minutes to review the procadures -

onc)every3 years,thetimecomnitmentwouldbe330hoursannually. At

.350 per hour of staff time, approximately $16,500 would be expended annually.

e 95 Enclosure 2/ Addendum 2

SUPPORTING STATEMENT FOR 10 CFR 20.1002(a)

ALTERNATIVE PROCEDURES FOR DISPOSAL OF LICENSED MATERIAL P

1. Justification Sections 20.1001, 20.1003, 10.1004 and 20.1005 specify methods for dis-posal of licensed (radioactive) material. Paragraph 20.1002(a) provides that a licensee may apply to the Commission for approval of proposed procedures to dispose of licensed material in a manner not otherwise authorized by ' art 20.

a. Need for'the Information Collection If a licensee wants to use alternative procedures for disposal of

-licensed material, it is necessary to evaluate the alternative pro-cedures to ensure that public health and safety are not compromised.

The licensee, or license applicant, must describe all aspects of the alternative procedure in an application for specific authorization in order for the NRC licensing staff to make the necessary health and safety evaluation.

b. Practical Utility of the Information Collection

-The NRC staff will evaluate the information submitted by the licensee

-or license applicant in order to determine the adequacy of the alter-native procedures from the hesith and safety standpoint.

c. Duolication with Other Collegtfons of Information l None.

i 96 Enclosure 2/ Addendum 2 k .. .

I

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 consultations have included members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle Facilities '

Medical Facilities Uranium Mills Well Loggers Radiographers, and others

--Trade Organizations Edison Electric Institute: Health Physics Committees, Subcommit-tees, 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 97 Enclosure 2/ Addendum 2

l

--Health Organizations Health Physics 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 Radietion

--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 Subecmmittees, NRC Occupational Safety and Health Administration Department of Health and Human Services

e. Other Succorting Information The requirements in S 20.1002(a) are not new in the revision of Part 20 and have been the subject of prior rulemaking for the existing 8 20.302.

2. Description of the Information Collection

a. Number and Type of Respondents The provisions of S 20.1002(a) are available to all 7,500 NRC licen-sees. However, it is anticipated that only about 25 licensees or 98 Enclosure 2/ Addendum 2

6

license applicants will seek approval of alternative disposal pro-cedures each year. These applicants may be large or small licensees who find alternative disposal procedures desirable for convenience or economic reasons.

b. R'easonableness of-the Schedule for Collecting Information The alternative disposal procedures must be evaluated for health and safety aspects prior to use of those disposal procedures.

~

c. Method of Collecting the Information The information would be included in an application filed by the licensee'or applicant for license.

d. Record Retention Period Not applicable. This justification does not involve a recordkeeping requirement.

e f

e. 'Reaceting Period The application for authorization of alternative disposal procedures 4

I must be filed and specific license approval granted prior to use of

.the alternative procedures.

. f. Copies Required to be Submitted One copy of the license application is to be filed with the NRC.

i

g. Format of Information to be Maintained or Submitted

) . Section 20.1002 indicates the types of information to be included in the application, but does not specify the format.

99 Enclosure 2/ Addendum 2

3. Estimate of Burden

a. Estimated Hours Reouired to Respond to the Collection It.is estimated that, on the average, 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months will be spent by each of about 25 licensees in preparation of the application. The total burden would approach 825 hours0.00955 days 0.229 hours 0.00136 weeks 3.139125e-4 months per year.

1 Number of respondents....................... 25 2 Number of responses per respondent.......... '

1 3 Total annual responses...................... 25 4 Hours per response.......................... 33 5 Total hours................................. 825

b. Estimated Cost Required to Resoond to the Collection .

The cost is estimated to be about $41,250/ year (25 applications / year x-33 hours / application x $50/ hour).

c. Source of Burden Data and Method for Estimatino 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 The estimate of burden is comparable to that estimated under S 20.302 -

of the existing Part 20.

4. Estimate of the Cost to the Federal Government Approximately 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , on the average, would be spent in the evaluation "of the application for alternative disposal procedures. The cost could approach $7,500 per year (25 applications / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / application x

$50/ hour).

100 Enclosure 2/ Addendum 2

o .

SUPPORTING STATEMENT FOR 10 CFR 20.1201 (a), (b) and (d)

REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL

1. Justification S 20.1201 establishes that the licensee report a theft or a loss of licensed material by telephone and in writing depending upon the potential risk to g the health and safety of the public associated with the missing radicactive material.

a. Need for the Information Collection A loss or theft of licensed material that appears to the licensee to result in a substantial hazard to persons in unrestricted areas must be reported because of NRC responsibilities for protecting the health and safety of the public. It is essential that the licensee report the theft or loss of licensed material to the Commission in order to limit the risk to the public through counteractions to the extent feasible, and to ensure against recurrence.

b. Practical Utility of the Information Collection The NRC will use the reports to confirm the licensee's evaluation of the hazards and to determine if additional safety procedures should be instituted for the protection of the public. Other agencies might also be alerted through this mechanism. In addition to the written reports maintained in permanent files in the appropriate regional office, copies are distributed throughout the Regulatory Information Distribution System (RIDS) to the Office of Inspection and Enforce-ment for generic analysis and to the Office for Analysis and Evalua-tion of Operational Data where they are compiled for use in assessing the adequacy of existing regulations.

101 Enclosure 2/ Addendum 2

c. Duplication with Other Collections of Information None. A duplicate report is not required if the licensee is required to submit a report pursuant to SS 30.55(c), 40.64(c), 50.72, 50.73, 70.52, 73.27(b), 73.67(e)(3)(vi), 73.67(g)(3)(fii), 73.71, or 150.19(c) of this chapter.

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 frcm a number of interested parties. These consultations have inclu'ded members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle Facilities

Medical Facilities Uranium Mills Well Loggers Fadiographers, 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 102 Enclosure 2/ Addendum 2 l

--Labor Unions !

2 International Brotherhood of Electrical Workers Utility Workers Union of America 4

--Public Interest Groups Natural Resources Defense Council

--Health Organizations

. Health Physics 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 .

T

--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 Supportino Information None.

103 Enclosure 2/ Addendum 2

o 4

2. Description of the Information Collection

a. Number and Type of Respondents SS 20.1201(a) and (b)--These requirements would apply annually to ,

approximately 30 material licensees of various types and sizes, who might have to deal with a theft or loss situation.

