ML20138C639

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

ML20138C639
Person / Time
Issue date:	12/08/1985
From:	Norry P NRC
To:
References
OMB-3150-0044, OMB-3150-44, NUDOCS 8512130062
Download: ML20138C639 (8)

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trw Piperwork Reduct on Act ra.* ' work- - t'ut +> < et a s c' the sunortirer state-mei.t. to Anwr a1 questiccs m Part i If tn,s request is ter reu a < neer E O Of fg e of tr,termabon and Reguutos, A*ta.rs 121. comp'ete Part il and s:gn the regulator, cer % ' if this Office of Mannement and t3uct:et fecuest is for arcreva! cncer tne Pas.eract A Redus t on At .ioa 5 Cf p Atten!K-n Doc ket Libra'y, Room 3201 1320. shp F' art ti. compete Part 111 and syn tr.e paper *ein c <tJ. cat.cn Washmrton. DC 20503 FART l.-Complete This Part for All Requests.

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4. T t'e c? >nkrn a'xe co ;e<t.cn or esca'ah rg 10 CFR 19 - Notices, Instructions, and Repcrts to Workers; Inspections

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PALT llL-Compista This Part Only if th) Requxt is for Appr vtl Cf a C111ection of Inf:rmatirn Undtr th2 Papetwork Reducti:n Act rnd 5 CFR 1320.

13. Abstract-0 ebe neess. uses and affected pubhc in 50 aords or less  !

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

14 f,pe of efennaton c#i=cta- Ne on'y one)

Informats, eodes t*oss not c entained in rules i Eac nrsu n .s w 2 O Emerse,cv suberussion(cert r,catenattached>

information c0Hsctions contal:'ed in rules 3 b Eosteg regwaton (no change proposedt 6 Fmal or mtaren fmat without pnor NPRM 1 Enter date of espected or actual Federas

{ 4 C Natge of proposed ru'e-awg(NDRM) 4 O Reg /ar subme von Reg' ster puDucatron at this stage of ruleman.ng 5 O Fina!. NPRM .a. rev %st, pub:ishec 8 O Em%ancy suomeum(certit<.tre attxhed) (* M t d'r red')

15. Type o+ revee reyes e rcnect on:y one) 1 C Naw c3Pect on 4 0 Reinstatement of a pre ousi, approved canecte vor -nien app o.ai 2 b Rev,s:o, of a cunanttf waved cos.ect.on ""P"'d

3 O E tenvon ct the esp. rat 99 da e of a currentty approved co9ection 5 O E-sims coaccie n use -ithout an oms controi n umber w.t%t any charga in the substance or an the method of conecten 16.Asenc r re.,urt 'orm rv ber(s)(uwJe stJ 1d. sed ' opt.onal form numocr(s)J 22. Purpose of in'ormat>on cowact.on (chece as many as apply; NA 1 O Apphcare t= bene *its

2 Program evaluaten

17. Annuai recortrg or d wwre 0/ den 3 C General purpose stJtr@cs 4800

I tomter of rewndents 4 [ Ressulatory or comphance 2 N amaer of response 6r pe reecet. 5 O ProgrJm planning or m snagement 3 T3 tat a*rw respor ws Pm I taes f ne 2) 548~'03 _F 6 0 Reseuch 4 Hau s pe, response e *N 7 O Aud't 5 fctamous M* 3 "*s rne t) NW

18. Annual recordueco ng burden 23. Frequency of recordmeepeng or reporting (cneck a# thatapply) 1 Number of recordece;ers t O Recerd=eep.ns 2 Aarosi hour 5 per record ecoer NePortfas 3 Total tecnrikeep*ng Fours (l>'e I f.mes Jrne 2) 2 %) onoccaron 4 Record.e.pmg ee en*on pero 1 year $ 3 0 we.*i,

19. Totaf annat bcden 4 O Monini, 1 Requestsi t:me IT5 otus Iwe 18 3) . 9l* 9 s O QuarterN 2 in c.trent OM S m.entory

• 6 0 semrannuao, 3 D.fferenee(hve j iess roe 2J +13;53F 7X J AnnuJily holanation of difference 8 0 Bienneesty 4 Prcram cn tage 1

9 0 orner(desenbei sq,t-t + 13,53F 1 20. Current (mst reccat) OM8 control nureber or comtrent number 24. Respondents

• obl gation to coraper (c/tect toe strongest ob6 gate that apphes t 3150 0044 1 O voiuntary j 21. %ested espiration d#e

[ 2 Requered to obtaen or retain a benefet 11/88 l 3 )() uanda,0,y

25. Are the respondenti pr.rwv edwcatmai agenoes or institutons or is the pomary purpose of tne collection related to Federas education programs? O ves G rio -

26. Does the agency use samyng to seiect respondents or does the agency recommend of prescnbe the use of samphng or statistical analysis by respondents?