S 20.1201(d)--This requirement would apply to a few, taken as five/

year for purposes of this report justification, of the licensees experiencing a theft or loss, who might become aware of additional

. substantive information regarding a theft or loss after having filed the written report required by 6 20.1201(b').

b. Reasonableness of the Schedule for Collecting Information The licensee is the most likely source for notification of lost or stolen radioactive material. (Sometimes the radioactive material is found by members of the public and notification is provided to public officials.) It is important that notification be made promptly upon becoming aware of the theft or loss in order that efforts can be mada to locate tne missing material or to otherwise reduce risk to the health and safety of the public.

c. Method of Collecting the Information The licensee provides the information by telephone and in writing to ;

the NRC.

I l

, d. Record Retention Period '

The licensee is not required by S 20.1201 to maintain any records.

~

l l

l 4

104 Enclosure 2/ Addendum 2

e. Reporting Period The telephone reporting period varies from immediately to 30 days after the licensee becomes aware of the theft or loss, depending on the situation. Immediate reporting is required when prompt counter-actions might be necessary to limit the risk to the public. Follow-up written reports within thirty days will confirm-information which will require. time to ascertain. The thirty-day reporting period will-allow

--the licensee time to evaluate the exposures of individuals to radia-

~ tion,-time to either recover the material or develop action plans for

~

its recovery, and time t,o develop procedures to ensure against a recurrence of the loss or theft of licensed material. While the infornation necessary for the written reports is being obtained and assessed, the earlier telephone reports will' limit any health and safety impact on the public.

f.- Copies Reouired to be Submitted

-Only one telephone call and one copy of a. written report is required pursuant to SS 20.1201(a) and-(b). If additional information becomes available, the licensee is required by S 20.1201(d) to submit one copy of that information.

_g. Format of Information to be Maintained or Submitted None specified.

3. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection S'20.1201(a)--The time required to respond to the telephone reporting requirements is estimated to be 10 minutes for each telephone report, and is estimated to amount to 5 staff hours per year (30 licensees x 10 minutes per year).

105 Enclosure 2/ Addendum'2

$$ 20.1201(b) and (d)--The time required to respond to these written reporting requirements is estimated to be 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , and is estimated to amount to 90 staff hours / year (30 licensees x 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months per year) and 15 staff hours / year (5 licensees x 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months per year), respectively.

S 20.1201 (a) (b) (d) 1 Number of respondents................ 30 30 5 2- Number of responses per respondent... 1 1 1 3 Total annual responses............... 30 30 5 4 Hours per response................... 10 min 3 3 5 Total hours.......................... 5 90 15

b. Estimated Cost Recuired to Resoond to the Collection The estimated cost of these reporting requirements is:

S 20.1201(a) $ 250 (5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months / year x $50)

$ 20.1201(b) $4,500 (90 bcurs/ year x $50)

$ 20.1201(d) $ .750 (15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months / year x $50)

Total $5,500

c. Source of Burden Data and Method for Estimating the Burden The costs and time estimates used in this statement were obtained from the Office of Inspection and Enforcement and from discussions with licensees. ~The time estimates are based on historical data from similar reporting requirements. _The estimate of the number of reports per year-is based on industry and NRC experience with the theft and loss of licensed materials.

106 Enclosure 2/ Addendum 2

d. Reasonableness of Burden Estimates The burden estimates appear to be reasonable owing to the sources of data available (See 3.c. of this supporting statement).

4. Estimate of the Cost to the Federal Government S 20.1201(a)--The telephone reports would cost the government about $250 per year (30 reports x 10 minutes / report x $50/ hour).

S 20.1201(b)--The 30 written reports would cost the government about

$1,500 per year (30 reports x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months / report x $50/ hour).

' S 20.1201(d)--The five written follow-up reports would cost the govern-ment about $250 per year (5 reports x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months / report x 550/ hour).

't f

e

. . s

107 Enclosure 2/ Addendum 2

.- - - =.- -

s *

SUPPORTING STATEMENT FOR n-- .- 10.CFR 20.1202 (a) and (b)

~

NOTIFICATION OF INCIDENTS a

1. Justification

.$ 20.1202(a)-requires that the licensee immediately notify NRC upon becom-

, ing aware of specific incidents causing substantial exposure from, or releases of, licensed material. Section 20.1202(b) requires that the licensee notify NRC within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months upon becoming aware of other specific incidents involving licensed material. Such prompt notification permits an early evaluation of the incident by NRC in order that appropriate. action

.can'be-taken to protect against further hazard to life or property.

a. Need for the Information Collection Such reports are needed in order for NRC to assess the licensee's evaluation of incidents to determine if additional safety procedures should be instituted for the protection of the public,

b. Practical Utility of the Information Collection i

The reports will be utilized by the NRC staff to determine if the

, incident has resulted in any individuals receiving doses in excess of the limits and to determine if adequate safety procedures have been instituted to prevent any additional health risks due to the

incident.

c. Duplication with Other Collections of Information None.

108 Enclosure 2/ Addendum 2

(

! e ! q t , .

d. ConsultationsOutsidetNeNRC During the past 36 months, members of the Part 20 revision task force have discu[ sed the proposed revision and sought comments on the s

various draflis from a number of interested parties. These consulta-tions-have included members of th'e following groups:

s

--Licensees of various types and sizes Architects, Engineers, Contractors Power Reactors <(niR)

Research-ReactoNs Universities-Uranium Fuel Cyc1,e Facilities Medical Facilities.

. Uranium Mills Well Loggers *

.Radiogra hers, and"others j --Trade Organizations Edison' Electric. Institute: Health Physics Committees, Subcommittees, and Tasb 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 c k International Brotherhood of Electrical Workers Utility Workers Union of America ll , > -

--Public Interest Grotos {

Natura?,feshurcesDefenseCouncil

[ .)

.\- i ,

l

([

l f

)

109 Enclosure 2/ Addendum 2 l - r n y- - --~ww-w , ,e mca-rw,,-,,m._m.,,,.w.,- -.,,v,._w-,_,_n -

l

. . -l l

l c

--Health Organi::ations - l 1

Health. Physics Society: National, Local Chapters, and ad-hoc ;

Study Groups

' l; American Association of Physicists in Medicine Society of huclear Medicine l National Council on Radiation-Protection and Measurements International Commission on Radiological Protection i United Nations Scientific Committee on the Effects of Atomic l q

Radi a' tion -

i

~

i

--Agreement States -

, j Conference of Radiation Control Program Directors l l

--Federal Agencies and Committees

-Interagency Working Group on Occupational Exposure Guidance [

j Environmental Protection Acjency , , ,

Department of Energy-Department of Defense Adv.isory. Committee on Reactor Safety and Subcommittees, NRC .

Occupational Safety and Health Administration

~

Department of Health and Human -Services

e. Other Suoporting Information i

None.

ll

2. Description of the Information Collection '

'a. Number and' Type of Respondents '

l

-l S 20.1202(a)--This reporting requirement would involve approximately 1 10 licensees annually.

f r

( $ 20.'1202(b)--This reporting requirement would involve approximately 40 licensees annually. '

110 Enclosure 2/ Addendum 2 .

. . o .

b. Reasonableness of the' Schedule for Collecting Information The immediate and 24-hour schedule for reporting the information is to permit timely countermeasures to be taken, as necessary, to reduce the risk to the health and safety of workers and the public.

c.- Method of Collecting the Information

' Notification by licensees is of the following two types:

Licensees that have an installed emergency notification system shall make the reports required either immediately or within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to the NRC Operation Center in accordance with 5 50.72.

All other licensees shall make the reports required either immediately or within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by telephone and by telegram, mailgram, or fac-simile to the Administrator of the appropriate NRC Regional Office listed in Appendix 0 of Part 20.

i

. d. Record Retention Period No record is required pursuant to S 20.1202.

e. Reporting Period Immediate and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months -- see 1. of this supporting statement.

f. Cooies Required to be Submitted

)

l. Written reports require one copy to the Commission.

g .~ Format of Information'to be Maintained or Submitted 1

'None specified, but see 2.c. of this supporting statement.

I

(

1 111 Enclosure 2/ Addendum 2 e

i i

3. Estimate of Burden

, a. Estimated Hours Recuired to Respond to the Collection

, S 20.1202(a)--Based on an estimate of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per licensee, and assum-ing that 10 licensees are affected each year, 10 licensee-hours would be required annually.

S 20.1202(b)--Based on an estimate of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per licensee, and assum-ing that 40 licensees are affected each year, 40 licensee-hours would be required annually.

S 20.1202 (a) (b) 1 Number of respondents.*...................... 10 40 2 Number of responses per respondent.......... 1 1 3 Total annual responses...................... 10 40 4 Hours per response.......................... 1 1 5 Total hours................................. 10 40

b. Estimated Cost Recuired to Resoond to the Collection The cost of complying with this information requirement is the cost required to notify NRC of incidents, as previously detailed. At $50 per staff hour of licensed time, each licensee involved would expend

$50 annually. This yields an annual cost of $500 for the 10 licensees under S 20.1202(a) and $2,000 under S 20.1202(b). ,

c. Source of Burden Data and Method for Estimating the Burden The burden data were obtained from a review of the kind of activities licensed by the NRC and consideration of the amount of time estimated to be required by licensees to prepare notification of incident reports.

112 Enclosure 2/ Addendum 2

d. Reasonableness of Burden Estimates No alternative sources of cost estimates are available.

4. Estimate of the Cost to the Federal Government 4

At $50-per hour of staff time, it is estimated that the NRC annual cost for the 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months of staff time required to review the reports of the inci-dents would be $2,500.

i a

1 9 s.

J I

4 113 Enclosure 2/ Addendum 2

SUPPORTING STATEMENT FOR 10 CFR 20.1203(a)(1), (a)(2), (a)(3), (a)(4), (a)(5) and (c)

REPORTS OF OVEREXPOSURES AND EXCESSIVE RADIATION LEVELS AND CONCENTRATIONS OF RADIOACTIVE MATERIAL

1. Justification S 20.1203 establishes-that the licensee submit a written follow-up report within 30 days of: (1) each exposure of an individual to an occupational

. effective dose equivalent in excess of SS 20.201, 20.205, and 20.207, or ifcense limit; (2) levels of radiation or concentrations of radioactive material in a. restricted area in excess of any other applicable limits; (3) any incident for which notification is required by S 20.1202, the sec-tion involving notification of incidents; (4) any occurrence in which an individual.in an unrestricted area has received an effective dose equiva- ,

lent exceeding the annual dose limits in S 20.301, the section involving dose limits for individual members of the public; (5) levels of radiation or concentrations of radioactive material in an unrestricted area in excess of 10 times any limit in the license; and (6) for licensees operating a uranium fuel cycle facility, levels of radiation or releases of radioac-tive materials into the general environment exceeding the limits specified in 40 CFR Part 190 or in licensed conditions imposed pursuant to 40 CFR Part 190.

.a. Need for the Information Collection The information required by these reports is needed for NRC staff to assess what went wrong in the licensee's program that caused the occurrence, to evaluate the degree of risk to the health and safety of wor'K ers and the public, to evaluate the adequacy of actions taken I l

l 114 Enclosure 2/ Addendum 2

<, :s to reduce that risk, and to evaluate the adequacy of steps taken or

, planned to ensure against recurrence. While an early (within 30 days) repart-is. considered necessary in order to permit timely assessments

.and evaluations of the health and safety impact on the public, the significance of these occurrences does not warrant the more immediate reports required for theft or loss ($ 20.1201) or for incidents

($ 20.'1202). ,

b. Practical Utility of the Information Collection 1 '

NRC staff will use the information to:make the assessments and

. evaluations described in 1.a. of this, supporting statement. Follow-up questions may.be directed to the lice'nsee, and, in some cases, there 4

may be follow-up inspections. However, in most cases, the follow-up ;

would be conducted during the next scheduled inspection.

c.- Duplication with Other Collections of Information None. For holders of an operating license

for a nuclear. power plant, some of these occurrences must be reported pursuant to $_50.73. Para-graph 20.1203(d) specifies that occurrences reported in accordance

- with 9 50.73 need not be reported by a duplicate report under 9 20.1203.

d. Consultations Outside the NRC L

=

Ouring the past 36 months, members of the Part 20 r,evision task force

! have discussed the proposed revision and sought comments on the various drafts from a number of interested parties. These consulta-tions have included members of the following groups:

1

-Licensees of various types and sizes f

Architects, Engineers, Contractors Power Reactors (LWR)

Research Reactors Universities 115 Enclosure 2/ Addendum 2 6- ,e, .--ww-we-,o.-- .- ,.,,..,_e-.,mno . - - ,w . ,,.---2-,,..-,,.-,v.,,- ,,,..--,.----.-.--,,,.,,,,.-++,-r-,

,, y -- e v-v-,v-,-w-- ,q. g

4 Uranium Fuel Cycle 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 Physics 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

--Agreement States Conference of Radiation Control Program Directors 116 Enclosure 2/ Addendum 2

J.; .

--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 None.