. O ves Q no i E1. Regsator utnonty he infonnation cot.ecte CFR , or FR ,or,other (specify)

Paperwoek NrtMilon in sabm tteg (Ns redeV Nr CMB approvat the agency head, the servar officsal or en autnoreted teprescritative. Certifies trist the rertuerements of s CFR 1320 the Pnv scy Act, stMtst. car st 4+1 Fds or a rectives and any utner apohcabie en formaron pohcy direct #ves have been compo.ed w,th I

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SUPPORTING STATEMENT FOR SECTION 19.13 of 10 CFR PART 19,

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

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

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

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

This report is furnished to you under the provisions of the Nuclear Regula-tory Commission regulation 10 CFR Part 19. You should preserve this report for further reference."

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

S19.13(c) "At the request of a worker formerly engaged in licensed activities controlled by the licensee, each licensee shall furnish to the worker a report of the worker's exposure to radiation or radioactive material. Such report shall be furnished within 30 days from the time the request is made, or within 30 days after the exposure of the individual has been determined by the licensee, whichever is later; shall cover within the period of time specified in the request, each calendar quarter in which the worker's activities involved exposure to radiation from radioactive materials licensed by the Commission; and shall include the dates and locations of licensed activities in which the worker participated during this period."

$19.13(d) "When a licensee is required pursuant to $20.405 or 520.408 of this chapter to report to the Commission any exposure of an individual to radiation or radioactive material the licensee shall also provide the individual a report 1

on his exposure data included therein. Such report shall be transmitted at a time not later than the transmittal to the Commission." (These are reports of radiation exposure in excess of NRC limits.)

$19.13(e) "At the request of a worker who is terminating employment in a given calendar quarter with the licensee in work involving radiation dose, or a worker who, while employed by another person, is terminating assignment to work involving radiation dose in the licensee's facility in that calendar quarter, each licensee shall provide to such worker, or to worker's designee, at termination, a written report regarding the radiation dose received by that worker from operations of the licensee during that specifically identified calendar quarter or fraction thereof, or provide a written estimate of that dose if the finally determined personnel monitoring results are not available at the time. Estimated dose shall be clearly indicated as such."

1. Need for the Collection of Information The licensee is required to control radiation doses to individuals in restricted areas so that, with one exception, no one receives an accumulated dose during a quarter that exceeds the limits established by 10 CFR 20.101(a). These radiation dose limits are 1.25 rems to the whole body, 18.75 rems to the extremities and 7.5 rems to the skin of the whole' body. Section 20.101(b) permits a whole body radiation dose per quarter not to exceed 3 rems provided that the planned additional dose plus the lifetime accumulated dose does not exceed 5 (N-18), where "N" is the individual's age in years.

The individual should be informed of the radiation dose he or she receives because (a) that information is needed by both a new employer and the individual when the employee changes jobs in the nuclear industry; (b) radiation dose information from past employers is needed when the individual is not changing jobs in order to determine whether additional exposure can be permitted up to 3 rems per quarter based on the lifetime accumulated dose and the individual's age; (c) the individual needs to know the radiation dose received as a result of an accident or incident so that he or she can seek counseling about future work involving radiation or medical attention or both, as desired; and (d) since long term exposure to radiation may be an adverse health factor, the individual needs to know whether the accumulated dose is being controlled within NRC limits.

2. Agency Use of Information Section 19.13 does not require the reporting office to send information to the NRC.

3. Reduction of Burden Through Information Technology Not Applicable.

4. Effort to Identify Duplication There is no duplication.

5. Effort to Use Similar Information There is no source for the required information other than licensees. Licensees are required to maintain this information by the provisions of $20.401(a),10 CFR Part 20.

6. Effort to Reduce Small Business Burden There is no feasible way of reducing the burden on'small businesses while still accomplishing the objective of informing individuals of their exposure to radiation. However, the burden is small and should have no significant impact on operating costs.

! 7. Consequences of Less Frequent Collection I

Workers would not be aware of their total radiation dose. '

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

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

10. Confidentiality of Information Not Applicable.

11. Justification for Sensitive Questions Not applicable

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

13. Estimate of Burden

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

The total population thus monitored is about 308,000 individuals. These data are based on reports which licensees have provided the NRC in compliance with the reporting requirement of 10 CFR 20.407(a). Assuming that: (1) each worker requests an annual report of his radiation exposure, and (2) each report takes 10 minutes of preparation time, the total compliance burden of fl9.13(b) on the population of 4,800 licensees is estimated to be 51,333 man-hours per year.