2. Description of the Information Collection

a. Number and Type'of Respondents The requirements in S 20.1203 apply to all 7,500 NRC licensees. Re-ports that have been filed under the existing S 20.405 have been mostly from industrial radiography, power reactor, medical, research, and' educational licensees. The number of respondents estimated to file.one report under 5 20.1203 annually is:

9 20.1203(a)(1) 40 S 20.1203(a)(2) '

5 9 20.1203(a)(3) 10 6-20.1203(a)(4) 5 9 20.1203(a)(5) 5 9 20.1203(c) _5

Total 70 respondents i

b. Reasonableness of the Schedule for Collecting Information The 30-day reporting period is considered reasonable. It provides

earlyfinformation permitting the assessments and evaluations needed, without requiring immediate reporting.

117 Enclosure 2/ Addendum 2.

m.~

r:

c. Method of Collecting the Information The information is to be submitted in writing by the licensee. For holders of an operating license for a nuclear power plant, these occurrences must be reported in accordaace with 5 50.73, and need not ,

be reported.by a duplicate report under this section.

d. Record Retention Period This justification does not deal with a recordkeeping requirement.

e. Reporting Period The reports are to be filed within 30 days after the licensee learns of the occurrence,

f. Copies Required to be Submitted One copy of the report is to be sent to the US NRC Document Control Desk, Washington, DC 20555, with a copy to the Administrator of the appropriate NRC Regional Office listed in Appendix D of Part 20.

g. Format of Information to be Maintained or Submitted The format of the report is not specified in the regulation.

3. Estimate'of Burden

a. Estimated Hours Required to Respond to the Collection It is estimated that licensees would spend an average of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months /

year in the preparation of each of the reports required by 9 20.1203.

The burdens are estimated as:

118 Enclosure 2/ Addendum 2

. x S 20.1203(a)(1) 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months / year (40 reports / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / report)

$ 20.1203(a)(2) 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months / year ( 5 reports / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / report) 6 20.1203(a)(3) 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months / year (10 reports / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / report) 5 20.1203(a)(4) 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months / year ( 5 reports / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / report)

S 20.1203(a)(5) 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months / year ( 5 reports / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / report)

$ 20.1203(c) 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months / year ( 5 reports / year x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months / report)

Total 420 hours0.00486 days 0.117 hours 6.944444e-4 weeks 1.5981e-4 months / year S 20.1203 (a)(1) (a)(2) (a)(3) (a)(4) (a)(5) (c) 1 Number of respondents.............. 40 5 10 5 5 5

~

2 Number of responses per respondent. 1 1 1 1 1 1 3 Total annual responses............. 40 5 10 5 5 5 4 Hours per response................. 6 6 6 6 6 6 5 . Total hours....................... 240 30 60 30 30 30

b. Estimated Cost Required to Respond to the Collection The costs per year are estimated as:

S 20.1203(a)(1) $12,000/yr (40 reports /yr x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months x $50/ hour)

'S 20.1203(a)(2) $ 1,500/yr ( 5 reports /yr x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months x $50/ hour)

$ 20.1203(a)(3) $ 3,000/yr (10 reports /yr x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months x $50/ hour)

S 20.1203(a)(4) $ 1,500/yr ( 5 reports /yr x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months x $50/ hour)

S 20.1203(a)(5) $ 1,500/yr ( 5 reports /yr x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months x $50/ hour)

S 20.1203(c) $ 1,50/yr ( 5 reports /yr x 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months x $50/ hour)

Total $21,000/ year

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

119 Enclosure 2/ Addendum 2

f I . ,

I

d. Reasonableness of Burden Estimates

. The estimates of burden are thought to be reasonable estimates by staff. No alternative source of information on these estimates of l burden is available.

'4. Estimate of the Cost to the Federal Government It is estimated that NRC staff would, on the average, spend about 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months receiving and evaluating the reports submitted pursuant to S 20.1203. The annual' costs are estimated as:

I S 20.1203(a)(1) $4,000 (40 reports / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months x $50)

S 20.1203(a)(2) $ 500 ( 5 reports / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months x $50)

6 20.1203(a)(3) $1,000 (10 reports / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months x $50)

S 20.1203(a)(4) $ 500 ( 5 reports / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months x $50)

! S 20.1203(a)(5) $ 500 ( 5 reports / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months x'$50)

S 20.1203(c) $ 300 ( 5 reports / year x 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months x $50)

Total $7,000 I

120 Enclosure 2/ Addendum 2

1 f

SUPPORTING STATEMENT FOR 10 CFR 20.1204 REPORTS OF PLANNED SPECIAL EXPOSURES 4--

- 1. Justification F

Section 20.206 provides for planned special exposures under which a licensee

, may allow;an adult worker to receive doses above the basic dose limits,

-but within specific annual and lifetime constraints. These planned special exposures are to be authorized only in exceptional situations, when alter-i natives which might avoid the higher exposures are unavailable or imprac-i

, tical. The planned special exposure provision would provide some of the

' flexibility .in the management of occupational exposures necessary to accomp-lish tasks in high radiation areas that was provided under the 5(N-18) dose-averaging formula, which has been deleted from the proposed revision. The planned special exposure provision implements a somewhat less restrictive

~

recommen'dation in Publication 26 of the International Commission on Radio-logical Protection.

i

~

a. Need for the Information Collection Since the planned special exposure provision allows for doses in excess of the annual limits, the NRC wishes to monitor the use-of planned special exposures closely. to promptly review the circum-

-stances for which the planned'special exposures were considered necessary, and to ensure that the provision is not being abused. In order to be aware of the conduct of such exposures, it is considered necessary for a licensee to notify NRC, pursuant to the requirements in S 20.1204,- that a planned special exposure event was conducted on

~-

a particular date.

121 Enclosure 2/ Addendum 2

>m

b. Practical' Utility of the Information Collection v- -

Upon notification of 'a planned special exposure event, NRC inspectors can arrange for an early review of the circumstances involving the use of this provision and the resultant occupational exposures.

c. Duplication with Other Collections of Information None.

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 varicus drafts from a number of interested parties. These consulta-tions have included members of the following groups: -

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

.. Research Reactors Universities Uranium Fuel Cycle Facilities Medical Facilities Uranium Mills Well Loggers Radiographers, and others

--Trade Organizations Edison Electric Institute: Health Pnysics 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 122 Enclosure 2/ Addendum 2

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

--Public Interest Groups Natural Resources Defense Council

--Health Organizations Health Physics 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

--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 Supoortina Information None.

123 Enclosure 2/ Addendum 2

O

2. Descriotion of the Information Collection

a. Number and Tyoe of Resoondents The provisions for planned special exposures are available to all NRC specific licensees, and, if used, the reporting requirements in S 20.1204 would apply. Practically, only licensees having very large sources, such as power reactors, are likely to encounter circum-stances justifying planned special exposures. Since the planned special exposures are to be used only in exceptional situations, the NRC staff believes that the provision for planned special exposures ,

might not be used. However, for purposes of this reporting justifi-cation,'ew are assuming that 5 reactor licensees each year will con-duct planned special exposure events, subject to this reporting requirement.

b. Reasonableness of the Schedule for Collecting Information Section 20.1204 requires that a simple notice of having conducted +a planned special exposure event be submitted to the NRC within 15 days following the exposure. Prompt notification of the NRC of a planned special exposure is necessary because these events involve exposuret above the normal occupational exposure limits. Therefore, because of health and safety reasons, the NRC needs to closely monitor the use of this provision. Once the NRC has been notified that a planned special exposure took place, NRC inspectors can review the licensee's records of the event to ensure that a prompt evaluation of the workers' exposures was made and that the workers are adequately protected at the licensee's facility. Since the licensee is required to make the evaluation of circumstances and to formally authorize the planned special exposure event in advance, the 15-day period appears more than adequate.

124 Enclosure 2/ Addendum 2 l

i

c. Method of Collectino the Information The notice of conducting a planned special exposure event is to be submitted, in writing, to the Administrator of the appropriate NRC Regional Office. The licensee is the only source of this information.

d. Record Retention Period Recordkeeping aspects of planned special exposure events are covered under 5 20.1105.

e. Reporting Period The notice of having conducted a planned special exposure event is to be submitted to the NRC within 15 days following the exposure.

f._ Copies Required to be Submitted One copy of the notice of having conducted a planned special exposure event is required to be filed with the NRC.

g. Format of Information to be Maintained or Submitted Section 20.1204 requires only that the licensee submit a notice that a planned special exposure event was conducted and the date on which it was conducted. No format is specified in the regulation.

3. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection

.It is estimated that each of the 5 licensees'who might conduct a planned special exposure event in a year would commit 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to the 125 Enclosure 2/ Addendum 2

preparation of a written notice to the NRC, for a total of 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months per year.

1 Number of respondents....................... 5 2 Number of responses per respondent.......... 1 3 Total annual responses...................... 5 4 Hours per response.......................... 1 5 Total hours................................. 5

b. Estimated Cost Required to Respond to the Collection The annual cost under S 20.1204 would be about $250 (5 licensees x 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months / licensee x $50/ hour),

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

d. Reasonableness of Burden Estimates The estimates of overall burden are comparable to those developed by S. Cohen & Associates, Inc., under contract with the NRC.

4. Estimate of the Cost to the Federal Government Under 9 20.1204, it is estimated that NRC inspectors would spend 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months receiving and evaluating each of the notices of planned special exposure events conducted by licensees, for a total of 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months / year and a cost of about $250/ year.

126 Enclosure 2/ Addendum 2

o .

SUPPORTING STATEMENT FOR 10 CFR 20.1205 REPORTS OF EXCEEDING THE REFERENCE LEVEL

1. Justification The annual dose limits in S 20.301 apply to actual doses that are received by individuals in the public. However, for a variety of complex reasons, it might be impractical to determine precisely an annual dose. Therefore, it might be desirable for a licensee to establish compliance with the dose limits in a practical manner by using site-specific parameters and reason-able assumptions to demonstrate that the doses are not likely to g,ceed a fraction of the limits. For this purpose, reference levels will ensure that no individual member of the public will be subject to doses that ex-ceed the annual dose limi,ts in S 20.301. When a licensee becomes aware that operations have resulted in an exposure to an individual member of the public in excess of the reference level, the licensee is required to submit a written report to the NRC, pursuant to S 20.1205, within 30 days after becoming aware that an individual member of the public has received, or is likely to receive, in a calendar year, an effective dose equivalent in excess of 0.1 rem.

a. Need for the Information Collection If a licensee experienced operating conditions such that individuals in the public received doses in excess of the reference level, NRC needs to be aware of such a large contribution to public dose. NRC needs the information to assess the cause of the exposures, and to verify that the licensee's program assesses the doses properly and

~

that exposures are maintained as low as is reasonably achievable.

127 Enclosure 2/ Addendum 2

b. Practical Utility of the Information Collection NRC staff will use the information to make the assessments recognized as needs in 1.a. of this supporting statement. NRC will also note-the potential for multiple licensees to contribute dose to the same population group and impose additional constraints, if needed.

c. Duplication with Other Collections of Information None.

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 consulta- -

tions have included members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle 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 128 Enclosure 2/ Addendum 2

.. zu

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

--Public Interest Groups Natural Resources Defense Council ,

--Health Organizations Health Physics 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 i

Radiation

--Agreement States l Conference of Radiation Control Program Directors

--Federal Agencies and Committees l Interagency Working Group on Occupational Exposure Guidance Environmental Protection Agency Department of Energy Departnent 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 l

None. -

l 129 Enclosure 2/ Addendum 2

7

2. Description of the Information Collection

a. Number and Type of Respondents The requirements in S 20.1205 apply to all 7,500 NRC licenstes. How-ever, it is believed that licensees might exceed the reference level in only a few occurrences. For purposes of this report justification,

-we have assumed that the proposed reporting requirement would involve one response from 40 licensees per year.

b. Reasonableness of the Schedule for Collectina Information The 30-day reporting period is considered reasonable. It provides early information permitting the assessments and evaluations needed, without requiring immediate reporting.

c. Method of Collecting the Information The information is to be submitted in writing by the licensee.

d.' Record Retention Period No records must be retained pursuant to S 20.1205.

e. Reporting Period The report must be made within 30 days after becoming aware that an individual'has received, or is likely to receive, a dose exceeding

.the reference level.

f. Copies Required to be Submitted One copy goes to the appropriate NRC Regional Office.

130 Enclosure 2/ Addendum 2

e .

g. Format of Information to be Maintained or Submitted The licensee must provide a written report, the format of which is not specified in the regulation.

3. Estimate of Burden

a. Estimated Hours Required to Respond to the Collection An estimate of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months per response gives an annual total of 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months (40 responses / year x 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months / response).

1 Number of respondents....................... 40 2 Number of responses per respondent. . . . . . . . . . 1 3 Total annual responses...................... 40 4 Hours per response.......................... 4 5 Total hours................................. 160

b. Estimated Cost Required to Respond to the Collection The estimated cost of complying with this information requirement is

$8,000/ year (40 responses / year x 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months / response x $50/ hour).