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

Section 19.13(c) Reports to Former Employees Based on reports to the NRC of radiation doses that terminating employees have received, it is estimated that approximately 500 licensees are affected by the requirement to provide a report to former employees of the total dose received while in the employment of the licensee. Since about 120,000 reports of individual terminations are made to the NRC each year, that is the maximum number 4 of reports that could be requested by the affected former employees. However,

the number of individuals involved (as contrasted with reports) is around

53,000. This indicates that there is a fairly large transient group that changes employers more than once per year.

Assuming that 50% of 120,000 terminations involve individuals who request a

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

T5 minutes J Section 19.13(d) Reports to Overexposed and Terminatina Employees Section 20.405 of 10 CFR 20 requires licensees to report to the NRC any incident involving a radiation dose that exceeds NRC limits. Section 20.408 of that regulation requires that the licensee report the radiation dose received during j the period of employment at the time an employee terminates his/her employment.

i In each of the two sets of circumstancer define above, the licensee must also report the same information to the affected employee.

The .20.405 requirement affects a total population of approximately 4,800 licensees, the number providing radiation monitoring of their workers. The number of individuals overexposed has ranged during the years of record from about 15 to 50. Assuming that: (1) an average of 36 overexposures reports per year and (2) that each report takes 10 minutes to prepare, the total compliance burden of 919.13(d) (for 520.405 reports) on the population of 4,800 licensees is estimated to be 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per year. (36 reports / year X 10 minutes / report =

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

The 520.408 requirement affects about 500 licensees per year. This report is the same as required by 919.13(c), the offference being that the Q19.13(d) report is furnished automatically while the Q19.13(c) report is furnished at the request of the terminating employee.

J As the reports are similar, the same assumptions used for 519.13(c) are used for $19.13(d), and the total compliance burden of $19.13(d) on the population of 500 licensees affected is estimated to be 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year. (120,000 reports X 10 minutes / report = 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.)

Section 19.13(e) Report to Terminating Employee of Last Quarter's Radiation Dose With the exception of radiation exposure received during incidents, the reports described previously deal with the total radiation dose received during either a year or the period of employment at a single licensee's facility. However, i since the radiation dose is controlled by a quarterly limit, it is desirable that a terminating employee receive a report of the dose received to date during the i; fraction of a quarter in which he/she has been employed by the licensee. If that report indicates the limit has not been reached for the quarter, the individual can continue receiving radiation exposure during work activities during the rest of the quarter with the new employer.

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

the total compliance burden of 919.13(e) in the population of 500 affected licensees is estimated to be 10,000 man-hours per year (assuming 50% of employees will request report.) (60,000 reports X 10 minutes / report = 10,000

hours.)

14. Reasons for Change in Burden This supporting statement for extension of requirements in 10 CFR 19.13 contains an increa:e in the burden on licensees as a result of an increase in the number of individuals employed by licensees who receive exposure to radiation. These affected individuals have increased from an estimated 287,000 in 1982 to a current estimate of about 308,000. By the rationale and estimates presented previously in this statement, the increased employment indicates an increase in the number of reports to individuals from 467,000 in 1982 to a current estimate of 548,000. The associated burden on licensees has correspondingly increased from 77,800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in 1982 to about 91,300 in 1985. (See attached table for computationof1985 burden.)

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While the totti number of licensees has not changed appreciably, there has been '

an increase in the number of operating nuclear power plants and a decrease in the number of fuel cycle facilities. Because there are many more workers monitored for radiation exposure at nuclear power plants, the net effect is an increase in the number of reports that licensees must prepare.

15. Publication for Statistical Use Not applicable.

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Attachment BURDEN TABLE i

RESPONSES PER TOTAL BURDEN PER l

SECTION RESPONDENTS RESPONDENT RESPONSES RESPONSE TOTAL BURDEN I

19.13(b) 4,800 64.2 308,000 10 min. 51,333 19.13(c) 500 120 60,000 10 min. 10,000 19.13(d) 4,800 2.5 120,000 10 min. 20,000 500 .07 36 10 min. 6 19.13(e) 500 120 60,000 10 min'. 10,000 Totals 4,800 114.2 548,036 10 min. 91,339

• Burden hours X $60.00/ hour 1

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