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

d. Reasonableness of Burden Estimates The estimates of burden are thought to be reasonable. No direct information on burden is available.

131 Enclosure 2/ Addendum 2

l l.

4. Estimate of the Cost to the Federal Government i A l'

The cost-to NRC will be the time required by the staff to review the sub-t mitted report. Assuming $50 per staff hour and that 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months would be '

l spent reviewing each report, there would be an estimated annual time burden

of 160 hours0.00185 days 0.0444 hours 2.645503e-4 weeks 6.088e-5 months and an annual cost of $8,000. .

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l 132 Enclosure 2/ Addendum 2

SUPPORT:NG STATEM$NT FOR 10 CFR 20.1206 PERSONNEL MONITORING REPORTS

1. Justification Section 20.1206 requires seven categories of NRC licensees to submit .

an annual statistical summary report of the effective dose equivalent recorded for all individuals for whom the licensee was required to provide personnel monitoring devices or services pursuant to S 20.502. .

The seven categories of licensees (nuclear power reactors, industrial rndiographers, fuel processors and reprocessors, high-level waste disposers, independent spent fuel-storage installations, commercial suppliers of large quantities of byproduct material, and persons who receive radioactive waste from other persons for disposal under Part 61),

are those considered to involve the greatest potential for significant occupational exposures,

a. Need for the Information Collection The :nnual statistical summary reports are needed for NRC to (1) eval-uate the effectiveness of radiation protection programs for those licensed activities which involve the greatest potential for signiff-cant occupational exposures. In addition, the reports: (2) permit comparisons of exposure experience among types of ifcensees and among licensees within each type; and (3) identify situations where further guidance might need to be developed in order to assure that exposures are kept as low as is reasonably achievable.

The information furnished under S 20.1206 is available to the particu-lar licensees involved and is not otherwise available to the NRC or 133 Enclosure 2/ Addendum 2

p other agencies. The individual exposure records from which the

. statistical summary report is derived are reviewed by NRC inspectors during periodic inspections of licensee facilities and activities.

I

-However, not' all 'of. these licensees are inspected every year and it would take an inspector longer to prepare the report than it would

'take an individual who is familiar _with the licensees' systems and

.works with the records every day. A one-time survey would not permit I >

'i dentification of trends and spot checking of a few licensees would not provide an adequate overall picture.

'b. Practical Utility of the Information Collection

-Because of the considerable interest that has been expressed in the exposure experience of various types of radiation workers, the infor-mation reported to the Commission pursuant to S 20.1206 is tabulated and published on an annual basis. These reports are made available at.the Commission's Public' Document Rooms and at the National Tech-nical Information Service. These reports have been used extensively by various NRC offices, such as Nuclear Regulatory Research and Nuclear Reactor Regulation, and by other federal, national and private organizations. -Information concerning the estimated doses

actually being experienced assist in the evaluation of the effective-ness of the NRC's regulatory program and can be used as one indicator in the assignment of priorities for inspection and enforcement actions.

The Environmental Protection Agency continually makes use of this data to assist them in their efforts to ensure that the radiation exposure limits are appropriate and in their studies of_ the radiation exposures being incurred by all types of radiation workers. The National Council on Radiation Protection and Measurements, the International Atomic Energy Agency and the United Nations Scientific Committee on the Effects of Atomic Radiation are some of the organizations that have used the data in'various studies.

c.- Duplication with Other Collections of Information None.

134 Enclosure 2/ Addendum 2-

. v

d. Consultations Outside the NRC

~

During the past 36 months, members of the Part 20 revision task k

force have discussed the proposed revision and sought comments on the various drafts from a number of interested parties. These 4

consultations have included members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle 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 t Westinghouse Health Physics Staff (REM Program)

Electric Power Research Institute e

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

--Public Interest Groups Natural Resources Defense Council i

135 Enclosure 2/ Addendum 2

P r .

--Health Organizations Health Physics 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 i

United Nations Scientific Committee on the Effects of Atomic Radiation

--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 Succorting 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.

2. Description of the Information Collection

a. Number and Type of Respondents The annual statistical summary report would be filed by about 450 of the NRC's 7,500 specific licensees who conduct the types of activities listed in Item 1.

136 Enclosure 2/ Addendum 2

j

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! )~

4

b. Reasonableness of the Schedule for Collecting Information l'

The annual reporting of statistical summaries of individual monitoring data is considered reas'onable. The monitoring data are those required to be obtained by 5 20.502, records of which are required to be kept on NRC Form 5, or equivalent record pursuant to S 20.1106.

The only statistical analysis required is to determine the number of individ-uals having monitoring results in each of the 18 ranges of effective dose equivalent. Commercial dosimetry services have programmed their

,, computers to provide these reports of their customers' monitoring data, and offer'the service for a reasonable fee. The same data are used by the licensees to demonstrate compliance with the dose limit-ing sections of Part 20 and to assess the effectiveness of the J

licensees' own radiation protection programs. Ample time is allowed for processing of dosimeter data and preparation of the report.

c. Method of Collecting the Information i

The annual report is to be submitted by each NRC licensee.

d. Record Retention Period Not applicab1'e.~ (The report justification of personnel monitoring recordkeeping associated with S 20.1106 and NRC Form 5 is presented at Enclosure 2/ Addendum 4.)

{l' s

e. Reporting Period

~

The report is 'to' be submitted ' annually. It is to be filed on or before August 1 of each year covering the preceding calendar year.

1

<' f. Copies Required to be Submitted One copy of the report is to be submitted to the Director, Office of Nuclear Regulatory Research, Nuclear Regulatory Commission,

-Washington, DC 20555.

137 Enclosure 2/ Addendum 2

I r

g. : Format of Information to be Maintained or Submitted i 1

Licensees are to indicate the number of monitored individuals having j personnel' monitoring results in each of the 18 ranges specified in f

8 20.1206. However, no NRC Form or specific format is required.

3. Estimate of Burden- !

,l

a. Estimated Hours Required to Respond to the Collection .

The number of responses per licensee varies greatly because of the large size differences-in NRC licensees and can range fro,m zero to several hundred. Therefore, for c51culational purposes a point esti-mate of 352 responses per licensee must be used. Approximately 450 licensees are required to report personnel monitoring data on about 158,500 individuals. Responses to a request dated August 25, 1975,

~

for monitoring data for 1975 and associated burden, indicated a median time commitment of 2.75 minutes per individual. Using this value, the estimated burden would be about 7,265 hours0.00307 days 0.0736 hours 4.381614e-4 weeks 1.008325e-4 months per year (158,500 individuals x 2.75 minutes / individual + 60 minutes / hour). i l

-1 Number of respondents.......................

450 2 Number of responses per respondent.......... 352 3 Total annual responses...................... 158,500 4 Hours per response.......................... 2.75 minutes 5 Total hours................................. 7,265

b. Estimated Cost Required to Respond to the Collection The estimated cost is $145,300 (7,265 hours0.00307 days 0.0736 hours 4.381614e-4 weeks 1.008325e-4 months / year x $20/ hour).

c. Source of Burden Data and Method for Estimating the Burden The hours of burden were estimated.by NRC staff based on experience gained as licensees and as regulators. The time per individual was b'a sed on responses to a' request dated August-25, 1975, as indicated in 3.a.

, 138 Enclosure 2/ Addendum'2

d. Reasonableness of Burden Estimates, The estimates of burden are thought to be reasonable in view of many

. years of experience under the very comparable requirement in S 20.407 and in view of the licensee input in 1975 to the time committed per individual.

4. Estimate of the Cost to the Federal Government Approximately 2,500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months of NRC staff time would be needed to receive and analyze the statistical summary reports,of personnel monitoring results.

A negligible amount of time would be devoted during routine inspections to verify that the reports have been submitted. Approximately $50,000 per year is needed for compute. support. The total annual Federal cost would be about $175,000.

139 Enclosure 2/ Addendum 2

SUPPORTING STATEMENT FOR 10 CFR 20.1207 REPORTS OF PERSONNEL MONITORING ON TERMINATION OF EMPLOYMENT OR WORK

1. Justification Section 20.1207 ('ormer S 20.408) requires seven categories of NRC licensees to submit to the NRC, within 30 days after the exposure of a terminating individual has been determined or 90 days after the date of termination of employment or work assignment, whichever is earlier, a report that identifies the terminating individual and indicates that individual's exposure to radiation and radioactive material. (This reporting require-ment was previously approved by OMB Clearance No. 3150-0014.) The seven categories of licensees (nuclear power reactors, inc.ustrial radiographers, fuel. processors and reprocessors, high-level waste disposers, independent spent fuel storage installations, commercial suppliers of large quantities of byproduct material, and persons who receive radioactive waste from other persons for disposal under Part 61), are those considered to involve the greatest potential for significant occupational exposure. The report consists of radiation exposure information that is required to be monitored by S 20.502, and required to be recorded by S 20.1106.

a. Need for the Information Collection The termination data required to be reported by 5 20.1207 are used, primarily, to evaluate the doses received by transient workers (individuals working for more than one licensee in a given time period) and moonlighters (individuals working for more than one licensee at the same time). The regulations require licensees to request information from a job applicant regarding prior employments involving exposure to radiation and radioactive materials ($ 20.1104).

However, it is recognized that individuals may, for economic and 140 Enclosure 2/ Addendum 2

W e e i 1~ other reasons, withhold or falsify such information. The possibility exists for an individual, during multiple employments, to receive multiples of the dose limits. The reports permit retrospective evaluation of the multiple exposures and consideration of any correc-tive action that may be warranted. The seven categories of licensees are also those considered most likely to use transient or moonlighting ;

workers.

b. Practical Utility of the Information Collection In addition to meeting 'the need discussed in a., above, the termina-tion data also permit some assessment of lifetime exposures of workers in those seven categories of licensed activities (conditioned by the fact that the workers may have further employment involving radiation exposure), and the correction of compilations of annual statistical summary reports to account for the multiple reporting of some individ-uals during the year. An annual report of the data is included in NUREG-0714, " Occupational Radiation Exposure," and is widely used as a data source on occupational exposure. -

c. Duolication with Other Collections of Information None.

1

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 consulta-

, tions have included members of the following groups:

--Licensees of various types and sizes Architects, Engineers, Contractors 1

Power Reactors (LWR)

Research Reactors L

Universities 141- Enclosure 2/ Addendum 2

o Uranium Fuel Cycle 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 Gtoups

' Natural Resources Defense Council

--Health Organizations Health Physics 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

--Agreement States Conference of Radiation Control Program Directors

--Federal Agencies and Committees Interagency. Working Group on Occupational Exposure Guidance 142 Enclosure 2/ Addendum 2

E'n.vironmental 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 Public comments and other experience gained under the previous report-ing requirement in S 20.408, approved by OMB Clearance No. 3150-0014.

2. Description of the Information Collection

a. Number and Type of Respondents The termination reports would be filed by about 450 of the NRC's 7,500 specific licensees who conduct the seven types of activities listed in Item-1, above,

b. Reasonableness of the Schedule for Collecting Information The submission of the termination reports "...within 30 days after the exposure of the individual has been determined by the licensee or-90 days after the date of termination of employment or work assign-ment, whichevir is earlier, " is considered to be reasonable because adequate time is allowed for the processing of the individual's dosimeter (s). The exposure information contained in this report must

e.lso be'provided to the terminating individual ($ 19.13(d)) at a date not later than the date of the transmittal of the information to the NRC.

, The schedule was previously approved by OMB Clearance No. 3150-0014.

143 Enclosure 2/ Addendum 2

c. Method of Collecting the Information The termination report is to be submitted to NRC by each of the seven categories-of NRC licensees,

d. Record Retention Period Not applicable to this reporting requirement.

e. Reporting Period The report is to be submitted "...within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlier."

f. Copies Required to be Submitted One copy of each termination report is to be submitted to the Directer, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555. One copy is also to be submitted to the individual pursuant to S 19.13(d).

g. Format of Information to be Maintained or Submitted The format of the information to be submitted on exposure to radia-tion and radioactive material is not specified by the regulation.

3. -Estimate of Burden

a. Estimated Hours Required to Respond to the Collection

, Preliminary data for 1984 indicate that approximately 130,000 individ-ual terminations were reported to the NRC. About 50,000 of these reports were computer generated (by about 40 nuclear power plant licensees) and are estimated to take two minutes per report for a 144 -

Enclosure 2/ Addendum 2-

total of 1,667 hours0.00772 days 0.185 hours 0.0011 weeks 2.537935e-4 months . The rest of the reports (80,000) were manually completed and are estimated to take five minutes per report for a total of 6,667 hours0.00772 days 0.185 hours 0.0011 weeks 2.537935e-4 months . Therefore, the total time estimated for licensee response is 8,334 hours0.00387 days 0.0928 hours 5.522487e-4 weeks 1.27087e-4 months per year.

1 Number of respondents..................... 450 2 Number of responses per respondent........ 289 3 Total annual responses.................... 130,000 4 Hours per response........................ 3.85 minutes 5 Total hours............................... 8,334

b. Estimated Cost Required to Resoond to the Collection

.The estimated cost is $166,680 (8,334 hours0.00387 days 0.0928 hours 5.522487e-4 weeks 1.27087e-4 months / year x $20/ hour).

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 in managing the NRC's radiation exposure data system for the last 14_ years.

d. Reasonableness of Burden Estimate The estimate of burden is thought to be reasonable in view of the many years of Experience under the very_ comparable requirement in the present 9 20.408.

4. -Estimate of Cost to the Federal Government Approximately 3,000 hours0 days 0 hours 0 weeks 0 months of NRC staff time are expended each year for manual coding / processing of the termination data. A negligible amount of

. _ time would be devoted during routine inspection of-licensees' operations to verify that the reports have been submitted. Approximately $150,000 per year is needed for computer support. The total annual Federal cost would-be about $300,000.

145 Enclosure 2/ Addendum 2

- o SUPPORTING STATEMENT FOR APPENDIX F, SECTIONS I, II, AND III JUSTIFICATION OF A SHIPMENT MANIFEST AND A CERTIFICATION BY THE WASTE GENERATOR

1. Justification Appendix F and S 20.1006(b)(c) and (d) are designed to control transfers e

of low-level radioactive waste intended for disposal at a land disposal facility (as defined-in 10 CFR Part 60), establish a manifest tracking system, and supplement existing requirements concerning transfers and recurdkeeping for such wastes. .

Appendix .F, Sections I and II--Section I specifies the information required, pursuant to S 20.1006(b), to be on shipment, manifests accompanying shipments of radioactive waste intended for disposal at a licensed land disposal facility.Section II specifies the type of certification required, pur-suant to S 20.1006(c), to be included in the shipment manifest.

Appendix F, Section III--Section III sp'ecifies the requirements, pursuant to S.20.1006(d), that waste. generators, waste collectors, waste processors and disposal facility operators must follow in transferring and disposing of radioactive waste.

- Need for the Information Collection

- a.

r The manifest system proposed in Part 20 will address the need for

\more complete information for accountability of waste shipments.

The EPA has recently instituted a manifest tracking system for hazardous wastes. The General Accounting Office (GAO) noted the need for improvements in its March 30, 1980 report entitled "The i

Problem of Disposing of Nuclear Low-Level Waste: Where Do We Go From 146 Enclosure 2/ Addendum 2

Here?". The GA0 recommended that the Commission " Establish a method to track waste from the point of generation to the point of disposal."

Use of manifests is provided in the existing S 20.311 which provides a tracking system that is inspectable.

b. Practical Utility of the Information Collection The manifest tracking system provides information for accountability of waste shioments from the shipper to the intended receiver, and in the event of a late or missing shipment, provides information to the NRC, Department of Transportation, and to the States such that tracking and any other warranted action may be undertaken.

c. Duolication with Other Collections of Information None.

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 consultations have included members of the following groups:

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

Research Reactors Universities Uranium Fuel Cycle Facilities Medical Facilities Uranium Mills Well Loggers Radiographers, and others 147 Enclosure 2/ Addendum 2

--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 Physics 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

--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 148 Enclosure 2/ Addendum 2

- = -

. n

e. -Other Supporting Information None.

2. Description of the Information Collection

a. Number and Type of Resoondents There are about 7,500 NRC licensees, approximately 2,250 of which might make waste shipments at some time in the course of a year.

b. Reasonableness of the Schedule for Collecting Information The schedule for the provision of manifests and certifications seems reasonable. It is considered necessary for the shipper to forward an advance copy so that the receiver can anticipate the delivery and notify the shipper to initiate tracking if the shipment is late.

c. - Method of Collecting the Information The manifests and certifications are prepared by the licensee shipping the waste.

d. Record Retention Period Not applicable.

e. Reporting Period A copy of the manifest goes to the intended recipient at the time of shipment or it is delivered to a collector at the time the waste is collected. Acknowledgement of receipt in the form of a signed

, copy of the manifest or equivalent documentation is obtained from

. the collector.

149 Enclosure 2/ Addendum 2' L

f. Cooies Required to be Submitted As described in 2.e. of this supporting statement, one copy is involved.

g. Format of Information to be Maintained or Submitted NRC does not specify the format.

3. Estimate of Burden a.

Estimated Hours Recuired to Resoond to the Collection Appendix F, Sections I and II--Although the specified information required on the manifest document is sent to the disposal site oper-ator and not to the NRC, an estimate of the additional time required by individual licensees to provide such information is included here for completeness. If the previous experiences hold, there would be about 4,500 shipments originated each year by NRC licensees. Acquir-ing and recording the information will require an estimate of one staff-hour per shipment. .The total estimated annual burden to comply with this requirement is 4,500 staff-hours. -

Appendix F, Section III--If 25 of these licensees investigate late or mitosing shipments each year, as assumed above, and each spends 5 staff-days per investigation, the total effort expended would amount to about 1,000 hours0 days 0 hours 0 weeks 0 months per year.

Sections I & II Section III 1 Number of respondents. . . . . . . . . . . . . . . . 2,250 25

{

2 Number of responses per respondent... 2 1

, 3 Total annual responses............... 4,500 25 4 Hours per response................... 1 40 5 Total hours.......................... 4,500 1,000 150 Enclosure 2/ Addendum 2

1 w w

b. Estimated Cost Reouired to Respond to the Collection At $20 per clerical hour, an annual cost of $110,000 is projected for licensees.

c. Source of Burden Data and Method for Estimating the Burden The burden estimates were obtained from a review of the kind of activity licensed by the NRC and consideration of the amount of time required by licensees to prepare the manifest and certification.

d. Reasonableness of Burden Estimates The estimates of burden are thought to be reasonable. This reporting requirement has been the subject of previous rulemaking at which time the reasonableness of the burden estimate was also considered.

4. Estimate of Cost to the Federal Government There are no data on which to base the costs directly, but the costs can be inferred from the following assumptions. The NRC has approximately 7,500 licensees, about 2,250 of which would be expected to make a waste shipment at some time. If, on the average, each licensee makes 2 ship-ments per year and if one-half of one percent of all shipments are late or missing, this would result in about 25 investigations per year being reported. If half of these warrant follow-up investigation by NRC, with each follow-up requiring 3 staff-days, somewhat less than 40 staff-days per year would be required, for a total of $16,000 annually.

151 E7 closure 2/ Addendum 2

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